ML18036A514

Responds to NRC 920109 Ltr Re Violations Noted in Insp Rept 50-259/91-41,50-260/91-41 & 50-296/91-41 on 911116-911215. Corrective Action:Manager Issued a Verbal Stop Work Order for All Telecommunications Work Associated W/Contract

ML18036A514
Person / Time
Site:	Browns Ferry
Issue date:	02/07/1992
From:	ZERINGUE O J TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9202190062
Download: ML18036A514 (13)

See also: IR 05000259/1991041

Text

ACCELERATED

DISTRIBUTION

DEMONSTRATION

SYSTEM REGULATORY

INFORMATION

DISTRIBUTION

SYSTEM (RIDS)ACCESSION NBR:9202190062

DOC.DATE: 92/02/07 NOTARIZED:

NO FACIL:50-259

Browns Ferry Nuclear Power Station, Unit 1, Tennessee 50-260 Browns Ferry Nuclear Power Station, Unit 2, Tennessee 50-296 Browns Ferry Nuclear Power Station, Unit 3, Tennessee AUTH.NAME AUTHOR AFFILIATION

ZERINGUE,O.J.

Tennessee Valley Authority RECIP.NAME

RECIPIENT AFFILIATION

Document Control Branch (Document Control Desk)SUBJECT: Responds to NRC 920109 ltr re violations

noted in insp rept 50-259/91-41,50-260/91-41

&50-296/91-41

on 911116-911215.

Corrective

action:Manager

issued a verbal stop work order for all telecommunicatxons

work associated

w/contract.

DISTRIBUTION

CODE: IE01D COPIES RECEIVED:LTR

ENCL SIZE: TITLE: General (50 Dkt)-Insp Rept/Notice

of Violation Response NOTES DOCKET 05000259 05000260 05000296 INTERNAL: RECIPIENT I D CODE/NAME HEBDON,F WILLIAMS,J.

ACRS AEOD/DEIIB

DEDRO NRR MORISSEAU,D

NRR/DLPQ/LPEB10

NRR/DREP/PEPB9H

NRR/PMAS/I

LRB12 O~R-EG FTE:, 02 COPIES LTTR ENCL 1 1 1 1 2 2 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 RECIPIENT ID CODE/NAME ROSS,T.AEOD AEOD/DSP/TPAB

NRR HARBUCKiC~NRR/DLPQ/LHFBPT

NRR/DOEA/OEAB

NRR/DST/DIR

SE2 NUDOCS-ABSTRACT

OGC/HDS3 RGN2 FILE 01 COPIES LTTR ENCL 1" 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 EXTERNAL EG&G/BRYCE

i J~H~NSIC 1 1 1 1 NRC PDR 1 1 NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE!CONTACT THE DOCUMENT CONTROL DESK, t ROOM P 1-37 (EXT.20079)TO ELIMINATE YOUR NAME FROM DISTRIBUTION

LISTS FOR DOCUMENTS YOU DON'T NEED!TOTAL NUMBER OF COPIES REQUIRED: LTTR 25 ENCL 25

0

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

35609 pEB O7 i<92 O.J.'Ike'eringue

Vice President.

Browns Ferry Operations

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, 296/91-41-REPLY TO NOTICE OF VIOLATION (NOV)AND DEVIATION This letter provides TVA's reply to the NOV and deviation transmitted

by letter from B.A.Wilson to D.A.Nauman dated January 9, 1992.TVA acknowledges

the violation and the deviation.

Enclosure 1 to this letter provides TVA's"Reply to the Notice of Violation and Deviation" in accordance

with 10 CFR 2.201 and 10 CFR 2 Appendix C.Enclosure 2 provides a listing of commitments

made in this reply.If you have any questions regarding this response, please contact Raul R.Baron at (205)729-7570.Sincerely, r jjZ~r(~t 0.J.Zeringue Enclosure cc: See page 2 9202190062

920207 PDR ADOCK 05000259 Q PDR P1 i

0 0 0

U.S.Nuclear Regulatory

Commission

~EH 07 nm Enclosures

cc (Enclosures):

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

35611 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

0 0

ENCLOSURE 1 Tennessee Valley Authority Browns Ferry Nuclear Plant (BFN)Reply to Notice of Violation (NOV)and Deviation Inspection

Report Number"During the Nuclear Regulatory

Commission (NRC)inspection

conducted on November 16-December 15, 1991, a violation of NRC requirements

was identified.

