ML18030B273
| ML18030B273 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 04/22/1986 |
| From: | Clark R Office of Nuclear Reactor Regulation |
| To: | Muller D Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8604250348 | |
| Download: ML18030B273 (66) | |
Text
April 22,1986 Docket Nos.:
50-259/260/296 MEMORANDUM FOR:
Daniel R. Muller, Director, BWR PD¹2, DBL FROM:
SUBJECT:
DATE 8t TIME:
LOCATION:
PURPOSE:
Richard J. Clark, Project Manager, BWR PD¹2, DBL FORTHCOMING MEETING WITH TENNESSEE VALLEY AUTHORITY (TVA)
AND GENERAL ELECTRIC (GE) -
BROWNS FERRY NUCLEAR PLANT, UNITS I, 2 AND 3 Tuesday, April 29, 1986 - 8:30 a.m. to 12:30 p.m.
Room P-422, Phillips Building, Bethesda, Md.
To discuss TVA's program to environmentally qualify cable at Browns Ferry.
Requested
Participants:
NRC D. Muller R. Lagrange P.
Shemanski F. Cantrell (RII)
N. Merriweather (RII)
A. Masciantonio A. Cappucci U. Potapovs G. Hubbard J.
Knox TVA R.
Rogers R. Ericson, et al GE N. Shirley N. Luria C. Dulka R. Walstat Richard J. Clark, Project Manager BWR Project Directorate ¹2 Division of BWR Licensing cc:
See next page
,OFFICIAL RECORD COPY DBL:PD¹2 DBL:PD SNorris:nc RClar 4/
/86 44m./86 DISTRIBUTION:
~Doc et-F e
NRC PDR Local PDR ORAS HDenton GLainas RClark OELD EJordan BGrimes Receptionist (Phillips)
NRC Participants ACRS (10)
OPA NOlson Memo File Bb04250348 8b0422 PDR ADOCW 05000259 P
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~> f C g I:-);l..teal E
II'
Mr. S.
A. I!hite Tennessee Valley Authority CC:
II. S. Sanger, Jr.,
Esouire General Counsel Tennessee Yalley Authority 400 Commerce Avenue E 11B 330 Knoxville, Tennessee 37902 fir. Ron Rogers Tennessee Valley Authority 5N 130B Lookout Place Chattanooga, Tennessee 37402-2801
- Chairman, Limestone County Commission Post Office Box 188
- Athens, Alabama 35611 Ira L. meyers, N.D.
State Health Officer State Department of Public Ifealth State Office Building
!Iontqomery, Alabama 36130 Mr. K. I!. Itfhitt E3A8 400 liest Summit Hill Drive Tennessee Valley Authority Knoxville, Tennessee 37902 Regional Administrator, Region II U. S.
Nucl.ear Regulatory Commission 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303 fir. Steven Roessler U. S. Nuclear Regulatory Commission Reactor Training Center Osborne Office Center, Suite! 200 Chattanooga, Tennessee 37411 Brogans Ferry Nuclear Plant Units 1, 2, and 3
H. C. Bibb Site Director, BFNP Tennessee Valley Authority Post Office Box 2000
- Decatur, Alabama 35602 Resident Inspector U. S. I'luclear Regulatory Commission Route 2, Box 311
- Athens, Alabama 3561'I Mr. Donald L. 1!illiams, Jr.
Tennessee Valley Authority 400 I!est Summit Hill Drive, L!10B85 Knoxville, Tennessee 37902 Robert L. Leviis, fia'nager, BFNP Tennessee Valley Authority Post Office Box 2000
- Decatur, Alabama 35602
MEMORANDUM FOR:
Hugh Thompson, Director APR 3 3 j9Il5 TVA Oversight Group Office of Nuclear Reactor Regulation Lee Spessard, Deputy Director Division of Inspection Programs Office of Inspection and Enforcement Stephen P. Weise, Chief Reactor Projects Branch ¹1 Division of Reactor Projects Region II Robert Bernero, Director Division of BWR Licensing Office of Nuclear Reactor Regulation DISTRIBUTION SNorris MGrotenhuis RClark DMuller FROM:
SUBJECT Daniel R. Muller, Director BWR Project Directorate ¹2 Division of BWR Licensing BROWNS FERRY ISSUE
SUMMARY
On March 31, 1986, repres'entatives of Region II and NRR agreed upon the enclosed Browns Ferry Issue Summary (Enclosure I).
Enclosure II is the same Summary with a listing of the responsible (lead) staff member for each issue identified.
I have also marked with an asterisk
(*) those issues for which I don't have a summary.
(1) Would each responsible staff member prepare a summary along the lines of the example (Enclosure III),
and (2) for those summaries that have already been prepared please review and update (many were done a few months ago).
We'e planning a meeting with TVA on May 6, 1986 to review the issues.
Your response by the end of April would be most helpful.
Thank you for your cooperation; and if this is unclear, please call me (492-8026),
M. Grotenhuis (492-8298), or R. Clark (492-8298).
gy~nal slgr ed bg aa.',lol iL.
biull~t'b04280348 860422 CF ADOCK 05000259 CF Daniel R. Muller, Director BWR Project Directorate ¹2 Division of BWR Licensing
Enclosures:
As stated cc w/enclosures:
M. Grotenhuis R. Clark D. Wigginton J.
Hulman B.
K. Singh M. Srinivasan B.
D. Liaw G. Zech D. Vassallo B. Grimes
,R. Wilson C. Julian S.
Weise E. lmbro P. Stoddart F. Jape F. Cantrell DBL:PD¹2 DBL'PD¹2 'BL:PD¹2 DBL:P ¹2 SNorris:rs MGrotenhuis RClark D>N 4/
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ENCLOSURE I BROWNS FERRY ISSUE
SUMMARY
I.
Management A.
Site Management Organization B.
Employee Concerns C.
