CNL-16-122, Response to Apparent Violations in NRC Inspection Report 05000260/2016012 and Investigation Report No. 2-2015-008, EA-16-009

Response to Apparent Violations in NRC Inspection Report 05000260/2016012 and Investigation Report No. 2-2015-008, EA-16-009

ML16221A714
Person / Time
Site:	Browns Ferry
Issue date:	08/08/2016
From:	James Shea Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CNL-16-122, EA-16-009, IR 2016012
Download: ML16221A714 (6)

Text

1101 Market Street, Chattanooga, Tennessee 37402 CNL-16-122 August 8, 2016 10 CFR 2.201 ATTN : Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Browns Ferry Nuclear Plant, Unit 2 Renewed Facility Operating License No. DPR-52 NRC Docket No. 50-260

Subject:

Response to Apparent Violations in NRC Inspection Report 05000260/2016012 and Investigation Report No. 2-2015-008, EA-16-009

Reference:

Letter from NRC to TVA, "BROWNS FERRY NUCLEAR PLANT -

INSPECTION REPORT 05000260/2016012; INVESTIGATION REPORT NO. 2-2015-008; AND APPARENT VIOLATIONS" dated June 23, 2016

[ML16175A514]

This letter provides Tennessee Valley Authority's (TVA) response to the apparent violations of Browns Ferry Nuclear Plant Technical Specification 5.4.1 and 10 CFR 50 .9 NRC regulations described in the Reference letter. The details of TVA's response are provided in the Enclosure to this letter.

TVA acknowledges that these conditions existed as documented in the inspection report and does not contest these apparent violations.

There are no new commitments contained in this letter. If you have any questions, please contact Jamie L. Paul at (256) 729-2636 .

i:~~

Vice President, Nuclear Licensing Enclosure cc: See Page 2

U.S. Nuclear Regulatory Commission CNL-16-122 Page 2 August 8, 2016

Enclosure:

Response to Apparent Violations in NRC Inspection Report 05000260/2016012 and Investigation Report No. 2-2015-008, EA-16-009 cc: (w/ Enclosure)

NRC Regional Administrator - Region II NRC Senior Resident Inspector - Browns Ferry Nuclear Plant

Enclosure Response to Apparent Violations in NRC Inspection Report 05000260/2016012 and Investigation Report No. 2-2015-008, EA-16-009 Restatement of Apparent Violation 05000260/2016012-01, Failure to Follow Plant Procedures:

1. Technical Specification 5.4.1 requires written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. RG 1.33 App A 1.b, Authorities and Responsibilities for Safe Operation and A.1.c, Equipment Control, are implemented as part of licensee procedure OPDP-1, Conduct of Operations.

OPDP-1, section 3.4.2.O states, The SROs in an oversight position (SM and US) shall not manipulate plant equipment.

Contrary to the above, on December 21, 2014, while performing the licensed duties of Shift Manager, a Senior Reactor Operator (SRO) manipulated the 2A 480V Shutdown Board feeder breaker switch inducing a loss of power to the bus and a plant transient.

1. TVA Response to the Apparent Violation:

TVA understands and accepts the Apparent Violation.

Restatement of Apparent Violation 05000260/2016012-02, Failure to Maintain Complete and Accurate Control Room Logs:

2. 10 CFR 50.9, Completeness and Accuracy of Information, states, in part, information required by the Commissions regulations, orders, or license conditions to be maintained by the licensee shall be complete and accurate in all material respects.

Contrary to the above, on December 21, 2014, TVA failed to maintain information required by the Commissions regulations that was complete and accurate in all material respects. Specifically, following an equipment manipulation, plant transient and subsequent realization of an operator error, TVA maintained incomplete and/or inaccurate information on the cause of the transient in the operating logs and corrective action program. Shift logs are material to the NRC, as the logs are used to provide information in the determination of chronologies, root and contributing causes, and corrective actions for post-transient safety reviews and investigation by TVA and by the NRC.

CNL-16-122 Enclosure - Page 1 of 4

Enclosure Response to Apparent Violations in NRC Inspection Report 05000260/2016012 and Investigation Report No. 2-2015-008, EA-16-009

2. TVA Response to the Apparent Violation:

TVA understands and accepts the Apparent Violation.

Reason for the Apparent Violations:

The willful manipulation of plant equipment contrary to procedure and subsequent failure to accurately and completely record the event were identified by the Shift Managers own admission.

TVA conducted an investigation of the December 21, 2014 event using an attorney from the Office of the General Counsel. The OGC investigation was completed and documented in a report dated February 3, 2015. TVAs investigation evaluated three specific aspects of the event that relate to the reason for the apparent violations:

Did the specified Shift Manager intentionally and willfully cause the transient and subsequently withhold information that he knew was pertinent to the transient event?

