IR 05000259/2003008

IR 05000259-03-008, IR 050000260-03-008 and IR 05000296-03-008 on 11/3-7, 17-21/2003; Browns Ferry Nuclear Plant, Units 1, 2 and 3; Biennial Baseline Inspection of the Problem Identification and Resolution Program

ML033530368
Person / Time
Site:	Browns Ferry
Issue date:	12/19/2003
From:	Cahill S Reactor Projects Region 2 Branch 6
To:	Scalice J Tennessee Valley Authority
References
IR-03-008
Download: ML033530368 (24)

Text

ber 19, 2003

SUBJECT:

BROWNS FERRY NUCLEAR PLANT - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000259/2003008, 05000260/2003008 AND 05000296/2003008

Dear Mr. Scalice:

On November 21, 2003, the Nuclear Regulatory Commission (NRC) completed an inspection at your Browns Ferry 1, 2 and 3 reactor facilities. The enclosed inspection report documents the inspection results, which were discussed on November 21, 2003, with Mr. Ashok Bhatnagar and other members of your staff.

The inspection was an examination of activities conducted under your license as they relate to the identification and resolution of problems, and compliance with the Commissions rules and regulations, and with the conditions of your operating license. Within these areas, the inspection involved selected examination of procedures and representative records, observations of activities, and interviews with personnel. This inspection was a routine biennial inspection of your Corrective Action Program for Units 2 and 3 in the NRCs Baseline Inspection Program. However, it also evaluated the adequacy of your Corrective Action Program on Unit 1, currently undergoing recovery efforts to return to operation, for future inclusion into our Reactor Oversight Process and routine Baseline Inspection Program.

On the basis of the sample selected for review, there were no findings of significance identified during this inspection. The inspectors concluded that problems were properly identified, evaluated and resolved within the problem identification and resolution programs. In addition, the inspection confirmed that you have established an adequate corrective action process to support the current activities associated with Unit 1 recovery.

TVA 2 In accordance with 10 CFR 2.790 of the NRCs Rules of Practice, a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Stephen J. Cahill Reactor Projects Branch 6 Division of Reactor Projects Docket Nos. 50-259, 50-260, 50-296 License Nos. DPR-33, DPR-52, DPR-68

Enclosure:

NRC Inspection Report 05000259/2003008, 05000260/2003008, 05000296/2003008 w/Attachment: Supplemental Information

REGION II==

Docket Nos: 50-259, 50-260, 50-296 License Nos: DPR-33, DPR-52, DPR-68 Report No: 05000259/2003008, 05000260/2003008 and 05000296/2003008 Licensee: Tennessee Valley Authority (TVA)

Facility: Browns Ferry Nuclear Plant, Units 1, 2 & 3 Location: Corner of Shaw and Nuclear Plant Roads Athens, AL 35611 Dates: November 3 - 7, and November 17 -21, 2003 Inspectors: S. Shaeffer, Senior Project Engineer (Team Leader)

K. VanDoorn, Senior Reactor Inspector W. Bearden, Senior Resident Inspector, Unit 1 (first week)

E. Christnot, Resident Inspector (second week)

Approved by: Stephen J. Cahill, Chief Reactor Project Branch 6 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000259/2003-008, 05000260/2003-008, 05000296/2003-008; 11/3-7, 17-21/2003;

Browns Ferry Nuclear Plant, Units 1, 2 and 3; Biennial baseline inspection of the problem identification and resolution program. Included focused review of Unit 1 Corrective Action Program implementation to support ongoing Unit 1 recovery.

The inspection was conducted by a Senior Project Engineer, a Senior Reactor Engineer, a Senior Resident Inspector, and a Resident Inspector. No findings of significance were identified. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.

A. Inspector-Identified and Self-Revealing Findings Identification and Resolution of Problems No findings of significance were identified by the team. Overall, the licensee maintained an effective program for the identification and correction of conditions adverse to quality. The licensee was effective at identifying problems at a low threshold and entering them into the Corrective Action Program (CAP). In general, the licensee consistently prioritized issues in accordance with their CAP and routinely performed adequate evaluations that were technically accurate and of sufficient depth.