Employee Allegations D.
NSRS and NSRB Reports E.
INPO Findings II.
Design Modification A.
Seismic Design B.
Fire Protection C.
Pipe Inspection/Stress Relieving/Repairs D.
Contractor Recommendations E.
Electrical Calculations (NRR)
(NRR)
III. Design Control A.
Environmental gualification B.
guality Assurance C.
Design Control (Configuration Management)
IV.
Restart Inspection A.
Regulatory Performance Improvement Program (IE)
(RII)
B.
C.
D.
E.
F.
G.
H.
V.
Licensing A.
B.
C.
D.
E.
F.
G.
H.I.
J.
K.
L.
Operational Readiness Program Training Restart Test and Inspection Maintenance Improvement Program Physical Security Program Post Accident Sampling System MSIV Leakage Reduction Program Review Integrated Schedule Shift Staffing Unit 2 Reload Modification Amendment Appendix R Exemption Appendix J Exemption Organizational Change Amendment Independent Safety Engineering Group Evaluation Water Level Return Legs Cable Environmental gualification Program Inservice Pumps and Valve Test Program Technical Specification Clarification Sechedule For ATWS Rule Implementation (NRR)
BROllNS FERRY ISSUE
SUMMARY
I.
Management A.
Site Management Organization B.
Employee Concerns
% C.
Employee Allegations D.
NSRS and NSRB Reports
~ E.
INPO Findings V'~~s ~ //o Sony h
~,~~,~~fr~
Sr ~qh g~p P~C7vt/s (NRR)
(NRR)
II.
Design Modification A.
Seismic Design 4/ o B.
Fire Protection A'c /~~~
C.
Pipe Inspection/Stress'Relieving/Repairs 4 i~~
D.
Contractor Recommendations W E.
Electrical Calculations J p-an l YA$4 (IE)
Review gV P P~g~l S Integrated Schedul e Shift Staffing Unit 2 Reload Modification Amendment Appendix R Exemption Appendix J Exemption Organizational Change Amendment Independent Safety Engineering Group Evaluation Mater Level Return Legs Cable Environmental gualification Program Inservice Pumps and Valve Test Program Technical Specification Clarification Sechedule For ATRS Rule Implementation Licensing A.
B.
S C.
g D.
E.
4 F.
G.
4 H.
g I.
A J, P K.
+ L.
III. Design Control A.
Environmental gualification K e C
B.
guality Assurance C.
Design Control (Configuration Management)
IV.
Restart Inspection (RII)
A.
Regulatory Performance Improvement Program C ~
g~~ //
B.
Operational Readiness Program pv'~g> c C.
Training
~
~~ JI ~~
D.
Restart Test and Inspection E.
Maintenance Improvement Program F.
Physical Security Program G.
Post Accident Sampling System 4
H.
MSIV Leakage Reduction Program V.
/pg~g (NRR)
II.C Pipe Inspection/Stress Relieving/Repairs Statement of Problem:
In accordance with Generic Letter 84-11, all BWR Licensees are required to provide its program for NRR review to inspect a certain number of welds during each refueling outage.
TVA has submitted its program and NRC has approved it.
In the approved letter NRC has requested that TVA provide assurance of other aspects of the Generic Letter such as leakage monitoring.
Licensees are required by Generic Letter 84-11 to submit a report on the--
results of these inspections to HRR for review.
During the current Unit 2 outage, TVA Inspected all accessible welds and stress-relieved about 75K of the welds.
The results of the inspections have been submitted and are under review.
This problem applies only to Browns Ferry Lead Res onsibilit :
NRR - Liaw Major Tasks:
Item 1.
Review licensee submittal 2.
Review results of inspections, weld overlays and repairs and IHSI program 3.
Revise the TVA response regard-ing leakage limits in the technical specifications 4.
Prepare safety evaluation 5.
Prepare letter to TVA Schedule:
Res onsibilit DBL/EB (Liaw)
DBL/EB (Liaw)
DBL/EB (Liaw)
DBL/EB (Liaw)
DBL/PD¹2 (Clark)
Resources Man-Weeks
I.A. Site Mana ement Or anization Statement of Problem Management deficiencies were identified in 1981, 1982 and 1983 SALP evaluation.
The Regional Administrator's letters transmitting these SALP reports (June 17,
- 1983, September 4,
1984) stated that "the overall performance of your Browns Ferry facility indicates that resources continued to be strained or not effectively used such that only minimally satisfactory performance with respect to operational safety was achieved."
In January
- 1984, TVA was requested by Region II to develop a Regulatory Performance Improvement Program (RPIP) to correct the management and other SALP identified deficiencies.
Plan developed in conjunction with Region II during spring 1984.
Approved plan was required to be implemented by Confirmatory Order issued by Region II on July 13, 1984.
Two years experience with RPIP indicates that it is not achieving all the objectives.
TVA has concluded (December 18, 1985 presentation) that RPIP did not identify all critical problems, and since that time has taken additional steps to accommodate perceived deficiencies including:
Replace Site Director Replace Plant Manager Replace Maintenance Superintendent Replace Operation Supervisor The adequacy of these steps as well as additional initiatives planned by TVA will be evaluated and recommendations on adequacy or improvements will be made.
To the degree that there are comparable site management organizations at other TVA plants, this issue interacts with other TVA plants.
Lead Res onsibi lit :
NRR - D. Vassallo N~Tk:
Item Res onsibilit Resources Man Weeks 1.
Review the functioning of the Site Director's office to evaluate whether the reorganization is likely to improve coordination of support functions, oversight of plant operation, and implementation of the proposed master schedule.
Prepare safety evaluation.
FOB
Site Management Organization Cont'd Item Res onsibilit Resources Man Weeks 2.
TVA has replaced the Plant Manager, Superintendent of Maintenance and Operation Supervisor; an extensive reorganization is proposed to strengthen operations and maintenance and increase technical support; and a.number of the new positions will be filled by contract employees.
