ML18033B113
| ML18033B113 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry |
| Issue date: | 01/02/1990 |
| From: | Wilson B Office of Nuclear Reactor Regulation |
| To: | Kingsley O TENNESSEE VALLEY AUTHORITY |
| References | |
| NUDOCS 9001110174 | |
| Download: ML18033B113 (40) | |
See also: IR 05000259/1989043
Text
Doc'ket Nos.
50-259,
50-260,
50"296
License
Nos.
DPR"33,
Mr. Oliver
DE Kingsley, Jr.
Senior Vice President,
Nuclear
Power
Valley Authority
6N 38A Lookout Place
1101 Market Street
Chattanooga,
TN
37402-2801
Dear Mr. Kingsley:
SUBJECT:
ENFORCEMENT CONFERENCE
SUMMARY
(NRC
INSPECTION
REPORT
NOS. 50-259,
50-260,
AND 50-296/43)
This letter
refers
to the
Enforcement
Conference
held at
our request
on
November 21,
1989.
The
issues
discussed
at this conference
related
to the
Surveillance
Program for Browns Ferry Unit 2.
It is our
opinion that this meeting
was beneficial
and
has provided
a better
understanding
of the
inspection
findings,
the
enforcement
issues,
and
the
status
of your corrective
actions.
We
are
continuing
our review of these
issues
to determine
the appropriate
enforcement action.
In
a'ccordance
with 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 enclosures
will be place in the
NRC Public Document
Room.
Should you have
any questions
concerning this matter,
please
contact
us.
Sincerely,
A summary,
a list of attendees,
and
a
copy of the
handout
which accompanied
t
your presentation
are enclosed.
Bruce A. Wilson, Assistant Director
for Inspection
Programs
TVA Projects Division
Office of Nuclear
Reactor
Regulation
Enclosures:
(See
page 2)
9001110i74
900102
ADOCK 0 000~
Mr. Oliver D. Kingsley, Jr.
Enclosures:
1.
Enforcement
Conference
Summary
2.
List of Attendees
3.
Handout
cc w/encls:
F.
L. Moreadith, Vice President
Nuclear Engineering
Valley Authority
400 West Summit Hill Drive
WT 12A 12A
Knoxville, TN
37902
Dr .
M. 0. Medford
Vice Pre s ident
and
Nuc 1 ear.
Technical Director
Val'ley Authority
6N 38A Lookout Place
Chattanooga,
TN
37402-2801
Chairman,
Limestone
County
Commission
P. 0.
Box 188
Athens,
35611
Dr. Henry Myers, Science
Advisor
Committee
on Interior and
Insular Affairs
U.
S.
House of Representatives
D.
C.
20515
0. J. Zeringue,, Site Director
Browns Ferry Nuclear Plant
Valley Authority-
P. 0.
Box 2000
Decatur,
35602
Manager,
Nuclear Licensing
and Regulatory Affairs
Valley Authority
5N 157B Lookout Place
Chattanooga,
TN
37402-2801
State of 'Alabama
RII/ R
RII/NR
Johnson:vyg
WLitt/e
12/QA9
12/ 0:%89
P. Carier, Site Licensing Manager
Browns Ferry Nuclear Plant
Val,ley Authority
P.
0.
Box 2000
Decatur,
35602
G. Campbell,
Plant Manager
Browns Ferry Nuclear Plant
Valley Authority
P.
0.
Box 2000
Decatur,
35602
TVA Representative
Rockvi lie Office
11921 Rockville Pike
Suite
402
Rockvi lie,
20852
General
Counsel
Valley 'Authority
400 West Summit Hill Drive
ET 11B 33H
Knoxville, TN
37902
Claude Earl
Fox,
M.D.
State
Health Officer
State
Department of Public Health
State Office Building
Montgomery,
36130
bcc w/encls:
D.
M. Crutchfield,
B.
D. Liaw,
S.
C. Black,
R.
C. Pierson,
G.
E. Gears,
D. Moran,
W.
S. Little, NRR/RII
A. H. Johnson,
NRR/RII
R.
