ML18031A773
| ML18031A773 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 09/08/1986 |
| From: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | White S TENNESSEE VALLEY AUTHORITY |
| Shared Package | |
| ML18031A774 | List: |
| References | |
| EA-86-056, EA-86-56, NUDOCS 8609230099 | |
| Download: ML18031A773 (9) | |
Text
SEP 08 1986 gl Docket Nos.
50-259, 50-260, and 50-296 License Nos.
DPR-33, DPR-52, and DPR-68 EA 86-56 Tennessee Valley Authority ATTN:
Mr. S.
A. Mhite Manager of Nuclear Power
- 6N 38A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Gentlemen:
SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTIES (NRC INSPECTION REPORT NOS.
50-259, 50-260, 50-296/85-41; 50-259, 50"260, 50-296/85-45; 50-259, 50-260, 50-296/85-53; 50-259, 50-260, 50-296/85-57; 50-259, 50-260, 50-296/86-05; AND 50-259, 50"260, 0-29 This refers to the NRC inspections conducted during the periods August 12-16, 1985; August 21 - September 30, 1985; October 26 - December 31, 1985; and January 1-31, 1986, of activities authorized by NRC Operating License Nos.
DPR-33, DPR-52, and DPR-68 for the Browns Ferry Nuclear Plant.
The inspections included a review of cable trays and supports, vendor's recommended maintenance for the standby diesel generators, secondary containment isolation damper timing and configuration control, and cable separation design criteria for reactor safety systems.
As a result of these inspections, failures to comply with NRC requirements were identified, and accordingly, art Enforcement Conference to discuss these matters was held in the NRC Region II Office on May 28, 1986.
The inspection reports were issued separately on September 24, 1985; October 28, 1985; December 4, 1985; February 11, 1986; and March 5, 1986.
Violation I.A in the enclosed Notice of Violation and Proposed Imposition of Civil Penalties (NOV) involves certain cable tray supports that were not adequately designed to withstand a design basis earthquake.
You identified that cable tray supports in the Control Bay Area were not designed to meet seismic requirements, and some supports in the Diesel Generator and the Reactor Buildings did not have adequate conservatism in their'esigns to ensure their ability to perform their intended function during a seismic event.
In addition, a number of design calculations used to qualify many of the typical cable tray supports at Browns Ferry were neither checked nor verified as required.
Violation I.B involves fai lures in your corrective action program.
On February 18, 1981, you identified overfilled cable trays and cable penetrations in the cable spreading rooms (Corrective Action Report 81-035).
Various actions were taken from February 1981 until July 1985, none of which succeeded in correcting the overloaded condition of the cable trays.
In addition, on August 14, 1985, you CERTIFIED MAIL RRTR R
EIPT RE UEETER Sb09230099 8b0908 PDR ADOCK 05000259 8
PEP 08 1986 Tennessee Valley Authority discovered that corrective action taken in response to a previous Notice of Violation involving routine diesel generator maintenance inspections had not been accomplished.
As a result of this failure, you then discovered and reported on September 24, 1985, that the diesel generators were technically inoperable since the vendor-required inspections for the three, six, and twelve year intervals had not been performed.
Simultaneously, you also reported the standby diesel generators inoperable because the diesel battery racks were determined not to be seismically qualified as a result of stud welding deficiencies that occurred in April 1985.
Two other fai lures involving diesel generator maintenance were also identified.
Violation I.C involves failures to ensure that activities were accomplished in accordance with appropriate drawings and procedures.
You identified that the 4160 volt shutdown board control power was not connected in accordance with the appropriate drawing.
Because of the existing wiring configuration, the time the shutdown board would have been functional following an accident was reduced, and the error could have confused operators in an accident and further complicated the accident scenario as described in Licensee Event Report 85-56, dated July 8, 1986.
You also identified that the diesel generator oil pressure switches were not connected in accordance with plant drawings.
In addition, procedures to conduct a Local Power Range Monitor (LPRM) change-out were inadequate, which resulted in part of an LPRM surfacing in the spent fuel pool, and you also identified a failure to ensure that design drawings referenced the correct
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design specifications for the separation and identification of reactor safeguards electrical equipment.
The above violations indicate again that significant improvements are needed in the performance of licensed activities at the Browns Ferry Nuclear Plant.
The violations were identified in many of the areas involved in the oper ation of a nuclear facility and reflect an unacceptable level of compliance to NRC require-ments.
More attention should be provided to the interactions between the engineering organization and various groups within your plant staff to ensure design and analyses are correct and have the appropriate approvals.
More attention is also required in the area of corrective actions.
Although you identified most of the violations, they existed for an extended period of time during the operation of the facility.