However, minor problems were identified related to thoroughness of corrective action program issue documentation and categorization of level D PERs for issues where higher categorization may have been more consistent with the licensees CAP requirements. The team considered the licensees CAP tracking program output reports to be paper intensive and a contributor to inefficiencies identified in the area of issue documentation and ability to perform efficient CAP trending.

Formal root cause evaluations for significant conditions adverse to quality were thorough and detailed. Corrective actions developed for lower level root and contributing causes were generally timely, effective, and commensurate with the safety-significance of the issue. Although the licensee incorporated a wide variety of root cause techniques, non-uniform root cause report outputs resulted in a cumbersome process for personnel to ensure all contributing causes were being adequately considered for broader corrective actions or extent of condition reviews.

The licensees periodic self-assessments and audits were effective in identifying deficiencies in the CAP and covered all areas of plant performance. Corrective actions for previous performance examples were being actively monitored within self-assessments and audits of the CAP. Several identified repetitive deficiencies with the CAP that resulted in the issuance of higher level CAP problem reports to address.

Overall, the ability to perform self critical assessments was considered an effective program attribute, especially when addressing repetitive human factor performance issues where desired improvements were continuous in nature.

TVA 2 Site management was purposely active and involved in the CAP and focused appropriate attention on significant plant issues. At the Management Review Committee (MRC) meetings, management made frequent modification of Problem Evaluation Report (PER) priorities, PER descriptions, PER root cause determination techniques, and other items to ensure CAP expectations were being implemented.

Based on review of the licensees Concern Resolution Program and discussions conducted with plant employees from various departments, the inspectors did not identify any reluctance to report safety concerns.

Initial reviews of the CAP for Unit 1 concluded that the licensee had established adequate processes and measures for including Unit 1 into the CAP at Browns Ferry.

Problem identification thresholds were sufficiently low and management was actively involved in implementation of the program in order to instill consistent expectations and improve program efficiencies. Trending of Unit 1 PERs was well established and recent data did not indicate any areas of concern with the current Unit 1 recovery activities.

B. Licensee-Identified Findings None.

REPORT DETAILS

4OA2 Problem Identification and Resolution

a. Effectiveness of Problem Identification

(1) Inspection Scope The inspectors reviewed licensee Procedure SPP 3.1, Corrective Action Program, Revision 4, which describes the administrative process for the identification and resolution of problems.

The inspectors reviewed PERs that had been initiated by the licensee since July 2001 (prior to the last NRC baseline problem identification and resolution inspection conducted in December 2001) to verify that problems were being properly identified, appropriately characterized, and entered into the corrective action program (CAP).

Though not limited to, the reviews focused on issues associated with the following risk significant plant safety systems: emergency diesel generator (EDG), Residual Heat Removal Service Water (RHRSW), High Pressure Coolant Injection (HPCI) and the Control Air. In addition to the system reviews, the inspectors selected a representative number of PERs that were identified and assigned to the major plant departments which included operations, maintenance, engineering, security, chemistry, health physics, and emergency preparedness.

The inspectors also reviewed completed maintenance work orders (WOs), system health reports, and the Maintenance Rule database for the selected systems to verify that equipment deficiencies were being appropriately entered into the corrective action and Maintenance Rule programs. The inspectors conducted plant walkdowns of equipment associated with the EDG, RHRSW, HPCI, and Control Air to assess the material condition and to look for any deficiencies that had not been entered into the CAP. The inspectors reviewed historical control room operator logs to verify that equipment deficiencies, especially those involving the safety systems selected for the focused review, were entered in the CAP.

The inspectors reviewed selected industry operating experience items, including NRC generic communications, to verify that they were appropriately evaluated for applicability and whether issues identified through these reviews were entered into the CAP.

The inspectors reviewed licensee audits and self-assessments (focusing primarily on problem identification and resolution) to verify that findings were entered into the CAP and to verify that these findings were consistent with the NRCs assessment of the licensees CAP.