H. Bernhard,
NRR/RII
J.
Rutberg,
M. S. Callahan,
GPA/CA
NRC Document Control
Desk
NRC Resident
Inspector
U.S. Nuclear Regulatory
Commission
Route
12,
Box 637
Athens,
35611
ENCLOSURE
1
SUMMARY
'he
NRC briefly discussed
the potential
violations involving the Surveillance
Program identified in Inspection
Report 89-43.
The
number of violations
and
LERs related
to the
Surveillance
Program during
1989 were discussed
as
the
basis for NRC's concern
about the adequacy
of the Surveillance
Program
and its
implementation.
.-TVA did not take
issue
with the potential
violations in IR 89-43
and
agreed
that
improvement
was
needed
in
the
implementation
of
the
Surveillance
Program.
Enclosure
3 summarizes
TVA's presentation
including their evaluation
of the
causes
and their actions
to correct
the
problems.
TVA continues
to
believe that their greatest
need is to improve the nuclear work ethic of their
staff.
TVA believes
that the corrective
actions
that
they
had
implemented
earlier,
described
to the
NRC in
a meeting
on procedures
and procedure
error
on
September
28,
1989,
have
already
resulted
in
improvements
in
the
implementation
of
the
Surveillance
Program.
TVA described
"additional
corrective
actions'aken
since
September
28,
1989
which they
believe will
result in further improvements
in their performance.
TVA plans to meet with the
NRC in January
1990 to review the results of their corrective actions.
ENCLOSURE
2
LIST OF ATTENDEES
1.
0. Kingsley, Jr.,
Senior Vice President,
Nuclear
Power
J.
Bynum, Vice President,
Nuclear Production
M. Medford, Vice President
and Nuclear Technical Director
P. Carier, Site Licensing Manager,
Browns Ferry
0. Zeringue,
Site Director,
Browns Ferry
G. Campbell,
Plant Manager,
Browns Ferry
P. Salas,
Compliance Supervisor,
Browns Ferry
T. Ippolito, Consultant
2.
NRC
D. Crutchfield, Associate Director for Special
Projects,
B. Liaw, Director
TVAPD,
B. 'Wilson, Assistant Director for Inspection
Programs,
TVAPD,
S. Black, Assistant Director for TVA Projects,
TVAPD,- NRR
G. Gears,
Senior Project Manager,
TVAPD,
E. Goodwin, Technical Assistant,
TVAPD,
W.- Little, Section Chief, Inspection
Programs,
TVAPD,
K. Ivey, Jr.,
Resident
Inspector,
TVAPD,
R. Bernhard,
Project Engineer,
TVAPD,
G. Galletti,
Human Factors
Assessment
Branch,
W. Troskoski, Office of Enforcement
B. Clayton, Office of Executive Director for Operations
0'
ENCLOSURE
3
NRC/T'I/O Meeting
Implementation of Corrective Actions
To lmllirove Performance of the
Surveillance Testing Program
Rockville, MD
November 21, 1989
STP01
Ob'ectives
Overview of Activities Related
To Implementation of Surveillance
Program
Review September
28th Meeting
With Conclusions and Actions
Additional Actions
Subsequent
Trends
STPOR
Overview
/ Problem Areas
~ Technical Content
~ Programmatic Issues
~ Implementation
/ Assessments
~ Upgrade Process
is Adequate for
, Technical and Programmatic Issues
~ Lack of Correct Operational Mentality
- has Prevented
Proper Implementation
O'dditional Corrective Actions Required
8Tpos
From Se tember 28th Meetin
4 Trends
/ Assessments
/ Corrective Actions
STP04
LtCENSEE EVENT REPORTS
(Based on Event Date)
20)
10
+ Total Events
I
~ 0
~ ~
~
~
~
'
~,
~
0
~
~
0
0
~
~
0
'
~
~
0
0
~
~ g
'
00
'
0
0
0
0
0saaassssssao0
00
Oct
Hov
Dec
Jan
Feb
Mar
Apr
May
June
July
Aug
1988
1989
Legend
IX) Petaonnol Enor
lnvolvfno 5}a
I
lEEl Sl Deflafonoy
j
Assessment
/ Technical Adequacy
~ Verification/Validation Process
~ Strengthened
Review/Approval Process
STPOd
Assessment
contd.