Review qualifications and experience of new Plant Manager, Superintendent of Maintenance, Operation Supervisor, and other new assignees, and the new organizational structure to determine whether the changes are likely to improve coordination of support functions, oversight of plant operations, and implementation of the proposed master schedule.
Prepare safety evaluation.
DBL/FOB 3.
Review organizational modifications in an integrated fashion to see whether, collectively, they will be likely to solve the management problem.
Prepare safety evaluation.
4.
Prepare safety evaluation and issue license amendment.
(Sholly notice required)
Schedule:
DBL/FOB DBL/PDb2 (Clark)
I.B Em lo ee Concerns Statement of Problem Starting March 23,
- 1985, NRC received a number of allegations from TVA employees regarding the adequacy of construction at WATTS Bar, quality assurance and control at TVA corporate offices and at the TVA Nuclear sites and a variety of other issues.
Most of the initial allegations were received anonymously through either a Congressional staff member of by anonymous telephone calls to NRC headquarters staff members.
Some allegers felt that TVA would take retaliatory action if they expressed their concerns through the normal TVA process.
When TVA was informed of this situation, TVA management took a number of actions to enhance the existing Employee Concerns Program.
One of the actions taken by TVA was to hire an outside contractor, guality Technology Corporation (WTC) to interview all of the employees presently or formerly associated with Watts Bar - including those at TVA's knoxville and Chattanooga office's as well as those on-site - to find out what unacceptable conditions or practices the employees believed might exist relating to nuclear safety, industrial safety or policy implementation.
Provisions were also made to ETC to accept walk-in and call-in interviews from persons associated with other TVA nuclear facilities and offices.
In addition, TVA established a
separate office to receive employee concerns with a representative at each site for those employees who did not wish to express their concerns through normal channels and publicized the encouragement of employees expressing their concerns through notices, brochures, signs throughout Board of Directors, etc.
As a result of the overall "Employee Concerns Program," approximately 4300 concerns of one type or another have been raised; about half of these might be related to nuclear safety, intimidation, harassment, misconduct of other areas of interest to NRC; Of the approximately 1600 nuclear safety-related
- concerns, 24 were specifically identified as pertaining to Browns Ferry.
- However, some of the concerns identified as pertaining to Watts Bar and Sequoyah have been evaluated for possible generic application to Browns Ferry.
The Employee Concerns Issue is applicable to all TVA facilities and offices.
Lead Res onsibi lit :
NRR - B.
K. Singh
M~k Item Res onsibilit Resources Man Weeks 2.
Review and Categorize K-forms involving safety related issues and enter in data base.
(13/31/86)
Sort data base to provide groups of employee concerns by major issue heading.
Provide initial listing (and supporting information to office having lead for particular issue.
(2/7/86) - Note:
supplemental list-ings and information may be expected.
FRC*
NRR (Singh) 1/1/0 3/0/0 3.
4.
Conduct inspections at TVA corporate NRR/IR/RII and Browns Ferry to evaluate the adequacy of the implementation of TVA's actions and plans to address and resolve employee concerns that are specific and generic to Browns Ferry.
Several inspections will be conducted to ensure that (1) concerns are properly classified.
(2) concerns will be resolved at the proper time relative to unit startup, (3) concerns are thoroughly evaluated/
investigated, and (4) corrective actions are adequate, including implementation.
(Inspections should factor in relevant allegations, including implementation.
(Inspections should factor in relevant allegations, NSRS concerns and other concerns.
NRR to provide supporting information).
Prepare and issue draft SER and inspection reports(s).
Note:
specific technical concerns will be addressed under separate tasks.
SER Inputs issued upon completion of RII/NRR/IE 2/2/2 review (4 weeks after final investiga-tion report* issued by TVA) 5.
Review TVA Report (6/30/86)
RI I/NRR/I E 1/1/1 Final SERs issued (6/30/86)*
NRR/ (Singh) 2/0/0
- Note:
TVA must provide final investigation reports on employee concerns by 6/1/86.
- $150,000 has been allocated for this support effort.
1
I.C Em lo ee Alle ations To be provided by D. Higgington
I I
I.D NSRS and NSRB Re orts Statement of Problem The Nuclear Safety Review Staff (NSRS) and Nuclear Safety Review Board (NSRB) have investigated, evaluated and prepared reports on various systems (e.g.,
HPCI) at Browns Ferry and on facets of plant operation and maintenance.
The reports usually contain recommended actions from one or more organizations within TVA.
Each report will be reviewed and acted upon by NRC staff.
This relates solely to Browns Ferry Lead Res onsibi lit :
NRR - Singh Item Res onsibilit Resources Man-Weeks 1.
Review NSRS and NSRB reports pertaining to plant systems, plant organization and plant operation.
2.
Evaluated TVA's disposition and actions on recommendations 3.
Prepare SE on each report Schedule:
NRR (Singh)
NRR (Singh)
NRR (Singh)
1 l
I A
f.E
~IPO Fi di To be provided by M. Grotenhuis
Statement of Problem TVA and Region II inspection sin response to IE Bulletins 79-02 and 79-14 have raised questions on the seismic qualification for many of the plant components.
For instance:
Cable trays could not be considered seismically qualified without additional inspections, evaluation, and possible modifications, Reassessment of the torus attached piping installed as part of the.
Mark I torus integrity program raised questions on the seismic qualification of the piping, and Reassessment of seismic design criteria indicated a need to evaluated HVAC seismic supports.
This issue was identified as a result of Region II inspections and is independent of other TVA plants.
Summaries of individual seismic issues follow.
II.A.1 Seismic Oualification of Cable Tra s
Statement of Problem On February 18,
- 1981, TVA identified a nonconformance with respect to overfilled cable trays and cable penetrations in the cable spreading room Corrective action associated with this nonconformance was both delinquent (the estimated completion date was extended from 1981 to 1985) and inadequate (the root cause was not determined).