The violation involved failure to adequately

control design activities.

In accordance

with the'General Statement of Policy and Procedure for NRC Enforcement

Actions,'0

CFR Part 2, Appendix C (1991), the violation is listed below: 10 CFR 50 Appendix B, Criterion III, Design Control, requires that measures shall be established

for the identification

and control, of design interfaces

and for coordination

among participating

design organizations.

These measures shall include the establishment

of procedures

among participating

design organizations

for the review, approval, release, distribution, and revision of documents involving design interfaces.

Site Procedure, SDSP-16.17, Contractor

and-Contractors

Equipment Controls, required that for documentation

associated

with Design Change Notices or Engineering

Change Notices review and approval shall be per applicable

site procedures.

Contrary to the above, activities

involving design control were not implemented

in accordance

with requirements

in that during the installation

of upgraded communications

equipment, subcontractors

activities

were not adequately-

controlled

by their design organization

or by Nuclear Engineering, the site design organization.

Work Plans were not utilized to implement a design change and on October 13, 1991, the subcontractor

cut electrical

cables servicing two Personnel Radiological

Accountability

System readers used to account for personnel during a radiological

event.This is a Severity Level IV Violation (Supplement

I)applicable

to all three units."

0

Enclosure 1 Page 2 of 4 TVA did not have adequate controls in place to ensure the contractor

was meeting its contractural

requirements.

The site coordinator

for the telecommunications

project did not administer

adequate supervision

over the contractor, in that he failed to ensure the contractor

was complying with the site work control process.The coordinator

was not familiar with site procedural

control requirements

and did not verify work plans were in place prior to the start of work.Contributing

to this was the lack of involvement

by site personnel, inadequate

direction provided by responsible

management, and the failure to use the site procedure (Site Director Standard Practice[SDSP]-16.17)

for controlling

contractor

activities.

The telecommunications

project contract and design were developed and managed at the corporate level resulting in only peripheral

participation

at the site level (i.e., design changes were reviewed and approved in accordance

with the site program, but site personnel did not become involved in the project).The site coordinator

did not understand

his responsibilities

due to poor communication

by his management.

v t k t v Upon learning that the Personnel Radiological

Accountability

System cables were cut by telecommunications

personnel, the BFN site support manager issued a verbal stop work order for all telecommunications

work associated

with the contract.The site communications

engineer was provided training, which consisted of reviewing procedures

that address the handling of contractors

and maintenance.

A condition adverse to quality report was initiated and Site Quality issued a formal stop work order on the telecommunication

project.Q~ggt v t 3LMCLtiQnM

t v k t v th All telecommunications

work will be coordinated

through the Modifications

organization, who will be responsible

for ensuring site work practices are followed.Additionally, BFH will baseline contractors

authorized

to perform work within the protected area to ensure all contractors

are assigned to a TVA organization

aware of site work control practices.

The baselining

will be completed by February 24, 1992., A new contractor

release/work

control standard practice, which establishes

a technical contract manager (TCM)for TVA contractors, will be completed by March 9, 1992.This standard practice will supercede SDSP 16.17.The TCM will be required to verify proper orientation, training, and interfacing

of contractors

and their subcontractors

with TVA organizations, including Quality Assurance, when required.In addition, the Contractor

Work Release (CWR)program requires contractors

to impose controls on each of their subcontractors.

