ML20090H107
| ML20090H107 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 03/06/1992 |
| From: | Zeringue O TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9203130274 | |
| Download: ML20090H107 (6) | |
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U.S. Nuclear Regulatory Commission ATIN Document Control Desk Washington, D.C.
20555 Gentlement In the Matter of
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Docket Nos. 50-259 Tennessee Valley Authority
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50-260 50-296 5
BROWNS FERRY NUCLEAR PLANT (BF74) - NRC INSPECTION REPORT 50-259, 260, 296/91 REPLY TO NOTICE OF VI0lATION (NOV)
This letter provides 'IVA's reply to the NOV transmitted by letter from B. A. Wilson to D. A. Nauman dated February 6,1992.
TVA acknowledges the violation. to this letter provides TVA's " Reply to Notice of Violation" in accordance with 10 CFR 2.201 and 10 CFR 2 Appendix C.
provides a listing of commitments made in this reply.
If you have any questions regarding this response, please contact Raul R. Baron at (205) 729-7570.
Sincerely, liQ 40/00l 0 J Zeringue Enclosures cc See page 2 1 nGl 1*
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9203130274 920306 h
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2 U.S. Nuclear Regulatory Commission tt4R 0 01992 Enclosures cc (Enclosures):
NRC Resident Inspector Browns Ferry Nuclear Plant Route 12, Box 637 Athens, Alabama 35611 Mr. Thierry M. Ross, Project Manager U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Mr. B. A. Wilson, Project Chief U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323
Tennessee Valley Authority Browns Ferry Nuclear Plant Reply to Notice of Violation Inspection Report Number' 50-259. 260, 296/91-41 VIOLAT103 "During the Nuclear Regulatory Commission (NRC) inspection conducted on December 16 - January 16, 1991, a violation of NRC requirements was identified. This violation involved the failure to follow the Unit separat';..
procedure for personnel access.
In accordance with the " General Statement of Policy and Procedure for NRC Eriforcement Actions," 10 CFR Part 2, Appendix C (1991), the violation is listed below 10 CFR, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings and shall be accomplished in.accordance with these instructions, procedures, or drawings.
Site Procedure, SSP-12.50, Unit Separation for Recovery Activities, Section 3.4, implements the requirement for control of personnel access into Unit 2 operating upaces, and directs Unit 3 personnel to wear color coded hardhats and unique plant access picture badges.
Contrary to the above, this requirement was not met on January 8, 1992, when a NRC inspector identified Unit 3 personnel without uniquely identified access badges.
Licenece action to resolve this issuw in December, 1991, did not correct this problem.
This is a Severity Level IV Violation (Supplement I) applicable to all three units."
1.
Reapon for the Violation The reason for the violation was insufficient communication to personnel of the procedural controle of SSP 12.50.
SSP 12.50 specifies that non-exempt Unit 3 recovery personnel shall be identified by light blue hard hats and unique plant access (picture) badges.
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On January 8, 1992, two Unit 3 Stone And Webster Engineering Corporation j
(SWEC) contractor personnel did not enmply with SSP 12.50 in that their
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badges were not uniquely identified.
The two individuals did not l
understand the significance of the unique plant access badges.
Contributing to this noncompliance was the failure to provide a timely notification to the Plant Access seccion (PAS) of their transfer. The two individuals had just transferred from an organization not requiring unique plant access badges to a Unit 3 organization requiring unique 1
plant access badges.
TVA has utilized BFN PAS to help implement the administrative requirements of SSP 12.50 by having PAS place a unique identifier on non-exempt Unit 3 contractor / employee badges. The determination of whether the unique identifier is required is based on an individual's assigned organization. Therefore, if an individual is transferrod from a Unit 2 organization to a Unit 3 organization, the PAS must be notified in order to place the unique identifier on the individual's badge.
2.
ggrre,d,1y_gEens Taken and-hesults Achieved
$WEC 1mmediately provided their employees orientation on proper badge and hard hat identification and increaoed the emphaois placed on this requirement during its new hire orientation.
SWEC also modified its
- Individual Release to Protected Area" form to clarify badge requirements. As a interim precautionary measure, SWEC is monitoring personnel badges at the craft change house and access portal.
Additionally, Restart Management personnel (TVA and Contractor) were directed to emphasize the unique identification requirement for entering the protected area and stress the need to maintain the visibility of this program to their employees.
As an enhancement, on January 31, 1992, BFN began roquiring organizations transferring individuals to complete and provide an onsite transfer form to PAS prior to the effective date of the transfer.
3.
Egrigetive Steps That thave been ort Will Be Taken to Avoid Further Violations As noted in the viclation, discrepancies between. color coded hard hats and unique plant access picture badges first became. evident in December, 1991. At that time, TVA issued a written communication to emphasize SSP 12.50 requirements for unique identification. Accordingly, since this l
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Page 3 of 3 did not preclude the January 8, 1992 occurrence, TVA considers it prudent to supplement the written communications in this area with administrative controls. To this end, the requitemente for the use of the transfer form, described abova, will be incorporated into an appropriate procedure by March 31, 1992.
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Date When_Tull Compliance Will Be Aghieved Full compliance will be achieved by March 31, 1992, when the transfer form and the requirements for it use are incorporated into an appropriate procedure.
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ENCLOSURE 2 Tennessee Valley Authority Browns Ferry Nuclear Plant (BrN)
Reply to Notice of Violation (NOV)
Inspect ion Report Number 50-259, 260, 296/91-43 LIST OF COMMITMENTS The appropriate procedure will be revised by Harch 31, 1992 to require organizations transferring individuals to complete and provido an onsite transfer form to PAS prior to the effective date of the transfer.
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