ML18036B021

Responds to NRC Re Violations Noted in Insp Repts 50-259/91-26,50-260/91-26 & 50-296/91-26 on 910716-0816. Corrective Actions:Fire Watch Established on 910728 & Maintained Until Fire Wrap Replaced on 910802

ML18036B021
Person / Time
Site:	Browns Ferry
Issue date:	10/09/1991
From:	Zeringue O TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9110160193
Download: ML18036B021 (10)

Text

Tennessee Valley Authority, Post Olfice Box 2000. Decatur,'Alabama 35609 O. J, 'lite'eringue Vice President, Browns Ferry Operations 0CT 09

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U.S. Nuclear Regulatory Commission ATTN:

Document Control Desk Washington, D.C.

20555 Gentlemen:

In the Matter of Tennessee Valley Authority Docket Nos.

50-259 50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN) NRC INSPECTION REPORT 50-259,

260, 296/91-26 REPLY TO NOTICE OF VIOLATION (NOV)

This letter provides TVA's reply to the NOV transmitted by letter from B.

A. Wilson to D. A. Nauman dated September ll, 1991.

NRC cited TVA with two violations.

The first violation concerns the removal of the fire wrap from redundant trains of safe shutdown equipment without posting a

fire watch.

The second violation concerns two fuel movement errors within a two-week period.

TVA agrees that the violations noted in the NOV violated regulatory requirements.

During the investigation into the fire wrap removal, TVA determined that the Unit 3 walkdown inspection involving the fire wrap was not necessary since the equipment had previously been inspected during the Unit 2 walkdowns.

TVA has taken action that should minimize unnecessary walkdowns and impact on the operating unit from recovery actions.

Enclosed is TVA's "Reply to the Notice of Violation" in accordance with 10 CFR 2.201.

Corrective actions are complete for both these violations.

No commitments are made in this letter.

If there are any questions regarding this response, please telephone J.

E. McCarthy at (205) 729-2703.

Sincerely,

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Enclosure cc (Enclosure):

NRC Resident Inspector Browns Ferry Nuclear Plant Route 12, Box 637

Athens, Alabama 35609-2000 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

Enclosure Tennessee Valley Authority Browns Ferry Nuclear Plant Reply to Notice of Violation Inspection Report Number 50-259 260 296 91-26 RESTATEMENT OF VIOLATION 91-26-02 "During the NRC inspection conducted on July 16 August 16,

1991, two

, violations of NRC requirements were identified.

The first violation was for removing fire wrap without posting a fire watch.

The second violation was for failure to follow fuel movement procedures.

In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1991)=, the violations are listed below:

A.

Technical Specification 3.11.G.l.a requires that all fire rated assemblies separating systems important to safe shutdown within a fire a'rea shall be operable at all times or a fire watch must be established within one hour.

Contrary to the above, a

NRC inspector identified on July 28, 1991, that fire wrap had been removed from operable residual heat removal service water pump motor power cables in the intake structure and a fire watch was not established.

This fire wrap provides a one hour fire resistance barrier between redundant safe shutdown equipment, which do not meet the minimum 20 feet Appendix R separation criteria.

The fire wrap was removed on July 24, 1991, for Unit 3 walkdown inspection under an approved work order 91-35664-00, although walkdown inspections for Unit 2 had previously been performed in this area."

1.

Reason for the Violation The root cause was Field Services-Modifications management failure to ensure that Unit 3 planning and implementation of work was in full compliance with site procedures.

, Two ma)or contributing factors were inadequate verbal communications and management's failure to ensure the existence of a complete training matrix in Field Services that

identified all training needed to adequately perform a particular function.

The missed fire watch was a direct result of personnel not following procedures.

The fire wrap was removed by an approved work order on July 24, 1991, to support Unit 3 Walkdown activities.

A one hour fire watch was not established because TVA personnel did not follow procedures and failed to initiate an Attachment F as required by FPP-2, Fire Protection-Attachments.

(Attachment F is the mechanism used to ensure that Fire Protection requirements, including the posting of fire watches, are met.)

The Attachment F was identified as a prerequisite in the work order.

The implementing organization reduced the amount of fire wrap to be removed and discussed the reduced scope of the job with fire protection to determine whether the Attachment F was still needed.

Due to miscommunication, the individuals (a craft foreman and a fire protection operator) involved in this discussion concluded that an Attachment F was not required.

The foreman then started the work without an Attachment F.

This resulted in the removal of a fire barrier without establishing the compensatory fire. watch.

The governing procedure, SDSP 7.6 Maintenance Management

System, requires that if the work scope changes or the work cannot be performed then the work order should be evaluated for re-planning.

Corrective Ste s Taken and Results Achieved As an immediate action, a fire watch was established at 2050 hours0.0237 days <br />0.569 hours <br />0.00339 weeks <br />7.80025e-4 months <br /> on July 28,

1991, and maintained until the fire wrap was replaced on August 2,

1991.

Unit 3 work activities-were stopped until TVA determined root cause and appropriate corrective action.

The following event specific corrective actions were taken for the failure of personnel to follow procedures.'lanners and craft personnel were specifically instructed on the procedural requirement that the planner is to initiate an Attachment F if fire protection equipment or barriers are involved in the work activity.

Fire Protection operators have been instructed to perform a physical review of work packages prior to providing Fire Protection requirements.

Personnel corrective action, in accordance with TVA policy, was administered to the individuals who failed to follow procedure.

Corrective actions taken for management's failure to ensure full compliance to procedures were as follows:

The Field Services Manager briefed Field Services personnel on the requirement of supervision to be knowledgeable of and to adhere to procedural and policy requirements.

Written duties and responsibilities for Field Services-Modifications personnel were developed, and discussed to clarify job requirements for these individuals.