In June
- 1985, an in-depth study identified many deficiencies including inadequate design calculations (cable tray supports were designed for dead load only and did not consider live loads and applicable operating loads),
cable trays were overfilled, and many hold down clips were missing bolts.
The conclusion of the TVA study (conducted under contract with United Engineers) and Region II inspections was that the cable trays could not be considered seismically qualified without additional inspection, evaluation, and possible modifications.
This issue relates solely to Browns Ferry.
Lead Res onsibilit :
NRR - Liaw Major Tasks:
Item 1.
Review TVA report on findings
- analysis, calculations and proposed modifications.
Prepare safety evaluation.
2.
Inspect cable trays, conduits and modifications.
Prepare inspection reports.
Res onsibilit DBL/EB (Liaw)
RII (Blake)
Resources Man-Weeks 3.
Prepare safety evaluation Schedule:
DBL/PD82 (Clark) 2 II.A.2 Seismic ua1ificaiton of Pi in and Su orts To be provided by Liaw II.A.3 Seismic ualificaiton of HYAC Su orts To be provided by Liaw II.A.4 Torus Attached Pi in Statement of Problem As part of the program to upgrade the Mark I type torus, all piping connected to the torus (referred to as "torus attached piping") was supposed to be reanalyzed based on the revised design loads.
The reanalyses indicated the need to replace or augment many piping supports.
Initial inspections by Region II found that many of the supports were not installed in accordance with design documents.
(See inspection report 85-26).
Further investigation determined that there were no stress
- analyses, design calculations or approved design drawings-on some piping systems (e.g., the reactor building closed cooling water system), installations were in some instances based on sketches which had not been formally approved and there appeared to be instances where the design calculations were inadequate.
The overall findings raised the question of whether the torus attached piping systems had been adequately seismic event.
This issue is a subset of Issue 6b Seismic gualification of Piping and Supports.
Lead Res onsibilit NRR - Liaw N~Tk Item 1.
Review TYA's reanalyses of all torus attached piping 2.
Inspect TVA's design control program to verify that design documents and drawings exist for supports on torus attached piping.
3.
Inspect installation of supports 4.
Verify that adequate corrective action has been taken on previously identified deficiencies and de-viations Res onsibilit NRR (Liaw)
RII (Blake)
RII (Blake)
RII (Blake)
Resources Man-Weeks 5.
Prepare safety evaluation on item 1 and inspection reports on items 2, 3 and 4
Schedule:
Liaw/Blake
r J
II.B Fire Protection Statement of Problem TVA is revision the plant fire hazards analysis.
It was submitted on 01/21/86 and is under NRC review.
The submittal includes a request for several technical examptions.
Based on the revised fire hazards
- analysis, TYA is expected to find a number of modifications required.
Inspection by TVA and Region II found, for example, that 114 of 180 piping penetrations through walls and areas
= would not meet minimum rating (lk or 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />).
Due to the time required to complete engineering design of the modifications, procure materials and prepare work plans, TVA has requested a one cycle exemption to 10 CFR 50.48 and 10 CFR 50 Appendix R
for Unit 2.
(See item V.D)
This issue relates solely to Browns Ferry Lead Res onsibilit NRR - Hulman
~N' k
Item 1.
Review fire hazards analysis and prepare safety evaluation.
2.
Prepare safety evaluation and process exemptions.
Tkkkk DBL/PSB (Hulman)
DBL/PDb2 (Clark)
Resources Han-Weeks 3.
Inspect TVA repairs to fire barrier penetrations.
Prepare inspection report RII Schedule:
II.C Pipe Inspection/Stress Relieving/Repairs Statement of Problem:
In accordance with Generic Letter 84-11, all BWR Licensees are required to provide its program for.
NRR review to inspect a certain number of welds during each refueling outage.
TVA has submitted its program and NRC has approved it.
In the approved letter NRC has requested that TVA provide assurance of other aspects of the Generic Letter such as leakage monitoring.
Licensees are required by Generic Letter 84-11 to submit a report on the results of these inspections to NRR for review.
During the current Uni.t 2 outage, TVA Inspected all accessible welds and stress-relieved about 75K of the welds.
The results of the inspections have been submitted and are under review.
This problem applies only to Browns Ferry Lead Res onsibi lit :
NRR - Liaw Item 1.
Review licensee submittal 2.
Review results of inspections, weld overlays and repairs and IHSI program 3.
Revise the TVA response regard-ing leakage limits in the technical specifications 4.
Prepare safety evaluation 5.
Prepare letter to TVA Schedule:
Res onsibilit DBL/EB (Liaw)
DBL/EB (Liaw)
DBL/EB (Liaw)
DBL/EB (Liaw)
DBL/PDA'2 (Clark)
Resources Man-Weeks II.D Contractor Recommendations Statement of Problem TVA has hired over two dozen contractors to evaluate (a) operation maintenance and reliability of major plant systems, (b) the Technical Specifications, and (c) management organization.
Contractors include GE, SAI, Gilbert-Commonwealth, MAC, IMPEL, NUTEC, General
- Physics, DCP,
- NWT, United Engineers, and EGRG.
The GE report on the HPCI system, for
- example, had several pages of recommended actions.
United Engineers also recommended a number of modifications to the HPCI system to eliminate or reduce the water-hammer problems.
None of these reports have been formally requested and one have been formally transmitted to NRC.
The staff's recommendation is that Region II and NRR, with assistance from IE and AEOD as needed review the contractor's reports on site along with TYA's evaluations and proposed actions on the recommendations.
Formal action would depend on whether signification problems are identified.
This issue relates solely to Browns Ferry.
Lead Res onsibilit NRR - Clark M~ik:
Item 1.
Review contractor reports and recommended actions 2.
