ML18033B597

Responds to NRC 901108 Ltr Re Violations Noted in Insp Rept 50-259/90-29,50-260/90-29 & 50-296/90-29.Corective Actions: Mod Foreman Reprimanded & Retrained & Event Reviewed W/Sys Evaluators & Tagging & Support Coordinators

ML18033B597
Person / Time
Site:	Browns Ferry
Issue date:	12/28/1990
From:	MEDFORD M O TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9101090152
Download: ML18033B597 (14)

See also: IR 05000259/1990029

Text

ACCELERATED

DISTRIBUTION

DEMONSTRATION

SYSTEM REGULATORY

INFORMATION

DISTRIBUTION

SYSTEM (RIDS)ESSION NBR:9101090152

DOC.DATE: 90/12/28 NOTARIZED:

NO DOCKET ACIL:50-259

Browns Ferry Nuclear Power Station, Unit 1, Tennessee 05000259 50-260 Browns Ferry Nuclear Power Station, Unit 2, Tennessee 05000260 50-296 Browns Ferry Nuclear Power Station, Unit 3, Tennessee 05000296 AUTH.NAME AUTHOR AFFILIATION

MEDFORD,M.O.

Tennessee Valley Authority RECIP.NAME

RECIPIENT AFFILIATION

Document Control Branch (Document Control Desk)SUBJECT: Responds to NRC 901108 ltr re violations

noted in Insp Rept 50-259/90-29,50-260/90-29

&50-296/90-29.Corective

actions: mod forMan reprimanded

&retrained&event reviewed w/sys evaluators

&tagging&support coordinators.'ISTRIBUTION

CODE: IE01D COPIES RECEIVED:LTR

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

of Vio ation Response NOTES:1 Copy each to: B.Wilson,S.

BLACK 1 Copy each to: S.Black,B.WILSON

1 Copy each to: S.Black,B.WILSON

D A 05000259 05000260 05000296 D RECIPIENT ID CODE/NAME HEBDON,F I TERNAL: ACRS AEOD/DEIIB

DEDRO NRR SHANKMAN,S

NRR/DOEA/OEAB

NRR/DRIS/DIR

NRR/PMAS/I

LRB12 OE G FTrh 02 EXTERNAL EG&G/BRYCE i J~H~NSIC NOTES: COPIES LTTR ENCL 1 1 2 2 1 1'1 1 1 1 1 1 1 1 1 1 1.1 1 1 1 1 1 5 5 RECIPIENT ID CODE/NAME ROSS,T.AEOD AEOD/TPAB NRR MORISSEAU,D

NRR/DLPQ/LPEB10

NRR/DREP/PEPB9D

NRR/DST/DIR

8E2 NUDOCS-ABSTRACT

OGC/HDS3 RGN2 FILE 01 NRC PDR COPIES LTTR.ENCL 1 1 1 1 1 1 1'1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 D NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE!COiNTACT THE DOCUMENT CONTROL DESK, ROOli'I PI-37 (EYT.20079)TO ELliill NATE YOUR NAME FROID DISTRIBUTION

I.ISTS I OR DOCU)ilEiNTS

YOU DON'T NEED!TAL NUMBER OF COPIES REQUIRED: LTTR 29 ENCL 29 D D

TENNESSEE VALLEY AUTHORITY 5N 157B Lookout Place GEc 38 1990 U.S.Nuclear Regulatory

Commission

ATTN:'ocument

Control Desk Washington, D.C.20555 Gentlemen:

In the Matter of Tennessee Valley Authority Docket Nos.50-259 50-260 50-296 BROWS FERRY NUCLEAR PLANT (BFN)-NRC INSPECTION

REPORT 50-259, 260, 296/90-29-RESPONSE TO NOTICE OF VIOLATION This letter provides TVA's response to the Notice of Violation transmitted

by letter from B.A.Wilson to 0.D.Kingsley, Jr.dated November 8, 1990.NRC cited TVA with a violation with two examples for failure to follow procedures.

The first example involved personnel working within an equipment clearance boundary without proper authorization

on a hold order.The-second, example involved an improperly

completed impact evaluation

of work activities

0 t which resulted an an unplanned engineered

safety features actuate.on.