An enhanced training matrix was developed for Field Services personnel.

The training requirements for Field Services'

positions were verified adequate.

Training identified in the enhanced training matrix was completed before plant related activities were resumed.

Operational sensitivity training was given to the Unit 3 field and engineering personnel.

This training included a review of this specific incident, fire protection, environmental qualification, seismic issues, unit separation, and the changed operational environment due to Unit 2 operations.

TVA has also taken action to improve the control of inspection requests for Unit 3 components in systems that are required to be operable for Unit 2 power operation or Unit 3 layup.

Training was given on the use of color-coded separation drawings.

Walkdown procedures were revised to require the categorization of physical work involved during the walkdowns and to require engineering review and approval of walkdowns requiring physical work within Unit 2 operating spaces.

Walkdowns in Unit 2 operating spaces are to be scheduled by Unit 2 Operations.

These actions should minimize unnecessary walkdowns.

In order to verify the effectiveness of these improvements, contractor walkdown activities are being resumed using a phased approach.

Walkdowns involving Unit 3 systems or components requiring no physical work were started first.

Walkdowns involving Unit 3 systems or components not in Unit 2 areas requiring physical work were resumed next.

Finally, Walkdowns involving Unit 3 systems or components that are required for Unit 2/Unit 3 operations or require physical work in Unit 2 are being resumed.

3.

Corrective Ste s That Will Be Taken to Avoid Further Violations Corrective actions described above are complete and are considered adequate to preclude recurrence.

4 ~

Date When Full Com liance Will Be Achieved TVA was in compliance on September 9,

1991.

RESTATEMENT OF VIOLATION 91-26>>03 Technical Specification Section 6.8.1.1.a, requires that written procedures be established and implemented covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.

This includes procedures for refueling equipment operation.

0

Procedure 3-ST-91-03, Unit 3 Fuel Sipping, required that fuel bundle movements be in accordance with 3-GOI-100-3, Refueling Operations, and the Fuel Assembly Transfer Forms.

Procedure 3-GOI-100-3, step 5.4.6, required that all steps on the Fuel Assembly Transfer Forms be performed line by line.

Contrary to the above, on June 29,

1991, and July 6, 1991, during the performance of fuel sipping, fuel assemblies were placed in Unit 3 spent fuel storage pool locations other than those required by the approved Fuel Assembly Transfer Forms.

The second event occurred after the implementation of corrective actions taken for the first event which included first and second party.verification of both the fuel assembly

. serial number and spent fuel storage pool location."

1.

Reason for the Violation Procedure 3-ST-91-03, which controlled the fuel sipping activities, required that fuel 'bundle movements be performed in accordance with 3-GOI-100-3 and SDSP 26.1, Special Nuclear Material (SNM) Management.

TVA decided to use the fuel transfer form from SDSP 26.1, and use row-rack-column location with single party verification to account for fuel during fuel sipping activities.

On June 29, during the performance of Unit 3 fuel sipping activities, a fuel movement error occurred due to fuel handlers incorrectly identifying and moving a fuel assembly different from that identified by the transfer form.

The fuel movement error was attributed to personnel error and failure to follow procedures.

Prior to restarting fuel moves on July 1, TVA decided to add second party verification and also use the fuel assembly serial number during the remaining fuel moves.

On July 6, 1991, during the Unit 3 fuel sipping activities, a sequence of three fuel movement errors was discovered.

Fuel movement was halted pending investigation.

This second incident was also attributed to personnel error (misidentification of fuel assemblies) and failure to follow procedures.

SFSP rack location was performed but not by row-rack-column per the fuel handling training and procedure 3-GOI-100.3.

Fuel handlers were identifying the rack location based on the routine of fuel assembly movements in the rack.

First and second party verifications were performed based on this pattern of fuel movement.

The practice of reading the serial number off transfer form sheets before attempting to read it off the fuel assembly bail handle allowed verification errors to be introduced into the process.

Also, the bridge operator was relying on the spotter for confirmation of the fuel assembly serial number instead of reading the serial number directly from the transfer form.

0

2.

Corrective Ste s Taken gad Results Achieved After the first incident (June 29, 1991), the fuel assembly was immediately returned to its proper location and the surrounding fuel assemblies'ocations were verified correct.

An incident investigation was initiated to determine the cause and identify appropriate corrective action.

As a corrective action, fuel handlers were briefed on the importance of correctly identifying the SFSP rack locations.

An additional pre-)ob briefing was held to address second party verification requirements prior to resuming fuel sipping activities.

This corrective action was not effective as evidenced by the second incident on July 6, 1991 involving a sequence of fuel movement errors.

The fuel assemblies'ocations were verified and a field change to the transfer form was generated to permit return of the fuel assemblies to their correct rack location.

An incident investigation was conducted to determine the cause and appropriate corrective action.

This time the fuel handlers were counselled as a group and individually on the importance of performing second party verification.

Communications were improved by placing a supervisor on the bridge to monitor fuel handling activities and communications.

An operator's communication aid (list of questions) was established to formalize oral communications between the bridge and the Senior Reactor Operator (SRO),

and a radio was provided to the bridge and the SRO to assist in communications.

Personnel corrective action, in accordance with contractor policies, was administered to the personnel involved.

Special Test 3-ST-91-03, Unit 3 Fuel Sipping, was completed on July 13, 1991.

No further fuel movement errors occurred during the remaining sipping activities, which required the movement of approximately 590 fuel assemblies.

The fuel sipping involved the handling of a total of 1004 assemblies.

3.

Corrective Ste s That Will Be Taken to Avoid Further Violations Corrective actions described above are complete and are considered adequate to preclude recurrence.

4.

Date When Full Com liance Will Be Achieved TVA was in compliance on July 26, 1991 with the completion of contractor corrective actions.