IR 05000259/1989037
| ML18033A959 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 09/07/1989 |
| From: | Anand R, Jocelyn Craig, Daniels R, Raynard Wharton Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML18033A958 | List: |
| References | |
| 50-259-89-37, 50-260-89-37, 50-296-89-37, EA-85-049, EA-85-49, NUDOCS 8909260192 | |
| Download: ML18033A959 (16) | |
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UNITEDSTATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 OFFICE OF NUCLEAR REACTOR REGULATION TVA PROJECTS DIVISION Report Nos:
Licensee:
50-259/89-37, 50-260/89-37 and 50-296/89-37 Tennessee Valley Authority 6N 38A Lookout Place 1101 Market Street Chattanooga, Tennessee 37402-2801 Docket Nos.:
50-259, 50-260 and 50-296 License Nos.:
DPR-33, DPR-52 and DPR-68 Facility Name:
Browns Ferry Units-I, 2, and
Inspection Conducte
.
August 22, 1989 through August 25, 1989 Inspectors:
om anse s,
earn eader Rag Mn,
eactor ys ems ng>neer xi I
'I f fd( iCi4! tllli<
~f'y W arton, qua sty perations ngineer Approved by:
o niW.
rang, pecia ss>sta t Associate Director for Special'ojects Office of Nuclear Reactor Regulation ate g 7 8'9 ate Date
=7
>'1 ate SUMMARY
~Sco e:
This special announc d inspection was conducted in the areas of allegation fol lowup and implementation of the Conditions Adverse to gual ity (CA() Program to determine if all requirements of Order Modifying License, EA 85-49, have been addressed and completed for Browns 'Ferry.
The basis for this inspection was various allegations received by the NRC and the Order Modifying License, EA 85-49.
Results:
No violations, deviations, unresolved items or inspection followup items were identified.
8909260l92 890914 PDR ADOCK 05000259
Order Modifying License, EA 85-49, required actions were found to have been completed and their implementation at Browns. Ferry were acceptable.
Therefore, compliance with the Order was found to be acceptable.
The Order will be lifted by the normal licensing process.
Several allegation investigations were completed and wi 1 1 be'losed by'he allegation closure proces.
Persons Contacted REPORT DETAILS Licensee Em lo ees
- 0. Zeringue, Site Director
- G. Turner, gA Manager
- S. Rudge, Site Programs Manager
- L. Ellis, ECSP
- P. Salas, Compliance Licensing Supervisor
- J. Wallace, Compliance Engineer
- L. Clardy, gA Engineer S.
Moss, Site Labor Relations Officer and other personnel of the plant staff.
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- D. Carpenter, Site Manager
- C. Patterson, Restart Coordinator
- T. Daniels, Project Manager
- R. Anand, Reactor Systems Engineer
- R. Wharton, guality Operations Engineer
- B. Long, Project Inspector In a letter dated June 14, 1985, the NRC staff issued an Order (EA 85-49)
modifying the license of Browns Ferry.
This was a result of a special review conducted on March 27-29, 1985 where the NRC identified a breakdown in the management controls for evaluating and reporting potentially significant safety concerns.
- In that Order, NRC ordered that the Tennessee Valley Authority (TVA)
shall do the following:
Within 60 days complete an evaluation of its procedures at each of its operating nuclear power plant sites and at its Office of Engineering in Knoxville, Tennessee with regard to their adequacy for assuring that when potentially significant safety conditions are identified by engineering management such as the Chief Nuclear Engineer (Nuclear Engineering Branch Chief), they are immediately reported to plant management, evaluated expeditiously, for appropriate action, including applicability to other plants, reported if required, and corrected; submit the evaluation along with a plan and schedule for promptly revising the procedures as appropriate.
