ML20236B917
| ML20236B917 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 03/16/1989 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8903210367 | |
| Download: ML20236B917 (6) | |
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,s TENNESSEE VALLEY AUTHORITY CH ATTANOOGA, TENNESSEE 37401 SN 157B Lookout Place MAR 161989 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 50-296 BR0HNS FERRY NUCLEAR PLANT (BFN) - UNITS 1, 2, AND 3 - NRC INSPECTION REPORT NOS. 50-259/88-32, 50-260/88-32, AND 50-296/88 RESPONSE TO NOTICE OF VIOLATION This letter provides TVA's response to the letter from F. R. McCoy to
- 0. D. Kingsley, Jr. dated February 2, 1989, which transmitted the subject report. 'The report cited TVA with one Severity Level IV violation with two examples for failure to follow procedures in tagging out a diesel generator starting air compressor and performing a surveillance instruction (SI) on the radiation monitoring system.
Several recent examples of weaknesses in the SI have been recognized by TV/
management.
Even though the apparent cause of both examples of the above cited violation was personnel error, TVA has initiated a detailed evaluation of the surveillance program.
This includes SI scheduling, performance, and the adequacy of the SI. contains TVA's response to the violation. contains a summary of commitments made in this submittal.
If you have any questions, please telephone Patrick Carier at (205) 729-3570.
Very truly yours, TENNESSEE V LLEY AUTHORITY
/
R. Gridley, M ager Nuclear Licen ing and l
Regulatory Affairs cc: See page 2 9903210367 890316
' DR ADOCK0500,{rf j\\
Pa An Equal Opportunity Employer
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MAR 161989, 1
U.S. Nuclear Regulatory Commission Enclosures cc (Enclosures):
Ms. S. C.-Black,. Assistant Director c.
for Projects TVA Projects Division U.S. Nuclear ~ Regulatory Commission
.One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Mr. F. R. McCoy, Assistant Director for Inspection Programs TVA Projects Division.
U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NH, Suite 2900 Atlanta,-Georgia 30323 Browns Ferry Resident Inspector Browns Ferry Nuclear Plant Route 12, Box 637 Athens, Alabama 35609-2000 i
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RESPONSE - BROWNS FERRY NUCLEAR PLANT (BFN) i NRC INSPECTION REPORT NOS. 50-259/88-32, 50-260/88-32, AND 50-296/88-32 LETTER FROM F. R. McC0Y TO 0. D. KINGSLEY, JR.
l DATED FEBRUARY 17, 1989 Violation 1
Technical specification 6.8.1 requires that procedures recommended in Appendix "A" of Regulatory Guide 1.33, Revision 2, be established, implemented and maintained.
This includes maintenance and surveillance procedures.
The TVA Nuclear Quality Assurance Manual, Part I, Section 2.5, " Instructions, Procedures and Drawings," establishes programmatic requirements to assure that activities affecting quality are prescribed by and accomplished in accordance t
wi.th documented instructions, procedures, and drawings.
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Example l Contrary to the above, on October 16, 1988, the licensee failed to properly perform, and to independently verify, the tagging of equipment specified on a clearance sheet, in that "A" air start compressor for the units 1 and 2 diesel generator "C" was tagged instead of the compressor for the "B" diesel
.i generator as specified on the clearance.
This was iden.tified through the receipt of an annunciator alarm and resulted -in all eight diesel generators being technically inoperable.
TVA's' Response i
1.
Admission or Denial of the Alleged Violation TVA admits the violation.
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Reason for the Violation The root cause of the violation was personnel error in that the operators involved in the clearance and tagging process mistatenly tagged the "A" air compressor for the "C" diesel generator rather than for the "B" diesel generator as required in the clearance sheet. The operators also failed to c0rrectly perform the independent verification that would have identified the tagging error.
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Corrective Steps Which Have Been Taken and Results Achieved The tagging error has been corrected. An incident critique and a Condition Adverse to Quality Report were generated following the event to gain management attention and ensure tracking of corrective actions.
The
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operators involved have received appropriate disciplinary action.
The Shift Operations Supervisors were notified by the Operations Manager to reemphasize to their people the importance of correct independent verification and the requirements for attention to detail.
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Corrective Steps That Will Be Taken to Avoid Further Violations There is no further action required.
5.
Date When Full Compliance Hill Be Achieved Full compliance has been achieved.
Example 2 Contrary to the above, on October 17, 1988, steps 7.6.111.1 thru 7.6.111.4 of i
2-SI-4.2.A-10, " Reactor Building and Refueling Floor Ventilation Radiation Monitor Calibration and Functional Test," were not performed before performing step 7.6.111.6.
This resulted in an inadvertent engineered safeguards features actuation.
TVA's Response 1.
Admission or Denial of the Alleged Violation TVA admits the violation.
2.
Reason for the Violation i
This violation occurred as a result of personnel error during performance of postmaintenance testing on the secondary containment ventilation exhaust radiation monitoring system. After completing one portion of the test and recording the test data in a separate section of the surveillance procedure, the instrument technician returned to the wrong step in the procedure.
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Corrective Steps Which Have Been Taken and Results Achieved After the event, proper sequence of steps in 2-SI-4.2.A-10 was performed, and the Surveillance Instruction (SI) replaced with four shorter instructions.
The instrument technicians involved were counseled on the need to pay attention to details and to follow the procedures correctly.
-In addition, this incident has been critiqued with the Instrument Department personnel to again stress the need for attention to detall.
A particular concern was frequent procedural signoff steps in different
.i parts of the procedure requiring many transitions from the procedure text to the data recording section and back.
This resulted in missing steps and/or' performing steps out of order. An evaluation has been performed on the sis for any special packaging needs that would make the sis more user friendly. As a result of this evaluation, any special packaging needs for fleid performance of sis will be determined by the locations-of the work.
For example, sis performed in the radiological controlled and contaminated areas require packages (e.g., loose leaf binders) that would reduce personnel exposure and the spread of contamination.
4.
Corrective Steps That Will Be Taken to Avoid Further Violations Forthespecificidentifiedviolation,nofurtherabtionisrequired.
However, several other events have occurred indicating to TVA management that the surveillance program currently in place at BFN has some weaknesses. As a prudent management action, the surveillance program, including scheduling, performance, and the adequacy of the surveillance instructions, is currently being evaluated.
The'results of this evaluation and appropriate recommendations will be presented to TVA management by April 15, 1989.
5.
Date When Full' Compliance Will Be Achieved The results of the evaluation on the surveillance program and appropriate recommendations will be completed by April 15, 1989.
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- Enclosure 2-w RESP 0'NSE'- BR0HNS FERRY-NUCLEAR PLANT (BFN)
NRC INSPECTION REPORT NOS. 50-259/88-32, 50-260/88-32., AND 50-296/88-32
' 'j LETTER'FROM-F.-R..McC0Y TO 0. D. KINGSLEY, JR.
DATED FEBRUARY 17,'1989' l:
t Summary List of Commitments The 'results of the evaluation on the surveillance program;and appropriate
.. 1 recommendations'will-be completed by April 15, 1989.
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