4 Programmatic Issues
~ Conduct of Testing
~ LGO Tracking
~ Scheduling System
~ Management Involvement/Commitment
STPOO
Assessment
contd.
/ Performance
Problems
~ Employee Survey
~ Sl Task Group
~ Procedure
Review Group
~ V/V Implementation Review
/ Conclusion: Work Ethic
STPOT
Corrective Actions
Identified as of September
28th
/ Technical Adequacy
~ V/V Program
/ Programmatic issues
/ Work Ethic Standards
~ Set Expectations
Plant Managers Talks
Procedure
Compliance
- Goal of Zero Personnel Error
~ Define and Correct impediments
- Test Jack improvements
Quality vs Schedule
~ Reinforcement
Superintendent
Meetings to Discuss
Performance
and Critique Events
Post Results in Work Place
~ Personnel Corrective Action
Progressive
Disciplinary Action
- Error Review Committee
STPOS
Since Se tember 28th
/ implementation of Additional Corrective
Actions
/ We Have Set Expectations
4 Continuing to Focus on Human Performance
i Results are Posted Prominently on
Human Performance
STPOO
Browns Ferr
Site
~
~
~
Browns Ferry Site
35
28
21
0
Qct
Nov
Dec
Jan
Feb
Mar
Apr
May
Jun
J ul
Aug
Sep
Browns Ferry Site
ERRQF8
YlD
SECTlON
Chemistry
Construction
Maintenance
Operations
Plant Support
CA
RADOCN
Tech Support
Work Control
Qct
Nov
Dec
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sap
3
3
0
2
1
0
0
0
0
0
0
0
Three Personnel
Errors
CONSTRUCTION: Wires Lifted 8 Landed Without
Proper Work Plan Authorization
CONSTRUCTION: Penetration
Seal Performed
Improperly {QC Bypassed)
MAINTENANCE:
Inattention to Detail During
Testing
ST P10
Mana ement Actions:
/ Senior Site Manager Review
~ Field Involvement
~ Interface
~ Procedures
O'mproved Line Management
Involvement
~ Set Requirements
For:
Field Observations
- Documentation
Feedback of Results
~'andated
V/V Involvement
Completed Program Improvements
~ Restricted the Use of NIC's
~ Pre-approval Walkdown
~ Cog/Sys Engineer & Implementor Walkdown
~ Incident Investigation Process Significantly.
Strengthened
- Lower Threshold
- Immediate Response
Team
STP12A
In-process Program Improvements
~ Improved Scheduling For All Regular and
Non-periodic Sl's
~ Operations Log Sheet For In-progress Sls
~ Utilization of. INPO's HPES Program
~ Conduct of Surveillance Procedure
(Separate from "Conduct of Testing" )
Includes:
- Sl Qualify Craft
- Cog/Sys Engineer Test Director
Responsibilities
- Pre-approval Walkdown by CogiSys
Engineer and Qualified Performer
- Validation Run Prior to Official Run
~ Equipment Removal and Return to
Service Process Improvement
S ecial Reviews:
l Technical Reviews
~ Verify Sl Meets TS Frequency
~ identify Equipment Out-Of-Service
Condition
8 Event Analysis
~ Plant Staff
~ Independent
Safety,Engineering
~ INPO
87 P10
Radiological Incident Reports/Radiation
Work Permit Entries
100)
RWP En%ca
%000
80
10000
20
5000
Security Events
16
14
12
Events
SOURCE: "Quarterly Safegards Event Logs"
(Human Error Category of Security
Safeguards
Events Reported to
NRC IAW 10CFR 73.71)
10
Uner Regression Line
0
Jan
I
Feb
Mar
Apr
May
Jun
Jul
Aug
Sep
89
Oct
I
sTp803
CAQRs/PRDs
800
500
Total O~n
400
lX
5
500
O
200
100
Legend
CZI Cooed
A<
4
4
+
~
~
4
cP
LICENSEE EVENT REPORTS
(Based on Event Date)
Total Events
10
I
I
I
g ~
~
~
~
~
~
~
~
~
~
~
~
~
I
~
~
I
~
~
~
~
~
~
g ~
g
~
~
~
'
'
PPPPPPPPPPP
~I
~
~
t
Linear Rogreaelon
Q
I
Legend
CZl lieraonnel Enor I,'
Involvtno Sli
lEEl Sl Deflofono~y
a++
C
p
~O
~C
Apparent Violations identified in IR 89-43
89-43-01
Failure to Maintain the Minimum Number of
DGs Operable Due to an Inadequate Sl.