Within 120 days, develop and submit a plan for training of all personnel involved in 'implementing the revised procedures including t
- Attended exit interview-3-
responsible licensee management personnel both in Office of Engineering and the Office of Nuclear Power to ensure that such personnel recognize potentially significant safety conditions and ensure that they are expeditiously evaluated, reported, and corrected and understand their individual responsibilities in carrying out the procedure.
The plan shall provide a schedule when the training will be completed for all of the employees and managers.
Within 45 days, provide copies of all reports, evaluations or other analysis that may have been prepared of the circumstances surrounding, including chronology of events, the qualification issue of the pressure transmitters at Sequoyah between October 1, 1984 and April 1, 1985.
If investigations had been conducted or were ongoing that had not yet been completed this was to be indicated with an expected date when the documents would be provided.
In addition, within 45 days the licensee was required to survey all of its OE employees and NUC PR employees as well as any other appropriate employee and submit a report which identified each employee including managers who were aware of the pressure transmitter qualification issue between October 1,
1984 and April 1, 1985 at SNP and the date of his or her first knowledge of such an issue.
Persons who were employed during that period who have since left the licensee's employ were also required to be contacted.
The Director, Office of Inspection and Enforcement was authorized to relax or terminate any of the above conditions for good cause.
Documents Reviewed The following documents were reviewed to verify implementation of an upgraded program for Conditions Adverse to Quality (CAQ) at Browns Ferry Nuclear Plant (BFN):
(1)
Corrective Action, NQAM, Part 1, Section 2.16, Revision
(2)
Quality Notice, NQAM, Part 1, Section 2.16, Revision 0.
(3)
Corrective Action, NEP 9. 1, Revision 4.
(4)
Site Director Standard Practice, Corrective Actions, SDSP 3. 13, Revision 2.
(5)
BFN Nuclear Performance Plan, Part II, Section 2.5.
(6)
Audit Report, BFK 89905 - Correction of Deficiencies.
(7)
Employee Concern Investigation Report, ECP-88-CH-185-01.
(8)
Memorandum, 0. J. Zeringue, Site Director to All Managers, Browns Ferry Nuclear Plant, June 23, 1989.
(9)
NRC Inspection Reports 50-259/88-16, 50-260/88-21 and 50-296/89-12.
(10) Trend Analysis, QMP 116.3, Revision 1.
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(ll) Trend Analysis, QMI 616.3, Revision
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BFN Site Quality Trend Report, June 1989 Discussion The review indicates that TVA has made significant improvements in their corrective action programs.
This was evident by the programmatic upgrades including:
major revision of procedures for handling safety significant issues; conducting a formal comprehensive training program for using the revised procedures; the implementation of a tracking system which is capable of assuring timeliness of addressing identified issues; and the establishment of a site coordinator who is responsible for the administrative handling of the CAQ documents.
In addition to the programmatic procedural requirements" the level of management review for CAQ documents has been upgraded with participation by the Site Manager.,
Plant Manager, QA Manager and the Engineering Manager.
This is accomplished by having a Management Review Committee meeting dai ly to discuss the disposition of all CAQ reports.
Further, it was noted that several other non-programmatic factors have been implemented to contribute to a more workable and efficient corrective action process.
These factors include better informal communications between managers, supervisors, and the staff; a much improved upper and middle level management team at BFN; and increased attention by Senior
.
Management of TVA toward the improvement of the CAQ programs and their efficient implementation.
While the review indicated that there were still some implementation deficiencies in the CAQ process that need correction, overall TVA's program and more specifically BFN's program for handling of corrective actions meets or exceeds their licensing commitments.
Therefore, the requirements of the Order Modifying License EA 85-49 are considered completed for Browns Ferry.
The Order wi 11 be lifted by the normal licensing process in the near future.
3.
~A11 a.
OSP 89-A-0054 ( I)
An allegation was received by the NRC staff which stated:
TVA is dropping commitments, specifically TVA Topical, Section 17.1.15.3 addresses trending of Conditions Adverse to Quality (CAQ).