The inspectors attended plan of the day status and Management Review Committee (MRC) meetings to observe management oversight functions in the corrective action process. The inspectors also interviewed personnel from operations, maintenance, engineering, security, health physics, chemistry, and other site organizations to evaluate their threshold for identifying issues and entering them into the CAP.

Documents reviewed to support the inspection are listed in the Attachment.

(2) Assessment The inspectors determined that the licensee was effective in identifying problems and entering them into the CAP. PERs normally provided complete and accurate characterization of the subject issues. In general, the threshold for initiating PERs was very low and employees were encouraged by management to initiate PERs. This was currently evidenced by the approximate 4,500 Unit 2 and Unit 3 PERs in 2003 year to date and approximately the same amount exclusively for Unit 1. Equipment performance issues involving maintenance effectiveness, such as maintenance errors, poor maintenance work practices, and inadequate risk assessments, were being identified at an appropriate level and entered into the CAP. Although several NRC identified PERs were initiated during the inspection for identified material condition issues, plant tours confirmed that the threshold for identifying material condition issues was low.

The licensee was effective in evaluating internal and external industry operating experience items for applicability and entering issues into the CAP. The team found that communication for internal operating experience between other TVA sites was frequently reviewed and samples indicated that applicable issues were identified at the Browns Ferry site and appropriate followup was being performed. The licensees program for reviewing and processing operating experience for external sources was also well established. The site also contributed to operating experience databases on a frequent basis to allow other utilities to benefit from Browns Ferry operating experience.

Department self-assessments and audits performed by the Quality Assurance (QA)organization and other individual section groups covered all areas of plant performance and were effective in identifying issues and these deficiencies were entered into the CAP. QA audits were particularly self-critical and identified a number of substantive issues or directed attention to areas that needed improvement. The team considered that the audits and self-assessments reviewed were focused on identifying weaknesses and areas for improvement, rather than documenting existing program area strengths.

Corrective actions for previous performance examples were being actively monitored within self-assessments and audits of the corrective action program. Several assessments indicated repetitive deficiencies identified with the CAP requiring the issuance of higher level CAP problem reports to address. Overall, the ability to perform self critical CAP assessments was considered an effective program attribute, especially when addressing human factor performance issues where desired improvements were continuous in nature.

Site management was purposely active and involved in the CAP and focused appropriate attention on significant plant issues. At the Management Review Committee (MRC) meetings, management made frequent modification of PER priorities, PER descriptions, PER root cause determination techniques, and other items to ensure CAP expectations were being implemented.

b. Prioritization and Evaluation of Issues

(1) Inspection Scope The licensees Corrective Action Program (CAP) defined in SPP-3.1, defines four classifications of PER significance: A level was the most significant, typically safety-related and requiring a formal root cause analysis; B level was considered significant, required further evaluation, and may require a formal root cause determination based upon management decision; C level was for routine problems warranting additional corrective evaluation and action; and D level was for issues that could be quickly resolved/closed and trended or routine problems which were adequately addressed by immediate actions or the work control process.

The team reviewed a sampling of PERs to determine if issues were classified and processed in accordance with the requirements of procedure SPP-3.1. The team attended the licensees Management Review Committee (MRC) Meeting to observe the final classification assignment for emerging PERs. The team reviewed root cause analyses and apparent causes for PER items to assess the quality, adequacy, and thoroughness of the evaluations. In addition, the team assessed the corrective action items resulting from the cause determinations to determine if procedure requirements were met to correct the problem and to prevent recurrence if required. The cause codes identified in the PERs were compared to the identified apparent cause or root cause analyses determination to determine if the causes were correct and that the causes were adequately addressed by the corrective action item. Selected audits and self-assessments were reviewed by the team to determine if problems were developed into PERs.

Reviews were conducted to determine if the PERs were correctly classified in accordance with procedure guidance and that corrective action items were completed as described in the corrective action plan. While the majority of PERs reviewed were classified as Category D, the sample also included a representative number of Category A, B and C PERs. The inspectors review was also intended to verify that the licensee adequately determined the cause of the problems and adequately addressed operability, reportability, common cause, generic concerns, and extent of condition. For significant conditions adverse to quality, the review was also to verify that the licensee adequately addressed the root and contributing causes and appropriately identified corrective actions to prevent recurrence. The team also reviewed self assessment process concerning the grading of PERs for improvement purposes.

