ML20154H573
| ML20154H573 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 05/23/1988 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8805250407 | |
| Download: ML20154H573 (5) | |
Text
L TENNESSEE VALLEY AUTHORITY CHATTANOOGA. TENNESSEE 37401 SN 1578 Lookout Place NAY 231988 1
U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C.
20555 Gentlemen:
In the Matter of
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Docket Nos. 50-259 Tennessee Valley Authority
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50-260
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50-296 BROWNS FERRY NUCLEAP PLANT (SFN) UNITS 1, 2, AhD 3 - NRC INSPECTION REPORT NOS. 50-259/88-06, 50-260/88-06, AND 50-296/88-06, - RESPONSE TO NOTICE OF VIOLATION This letter is to provide TVA's response to your letter from K. P. Barr to S. A. White dated April 20, 1988, which transmitted the subject report.
The report cited TVA with one violation.
During a followup inspection, from May 6 through May 10, the NRC inspector noted that appropriate corrective actions had been implemented to preclude further violations of this type.
, provides background information and TVA's response to NRC concerns raised in the subject report. A list of commitments is provided in enclosure 2.
If you have any questions, please telephone Clark Madden at (205) 729-2049.
Very truly yours, TENNESSEE LEY AUTHORITY
)
I R. Gridley, D rector Nuclear Licensing and Regulatory Affairs Enclosures cc:
See page 2 8805250407 880523 I I PDR ADOCK 05000259 l
An Equal opportunity Employw Q
DCD 1
', U.S. Nuclear Regulatory Commission g g g jggg cc (Enclosures):
Mr. K. P..Barr, Acting Assistant Olrector for Inspection Programs TVA Projects Division U.S. Nuclear Regulatory Commission Region II l
101 Harletta Street, NW, Suite 2900 Atlanta, Georgia 30323 Mr. G. G. Zech, Assistant Director for Projects TVA Projects Division U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Brc~ns Ferry Resident Inspector Bro..is Ferry Nuclear Plant Route 12, Box 637 Athens, Alabama 35611
ENCLOSURE I
RESPONSE
NRC INSPECTION REPORT NOS. 50-259/88-06, 50-260/88-06, AND 50-296/88-06 LETTER FROM K. P. 5ARR TO S. A. WHITE DATED APRIL 20, 1988 VIOLATION
!0 CFR 50, Appendix B, Criterion V, 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.
Paragraph 5.2.3 of TVA's Standard Practice 7.8, Revision 2, entitled "Prevention of Foreign Material in the Reactor Vessel Cavity or Torus" states the following:
Unnecessi..y loose material will not be allowed within the control zone.
Accountability will be maintained of all tools and material, and material or accessories on equipment capable of being introduced into the pool or cavity.
Any activity that could result in the dropping of an item into the reactor pressure vessel will be observed by a person not involved with the activity.
This person will verify that any item that could drop into the reactor pressure vessel is tied off d th a lanyard, or suitable catch containers are used where it is imp;ssible or impractical to secure items.
All equipment used in the vessel will be verified complete with no undocumented pieces of the equipment missing when the equipment is put into the vessel.
Contrary to above on March 17, 1988, the following procedure violations were observed.
Loose rivets were found on the refueling floor within th? control zone and were mistakenly thought to have entered the reactor vessel during a lost item recovery operation.
Accountability records did not identify what screws or parts were missing on the ultrasonic (UT) scanner used in the vessel.
Several strews on the UT scanner were intentionally loosened rather than correct a geometric deficiency.
Screws on the UT scanner were not attached with a lanyard or locking de<lce.
ENCLOSURE 1
RESPONSE
NRC INSPECTION REPORT NOS. 50-259/88-06, 50-260/88-06, AND 50-296/88-06 LETTER FROM K. P. BARR TO S. A. HHITE DATED APRIL 20, 1988 VIOLATION 10 CFR 50, Appendix B, Criterlon V requires that activities affecting quality f
shall be prescribed by documented instructions, procedures, or drawings--and shall be accompil:ted in accordance with these instructions, procedures, or drawings.