When Engineering Assurance is abolished, TVA will not be prepared in Division of Nuclear Engineering (DNE) to accept trending responsibilities for engineering CAQs.
(2)
The allegation was not substantiated.
The commitment to trend CAQ was not dropped and is still continuing.
The trending of CAQ for DNE is being accomplished by Nuclear Quality Assurance (NQA).
Overall TVA trending is being accomplished by Nuclear Licensing-5-
and Regulatory Affairs Division in Chattanooga.
The governing procedure NQAM, Part 1, Section 2. 16 was in the process of
= revision at the time of this inspection and a Quality Notice was issued on August 11,. 1989 implementing tr ending responsibilities in the interim.
This allegation is considered resolved.
b.
OSP 87-A-0050 (2)
An allegation was received by the NRC staff which stated:
There are programmatic deficiencies -in handling of CAQ identified at other plants.
The allegation was substantiated.
When the allegation was received in early 1987 the new CAQ program was just being implemented at all TVA facilities.
Since th'at time the CAQ program has been fully implemented, training has been completed, and the documentation and trending of CAQ have improved.
The Order Modifying Licenses (EA 85-49) against the CAQ programs at Sequoyah (SQN)
and Browns Ferry (BFN) was closed for SQN on March 31, 1988 and will be closed for Browns Ferry by the end of September 1989.
In discussions w'ith the alleger, after, the new CAQ program was fully implemented, it was determined that satisfactory progress was being made at TVA concerning the CAQ program.
This allegation is considered resolved.
c, OSP 88-A-0086 (2)
An allegation was received by the NRC staff which stated; Disposition of CAQRs is inadequate.
The allegation was partially substantiated.
The alleger was concerned that CAQ were not adequately reviewed to address root causes.
The recent revisions to the CAQ program were found to adequately address this concern, especially since the addition of the Management Review Committee to the review process for the CAQ program.
Further, the increase in the level of management participation and overview were found to be sufficient to close the Order Modifying License, EA 85-49, Inadequate CAQ Program.
In discussions with the alleger, the CAQ program, as now implemented, has adequately addressed the root causes of CAQRs.
This allegation is considered resolved.
d.
OSP-88-A-0018 (2)
An anonymous allegation was received by the NRC staff which stated:
A contracted TVA employee had passed a
TVA drug screening test by using a substitute urine sample.
It is unfair for TVA employees to be RIF while drug abusing contractors are hired.
This allegation was not substantiated.
During the review of this allegation the subject contractor's personnel records were verified.
The alleged contract employee has been terminated and no longer
works at the plant.
With regard to the alleged use of substitute urine samples, Program Manual Procedure No. 0905.01.04,
"Fitness for Duty Program," Revision 4, has a provision for suspected substitute or tampered samples received during drug testing.
The provision requires direct observation of a second sample.
As a
part of the allegation investigation, the inspector also reviewed Browns Ferry's drug screening practices as implemented by the Fitness for Duty Program.
The inspector determined that the same test is administered to both TVA employees and contractor/vendor employees requiring unescorted nuclear plant access.
Based on the review of the Fitness for Duty Program, the inspector has determined that this allegation is resolved.
e.
OSP-88-A-0085 (1)
An allegation was received by the NRC staff which stated:
(a)
A former temporary employee was not treated fairly when he tested positive for marijuana use during a random drug test because he was not given the option of entering into a rehabilitation program, Employee Assistance Program (EAP).
(b)
TVA was not administering their drug testing program in a random manner.
(2)
The allegation was not substantiated.
i (a)
During the investigation of this allegation an interview was conducted with the BFN Site Labor Relations Officer.
He is responsible for the implementation and administration of the Fitness for Duty Program at BFN.
During discussions of the program, he stated the general practice regarding the referral of employees to the EAP was that the EAP is only applicable in situations dealing with TVA employees with more than a year seniority.
(b)
Part of TYA's Fitness for Duty Program includes a drug screening or test ng process.