Enclosure 1 Page 3 of 4 4.Date When Full Com liance will be Achieved TVA considers that full compliance

will be achieved upon completion

of the corrective

actions for baselining

contractors

at BFN and the issuance of the new standard practice.These corrective

actions will be completed by March 9, 1992.~BVIATI0"During an NRC inspection

conducted on November 16-December 15, 1991, a deviation from your reply to Notice of Violation 91-26-02 for your actions taken to control contractor

activities

was identified.

In accordance

with the"General Statement of Policy and Procedure for NRC Enforcement

Action", 10 CFR Part 2, Appendix C, 1991, the deviation is listed below: TVA in reply to Notice of Violation 91-26-02 dated October 9, 1991, stated that action taken to improve the control of inspection

requests of contractor

walkdown activities

would be resumption

of these activities

using a phased approach.Contrary to the above, on November 4, 1991, construction

contractor

walkdown activities

were not resumed using a phased approach.Contractor

personnel performed safety related work during a walkdown inspection

involving partial removal of a secondary containment

boot under work order 91-422447-00.

The contractor

involved had only been released for non quality activities

such as scaffold erection.Performance

of safety related work activities

was not scheduled to be released until December 9, 1991.This deviation is applicable

to Unit 3." 1.Reason for the Deviation TVA determined

that the work performed outside the scope of the CWR was the result of Stone 6 Webster Engineering

Corporation (SWEC)management's

failure to clearly communicate

the scope of the Contractor/Subcontractor

Work Release to SWEC managers, supervisors, and engineers.

The removal of the safety-related

piping penetration

boot by SWEC, to support the walkdown group, was beyond the scope of TVA administrative

requirements

established

by a CWR dated October 21, 1991.The CWR did not release SWEC to perform safety-related

work.In early October, the walkdown group initiated a work request to remove the boot at a penetration

in the Unit 3 Reactor Building to allow data verification

of pipe supports.On November 4, 1991,

0

Enclosure 1 Page 4 of 4 after receiving the reviews, evaluations, and permits required by procedure, the penetration

boot was removed, walkdown data was obtained, and the boot was reinstalled

and then inspected by TVA Quality Control.The work was implemented

properly (i.e., authorized

by Plant Operations

and conducted in accordance

with procedure).

On November 14, 1991, a TVA QA representative

became aware of the work performed on safety-related

equipment during a weekly status meeting and questioned

whether the work was within the scope of the CWR.SWEC reviewed the work order and agreed that it was outside the scope of the CWR and issued a stop work memorandum.

2.Corrective

Ste s Taken and Results Achieved All work orders were withdrawn from construction

until they could be reviewed for scope definition.

SWEC supervisors

and engineers were retrained in the CWR program.As corrective

action, TVA issued a memorandum

on November 20, 1991, outlining enhancements

to the work release process, which included requirements

to ensure that the scope of work is directly communicated

to line supervision.

TVA.Restart organization

and contractor

managers, who manage contractor

field activities, were briefed on this incident and the potential implications

by December 6, 1991.Interim written guidance for controlling

contractor

field work activities

for Unit 3 restart was issued on December 9, 1991, and will be used until a site instruction

is implemented.

No further corrective

action is considered

necessary.

3.Corrective

Ste s that have been or will be Taken to Avoid Further, Deviations

A site instruction

will be issued by March 9, 1992 to ensure that CWRs are properly controlled (reference

TVA's response to NOV 91-41-02, which precedes this deviation response).

4.Date When Full Com liance will be Achieved Full compliance

will be achieved by March 9, 1992.

ENCLOSURE 2'Tennessee Valley Authority Browns Ferry Nuclear Plant/,.8)Reply to Notice of Violation (NOV)and Deviation Inspection

Report Number 6 1.BPÃwill baseline contractors

authorized

to perform work within the protected area and ensure they are assigned to a TVA organization

aware of site work control practices.

This will be completed by February 24, 1992.2.TVA is writing a new contractor

release/work

control standard practice to establish a technical contract manager overview of contractors

and require contractors

to impose controls on each of their subcontractors.

This standard will be completed by Narch 9, 1992.