Documents reviewed are listed in the attachment.

(2) Assessment The inspectors determined that, overall, the licensee properly prioritized issues entered into the CAP in accordance with SPP 3.1. Generally, the licensee performed adequate evaluations that were technically accurate and of sufficient depth. Formal root cause evaluations for Category level PERs A and B were more thorough and detailed than those of lesser categories, as expected. The inspectors did not identify any risk significant issues that had not been appropriately prioritized and evaluated. However, the inspectors identified several minor problems involving PERs that lacked documentation that supported the Level D classification. Based on additional reviews into each PER subject matter, the basis for the Level D classification was more apparent; however, several PERs had generic implications which were not discussed or did not reference a higher level PER handling the generic corrective actions for the site.

Examples were identified where the team determined a higher level or more rigorous evaluation would have been more appropriate and/or may have been more effective in the timely resolution of the problem. Examples of these type of issues included the following:

• In 2003, PER 03-11995 identified an RHR swapover valve failed to stroke in automatic and was coded a D level PER. The apparent cause indicated hardened grease and the grease was replaced. The inspectors reviewed the valve history, and determined that this same valve had a failure to open in manual due to hardened grease in 2001 (WO 01-003661). Based on the potential for generic implications and entry into a degraded TS condition, this PER should have been a C or a B PER, according to the licensees categorization process. Long term corrective actions for this generic issue were being implemented, such as improved preventative maintenance instructions on looking for hardened grease symptoms and site change out to a new grease less susceptible to hardening; however, these additional actions were not documented in the PER.

• 02-005723, D level PER described a through wall leak in the RHRSW system cause by Microbiologically Induced Corrosion (MIC). The PER identified the problem and fixed the specific piping issue only without any discussion of generic applicability of extent or condition reviews which were being evaluated via other activities.

• 02-015702, D lever PER described multiple problems with Control Rod (CR)indications/movements. The PER stated that appropriate maintenance had been initiated, however, the PER failed to reference the Level B PER (02-013222) which was covering the generic aspects of rod control.

The inspection determined that the licensees use of Root Cause and Apparent Cause analysis, in general, was of sufficient quality, depth, and focus to identify applicable root causes. The licensee utilized a variety of root cause analysis techniques to determine these causes and their contributor; however, the results of the root cause evaluations were difficult to compare to other issues for commonality, primarily due to the non-uniform format of root cause results. The team did not identify any specific root cause adverse trends which were not identified. However, the team did concluded that efficiencies could be gained in the area of root cause analysis to ensure all contributing causes are being appropriately addressed.

An example was identified where an evaluation was not reassessed using more current information and the initial root cause identified in a PER was not updated following completion of the final root cause determination. PER 01-12072-000 detailed an event which occurred on November 24, 2001, affecting both operating units. With thunderstorms in the vicinity, Unit 2 experienced significant plant perturbations including the average power range monitor going from a low of 91 percent, to a high of 112 percent, and then back to 100 percent. Unit 3 plant experienced a significantly reduced effect which included a small power reduction and an immediate return to full power. The Unit 2 electro-hydraulic control (EHC)system for the turbine generator had been modified and included a generator load control network. The EHC system on Unit 3 had not been modified and did not have a generator load control network. The existing PER reflected that the initial analysis of the event determined that the storms caused a line fault and grid instabilities.

