ML18033A383

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Forwards Emergency Operating Instructions Insp Rept 50-260/88-200 on 880808-19 & Executive Summary.Instructions Can Function Adequately to Mitigate Consequences of Accident.Weaknesses Noted in Development & Implementation
ML18033A383
Person / Time
Site: Browns Ferry 
Issue date: 09/28/1988
From: Partlow J
NRC OFFICE OF SPECIAL PROJECTS
To: White S
TENNESSEE VALLEY AUTHORITY
Shared Package
ML18033A384 List:
References
RTR-NUREG-0660, RTR-NUREG-0737, RTR-NUREG-0899, RTR-NUREG-660, RTR-NUREG-737, RTR-NUREG-899 NUDOCS 8810030274
Download: ML18033A383 (14)


See also: IR 05000260/1988200

Text

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ACCESSION NBR:8810030274

DOC.DATE: 88/09/28

NOTARIZED:

NO

DOCKET

ACIL:50-260 Browns Ferry Nuclear

Power Station, Unit 2, Tennessee

05000260

UTH.NAME

AUTHOR AFFILIATION

RTLOW,J.G.

Ofc of Special Projects

RECIP.NAME

RECIPIENT AFFILIATION

WHITEiS.A.

Tennessee

Valley Authority

SUBJECT:

Forwards

Emergency Operating Instructions

Insp Rept

50-260/88-200

on 880808-19.

DISTRIBUTION CODE:

DF01D

COPIES

RECEIVED:LTR

/

ENCL

TITLE: Direct Flow Distribution:

50 Docket

(PDR Avail)

NOTES:1 Copy each to: S.Black,

J.G.Partlow,

S.Richardson

B.D.Liaw,F.McCoy.

SIZE:

05000260

S

RECIPIENT

ID CODE/NAME

INTERNAL: NUDOCS-ABSTRACT

EXTERNAL

LPDR

NSIC

NOTES:

COPIES

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NRC PDR

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ID CODE/NAME

COPIES

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TOTAL NUMBER OF COPIES

REQUIRED:

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UNITEDSTATES

~

NUCLEAR REGULATORY COMMISSION

WASHINGTON, D. C. 20555

September

28,

1988

Docket

No. 50-260

Nr.

S.

A. Mhite

Senior

Vice President,

Nuclear

Power

Tennessee

Valley Authority

6N 38A Lookout. Place

1101 Yiarket Street

Chattanooga,

Tennessee

37402-2801

Dear Nr. White:

SUBJECT:

BROMNS

FERRY UNIT 2

EMERGENCY OPERATING INSTRUCTIONS INSPECTION

(50-260/88-200}

This letter forwards the report and the executive

summary of the emergency

operating instructions

(EOIs) inspection

performed

by an

NRC inspection

team

during the period August 8-19,

1988.

The activities involved are authorized

by

NRC Operating

License

No.

DPR-52 for the Browns Ferry Nuclear

Power Station

(BFN), Unit 2.

At the conclusion of the inspection,

the

team discussed

the

findings with the members of your staff identified in Attachment

A of the

enclosed

inspection report.

Areas

examined during the inspection

included review of the EOIs, the

documents

used to develop the EOIs, the

FOI validation and verification

program,

and the

EOI training program;

walkdown of the

EOIs in the control

room and plant; evaluation of operator

performance of EOIs os your

site-specific simulator;

and performance of a

human factors evaluation of the

EOIs.

An overview of the inspection

and the team's findings are provided in

the enclosed

executive

summary.

Details of the inspection

are provided in the

enclosed

inspection report.

The team determined that the

BFN EOIs,

when used

by trained operators,

can

function adequately

to mitigate the consequences

of an accident.

However, the

team identified a number of weaknesses

involving the development

and

implementation of the EOIs.

Your attention is invited to the items detailed

in Section

3 of the inspection report.

These

include the need for improved

communications

among control

room personnel,

improvement of in-plant

communications

systems,

better definition of the duties of shift personnel,

and improved staging of EOI related tools in the plant.