Review TVA's evaluation and proposed disposition on contractor's recommendation Res onsibilit
- NRR (Clark)
- NRR (Clark)
Resources Man-Weeks 3.
Evaluate whether actions TVA proposes (a) prior to startup of a unit and (b) in the longer term, are appropriate 4.
Prepare safety evaluation or inspection report on each contractor report of study
- NRR (Clark)
- NRR (Clark)
- The specific group within NRR to conduct each review will depend on the subject matter.
)
II.E Electrical Calculations To be provided by Srinivasan III.A Environmental uglification Pro ram Statement of Problem TVA's implementation of the Equipment gualification Rule, 10 CFR 50.49 at Browns Ferry Units 1, 2, and 3 does not comply with the regulations.
During the current outages, approximately 1500 items of equipment have to be replaced in each unit with environmentally qualified components.
The documentation problems that prompted shutdown of the Sequoyah units and the cable qualification problem identified initially at Watts Bar also exist at Browns Ferry.
This problem applies to the other TVA facilities.
~N' k
Resources
'(Man-Weeks)
Item 1.
Conduct an audit of the documentation packages of selected pieces of equipment (date tbd).
2.
Conduct ins ection of TVA's program to imp ement 10 CFR 50.49 (date tbd).
Res onsibilit NRR/IE/RI I IE/NRR/RII 2/1/1 6/2/4 Subtasks:
a.
Follow-up on audit findings b.
Review selected packages for completeness c.
Review programs to maintain qualification status d.
Physical verification of as-installed condition e.
Review corrective actions for Westec findings f.
Review internal procedures for implementing 10 CFR 50.49 g.
Review resolution of employee concerns on Eg 3.
Write SER Input to support startup NRR/IE (Hubbard)
Write-up will identify issues that remain as potential enforcement items/unresolved items/open items (date tbd).
2/1/0
Equipment qualification Cont'd Item 4.
Reinspect corrective actions and perform final review of related documentation packages (date tbd) 5.
Evaluate TVA 10 CFR 50.49 certification submittal (date tbd) 6.
Write final inspection report (date tbd)
Res onsibilit IE/NRR/RII (Hubbard)
Contractor NRR/IE/RII IE/NRR/RII Resources Man-Weeks NRR IE/RI I 4/1/2
$8,000 2/1/1 4/2/2 III.B gualit Assurance Pro ram Statement of Problem Review of TVA actions to strengthen guality Assurance Programs at Browns Ferry.
Lead Res onsibilit IE - Grimes Major Tasks:
Item Res onsibilit Resources Man-Weeks l.
Itemized verification by direct inspection of selected items contained in the Browns Ferry Performance Plan.
2.
Itemized verification by direct inspection of selected items contained in the Corporate Nuclear Performance Plan (may be integrated with Sequoyah inspection).
RII/IE RII/IE 3.
Assessment of corrective action program at RII Browns Ferry relative to audit findings and other TVA identified problem areas.
4.
Assessment of TVA's ability to identify problems and to correct those problems.
5.
Prepare SER Input 6.
Complete inspection report.
7.
Allegation followup RI I RI I RII RI I III.C Desi n Control (Confi uration Mana ement Statement of Problem TVA had not established a plant configuration baseline, did not have a
program to identify and document design requirements for each modification, and did not have a program for establishing interaction between existing plant systems and proposed plant modifications.
Identified by Region II inspection, TVA findings and INPO evaluation.
This problem was identified for Browns Ferry; but also is probably a
corporate generic problem not specifically related to Browns Ferry.
Lead Res onsibilit R. Architzel Technical Lead:
IE - Imbro
~M' k
Item 1.
TVA Commission briefing on Units restart scheduled for 03/ll/86 Res onsibilit TVA Resources (Man-Weeks)
NRR/ IE/RI I 2.
Review and evaluated TVA's response IE/RII to the 50.54 (f) letter, Item B.6 on design control (date tbd).
TBD 3.
Review and evaluate the independent assessment of engineering design control at Browns Ferry, which was completed by TVA personnel led by an outside consultant from (very Tech Associated (date tbd)
IE/RII TBD 4.
Review and evaluate any design control items resulting from employee concerns/allegations (date tbd).
5.
Review, inspect, and evaluate seismic design of cable trays, piping supports and HVAC system (date tbd).
6.
Direct inspection of design control to assess adequacy of Browns Ferry design mods (date tbd).
IE/RII IE/RII TBD TBD
Design Control Cont'd Item 7.
Follow-up inspection for design control related items from 2, 3, and 4 above (date tbd).
8.
Prepare Inspection Report and SER input for submittal to NRR (date tbd).
\\
Res onsibilit IE/RII IE/RII Resources (Man-Weeks)
NRR/IE/RII TBD TBD IV.A Re ulator erformance Im orvement Pro ram (RPIP Statement of Problem In response to NRC concerns about the number of violation and escalated enforcement
- required, TVA implemented a RPIP in February 1984.
The NRC issued a Confirmation Order to implement the RPIP by letter dated July 13, 1984.
All of the short term items in the RPIP have been completed and most of the long term items are nearing completion,
- however, both TVA and the NRC have concluded that the RPIP Has been ineffective in obtaining the improvements required to consider performance accpetable.
In March 1985, TVA shutdown both. operating units unit TVA determine that each unit could be operated in compliance with regulatory requirements (Unit 2 was already shutdown for a refueling outage).
Region II confirmed to TVA in a 10 CFR 50.54(f) letter dated September 17, 1985, transmitting the TVA SALP for the period ending Nay 31, 1985, that none of the TVA units would be restarted without specific NRC approval TVA has informally proposed that the RPIP order be lifted and that the remaining RPIP items be incorporated into the Operational Readiness Program (ORP).
Lead Res onsibilit Region II - Cantrell
~fl k:
Item Res onsibilit Resources Man-Weeks 1.