The subsequently performed root cause for the event determined the Unit 2 modification caused the significantly different Unit 2 plant response. Although, corrective actions for the generator load control network modifications were incorporated, the existing PER was not updated to reflect the revised root cause.

c. Effectiveness of Corrective Actions

(1) Inspection Scope The inspectors evaluated a sample of PERs, WOs, self-assessments, licensee audits and operating experience items to verify that the licensee had identified and implemented timely and appropriate corrective actions to address problems. The inspectors verified that the corrective actions were properly documented, assigned, and tracked to ensure completion. Where possible, the inspectors independently verified that corrective actions were implemented as intended. For significant conditions adverse to quality, the review was to verify that effectiveness reviews were adequately performed as required by SPP 3.1, Corrective Action. The inspectors reviewed PERs to assess the adequacy of the corrective actions applied to the PER adverse conditions. Inspectors also reviewed WOs, audits, and self-assessments to evaluate the effectiveness of corrective actions, and to determine if the timeliness met the licensee's problem identification and resolution requirements, including corrective actions to address common cause or generic concerns. The PERs selected included the system PERs and WOs discussed in report section 4OA2.a (1), as well as a selection of human performance PERs attributed to operations, engineering, and maintenance personnel. Additional PERs were selected based on their relation to security, emergency preparedness and radiation protection. The inspectors also reviewed the corrective actions taken in response to Non-Cited Violations ( NCVs)documented in NRC inspection reports over the previous two year period to verify CAP procedure requirements were met and that actions were thorough and comprehensive.

Licensee corrective actions associated with 2001, 2002, and 2003 Licensee Event Reports (LER) were also sampled to confirm the implementation of key corrective actions.

The inspectors also performed selected sampling and trend analysis of a variety of CAP program and other corrective action related licensee programs. These included, but were not limited to: Operator work arounds; Temporary Alterations, Maintenance related functional failures; System Health Reports; and illuminated control room annunciators.,

The inspectors also reviewed the 50 oldest PERs and WOs to verify that the basis for the delay in correcting the identified problems was valid and that extensions were approved and justified as required by the CAP procedure. A sampling of deleted PERs were reviewed to assess the basis for the deletion and if the deletion was appropriate for the issue. The review was also to verify the adequacy of corrective actions to address equipment deficiencies and Maintenance Rule functional failures of the plant systems that were selected for the focused review as discussed in Section 4OA2.a.

Documents reviewed are listed in the attachment.

(2) Assessment Overall, corrective actions developed and implemented for problems were timely and effective, commensurate with the safety significance of the issues. Corrective actions developed and implemented for plant equipment problems were generally effective in correcting the equipment deficiencies. The inspectors found that the scope and depth of corrective actions taken by the licensee were appropriate for the severity and risk significance of the problem identified. Where repetition had occurred, the licensees trending program and rework program had identified the failures as such and the licensee had prescribed additional corrective action to address the cause.

Reviews of CAP related areas such as System Health Reports, Operator Work Arounds, control of temporary alterations, etc. indicated that the licensee was actively utilizing these programs to enhance the corrective action process in these specific areas. Once specific corrective actions for these areas were developed, they were re-integrated within the PER system. In addition, the team considered that recent improvements to the methods used to develop the System Health Reports were resulting in improved System Health Report detail and increased challenge to system engineers to identify potential safety issues not being addressed.

d. Assessment of Safety-Conscious Work Environment

(1) Inspection Scope During technical discussions with members of the plant staff, which included operations, maintenance, engineering, chemistry, health physics, emergency preparedness, and security personnel, the inspectors developed a general perspective of the safety-conscious work environment at the site. The discussions also helped the inspectors determine if any conditions existed that would cause employees to be reluctant to raise safety concerns. The inspectors also reviewed the licensees employee concerns program (ECP) which provides an alternate method to the CAP for employees to raise concerns and remain anonymous. The inspectors interviewed the ECP Coordinator and reviewed a select number of ECP reports completed since July 2001 to verify that concerns were being properly reviewed and identified deficiencies were being resolved in accordance with SPP-1.0, Organization and Administration, Revision 2, Appendix D, Concerns Resolution.

(2) Assessment The inspectors concluded that licensee management emphasized the need for all employees to identify and report problems using the appropriate methods established within the administrative programs. All of the predominant methods established by the licensee, including the CAP, the WO system, and the ECP, were readily accessible to all employees. Licensee management encouraged all employees to promptly identify nonconforming conditions. Based on discussions conducted with plant employees from various departments, the inspectors did not identify any reluctance to report safety concerns.

e.