Enclosure 1 provides TVA's response to this violation.

Each example is addressed separately

along with the corrective

actions taken.On December 17, 1990, NRC issued Inspection

Report 90-33 which cited two new.self-identified

examples of the problem identified

in this violation.

TVA will address both of these examples in a supplement

to this letter.The supplement

will be submitted by January 31, 1991.J As agreed with members of the NRC Region II staff, the due date for this'esponse was extended, to December 31, 19+.Enclosure 2 is a listing of the commitment

made in this response.If you have any questions regarding this response, please telephone Patrick P.Carier at (205)729-3570.Very truly yours, TENNESSEE VALLEY AUTHORITY gg gi 4<M.0.Medford, Vice President Nuclear Assurance, Licensing and Fuels Enclosure cc: See page 2 9101090152

901228 PDF'DGCI." 050002'=9 f,i PDR An Equal Opportunity

Employer g Eo/I/

l, l

U.S.Nuclear Regulatory

Commission

cc (Enclosure):

Ms.S.C.Black, Deputy Director Project Directorate

11-4 U.S.Nuclear Regulatory

Commission

One White Flint, North 11555 Rockville Pike, Rockville, Maryland 20852 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 1 RESPONSE-BROWNS FERRY NUCLEAR PLANT NRC'INSPECTION

REPORT 50 259'60~296/90 29 LETTER FROM B.A.WILSON TO 0.D.KINGSLEY, JR.DATED NOVEMBER 8, 1990 During the NRC inspection

conducted between September 16 and October 15, 1990 a violation of NRC requirements

for failing to follow procedures

was identified.

The first example of this violation involved personnel working inside an equipment clearance without proper authorization

on a hold order.The second example involved an improperly

completed impact evaluation

of work activities

which resulted in an unplanned engineered

safety features (ESF)actuation.

Technical Specifications, Section 6.8.1, Procedures, requires that written procedures

shall be established, implemented

and maintained

covering those recommended

in Appendix A of Regulatory

Guide 1.33, Revision 2, February 1978.Appendix A of Regulatory

Guide 1.33 includes administrative

procedures

and procedures

for controlling

repair activities

of safety-related

equipment.

Site Directors Standard Practice (SDSP)-7.9, Integrated

Schedule and Work Control, Section 6.4.1, requires that an impact evaluation

be performed on all activities

that have potential for affecting equipment operations

which may affect the safe and reliable operation of the unit except as specifically

exempted.Attachment

C to SDSP-7.9 is used to document that evaluation.

Section 7.0 specifies the Tagging and Support Coordinator's

duties in reviewing, correcting, and issuing hold order boundaries.

SDSP-14.9, Equipment Clearance Procedure, Section 6.1 provides both general and special requirements

for removing equipment from service to allow work to safely proceed.Contrary to the above, these requirements

were not met for the following two examples: l.On August 25, 1990 the requirements

were not met in that Workplan 0252-90 was determined

to be in progress without appropriate

supervision

having signed onto an existing hold order.2.On September 16, 1990 the requirements

were not met in that an inadequate

impact evaluation

resulted in licensee personnel cutting energized electrical

leads that were part of the D Diesel Generator initiation

logic circuits.This activity resulted in an unplanned engineered

safety feature actuation.

This is a Severity Level IV Violation (Supplement

I)applicable

to all three A units~

t x TVA admits the violation.

This violation occurred due to personnel error.The lead Modifications

foreman responsible

for signing on to the hold order failed to sign on to the hold order prior to the work being performed.

On August 16, 1990 while preparing to implement a workplan, modifications

personnel contacted the lead modifications

foreman and requested that he sign the workplan on to an existing hold order.After receiving the" request, the lead foreman noted in the Modifications

organization's

log book, which lists hold orders and denotes specific workplans covered by each hold order, that he had signed on to a hold order.Modifications

personnel responsible

for performing

the work reviewed the log book, confirmed that'the lead foreman had signed the workplan on the existing hold order, and proceeded to implement the workplan.However, although the lead foreman had noted in the log book that he had signed on to a hold order he never contacted appropriate

plant personnel to have the workplan signed on to the hold order.Signing on to hold orders prior to implementing

workplans is required by Site Director Standard Practice (SDSP)14.9, Equipment Clearance Procedure, if equipment must be removed from service to perform work.t v t v.n k v The Modifications

foreman associated

with this event received a reprimand from his supervisor.