Review outstanding RPIP items to determine which item (complete of incomplete should be included in the ORP 2.
Verify each of the above items judged to be included are included in ORP RII (Cantrell)
RII (Cantrell) 3.
Verify each of those items is implemented as part of the ORP (Not a separate effort) 4.
Issue an order to TVA confirming that the RPIP is closed and the open item will be completed as part of ORP 5.
Prepare a safety evaluation documenting justification for the above action RII (Cantrell)
RII (Cantrell)
IV.A Re ulator Performance Im rovement Pro ram Statement of Problem Review of TVA comments to strengthen TVA regulatory improvement by implementation of a Regulatory Performance Improvement Plan and the Browns Ferry Nuclear Performance Plan.
Lead Res onsibilit RII - Cantrell Major Tasks:
Item 1.
Review outstanding RPIP items 2.
Verify each item identified in 1 above is included in Nuclear Performance Plan RII RII 3.
Review actions taken and commitments contained in the Nuclear Performance Plan RI I 4.
Review and evaluate outstanding regulatory issues and resolve RII 5.
Evaluate improvements in licensee regulatory compliance history 6.
Complete SER Input to document results of findings RII RII IV.B 0 erational Readiness Statement of Problem In March 1985, Unit 2 was in a refueling outage, Unit 3 was shutdown March 9 because of water level instrument problems and Unit I was shutdown March 19 because of valve problems related to Appendix J testing.
TVA was also developing justification for continued operation of Units I and 3 with a large number of unresolved environmental qualification questions.
The Regulatory Performance Improvement Program (RPIP) was over one year old and significant regulatory/safety problems were still being identified.
TVA reviewed and adopted a methodology from EGImG call Operational Readiness which basically involved "the right people in the right place at the right time, working with the right hardware, according to the right procedures with the right management controls."
This was an orderly method of tabulating all items related to hardware, personnel, procedures, and paperwork required prior to restart of a unit.
Ideally, all of the open NRC Issues with TVA will be included in this program.
Practically, certain issues because of their significance, are being tracked for resolution separately by the NRC.
Operational readiness encompassed each organizational unit at the site submitting their own program of hardware, personnel, procedures and paperwork required for startup to the next higher unit supervisor which in turn submits his program t the next higher unit supervisor.
This continues up to the site director.
When all items are accepted as completed by the site director, the Board of Directors planned to have a
committee composed of representatives from other sites and utilities review the readiness for return to operation of each reactor.
During this period, NRC will independently review TVA readiness to restart each unit and independently evaluate the licensee's plans for restart.
Lead Res onsibilit :
RII - Weise N~Tk Item Res onsibilit Resources Man-Weeks 1.
Review plans for each organizat-RII (Cantrell) ional unit 2.
Develop inspection plans for items determined to require NRC followup RII (Cantrell) 10
Operation Readiness Cont'd Item 3.
Followup in accordance with inspection plans developed above Res onsibilit RII (Cantrell)
Resources Han-Weeks 4.
Verify that TVA has determined that all organizational units have completed their operational readiness program.
Perform sufficient sampling to verify completion.
RII (Cantrell)
IV. B.
0 erational Readiness Pro ram Statement of Problem To assess TVA's management and implementation of programs, corrective
- actions, and commitments described in the Browns Ferry Nuclear Performance Plans to assure the plant is ready to restart operation.
Lead Res onsibilit Region II (Weise)
~NT k:
Item 1.
Complete review of Nuclear Performance Plan 2.
Review HP Program to determine acceptability of equipment, personnel, procedures, etc.
0 3
Review OIL for issues that must be resolved/
corrected prior to operation 6.
Review licensee procedures and implementation of corrective actions as committed to in Nuclear Performance Plan 7.
Review implementation of site security plan 8.
Review adequacy of interface controls between units, including temporary alteration controls 9.
Review operating, emergency operating, and surveillance procedure adequacy 10.
Review plant modifications since last shutdown to determine if additional testing needed ll.
Review surveillance test results to assure readiness to change mode 4.
Review outstanding NUREG 0737 issues and determine acceptability of TVA action 5.
Review licensee procedures and training to assure proper assessment of 10 CFR 50.59 issues and potentially reportable occurrences under 10 CFR 21, 50.72, and 50.73
~Rebill RII RII (Hosey)
RII (Cantrell)
RII (Cantrell)
RII (Cantrell)
RII (Cantrell)
RII (HcGuire)
RII (Cantrell)
RII (Julian)
RII (Cantrell)
RII (SRI) 1V. C.
~Trainin Statement of problem Assess the overall adequacy of qualifications and training of the plant operating staff.
Lead Res onsibilit RII - Julian M~Tk:
Item l.
Verify that the requalification program has been successful in maintaining the competency of licensed operators for restart and safe operation
- Audit TVA requalification program completed 3/13/86
- Repeat audit of requalifi-cation program (reactor systems)
- Conduct simulator evalua-tions of about 50K of on-shift licensed operators
- Complete evaluation report and issue SER
~Rebill Region II (Munro)
Resources (Man-Weeks) 6 RII 8 other (HRR, IE and Region II) 2.
Training assessment to determine the effectiveness
'of licensed and unlicensed operator training
- Inspection SER input Region II (Wilson) 4 RII 9 other (IE and Region I)
- Issue inspection report 3.
Issue final SER on training activities Region II (Julian)
IV.D Restart Test and Ins ection Pro ram Statement of Problem Unit 2 has been shutdown since 9/84 and Units I and 3 since 3/85.
Because of the length of time that each unit has been
- shutdown, the number of repairs and modification, both prior to and subsequent to shutdown of each unit and changes to procedures, a restart test and inspection program is required to verify that equipment is operational and is capable of performing its safety function, and that operation/
maintenance personnel are knowledgeable of procedures needed to operate the equipment.