BFN management

attention

should

be directed at the weaknesses

noted above.

Other items that the team considered

needing

management

attention included

evaluation of containment venting procedures,

evaluation of personnel

access

to the reactor building during emergencies,

and review of deviations of the

EOIs from the documents that were used to develop

them.

Your responses

to the

identified weaknesses

outlined in Section

3 of this report are requested within

60 days of receipt of this letter.

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S.

A. White

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 1900,

PL 86-511.

In accordance

with 10 CFR 2.790{a),

a copv of this letter and enclosures will

be placed in the

NRC Public Document

Room.

Should you have

any questions

concerning this inspection,

please

contact

me or

Yir. J.

Cummins

(301-492-0957) of this office.

Sincerely,

Jame

G. Partlow, Director

Offi e of Special

Projects

Enclosures:

1.

Executive

Summary

2.

Inspection

Report 50-260/88-200

cc w/enclosures:

See next page

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Mr. S.

A. White

-3-

Browns Ferry Nuclear Plant

'0

General

Counsel

Tennessee

Valley Authority

400 West Summit Hill Drive

E11

B33

Knoxville, Tennessee

37902

Mr. R. L. Grid'ley

Tennessee

Valley Authority

5N 157B Lookout Place

Chattanooga,

Tennessee

37402-2801

Mr. C.

Mason

Tennessee

Valley Authority

Browns Ferry Nuclear Plant

P.O.

Box 2000

Decatur,

Alabama

35602

Mr. P. Carier

Tennessee

Valley Authority

Browns Ferry Nuclear Plant

P.O.

Box 2000

Decatur,

Alabama

35602

Mr. D. L. Williams

Tennessee

Valley Authority

400 West Summit Hill Drive

W10 B85

Knoxville, Tennessee

37902

Chairman,

Limestone

County Commission

P.O.

Box 188

Athens,

Alabama

35611

Claude

Earl

Fox, M.D.

State Health Officer

State

Department of Public Health

State Office Building

Montgomery,

Alabama

36130

Regional Administrator,

Region II

U.S. Nuclear Regulatory

Commission

101 Marietta Street,

N.W.

Atlanta, Georgia

30323

Resident

Inspector/Browns

Ferry

NP

U.S. Nuclear Regulatory

Commission

Route

12,

Box 637

Athens,

Alabama

35611

Dr. Henry Myers, Science

Advisor

Committee

on Interior

and Insular Affairs

U. S.

House of Representatives

Washingtor

D.C.

20515

Tennessee

Valley Authority

Rockvi lie Office

11921

Rockvi1 le Pike

Suite

402

Rockville, Maryland

20852

Mr. S.

A. White

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EXECUTIVE SUNNARY

INSPECTION

REPORT 50-260/88-200

BROWNS

FERRY NUCLEAR POWER

STATION

During the period August 8-19,

1988,

an

NRC inspection

team evaluated

the

Browns Ferry Nuclear

Power Station

{BFN) emergency

operating instructions

(EOIs).

The inspection

was conducted

to verify that the

EOIs were technically

accurate;

that thei r specified actions could be physically carried out in the

plant using existing equipment,

instrumentation,

and controls;

and that the

plant staff could correctly perform the procedures.

The inspection also

verified that the licensee's

program for development

and implementation of the

EOIs complied with the requirements

of Supplement

1 to NUREG-0737,

"Requirements

for Emergency

Response

Capability."

The inspection

was conducted

in accordance

with the guidelines

in Temporary Instruction 2515/92,

"Emergency Operating

Procedures

Team Inspection."

To evaluate

the EOIs, the team performed the following activities:

reviewed the

EOIs and the procedures

generation

package

submitted to

the

NRC for their development

compared

the

EOIs with the owners'roup

emergency

procedure

guidelines

(EPGs)

and reviewed the licensee's

justification for deviations of the

EOIs from the

EPGs for adequacy

performed in-plant walkdown of the

EOIs

t

evaluated

the

EOIs during the execution of accident scenarios

on the

site-specific simulator

performed

human factors evaluation of the

EOIs during all phases

of the

inspection.