This testing process is designed to deter the use of illegal drugs, alcohol or other controlled substances.
The tests are routinely administered to all TVA or contractor employees requiring unescorted plant access.
The random selection of individuals to be tested is established by a computer program.
The basis of the selection is (1) the number of employees in the pool, (2) the number of alternates required, and (3) annual employee test rates of at least 50%.
Based on the inspector's review of the Fitness for Duty Program, this allegation is considered resolved.
OSP-88-A-0066 (1)
An allegation was received by the NRC staff which stated:
(a)
TVA supervisors that had falsified travel claims were not prosecuted or treated similarly as their subordinates by TYA's Office of the Inspector Genera (b)
(c)
The Inservice Inspection Supervisor had, at his home, copies of original handwritten employee concerns; therefore, the originator's identity could be determined.
No exit, whole body coun't was administered when site access was revoked.
(2)
The allegation was substantiated in part.
(a)
While travel claim issues are an internal TVA matter, the following discussion is for information.
The travel claims issue was turned over to TVA Office of Inspector General (OIG).
The results of the OIG investigation were then referred to the Federal attorney for legal resolution of the issue.
The Federal attorney made the determination of which cases would be prosecuted.
Based on the results of litigation this part of the allegation was substantiated; some employees were prosecuted and some were not.
(b)
(c)
ECP personnel were interviewed regarding the handling of employee concerns.
The majority of the employee concerns were received prior to the establ-ishment of the ECP, by Quality Technical Corporation (QTC),
a contractor hired to initially handle the concerns.
When the concerns were turned over to TVA's ECP, the identities of the originators were not divulged.
The concerns received since the ECP has been established are being treated confidentially.
However, it was determined that there are situations where the identity of an originator is difficultif not impossible to mask.
The allegation could not be substantiated.
Interviews were conducted with Health Physics (HP) personnel regarding employee termination (exit) whole body counts.
The termination procedures and practices are difficult to enforce if an employee chooses to disregard them.
When an employee does not get a termination whole body count, a record of the individual's life time exposure is forwarded through the TVA Office of Personnel upon termination.
For the concerned individual, the inspector verified that there was no check out sheet in his personnel folder,.indicating he did not formally process out before terminating employment.
The inspector also observed that a sign was posted in the window of the HP office regarding termination whole body counts.
It was determined that the responsibility for receiving a whole body count upon termination rests solely with the individual and not with TYA or HP.
This allegation is considered resolved.
g.
OSP-89-R-0050 (I)
An allegation was received by the NRC staff which stated:
(a)
The ultimate goal of TYA with respect to nuclear safety should be to protect the population surrounding BFN, but this is not the case.
The engineering philosophy throughout
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(b)
TVA and particularly prevalent at the BFN is "the plant is safe as long as we meet the letter of the law."
No considera-tion is given to the probability of various malfunctions, particularly in the design change process, even though it is required by 10 CFR 50.59.
Engineering design management reviews design changes with blinders on so that overall plant safety is not considered.
CAQR (BFN 890341)
was processed by engineering design management as invalid and closed with no justification or explanation.
This represents the current management goal of quantitatively reducing the number of outstanding CAQRs by half within this 1989 fiscal year.
(2)
The allegation was substantiated in part.
(a)
(b)
During the investigation of this allegation the inspector interviewed NRC site personnel and reviewed recent inspection reports related to
CFR 50.59 requirements and unreviewed safety question determination (USQD).
Inspection reports 89-04 and 89-17 both identify (1) an unresolved item that significant weaknesses exist with 10 CFR 50.59 safety reviews, (2)
a violation involving failure to properly implement design change process and (3)
a violation involving failure to comply with the requirements of 10 CFR 50.59.
The design change process included a screening review that failed to require a safety evaluation or USQD be performed for facility changes not described in the SAR.
The inspection reports also concluded that the general licensee attitude appeared to emphasize compliance with requirements rather than safe facility operation.