Paragraph 5.2.3 of TVA's Standard Practice 7.8, Revision 2, entitled "Frevention of Foreign Material in the Reactor Vessel Cavih* or Torus" states the following:
Unnecessary loose material will not be allowed within the control zone.
Accountability will be maintained of all tools and material, and material or accessories on equipment capable of being introduced into the pool or cavity.
f Any activity that could result in the dropping of an item into the reactor l
pressure vessel will be observed by a person not involved with the activity. This person will verify that any item that could drop into the reactor pressure vessel is tied off with a lanyard, or suitable catch containers are used where it is impossible or impractical to secure items.
I All equipment used in the vessel will be verified complete with no undocumented pieces of the equipment missing when the equipment is put into the vessel.
Contrary to above on March 17, 1988, the following procedure violaticns were observed.
1 Loose rivets were found on the refueling ficor within the control zone and were mistakenly thought to have entered the reactor vessel during a lost 1
item recovery operation.
{
Accountability records did not identify what screws or parts were missing
(
on the ultrasonic (UT) scanner used in the vessel.
Several screws on the UT scanner were intenticially loosened rather than correct a geometric deficiency.
Screws on the UT scanner were not attached with a lanyard or locking device.
The UT scanner was inserted and removed from the vessel several times to trouble shoot and repair scanner. problems.
However, the missing screws and roll pin were never identified, even after a lost item recovery occurrence where this scanner was suspected of having lost the parts observed in the vessel cavity and inspection of the scanner device was suppose to have been thoroughly performed.
No one verifled or accounted for any of the missing screws or the roll pin.
This is a Severity Level IV violation.
TVA's Response 1.
Admission or Denial of the Alleged Violation TVA admits to the violation as stated.
2.
Reasons for the Violation Inadequate supervision of the contractor activities and failure to ensure strict compliance with procedures, specifically Standard Practice BF-7.8, "Prevention of Foreign Material in the Reactor Vessel Cavity and Torus" were the root causes of this violation.
General Electric test equipment was allowed to be placed in the reactor vessel without proper securing provisions and accountability records.
3.
Corrective Steps Which Have Been Taken and Results Achieved While performing the examination, TVA noticed that the video monitor indicated two foreign objects on the shroud support access cover plate.
Refuel floor activity was stopped while recovery plan for the article: was developed in accordance with Standard Practice EF-7.7.
The foreign articles were retrieved from the reactor vessel.
When contractors are assigned work on the refuel floor, 8FN management now ensures they clearly understand our work controls and procedures.
For refuel floor or in-vessel work, consideration will continue to be given to having an engineer or operations supervisory personnel in charge or acting as an independent monitor.
The appropriate supervisor will continue to ensure control zone monitoring personnel are properly trained and in place to help prevent uncontrolled material from entering the reactor vessel cavity and torus.
A loose item log will be maintained, documenting control and accountability.
Please note that Standard Practice BF 7.8 as changed to Plant Manager's Instruction (PMI 7.2), "Prevention of Foreign Material in the Reactor Vessel Cavity and Torus."
4.
Corrective Steps Which Will Be Taken to Avold Further Violations None 5.
Date When Full Compliance Hill Be Achieved Full compliance has been achieved.
ENCLOSURE 2
RESPONSE
NRC INSPECTION REPORT NOS. 50-259/88-06, 50-260/88-06, AND 50-296/88-06 LETTER FROM K. P. BARR TO S. A. WHITE' DATED APRIL 20, 1988 LIST OF COMMITMENTS 1.
A recovery plan for the articles was developed in accordance with Standard Prac tice BF-7.7.
The foreign articles were retrieved from the reactor vessel.
(Complete) 2.
The appropriate supervisor will continue to ensure control zone monitoring personnel are properly trained and in place to help prevent uncontrolled material from entering the reactor vessel cavity and torus. A loose item log will be maintained documenting control and accountability.
(Complete.)
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