The NRC expects its licensees to promptly evaluate and correct problems they identify.
As the examples in the enclosed Notice indicate, you have not achieved that level of performance.
In addition, the existing configurations of plant equipment that were not in accordance with the appropriate drawings may be indicative of inspection program inadequacies.
Similar types of deficiencies must be corrected prior to the restart of the Units at Browns Ferry to ensure that all plant equipment is installed in accordance with the required drawings.
The violations described herein are additional examples of the general management breakdown for which Tennessee Valley Authority (TVA) was cited by the NRC and because of which the Browns Ferry units were shutdown in March 1985.
The root cause of the general management breakdown was the lack of strong leadership necessary to develop and maintain (1) the high level of discipline required for nuclear operations, and (2) the mutual trust between management and staff needed
SEP 08 1986 I Tennessee Valley Authority to ensure good communications throughout the organization.
To correct these
- problems, TVA this year has made significant changes in "corporate" management and, very recently, has installed a
new Site Director at Browns Ferry.
While this represents a good start, it is essential that there be evidence that TVA has corrected these fundamental problems throughout their organization before startup of any unit at Browns Ferry.
These violations have been categorized as three Severity Level III violations in accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1986) (Enforcement Policy)
The base civil penalty for a Severity Level III violation is $50,000.
After considering the escalation and mitigation factors permitted in the Enforcement Policy, the staff considered that the base civil penalty for each violation could have been increased substantially because the plant operated for an extended period of time with many of these equipment deficiencies.
- However, after consultation with the Director, Office of Inspection and Enforcement, I have decided not to escalate the civil penalty and to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalties in the amount of One Hundred Fifty Thousand Dollars ($150,000).
The civil penalty was not escalated in this case because many of the violations were identified by you as a result of the actions you have taken since the shutdown of the three units at Browns Ferry in March 1985 to improve licensed activities.
Violation II in the enclosed NOV involves the failure to determine pursuant to 10 CFR 50.59 whether changing secondary containment isolation damper closure time from the time specified iri the Final.Safety Analysis Report (FSAR) involved.
an unreviewed safety question.
Because your subsequent review indicated that this change did not constitute an unreviewed safety question requiring prior NRC approval, this violation has been categorized as a Severity Level IV violation.
You are required to respond to the enclosed Notice and should follow the instruc-tions specified therein when preparing your response.
In your response, you should document the specific actions taken and any additional actions you plan to prevent recurrence.
After reviewing your response to this Notice, including your proposed corrective actions, the NRC will determine whether further enforcement action is necessary to ensure compliance with NRC regulatory requirements.
Another issue involving a licensing submittal was also discussed during the May 28, 1986, Enforcement Conference.
On February 25, 1985, an Amendment Request was submitted to delete the Limiting Condition for Operation (LCO) and surveillance requirement from the Browns Ferry Technical Specification associated with the Residual Heat Removal (RHR) system crosstie between adjacent reactor units.
The safety analysis associated with the proposed change was incomplete in that it failed to address the licensing basis for the crosstie feature as discussed in paragraphs F.7. 16 and I.3.3.2 of the FSAR.
These paragraphs clearly described the original plant licensing concerns related to flooding of the Reactor Building basement corner rooms which could possibly render all of the affected units of the Emergency Core Cooling Systems (ECCS) inoperable.
When the original plant licensing basis was examined by the NRC reviewers, the amendment request was deferred pending further justification by the licensee.
It is imperative that future licensing submittals contain complete safety analyses which fully address the design bases for plant features affected by the submittals and you are requested to direct your attention to this matter in future submittals.
f) 0'
Tennessee Valley Authority SEP 08 1986 In accordance with 10 CFR Section 2.790 of the NRC's "Rules of Practice,"
Part 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosure will be placed in the NRC Public Document Room.
The responses directed by this letter and its enclosure 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.
Should you have any questions concerning this letter, please contact us.
Sincerely,
Enclosure:
Notice of Violation and Proposed Imposition of Civil Penalties cc w/encls:
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- Pomrehn, Browns Ferry Nuclear Site Director J R.
L. Lewis, Plant Manager J
M. J.
May, Site Licensing Manager g R.
L. Gridley, Director, Safety and Licensing Original Signed by
- 3. Nelson Grace J.
Nelson Grace Regional Administrator
Tennessee Valley Authority SEP O8 1986 Distribution pa J.PDR 4$ ECY ACRS JJMTay1or, IE RStarostecki, IE
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)R.J. Clark, Li<<ena>ng Project Manager, NRR
'JM. Grotenhuis, Project
- Manager, NRR G.
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