Implementation of Corrective Action Program to Support Unit 1 Recovery

(1) Inspection Scope The inspection included reviews associated with implementation of a Corrective Action Program for the Recovery Project on Unit 1. The licensee implemented a parallel CAP for Unit 1 via the incorporation of a sub-committee forming a Unit 1 Management Review Committee. The sub-committee functions the same as the Unit 2 and 3 MRC and conducts daily meetings to evaluate, control, and monitor implementation of the Unit 1 CAP. The purpose of the review was to determine if the licensee has implemented an adequate CAP to support Unit 1 recovery. In addition, the inspection reviewed whether the licensees CAP was adequately established to support future incorporation of Browns Ferry Unit 1 into the Revised Oversight Process (ROP). The ROP is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. The ROP program was designed for evaluation of operating reactors and is described in NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.

The team observed a variety of the Unit 1 MRC and other related meetings, discussed program monitoring and trending with CAP personnel, and reviewed existing self-assessments and an audit which included Unit 1 activities. A significant portion of the Unit 1 PERs to date were screened by the team and those issues identified in the were reviewed in detail to determine the breadth of the Unit 1 Corrective Action Program. Analysis of the types of corrective action issues being identified was performed to evaluate whether any adverse trends existed. Unit 1 reviews similar to the Unit 2 and 3 reviews described in Sections 4OA2 a. thru 4OA2 d. were also performed.

There were no Unit 1 Licensee Events Reports issued over the previous three years for review.

Documents reviewed are listed in the attachment.

(2) Assessment Initial reviews of the corrective action program for Unit 1 concluded that the licensee had established adequate processes and measures for including Unit 1 into the corrective action program at Browns Ferry. Problem identification thresholds were notably low and management was actively involved in implementation of the program in order to instill consistent expectations and improve program efficiencies. Thresholds for PER prioritizations were reasonably well established; however, occasional management upgrading of issues at the MRC was occurring. Based on trend analysis of the PERs reviewed, the team considered that the major types of PERs being identified were consistent with the status of the Unit 1 recovery effort. No unidentified adverse trends were established.

Observations of the Unit 1 MRC verified managements active and continual involvement in establishing the Unit 1 CAP. Several examples were noted where efficiencies could be gained in the processing of PERs and other information through the MRC. Examples included improvements through the reduction of paperwork associated with the existing PER system and better organization of CAP status presentations to the MRC via standardized root cause evaluations and more streamlined status updates, such as the periodic CAP update.

Through observations of the MRC for Units 2 and 3 and the Unit 1 MRC, discussions with operations shift personnel, and interface with PER coordinators, the team concluded that the licensee had established appropriate communications between the Unit 1 organization and the operating units. Daily reviews of Unit 1 issues and work activities were occurring to identify any operational impacts needing immediate or longer term corrective actions.

For Unit 1, the inspectors confirmed that the onsite contractors ECPs were established in a manner similar to the licensees and that the licensee ECP coordinator was periodically monitoring any active cases for the Unit 1 restart vendor organizations.

Vendor accessibility to the licensee ECP was also reviewed and considered an available option for vendor personnel reporting safety concerns.

4OA6 Management Meetings

The inspectors presented the inspection results to Mr. Ashok Bhatnagar, and other members of licensee management at the conclusion of the inspection on November 21, 2003. The inspectors confirmed that proprietary information was not provided or examined during the inspection.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

T. Abney, Nuclear Site Licensing & Industry Affairs Manager

A. Bhatnagar, Site Vice President

L. Clardy, Site Nuclear Assurance Manager

T. Feltman, Emergency Preparedness Supervisor

R. Golub, Component Engineering Manager

C. Ottenfeld, Radiation Protection and Chemistry Manager

R. Jones, Unit 1 Restart Manager

J. Lewis, Nuclear Plant Operations Manager

T. Niessen, Jr., Engineering & Site Support Manager

R. Rogers, Maintenance & Modifications Manager

M. Skaggs, Nuclear Plant Manager

NRC personnel

B. Holbrook, Senior Resident Inspector, Browns Ferry

S. Cahill, Branch Chief, Division of Reactor Projects, RII

LIST OF ITEMS

OPENED, CLOSED AND DISCUSSED

None.