ML18033B113

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Forwards Summary of Enforcement Conference Re Insp Repts 50-259/89-43,50-260/89-43 & 50-296/89-43 Re Surveillance Program for Facility.Meeting Beneficial & Provided Understanding of Insp Findings
ML18033B113
Person / Time
Site: Browns Ferry  Tennessee Valley Authority icon.png
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,

DPR-52,

DPR-68

Mr. Oliver

DE Kingsley, Jr.

Senior Vice President,

Nuclear

Power

Tennessee

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

PDR

ADOCK 0 000~

PDC

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

Tennessee

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

Tennessee

Val'ley Authority

6N 38A Lookout Place

Chattanooga,

TN

37402-2801

Chairman,

Limestone

County

Commission

P. 0.

Box 188

Athens,

AL

35611

Dr. Henry Myers, Science

Advisor

Committee

on Interior and

Insular Affairs

U.

S.

House of Representatives

Washington,

D.

C.

20515

0. J. Zeringue,, Site Director

Browns Ferry Nuclear Plant

Tennessee

Valley Authority-

P. 0.

Box 2000

Decatur,

AL

35602

Manager,

Nuclear Licensing

and Regulatory Affairs

Tennessee

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

Tennessee

Val,ley Authority

P.

0.

Box 2000

Decatur,

AL

35602

G. Campbell,

Plant Manager

Browns Ferry Nuclear Plant

Tennessee

Valley Authority

P.

0.

Box 2000

Decatur,

AL

35602

TVA Representative

Rockvi lie Office

11921 Rockville Pike

Suite

402

Rockvi lie,

MD

20852

General

Counsel

Tennessee

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,

AL

36130

bcc w/encls:

D.

M. Crutchfield,

NRR

B.

D. Liaw,

NRR

S.

C. Black,

NRR

R.

C. Pierson,

NRR

G.

E. Gears,

NRR

D. Moran,

NRR

W.

S. Little, NRR/RII

A. H. Johnson,

NRR/RII

R.

H. Bernhard,

NRR/RII

J.

Rutberg,

OGC

M. S. Callahan,

GPA/CA

NRC Document Control

Desk

NRC Resident

Inspector

U.S. Nuclear Regulatory

Commission

Route

12,

Box 637

Athens,

AL

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.

TVA

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,

NRR

B. Liaw, Director

TVAPD,

NRR

B. 'Wilson, Assistant Director for Inspection

Programs,

TVAPD,

NRR

S. Black, Assistant Director for TVA Projects,

TVAPD,- NRR

G. Gears,

Senior Project Manager,

TVAPD,

NRR

E. Goodwin, Technical Assistant,

TVAPD,

NRR

W.- Little, Section Chief, Inspection

Programs,

TVAPD,

NRR

K. Ivey, Jr.,

Resident

Inspector,

TVAPD,

NRR

R. Bernhard,

Project Engineer,

TVAPD,

NRR

G. Galletti,

Human Factors

Assessment

Branch,

NRR

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

NSS

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

\\ ~