ML18036B021

Responds to NRC 910911 Ltr 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 J TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9110160193
Download: ML18036B021 (10)

See also: IR 05000259/1991026

Text

Tennessee Valley Authority, Post Olfice Box 2000.Decatur,'Alabama

35609 O.J,'lite'eringue

Vice President, Browns Ferry Operations

0CT 09>SS)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,//Zg':if('i:</

0.Zeringue'?li0160ir?3

r0iioOi?PDR I-"IDOCI;O=OOO.~q I.(PDR p(/Q1

0

U.S.Nuclear Regulatory

Commission

OCT Pg)gg)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, f ire protection, environmental

qualif ication, 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 theircorrect 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.