ML18026B005
| ML18026B005 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 05/11/1984 |
| From: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Parris H TENNESSEE VALLEY AUTHORITY |
| Shared Package | |
| ML18026B006 | List: |
| References | |
| EA-84-032, EA-84-32, NUDOCS 8405210682 | |
| Download: ML18026B005 (8) | |
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UNITEDSTATES EAR REGULATORY COMMISSION REGION Il 101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30303 IAg/
Tennessee Valley Authority
'TTN:
Mr. H.
G. Parris Manager of Power and Engineering 500A Chestnut Street Tower II Chattanooga, TN 37401 Gentlemen:
SUBJECT:
PROPOSED CIVIL PENALTY ACTION:
EA 84-32 IMPROPER REACTIVITY CONTROL (REFERENCE INSPECTION REPORT NOS. 50-259/84-02, 50-260/84-02, AND 50"296/84"02)
A special NRC safety inspection was conducted during the period of January 16-19, 1984, of activities authorized by NRC Operating License Nos.
DPR-33, DPR-52, and DPR-68 for the Browns Ferry facility.
The inspection included a review of the circumstances surrounding improper shutdown of the Unit 1 reactor on January 6,
1984.
In addition, the, inspection revealed that a similar problem had occurred during a shutdown of Unit 3 on September 6,
1983.
As a result of this inspection, significant failures to comply with NRC regulatory requirements were identified.
An Enforcement Conference to discuss this matter was held in the Region II Office of the NRC on February 24, 1984.
The violations described in the enclosed Notice of Violations and Proposed Imposition of Civil Penalty involve a failure to adhere to the requirements of 10 CFR 50.59 and failure of a licensed operator to properly enforce control rod group limits when the Rod Worth Minimizer was inoperable.
These failures consti-tute four distinct violations of NRC requirements.
Although a limited number of rods were
- moved, those movements were made in accordance with a previously analyzed rod
- sequence, the NRC is concerned that these violations could have resulted in the reactor being placed in a condition less safe than that contemplated by the Final Safety Analysis Report (FSAR).
The FSAR assumes proper operation of the Rod Worth Minimizer (RWM) and Rod Sequence Control System (RSCS) in the evaluation of the consequences of a rod drop accident.
Use of the Rod Out Notch Override (RONOR) switch and failure of the licensed operator to maintain group limits while the RWM system was inoper-able effectively defeated the safety function performed.by the RSCS and RWM.
During the Enforcement Conference on February 24,
- 1984, the Tennessee Valley Authority (TVA) stated that an analysis of the events performed by TVA indicated
- that, had a rod drop accident taken place, permissible reactor core limits would not have been exceeded.
Although no core limits were actually exceeded in this
- case, automatic safety functions were overridden without performing a safety evaluation in accordance with NRC requirements.
CERTIFIED MAIL RETURN RECEIPT RE UESTED 840M10682'405fi PDR ADOCK 05000259
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Tennessee Valley Authority AYiI lggg j
To emphasize the seriousness of these violations, I have been authorized, after consultation with the Director, Office of Inspection and Enforcement, to issue the enclosed Notice of Violations and Proposed Imposition of Civil Penalty in the amount of Sixty Thousand Dollars ($60,000) for the violations described in the enclosed Notice.
The violations have been categorized at Severity Level III in accordance with the NRC Enforcement Policy, 10 CFR Part 2, Appendix C.
The base civil penalty for a Severity Level III violation is
$40,000.
Prior notice of similar events was provided to TVA by NRC's Information Notice No. 83-75, entitled "Improper Control Rod Manipulation,"
issued on November 3, 1983.
Because TVA had failed to take effective preventive steps suggested by the IE Information Notice, the base civil penalty amount is increased by 25 percent.
We wish to recognize that TVA did report this event to the NRC immediately upon its discovery.
- Also, TVA promptly investigated the circumstances of this event and took proper immediate actions to preclude its recurrence.
However, the corrective action proposed by TVA at the Enforcement Conference on February 24, 1984, dealt only with the immediate event and not the underlying cause.
TVA did not propose long-term corrective action to prevent similar occurrences from happening in other areas of operations.
Specifically, procedures and programs to disseminate significant and safety-related information (IE Notices, IE Bulletins and other communications) promptly do not appear to be in place.
This inadequacy could be adverse to safe plant operation as evidenced by the failure to take appropriate precautions as delineated in IE Information Notice No. 83-75.
Due to this lack of adequate long-term corrective action, the civil penalty amount is increased an additional 25 percent.
This results in a total proposed civil penalty of $60,000.
You are required to respond to the enclosed Notice and you should follow the instructions specified therein when preparing your response.
Your response should specifically address the corrective actions planned with regard to ensuring that:
- 1) training of licensed operators incl,udes adequate reviews of current operational events and problems identified at other, similar facilities; 2) proce-dures required for the operation of the facility are adequate to achieve the intended result and that operators understand the need for proper procedural adherence;
- 3) the operator training program at the Browns Ferry facility instills the proper attitude toward reactor safety;
- 4) proper administrative control is maintained for operating procedures; 5) the flow of communication i.e.,
IE Notices and IE Bulletins, both from the plant and corporate level, is prompt and
- 6) TVA, both at the corporate and plant management level, identifies root causes for problems and takes comprehensive action to prevent their recurrence.
In your response, appropriate reference to previous submittals is acceptable.
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice,"
Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosure will be placed in the NRC's Public Document Room.
Tennessee Valley Authority gpy pi, >984 The responses directed by this letter and accompanying Notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.
Sincerely,
- g. c; ames P. O'Reilly Regional Administrator
Enclosure:
Notice of Violations and Proposed Imposition of Civil Penalty cc w/encl:
J. A. Coffey, Director of Nuclear Power G.
T. Jones, Plant Superintendent J.
M. Anderson, Manager Office of guality Assurance H.
N. Culver, Chief, Nuclear Safety Review Staff D.
L. Milliams, Jr., Supervisor Licensing Section R.
E. Rogers, Project Engineer
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