This foreman was also retrained in the requirements

of SDSP 14.9.This training was conducted by a Shift Operations

Supervisor

and specifically

emphasized

the correct preparation

of tagout requests, the purpose of equipment clearances (to protect personnel and equipment), responsibilities

of the Operations

organization

for establishing

clearance boundaries, and responsibilities

of the Modifications

organization

for walking down and verifying established

boundaries

before beginning work.Prior to completing

this training the foreman was restricted

from signing on to hold orders.Rhd~t'a t v th r To prevent further recurrence

of this type of event, Modifications

management, general foremen and foremen were retrained in the requirements

of SDSP 14.9.The specifics of this training are discussed above.This training has been completed.

5.v TVA considers that it has achieved full compliance

with the specifics of this example of the violation.

1.m'h TVA admits the violation.

2.This violation occurred due to personnel error on the part of the individuals

responsible

for preparing and reviewing the impact evaluation

sheet.SDSP 7.9, Integrated

Schedule and Work Control, requires that scheduled work activities

be evaluated for impact on plant equipment.

This evaluation

is documented

on, Attachment

C, Plant Operation Impact Evaluation

Sheet (POIES).Individuals

responsible

for preparation

and review of the POIES are responsible

for identifying

significant

component and system responses such as ESF actuations, in addition to determining

whether work will be within a hold order boundary.Specifically, the Work Control System Evaluator (or system evaluator)

is responsible

for developing

a"...suggested Hold Order that encompasses

all the work that can be logically done under a given set of boundaries." The Tagging and Support Coordinator

is responsible

for"...review[ing]

and correct[ing]

the suggested Hold Order boundaries." In this event, the system evaluator was assessing the impact of two work orders directing replacement

of Raychem splices on the leads to two reactor vessel level transmitters.

These work orders were among approximately

15 other work orders directing replacement

of Raychem splices.Because several of the other work orders involved reactor protection

system (RPS)components, the system evaluator incorrectly

assumed that the work would affect RPS components

instead of emergency core cooling system components.

Based on this, he concluded that the work could be performed under an existing hold order for RPS components.

The system evaluator then provided this assessment

to the Tagging and Support Coordinator.

During his review of the assessment, the Tagging and Support Coordinator

questioned

personnel performing

the work, and their supervisor, regarding the appropriateness

of the suggested hold order boundary.Based on this information

and the assessment

provided by the system evaluator, the Tagging and Support Coordinator

incorrectly

determined

that the work could be performed under the existing hold order.

(~o

3.t'v t t'The Plant Operations

Manager reviewed this event with the Work Control Manager and the Operations

Superintendent.

These managers have in turn taken appropriate

corrective

actions with the system evaluator and the Tagging and Support Coordinator

associated

with this event.4, t'In order to prevent further recurrence

of this type of event, TVA reviewed this event with the system evaluators

and the Tagging and Support Coordinators

to stress the importance

of properly and thoroughly

completing

the impact.evaluation

sheet for each work activity to be performed.

In, addition, the importance

of Operations

personnel performing

a thorough review prior to work approval was stressed.5.t h n A v TVA considers that it has achieved full compliance

with the specifics of this example of the violation.

ENCLOSURE 2 COMMITMENT

RESPONSE-BROWNS FERRY NUCLEAR PLANT NRC INSPECTION

REPORT 50-259, 260, 296/90-29 LETTER FROM B.A.WILSON TO 0.D.KINGSLEY, JR.DATED NOVEMBER 8, 1990 On December 17, 1990, NRC issued Inspection

Report 90-33 which cited two new self-identified

examples of the problem identified

in this violation.

TVA will address both of these examples in a supplement

to this letter.The supplement

will be submitted by January 31, 1991.