The program should be patterned after the preoperational test program required prior to licensing but is not expected to be in the same depth.
Each safety related system should be loss of offsite power/
simulated LOCA test.
Emphasis should be placed during the loss of offsite power/LOCA test on verifying that all supporting equipment required for safety systems to perform their safety coolers/ventilation systems actuate to supply cooling to RHR/Core Spray diesel generators, pump/water bearings, etc.
Special test procedures should be written and approved to supplement surveillance instruction.
The licensee should review each test to evaluate exception and to insure test objectives are met.
NRC will follow a modified NC 2513/2514 inspection to insure that test programs are met.
Lead Res onsibi lit :
Region II M~Tk:
Schedule:
1 I
IV.
D Restart Test and Ins ection Statement of Problem To assure that essential post modification and preoperational tests have been completed prior to restart of any Browns fer ry unit.
Lead Res onsibilit RII - Jape Major Tasks:
Item 1.
Review licensee Nuclear Performance Plan to determine adequacy of pre-operational test program 2.
Develop inspection schedule for pre-operational test program 3.
Conduct Inspections 4.
Provide SER Input to support startup 5.
Develop schedule of resident inspections to provide 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> coverage during startup
~Rebill NRR
(
)
RII (Cantrell)
RII ('ape)
RII (Cantrell)
RII (Cantrell) 6.
7.
Conduct Inspections Provide Commission Paper input to terminate augmented resident coverage RII (Jape)
RII'Cantrel 1 )
l IV.
E f1aintenance Im rovement Pro ram Statement of Problem Conduct a review of the maintenance improvement program to include limitorque valve maintenance and inspection program Lead Res onsibilit RII - Wilson Major Tasks:
Item Res onsibilit 1.
Review maintenance section reorganization for qualification and adequacy 2.
Review maintenance equipment history tracking program 3.
Evaluate control of vendor manual implemen-tation schedule for adequacy 4.
Review maintenance sections personnel training program 5.
Evaluate adequacy of modification control program 6.
Evaluate planning and scheduling coordination of maintenance activities RI I RI I RII RII RI I RII 7.
Closeout IFIs, open items, unresolved items related to maintenance activities RII 8.
Review the employee concerns program 9.
Prepare SER inputs 10.
Prepare inspection reports RII RI I RII IV.
F Ph sical Securit Pro ram Statement of Problem Browns Ferry has been a
SALP III performer for the last three rating periods.
In the last two periods, TVA has paid
$ 140,000 in Civil Penalties for five Security Level IIIs, three IVs, and one V.
Historically, we experienced continued weakness in the control of access to the protected and vital areas, and repetitive failure to protect vital equipment.
Additionally, the licensee routinely relies upon compensatory measures (security posts) in lieu of security barriers and alarms.
This lack of maintenance has resulted in increased violations.
Reorganization and the recently revised Physical Security Plan have shown some encouraging results in our inspections over the last few months.
However, access controls and compensatory measures are 'still issues in the startup of Browns Ferry.
Considering that Browns Ferry is similar to Davis Besse, and thus effected by NUREG-1154, the question of access to vital equipment by operators during emergencies must also be addressed.
Lead Res onsibilit Region II, Physical Security Section
~M' R
Item
~Rib iR R
1.
Review Security Corrective Actions in RII, PSS Licensee's RPIP Resources 2 days 2.
Audit Licensee s Identified Deficiencies 3.
Evaluate "Employee Concerns" Regarding Security 4.
Evaluate Impact of NUREG-1154 RII, PSS RII, PSS RII, PSS 1 day 1 day 1 day 5.
Inspect Training Plan for Security Force RII, PSS 2 days 6.
Review Licensee's use of Compensatory Measure 7.
Analyze Licensee's Corporate Audits RII, PSS RII, PSS 1 day 1 day
lW)
IV.
G Post Accident Sam lin S stem (PASS)
Statement of Problem Item 24, Licensing Issues (p.
32 of 3/13/86 memo, Olshinski to Stohr et al.)
indicates that a license amendment for the Browns Ferry PASS is not required for restart.
H. Denton's memorandum of 2/28/86 to J. Olshinski references to 2/21/86 NRR evaluation of the Browns Ferry PASS, in which the cover letter, signed by D.
R. Muller (NRR-BWR Licensing), states that revised procedures for use with the interim PASS must be provided to NRR in time for NRR to complete their evaluation prior to startup of Unit 2.
There appears to be a conflict here requiring resolution prior to startup in that the Denton memo seems to indicate a requirement for operability of the, PASS prior to restart.
The RII staff considers that the evaluation of the PASS by NRR should not be done solely on the basis of documentation but should require onsite inspection and review as well. If onsite inspection has been performed, RII
~ ~
staff is not aware of it.
Lead Res onsibilit :
Region II - Stoddart
~N' k:
Item Res onsibi lit Resources (man-week) 1.
Review PASS procedures.
RII (Stoddart) 2.
Conduct inspection to review RII (Stoddart) a.
Operability of PASS b.
Training on procedures c.
NUREG-0737 criteria of present interim system 3.
Prepare inspection report RII (Stoddart)
IV.H MSIV Leaka e Reduction Pro ram To be provided by Jape V.A Inte rated Schedule for Plant Modifications Statement of Problem TVA submittal of April 2, 1985 provided an integrated schedule of plant modifications with a list of commitments and requested staff approval in the form of a license amendment.
The Integrated Schedule includes all foreseeable plant modification items required by the NRC regulatory program.
The plan is extensive, and includes modifications that are required; but some of which will not be installed for at least a decade.
The issue is whether this is adequate, whether TVA is taking appropriate actions to expedite, and whether TVA's priorities are acceptable,'nd whether the overall schedule meets NRC safety requirements.
This issue encompasses most issues on the TVA Browns Ferry Issue Summary and its approval is fundamental to TVA moving ahead on restart of the three units.
