ML18033A974
| ML18033A974 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 10/03/1989 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML18033A973 | List: |
| References | |
| EA-85-049, EA-85-49, NUDOCS 8910060252 | |
| Download: ML18033A974 (7) | |
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t UNITEDSTATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 ENCLOSURE SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO THE CLOSURE OF ORDER NO.
EA 85-49 TENNESSEE VALLEY AUTHORITY BROMNS FERRY NUCLEAR POWER PLANT UNITS 1 2 AND 3 DOCKET NOS. 50-259 50-260 AND 50-296
1.0 INTRODUCTION
By letter dated June 14, 1985, NRC issued the Order No.
EA 85-49 modifying the licenses for Sequoyah and Browns Ferry.
The basis for the Order was the circumstance surrounding the preparation of a nonconformance report (NCR) related to the Sequoyah containment pressure transmitters.
As a result of the special review conducted on March 27-29,
- 1985, NRC identified a breakdown in the management controls for evaluating and r eporting potentially significant safety concerns.
In its Order Modifying Licenses dated June l4, 1985, NRC ordered effective immediately that the Tennessee Valley Authority (TVA) shall do the following:
A.
Within 60 days (I)
Complete an evaluation of its procedures at each of its operating nuclear power plant sites and at its Office of Engineering in Knox-ville, Tennessee with regard to their adequacy for ensuring that when potentially significant safety conditions are identified by engineering management such as the Chief Nuclear Engineer (Nuclear Engineering Branch Chief), they are imediately reported to plant management, evaluated expeditiously, for appropriate action, including applicability to other plants, reported if required, and corrected; (2)
Submit the evaluation along with a plan and schedule for promptly revising the procedures as appropriate.
B.
bfithin 120 days, develop and submit a plan for training of all personnel involved in implementing the revised procedures including responsible licensee management personnel both in the Office of Engineering and the Office of Nuclear Power to ensure that such personnel recognize potentially significant safety conditions and ensure that they are expeditiously evaluated,
- reported, and corrected and understand their individual responsibilities in carrying out the procedure.
The plan shall S9i0060252 891003
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provide a schedule when the training will be completed for all of the employees and managers.
C.
Within 45 days, provide copies of all reports, evaluations or other analysis that may have been prepared of the circumstances surrounding, including chronology of events, the qualification issue of the pressure transmitters at Sequoyah between October 1.
1984 and April I, 1985. If investigations had been conducted or were ongoing that had not yet been completed this was to be indicated with an expected date when the docu-ments would be provided.
In addition, within 45 days the licensee was required to survey all of its OE employees and NUC PR employees as well as any other appropriate employee and submit a report which identified each employee including managers who were aware of the pressure transmitter qualification issue between October 1. 1984 and April l. 1985 at Sequoyah and the date of his or her first knowledge of such an issue.
Persons who were employed during that period who have since left the licensee's employ were also required to be contacted.
The Director, Office of Inspection and Enforcement, was authorized to relax or terminate any of the above conditions for good cause.
2.0 BACKGROUND
As described more fully in the Order, on October 26, 1984, Nonconformance Report (NCR)
WBNNEB 8415 was initiated at the Watts Ba'r Nuclear Plant docu-menting that certain containment pressure transmitters at the Watts Bar facil-ity were not environmentally qualified.
Even though the Office of Engineering (OE) in Knoxville recognized the need to review similar instrumentation at the Sequoyah Nuclear Plant, no review was conducted until nearly two months later when NCR SgNNEB 8501 was initiated.
The associated Failure Evaluation/
Engineering Report (FE/ER) on NCR SgNNEB 8501 concluded that as a result of the failure mode, a reactor operator would have inaccurate information to mitigate a loss-of-coolant accident or main steam line break event inside containment and that. as a result, certain safety functions or actions would be defeated or delayed.
The engineering analysis of these events included as part of the FE/ER concluded that the consequences of such events could lead to exceeding the containment design pressure limits.
The FE/ER was initiated on February 5, 1985, by a staff engineer who signed it on February 25, 1985.
The FE/ER was reviewed and signed by another staff engineer on February 27, 1985.
The FE/ER was concurred in by the engineering staff at the Sequoyah site on March 4, 1985, and signed by the Chief Nuclear Engineer (Nuclear Engineering Branch Chief) on March 5, 1985.
Although the FE/ER documented a significant safety issue, at no point during the development and issuance of the document was the issue brought to the attention of senior plant operations management.
The FE/ER was not formally issued by the plant operations management.
The FE/ER was not formally issued by the Engineering Office in Knoxville until March 7, 1985, and not received onsite until March 8, 1985.
The significant issues raised by the FE/ER were not brought to the
attention of senior operations management (the Plant Superintendent and Plant Manager) until March 11, 1985.
3.0 EVALUATION TYA responded to the Order in its letters dated July 2, July 26, August 13 and September 27.
1985.
The August 13, 1985 letter responded to Order Item A
- above, the Ju'ly 2, 1985 and July 26, 1985 letters responded to Item C and the September 27, 1985 letter responded to Item B.
The NRC reviewed the TVA letter dated August 13, 1985 providing procedural improvements for the prompt notification, evaluation, and reporting of potentially significant safety conditions.