Based on the inspection findings, the inspector determined that this portion of the allegation was substantiated.
As part of the investigation of this allegation, the inspector interviewed CAQ coordination'ersonnel and reviewed CAQR No.
BFP 890341.
The CAQR was initially escalated, requiring management attention, because the management review was not completed within the designated time period.
The CAQR was then evaluated by the management reviewer, who recommended invalidation because he disagreed with the initiator's analysis of the problem.
The initiator disagreed with the management reviewer's evaluation and documented an explanation to refute each point of the evaluation.
The escalation reviewer evaluated the initiator's analysis, the reviewer's evaluation, and the initiator's response to decide that the CAQR was invalid.
Additionally, the ECP has reviewed all recently invalidated CAQRs to determine if there was a
problem with improper invalidation of CAQRs.
This CAQR, BFN 890341, was not identified as having been improperly invalidated.
The NRC staff also concurred with the safety evaluation required by an associated technical specification change.
Based upon the discussion above, this portion of the allegation was not substantiated.
This allegation is considered resolved.
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OSP-85-A-0052 (2)
An anonymous allegation was received-by the NRC staff which stated:
TVA Office of Engineering is inadequate, with 12 specific citations of inadequacies concerning engineering functions.
This allegation was substantiated.
The issue is prograomatic in nature and refers to organizational and/or procedural problems in the engineering design process.
The NRC consultant, Parameter, Inc.,
reviewed the subject allegation and prepared a Technical Evaluation Report (TER).
The staff reviewed the TER and concurred in the bases and findings for Sequoyah and considers that the same findings were applicable to all the other design organizations of the TVA.
A review of TVA Corrective Action Tracking Documents (CATO) and employee concern subcategory report 20400 "Engineering Organization and Operating Procedures",
resolves the concerns and properly encompasses the issues addressed in the allegation.
In addition, TVA has targeted improvements in engineering and design process as defined in Corporate Nuclear Performance Plan (NPP)
and site specific performance plans.
In some cases, NRC inspections of the Design Baseline and Verification Program (DBVP) and Independent Design Inspection ( IDI) are acceptable verification of satisfactory completion of required corrective actions.
This allegation is considered resolved.
OSP-86-A-0001 (2)
An allegation was received by the NRC staff which stated:
The lack of accountability and mismanagement at TVA has caused a
degradation of work quality and morale.
This allegation was substantiated.
In order to address management problems, TVA has developed the Corporate Nuclear Performance Plan (CNPP) which identifies and proposes corrections to problems with the overall management of the TVA nuclear program.
TVA has made significant progress in their recovery program as descr ibed in their CNPP, Revision 6 dated May 5, 1989.
Specifically, Revision 6 describes the progress made in each of several identified" programmatic areas..
In addition, TVA has developed the Browns Ferry Nuclear Performance Plan (BFN NPP),
Volume III, Revision 2, dated October 24, 1988.
To address the problem of lack of authority, position descriptions have been developed for each TVA manager against which he or she will be measured and which will clarify each manager's authority and responsibilities.
To address the problem of insufficient management involvement and control, site goals are being implemented that are consistent with the corporate goals defined in the CNPP.
Communication with employees has been strengthened to enhance management involvement.
Training has been strengthened to reinforce management's directive to have procedures followed and upgraded as a means to ensure better control of work.
In addition',
the BFN NPP, Volume III, stresses that emphasis will be placed on holding each employee accountable for proper accomplishment of assigned duties.
It also stresses the-10-
effort that will be placed in regaining the trust and confidence of the employee so as to improve their morale.
Based on the results of NRC's evaluation of the CNPP and site specific NPP and the appropriate corrective measures that have been initiated by TYA, this allegation is considered resolved.
OSP-86-A-0002 (2)
An allegation was received by the NRC which stated:
Generally, TVA employees are incompetent, inexperienced, and lack knowledge in regulatory requirements.