Did the evidence support that the specified individual acted alone and that there were no other questions of trustworthiness related to other Browns Ferry employees?

Did the actions of the specified individual reflect the overall nuclear safety culture at BFN with regards to attributes such as Questioning Attitude, Leadership Commitment to Safety, Problem Identification and Resolution, Maintaining an Environment for Raising Concerns, and Work Processes Recognize Nuclear as Special and Unique?

TVAs investigation concluded that the specified Shift Manager knowingly operated plant equipment and knew that doing so was contrary to plant procedures. The investigation concluded that his action was impulsive and the result of a rash decision. The investigation determined that the individual was initially unaware that in operating plant equipment, he had in fact operated the incorrect plant equipment. The individual did initially communicate that he had operated plant equipment to a number of coworkers. However, when he subsequently became aware that he had in fact operated the wrong equipment, he knowingly delayed for some period of time communicating that significant detail.

Through its investigation, TVA determined that the procedural controls prohibiting the manipulation of switches by individuals other than Unit Operators or Assistant Unit Operators were clear and were understood by all individuals interviewed including the specified Shift Manager. The investigation did note that those prohibitions on equipment manipulations by Shift Managers were different than existed in years past at Browns Ferry.

TVA has determined that the actions by the Shift Manager were taken by the Shift Manager alone and were the result of the individual knowingly operating the plant contrary to established procedures. In addition, TVA concluded that the withholding of the updated information regarding operation of the incorrect plant equipment was deliberate notwithstanding that the individual ultimately brought the information forward himself of his own volition.

CNL-16-122 Enclosure - Page 2 of 4

Enclosure Response to Apparent Violations in NRC Inspection Report 05000260/2016012 and Investigation Report No. 2-2015-008, EA-16-009 Finally, the investigation determined there was no evidence to suggest that the behavior of the specified Shift Manager was reflective of the operating environment at BFN. Individuals interviewed confirmed that employees are encouraged to raise questions or concerns at any time, and there is no penalty for doing so. Individuals indicated that a commitment to following procedures and policies is evident at all levels within the organization. Issues that are identified are methodically analyzed and specific plans are developed for resolution of issues. Several interviewees indicated that this culture of a respect for safety and the uniqueness of a nuclear environment has increased significantly in the past few years.

Corrective Steps That Have Been Taken And The Results Achieved:

The site immediately suspended the Individuals access and expired his hand geometry when the event was discovered in December 2014, until an investigation was complete and determination of his suitability for unescorted plant escort was finalized.

The Individual has since left TVA, and his license has been terminated.

This event was entered into BFNs Corrective Action Program as Problem Evaluation Report (PER) 970963. The following Corrective Actions (CAs) were identified under PER 970963 to address this event:

Administer the appropriate personnel accountability actions in accordance with the accountability matrix for the individual involved in the event.

Conduct a briefing with SROs to reinforce the requirements set forth in OPDP-1 section 3.4.2.O.

With regard to the first corrective action associated with the administration of appropriate accountability, the affected individual turned in his resignation prior to completion of the accountability actions. Accordingly, and consistent with TVA Corrective Action procedures, this CA was documented as completed without the specified action being taken as of February 10, 2015.

With regard to reinforcing the requirements set forth in OPDP-1, on December 30, 2014, Operations Management discussed the importance of adhering to standards with Shift Managers. Additionally, on December 23, 2014, the BFN Plant Manager communicated with all Shift Managers and Licensed SROs to reaffirm the commitment to the expectations in OPDP1, Conduct of Operations. TVA has not identified any further instances of SROs manipulating plant equipment.

Subsequent to receipt of the Apparent Violation on June 23, 2016, related Condition Report 1189442 was created in order to implement an additional CA.

Verify a briefing has been delivered to the operations licensed personnel to reinforce the requirements set forth in OPDP-1 section 3.4.2.O and to emphasize that control room logs are subject to 10 CFR § 50.9 and must be complete and accurate and that failure to comply could result in NRC enforcement action potentially against both TVA and the individual(s) involved.

The scheduled completion date reflected in the Correction Action Program is September 26, 2016.

CNL-16-122 Enclosure - Page 3 of 4

Enclosure Response to Apparent Violations in NRC Inspection Report 05000260/2016012 and Investigation Report No. 2-2015-008, EA-16-009 Date When Full Compliance Will Be Achieved:

BFN is in full compliance. Based on CAs and on investigations conducted by OGC, TVA has determined that BFN SROs are properly trained on plant procedures and that the individuals behavior is not reflective of the Operations department work environment at BFN.

CNL-16-122 Enclosure - Page 4 of 4