ML20043C054
| ML20043C054 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 05/30/1990 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML20043C040 | List: |
| References | |
| NUDOCS 9006010247 | |
| Download: ML20043C054 (2) | |
Text
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'o UNITED STATES
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o-NUCLEAR REGULATORY COMMISSION h.
W ASHING TON, D. C. 20555 f
l ENCLOSURE L
SAFETY EVALUATION REGARDING THE' PROCEDURES GENERATION PACKAGE FOR BROWNS FERRY NUCLEAR PLANT l
1.0 INTRODUCTION
The "TMI Action Plan" (NUREG-0660 and NUREG-0737) required licensees of operating reactors to reanalyze transients and accidents and to upgrade emergency operating procedures (EOPs). The plan also required the NRC staff to develop a long-term plan that-integrated and expanded efforts in the writing, reviewing, and monitoring of plant procedures. NUREG-0899,
" Guidelines for the Preparation of Emergency Operating Procedures," describes the use of a " Procedures Generation Package" (PGP) to prepare E0Ps. A PGP is required by Generic Letter 82-33, Supplement 1 to NUREG-0737, " Requirements for Emergency Response Capability." The generic letter requires each licensee to. submit a PGP, which includes:
(i)
Plant-specific technical guidelines (ii)
A writer's guide 1
(iii) A description of the program to be used'for the validation of E0Ps (iv)
A description of the training program for the upgraded E0Ps.
This report documents the review of the Tennessee Valley Authority (TVA)
I program for the development and implementation of E0Ps for Browns Ferry L
NuclearPlant(BFN).
The review was conducted through. evaluation: of-TVA I
submittals, an on-site EOP inspection and an on-site audit-to determine the adequacy of the TVA program for preparing,(E0Is).for,BFN. implementing, and mainta upgraded emergency operating instructions The review was based on NUREG-0800, Subsection 13.5.2, " Standard Review Plan for-the Review-of Safety Analysis Reports for Nuclear Power. Plants."
2.0 EVALUATION In a letter dated June 22, 1984, TVA submitted to NRC the PGP for BFN. A l-Technical Evaluation Report (TER) documenting the review of the BFR PGP was.
provided to TVA for information only, by letter dated January 25, 1988. This TER identified areas of concern about the adequacy ot-TVA's program for preparing and implementing upgraded'E01s for BFN.
The staff conducted a site visit February 22-26, 1988, to discuss the PGP.
Following this visit, a revised PGP was submitted to the NRC by TVA-in a letter dated July 20, 1988.
An E0P inspection was conducted by the NRC1 August 8-19, 1988.
As a result of the. inspection, the NRC team identified a -
number of weaknesses involving the development and implementation of the BFN E0Is.
These items are detailed in Inspection Report No. 50-260/88-200 transmitted by a letter to S. A. White (TVA) from J. G. Partlow (NRC) dated September 28, 1988.
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, TVA responded to Inspection Report No. 50-260/88-200 in a letter dated May 31, 1989.
In this letter, TVA committed to fix a limited number of identified weaknesses in the BFN E01s.
The NRC staff revisited the BFN site on October 17-18, 1989, to review the I
l-status of the BFN E01s for restart. The audit identified several issues l
involving the Revision 3 E0!s that require TVA attention prior to Unit 2 restart. TVA had previously comitted to have BFN operators fully trained in Revision 4 of the E01s prior to the end of 1990, which is after the scheduled restart date for Unit 2.
In addition, a number of weaknesses in the BFN Writer's Guide that were previously discussed in Inspection Report No. 50-200/88-200 were found to still exist.
Specifically, the NRC determined that the BFN Writer's Guide should be rewritten to eliminate potential problems in the development of the E01s, especially with respect to logic statement weaknesses and referencing)
The findings from this audit were transmitted to 0. D. Kingsley (TVA problems.
from D. M. Crutchfield (NRC) in a letter dated January 18, 1990.
3.0 CONCLUSION
S The staff concludes that the PGP submitted by TVA for the Browns Ferry Nuclear Plant needs improvement in some respects to ensure the ability of TVA to develop
~
3 and maintain high quality E01s.
Furthermore, the staff requests TVA to revise, t
as appropriate, its PGP to address the concerns identified in the January 18, l
l 1990 letter from D. M. Crutchfield (NRC) to 0. D. Kingsley (TVA),
1 However, no further submittals to the NRC regarding this program are necessary.
For items identified by the NRC that TVA deems inappropriate for its program, it should develop and maintain documented justification in an auditable form. All revisions to the PGP should be reflected in plant E0Ps within a reasonable period of time, e.g., the next planned revision of the E01s.
Principal Contributor:
Greg Galletti Dated: May 30, 1990
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