This allegation was partially substantiated.
TVA has recognized and acknowledged the lack of experienced technical and management personnel and has developed and initiated corrective actions which are addressed in the Corporate Nuclear Performance Plan (CNPP).
The CNPP was reviewed by the NRC staff and the results of the review documented in the Safety Evaluation Report (SER),
NUREG-1232, Volume I, dated 1987.
Portions of this SER are pertinent to the subject allegation.
One major cause of the problems with the management of TVA'.s nuclear program was the widespread shortage of experienced managers.
To remedy this situation, TVA has hired new managers to fill key positions.
Collectively, these new managers have a broad base of experience in and knowledge of nuclear operations.
TYA's revised CNPP addresses four areas of past concern:
quality assurance/quality control (QA/QC), engineering, training and licensing.
On the basis of its review to date, the staff believes that the consolidation of QA/QC functions, the establishment of clear lines of responsibility for engineering activities, the reorganization of the training program, and management's new commitment to meet its responsibilities, along with centralization activities, will address the concerns stated in the allegation.
Based on the results of the evaluation of the subject allegation, the staff finds that the appropriate corrective measures have been initiated by TYA to assure that the TYA staff is qualified and competent to perform their assigned tasks.
In addition, the NRC will monitor implementation of the CNPP to determine whether or not the Employee Concern Program is working, that an environment of intimidation and harassment does not exist, and that employees are not prevented from expressing safety-related concerns.
This allegation is considered resolved.
k.
OSP-86-A-0016 and OSP-86-A-0040 (1)
An allegation was received by the NRC staff which stated:
The major electrical calculations may not be adequate or records cannot be verified to include the proper inputs.
Therefore, the electrical systems and components may not be functioning within their design limits set forth by the regulatory requirements, licensee commitments and license conditions.
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(2)
This allegation has been substantiated.
In the past, problems and confusion developed with respect to TVA's nuclear engineering organization and on site engineering activities.
The lack of a centralized engineering organization and duplication of engineering expertise and overlapping responsibilities contributed to problems in areas such as design control and configuration control.
TVA has developed a series of nuclear performance plans (NPPs) to correct programmatic and management deficiencies that have contributed to the continued poor direction and control of TVA's nuclear activities.
Volume 1 of the NPP describes the measures that TVA has taken and currently intends to take to improve the corporate-level management of its nuclear activities and to correct the problems that have occurred in this area.
Volumes 2, 3, and 4 address Sequoyah (SgN),
Browns Ferry (BFN) and Watts Bar (WBN) respectively.
The three site specific nuclear performance plans provide an account of the actions TYA is taking, or will take, to improve its nuclear program.
These measures, when implemented, should resolve the identified problem areas and prevent their recurrence.
TVA has committed in the site specific NPPs (under "Special Programs" )
for SgN, BFN, WBN to a design calculation review program.
The cal-culation reviews have the common objectives of identifying essential calculations, verifying the existence of essential calculations, ensuring the technical adequacy of essential calculations, and ensuring that essential calculations are current.
"Essential calculations" are defined as calculations for safety-related plant features.:
As calculations are reviewed for technical adequacy, significant deficiencies will be identified and tracked with a Condition Adverse to guality Report.
This process includes the identification of appropriate corrective actions.
Similar to SgN, the staff is currently reviewing BFN NPP with respect to the calculation efforts.
The final acceptance of TVA's corrective actions will be documented in BFN NPP Volume III SER.
Exit Based upon the evaluations performed by the TVA's employee concerns efforts, the staff review of those corrective actions and the actions described in the Browns Ferry NPP, the staff concludes that actions are acceptable to resolve this allegation.
Interview The inspection scope and findings were summarized on August 25, 1989 with the personnel indicated in paragraph 1.
The Team Leader described the areas inspected and discussed the status of each allegation reviewed.
The licensee did not identify as proprietary any of the material provided to or reviewed by the inspectors during this inspection.
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