This issue may interact with other TVA plants to the extent that common resources are needed for engineering,
- analysis, and installation of plant modifications.
May conflict with similar needs for other plants.
Lead Res onsibilit NRR - Grotenhuis/Clark
~fI T
k Item Res onsibilit Resources Man-Weeks 1.
Review Program Plan 8 prepare SE DBL/PD82/Grotenhuis 2.
Review proposed schedule DBL/PD82/Grotenhuis 3.
Prepare safety evaluation and DBL/PD82/Grotenhuis Issue amendment
.B
~5hif ffi Statement of Problem TVA has had problems at Browns Ferry in maintaining sufficient qualified reactor operators (ROs) and senior reactor operators (SROs) to meet shift
'taffing requirements without significant overtime in providing opportunities for recycling operators through training, in providing experienced licensed operators as instructors in the training program, in having experienced licensed operators review procedures and proposed modifications, and in providing supervision in the plant for maintenance and modification activities.
The situation has been aggravated by the fact that in November
- 1985, 12 out of 15 licensed operators failed a
requalification exam.
. The issue is specific to Browns Ferry.
Lead Res onsibilit NRR - Grotenhuis/Clark
~N' k:
Item Res onsibilit Resources Man-Weeks 1.
Evaluate TVA's training and requalification programs.
Meeting with TVA 2/21/86.
RII 2.
Review proposed shift staffing with respect to meeting not only 10 CFR 50.54 requirements but also TVA's commitments for increased supervision on shift, more intensive followup on operating
- events, augmented training, management presence on off-shifts, ect.
DBL/FOB (Vassallo) 3.
Prepare inspection and safety evaluation reports.
Schedule:
RI I/NRR Y.C Vnit 2 Reload Modification Amendment To be provided by Grotenhuis/Clark V.D A
endix R Exem tion To be provided by Grotenhuis/Clark
0 1
1
'l V.E A
endix J Exem tion Statement of Problem:
TVA Performed an extensive reevaluation of the Appendix J leak test program at Browns Ferry.
The evaluation determined that there were some valves (primarily small drain valves) that could under some circumstances constitute the containment boundary and that were not being Type C tested for possible bonnet leakage.
The valves will have to be replaced (with "0" ring seal bonnets) to be able to be tested.
Due to lead time in procuring replacement
- valves, TVA has requested an one cycle exemption to the Appendix J local leak rate test requirements.
for 14 valves.
This issue applies to Browns Ferry only.
Lead Res onsibilit NRR - Grotenhuis/Clark
~Tk Item 1.
Review TVA's submittal of ll/20/85.
Prepare safety evaluation 2.
Prepare exemption or denial and Environment Assessment Res onsibilit DBL/PSB (Hulman)
DBL/PD82 (Clark)
'Resources Man-Weeks Schedule:
V.F Or anizational Chan e Amendment To be provided by Grotenhuis/Clark V.G Inde endent Safet En ineerin Grou Statement of Problem:
NUREG-0737, Item I.B. 1.2 requires applicants for an operation license to establish an onsite independent safety engineering group
( ISEG) to perform independent review and audits of plant activities, maintenance, operational problems, modifications, etc.
This requirement was applied only to applicants for an operating license and not to operating plants.
As noted in paragraph 8 of NUREG-1154, the team investigating the Davis-Besse Loss of Feedwater Event "concluded that the underlying cause--
of the loss of main and auxiliary feedwater event of June 9,
- 1985, was the licensee's...history of performing troubleshotting, maintenance and testing of equipment, and of evaluating operating experience related to equipment in a superficial manner and, as a result, the root cause of problems are not always found and corrected.
Engineering design and analysis effort to address equipment problems has frequently either not been utilized or has not been effective."
Several years ago, the NRC staff concluded that a situation similar to that found at Davis-Bessee existed at Browns Ferry.
TVA agreed, in principal, with the need for an ISEG and committed (July 1984) to establish such a group as part of the Regulatory Performance Improvement Program (RPIP).
An ISEG, as such, was not established although some of the functions that would be performed by such a group were accomplished by the Compliance Group.
While improvements have been noted in the followup of operating events, the NRC staff is of the opinion that an ISEG is still needed.
Accordingly, in the September 17, 1985 letter
'orwarding the most recent SALP report, the staff requested (item 9) that the TVA evaluated the need to establish an onsite ISEG to review operational events as they occur.
In the meeting with NRC 'oh December 18, 1985 on the Browns Ferry Nuclear Performance
- Plan, TVA stated that an onsite ISEG will be established.
We envision the functions of the ISEG would be similar to that described in NUREG-0737, Item I,B.1.2.
The objective of having an ISEG would be to provide an additional level of protection to assure that necessary attention to detail is maintained in the care of plant equipment and that root causes of problems such as equipment failures, test deficiencies, personnel error, design deficiencies and the impact of modification criteria are effectively identified and corrected.
This issue applies only to Browns Ferry.
Independent Safety Engineering Groups have been established at Sequoyah and Watts Bar.
Lead Res onsibilit NRR - Grotenhuis/Clark
Safety Engineering Group Cont'd Major Tasks:
Item 1.
Review the duties, responsibil-ities and organizational status of the proposed ISEG to evaluate whether the group will achieve the desired objectives.
2.
Prepare safety evaluation Schedule:
Res onsibilit NRR/RII NRR (Crocker)
Resources Man-Weeks V.H llater Level Performance Le s
To be provided by Grotenhuis/Clark
44 V. I Cable Environmental uglification Pro ram To be provided by Grotenhuis/Clark
/
V.J Inservice Pum and Valve Test Pro ram To be provided by Grotenhuis/Clark
4
'1
~
" )o V.K Technical S ecification Clarification To be provided by Grotenhuis/Clark V.L Schedule for ATWS Rule Im lementation To be provided by Grotenhuis/Clark
~