ML18036B021
| 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.