89-43-03
.
Failure to Sample DG Fuel Oil Per TS
Frequency.
89-43-04
Failure to Maintain TS LCO Compensatory
Measures for Inoperable Fire Hose
Stations.
89-43-05
Failure to Follow Sls and Inadequate Sls.
- Root Cause Analysis
- Specific Corrective Actions
- Generic Corrective Actions
STPA0$
89-43-01
Failure to Maintain the Minimum Number
DGs Operable Due to an Inadequate Sl.
On August-15, 1989 a test of the RHR service water
initiation logic was performed to satisfy a TS surveillance
requirement.
A subsequent
review of the text procedure
determined that it required the disabling of the automatic
start logic of the emergency equipment cooling water system.
This system provides cooling water to the diesel generators.
Consequently, the diesel generators were declared
technically inoperable.
ROOT CAUSE:
~ Failure of Management Systems
SPECIFIC CORRECTIVE ACTION:
~ Sl Revision
GENERIC CORRECTIVE ACTION:
~ Cross-discipline Procedure Review Group
~ Procedure Verification Review Checklist Revision
~ Procedure Writers Guide Revision
STPh02
89-43-03
Failure to Sample DG Fuel Oil Per TS
Frequency.
As a result of a review of the diesel generators, TVA
.determined that fuel oil quality for all the seven-day
storage tanks for the diesel generators should be sampled
monthly in order to meet the requirement of TS 4.9.A.1.e.
BFN had historically interpreted the TS to mean the seven-
day storage-tanks
shall be sampled once a month on a
staggered
basis.
ROOT CAUSE:
~ Ambiguous Technical Specification
Requirements
E
SPECIFIC CORRECTIVE ACTIONS:
~ Sampling of Each Tank on a Monthly Basis
~ Sl Revision
~ TS Revision to Reflect Industry Standards
GENERIC CORRECTIVE ACTION:
~ Verify Sl's Meet TS Frequency
0
0
89-43-04
Failure to Maintain TS LCO Compensatory
Measures for Inoperable Fire Hose
Stations.
A QA evaluator observed that the TS compensatory measure was
not in place for two inoperable Unit 2 fire hose stations.
ROOT CAUSE:
~ Personnel Error and Lack of Process Control
SPECIFIC CORRECTIVE ACTIONS:
~ Immediate Re-establishment
of Required
Compensatory Measures
~ Fire Protection Procedure Enhancement
~ Weekly Audit of All Open Permits
GENERIC CORRECTIVE ACTION:
~ Improved Scheduling of Sl's
~ Equipment Removal & Return to Service
~ Incident Investigation Program
~ Corrective Actions Articulated in this
Presentation to Correct Work Ethics Standards
STPAOi
89-43-05
Failure to Follow Sls and Inadequate Sls
NRC cites three events and associated
LERs as examples
of an apparent violation of TS 6.8.1.1.c for failure to
maintain and implement Sl procedures.
CORRECTIVE ACTIONS:
~ Set Expectations
~ Defined 8 Corrected Impediments
~ Management Actions
~ Special Reviews
~ Program Improvements
STPAOS
4
'UMMARY
- Trends Confirm That Corrective
Action Discussed During
September
28, 19S9 Are Working
- Additional Corrective Actions
Will Further Strengthen Our
Performance
- Review Results With NRC
STPI 5
\\ ~