In its [[letter::05000259/LER-1985-043, :on 850825,during Performance of Surveillance Instruction on Aprm,Full Scram Inadvertently Occurred. Possible Causes Include Low Scram Header Pressure & APRM Equipment Failure.Aprm Bypass Switch Replaced|letter dated September 24, 1985]]. the NRC requested additional information on these improvements from TVA.
TVA responded by letter dated November 15, 1985, providing the following enclosures:
(1) copies of revised procedures incorporating the improvements being implemented, (2) examples of evaluations of a Condition Adverse to guality (CA() using the revised procedures and illustrating both minimum and maximum timeframes at each step of the process, (3) the specific procedure steps for prompt notification of plant and corporate management and for tracking resolution and correction of CA( and (4) the code list of persons who were aware of the pressure transmitters qualification issue with their title or position.
TVA, in its letter of March 7, 1986, stated that the short-term management controls outlined in its August 13, 1985 letter were being discontinued.
These controls were the independent verification of compliance with procedure controls by the Nuclear Safety Review Staff.
Also, TVA stated that the Nuclear Safety Monthly Top Management meetings discussed in its responses to the Order were being held in abeyance pending the issuance of the revised TVA Corporate Nuclear Per formance Plan (Volume 1).
In a letter dated February 4, 1986, the Manager of Nuclear Power stated that the November 1,
- 1985, Volume 1 of Corporate Nuclear Performance Plan (CNPP) was cancelled and a revised plan would be issued.
TVA submitted its revised CNPP by letter dated March 10, 1986.
The plan included the restructuring of TVA's organization and improvements to TVA's Corrective Action Program.
In its letter dated May 5, 1986, the NRC staff issued an evaluation of TVA's letters dated July 26, August 13, September 27 and November 15, 1986.
This evaluation was based on NRC staff visits to Sequoyah conducted December 18-20,
- 1985, to review the actions taken by TVA.
The NRC staff stated that, although some programmatic deficiencies needed to be corrected, the overall program for handling potentially significant CA( had been substantially improved.
- However, the changes described in TVA's revised CNPP appeared to impact the programs for evaluating and reporting significant CA( which were the subject of the Order.
Therefore, the NRC staff stated that the determination of compliance with the Order would include the evaluation of these changes in the CNPP.
The NRC staff also stated that the evaluation of TVA employee concerns and allegations pertaining to
TVA's handling of significant CA/ might affect the determination of compliance with the Order.
In response to the NRC letter of May 5, 1986, TVA submitted letters dated July 2, 1986, and March 2, 1987.
TVA explained that as part of its coomitments in the revised CNPP it had begun work to standardize its Corrective Action Program.
The letter of March 2, 1988 provided a copy of the new generic CA/
procedure to revise the Corrective Action Program.
TVA stated that this procedure represented the culmination of its efforts, as described fn the CNPP and in the TVA letter dated July 2, 1986, at fulfillingthe requirements of the Order.
The generic procedure had been incorporated in Part I, Section
- 2. 16, of the TVA Nuclear guality Assurance Manual. 'It combined reporting of items previously done on many different forms and was written to streamline the corrective action process and provide procedurally designated quality assurance involvement and management oversight.
The revised Corrective Action Program was implemented at Browns Ferry on March 30, 1987.
TVA concluded, in its letter of March 2, 1987, (that with the implementation of this program) it met the performance improvements required in the Order.
The TVA revised corrective action or CA/ Program was also described in the TVA Browns Ferry Nuclear Performance Plan (BFNPP).
NRC evaluated the TVA CNPP up to and including Revision 4 submitted by TVA letter dated April 22, 1987.
The evaluation is documented in the NRC's Safety Evaluation Report on the TYA revised,
- CNPP, NUREG-1232, Volume I, dated July 1987 which was issued by letter dated July 28, 1987.
The NRC staff reviewed the restructuring of the TVA organization and the improvements in the TVA Nuclear Corrective Program and found them acceptable.
On the basis of its review, the NRC staff concluded that TVA has described adequate programs to ensure that timely corrective action is taken, that the root causes of problems are identified, and that problems applicable to more than one plant are identified.
The NRC staff stated that it would continue to monitor this area to ensure that implementation of the program is adequate.
The NRC staff has reviewed TVA's programaatic improvements to its CA/ program and the implementation of these programs.
There have been the following NRC inspections at Browns Ferry:
50-259, 50-260, 50-296/86-36, 86-43, 87-24.
87-37, 87-41, 88-21 and 88-37.
Based on its review and the inspections, the NRC staff accepted the CA( Program described in the BFNPP.
This is docu-mented in the staff April 1989 SER of the BFNPP.
TVA has provided training on the CA( Program to all appropriate individuals including managers.
TVA has committed to provide training on this program annually for all individuals who process CA( Reports.
The conclusion of the NRC inspections is that TYA has implemented its CA/ Program at Browns Ferry.
Some weaknesses in implementation have been identified and the staff will
-continue to monitor the effectiveness of the implementation program.
4,O CONCLUSION The staff has reviewed TVA's responses to the Order No.
EA 85-49 and its revised CAQ program.
Based on the staff's review and on NRC inspections conducted at Br owns Ferry, the staff concludes that TVA's response to the Order, the revised CAQ Program, and training at Browns Ferry are acceptable and meet the requirements of the Order.
Therefore, the staff finds that TVA has acceptably addressed the Order.
The staff will continue to monitor this program as part of its normal inspection program for Browns Ferry.
Principal Contr ibutor:
T. Daniels Dated:
October 3, 1989