SUMYiARY OF SIGNIFICANT FINDINGS

It appeared

to the team members

observing

performance of the accident scenarios

on the simulator, that improved communications

between control

room personnel

could have

made the

EOI accident

response

more effective.

Specifically, the

team observed

instances

where the unit operator

was providing important

information to the

ASOS, but the

ASOS was not listening because

he was too

involved in reading the

EOIs and focusing

on other problems in the plant.

Also, interviews with BFN staff personnel

and observations

made during plant

walkdowns indicated that in plant communications

systems

were not adequate

to

support the implementation of EOI appendices

which required operations

outside

the control

room.

0

Duties of shift personnel

for responding

to events

were not clearly defined.

There

was

no clear-cut assignment of responsibilities

and roles nor an

indication of who was qualified to perform tasks outside the control

room when

called for in the EOIs.

The functions of the shift technical

advisor

and shift

operations

supervisor

were not clearly defined.

It was apparent that during the first few minutes of some transients,

the

assistant shift operations

supervisor

(ASOS),

who was responsible

for reading

the

EOIs and directing the response

to the accident,

did not have time to

follow the

EOIs step

by step.

As

a result, unit operators

had to take actions

such

as controlling pressure

before being directed to do so by the

ASOS.

After

the initial transient,

the

ASOS had time to refer to the

EOIs to ensure that all

immediate actions

had

been correctly performed.

The

ASOS could then begin to

use the

EOIs to deal with the emergency

by reading the steps

and giving directions.

There appeared

to be

a lack of coordination

among the

BFN staff groups

responsible for the detailed control

room design

review labeling program,

plant labeling program,

and

EOI revisions.

During the inspection,

the

team noted that these

groups

appeared

to be functioning in a largely

autonomous

mode until a restart

date is approached.

Although the procedures

for containment venting were consistent with the

Boiling Mater Reactor Owners'roup

guidance,

the plant-specific analyses

had

not been

done to confirm vent valve capability and reactor building integrity.

No evaluations

had

been

performed to confirm that vent path valves

and dampers

would function at expected

flow and differential pressure

conditions;

this

evaluation,

however,

was in progress

during the inspection.

Vent path ductwork

was expected

to fai 1 inside the reactor building.

In this case

vented flow

could be processed

via reactor building ventilation to the filtered elevated

release

point, but the possible

consequences

of containment building pressuriza-

tion had not been analyzed.

The effects of accident radiation levels in the reactor building on the

operators'bility

to perform local operations

had not been analyzed.

NUREG-0737, item

II.B.2, and

an

NRC Confirmatory Order of July 10,

1981, requi red the evaluation

of personnel

access

to the reactor building during emergencies.

In its response,

prepared

before the current symptom-based

EOIs were issued,

the licensee

concluded that the radiation levels would preclude reactor building entry, but

that the previous event-based

EOIs and plant design would support accident

mitigation without reactor building reentry.

The symptom-based

EOIs require

entry to compensate

for equipment failures.

Since the development

and imple-

mentation of the current

symptom-based

EOIs, the licensee

had not reevaluated

its former position

and analysis.

CONCLUSIONS

The

EOIs were generally technically accurate

and could be performed

by the

plant staff using existing plant equipment,

instruments

and controls.

Following the

EOIs would be difficult in a rapidly developing event;

however,

it appeared

that the EOIs, when used

by trained operators,

would function to

mitigate the consequences

of an accident.

The

BFN staff demonstrated

that the proper personnel,

basic procedures,

and

program plans were in place to correct the problems with the

EOIs identified in

this report.

Problems pertaining to personnel

that will require

management

decisions

and increased

attention include:

(1) improving communications

between control

room personnel

and (2) defining the duties of shift personnel

during emergencies.

4

4

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