ML20079D397
| ML20079D397 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 07/10/1991 |
| From: | Medford M TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9107120268 | |
| Download: ML20079D397 (28) | |
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Tunessee V34ey A nny. H0i Mm.W 59mn ChaPymp Tonm,sw 37C Mark O Medford vecc hesdem Naci,-w Arsarance Licens;r>g an;1 Fues JUL 101991 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Centler.an:
In the Matter of ) Docket Nos. 50-259 Tennessee Valley Authority ) 50-296 BPOWNS FERRY NUCLEAR PLANT (BFN) - REGULATORY FRAMEWORK FOR THE RESTART OF UNITS 1 AND 3
References:
- 1. TVA letter dated January 9, 1991, Plans for the Return to Servica of BFN Units 1 and 3
- 2. NRC letter dated March 14, 1991 _ Restart of Browns Ferry, Units 1 and 3 This letter provides TVA's proposcd overall regulatory framework for the restart of Units 1 and 3. TVA provided, as part of Reference 1, an evaluation of the Browns Ferry Nuclear performance Plan (BFNPP) special programs and an outline of their applicability to the restart of Units 1 and 3. NRC provided an initial response to this letter by Reference 2 and requested additional information regarding the management, programs addressed in Sectinn II of the DFNPP and whether TVA plans to conduct an 9peraticnal Readiness Review prior to the restart, of Unit 3. On May 22, 1991, TVA and NRC met to discuss these lettert in the context of the overall regulatory framework for the restart of Units 1 and 3.
The regulatory framework for the restart of Unit 2 was atypical. TVA's submittal of the BFNPP and NRC's review and issuance of Safety Evaluation Reports for each individual program were unique. While this level of NRC involvement did result in added confidence for the approval of Unit 2 restart, it required significant TVA and NRC resources. In most cases, j TVA began the implementation of those programs prior to NRC approval.
l- Significant redesign and additional modifications were required whenever l
_the criteria were changed during the approval procesa. Additional E details of.the regulatory framework for Unit 2's restart and a discussion of the lessons learned are provided in Enclosure 1.
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-U.S. Nuclear Regulatory Commission (JUL 101991 TVA's proposed regulatory framework for the restart of Units 1 and 3 is consistent with normal industry practice. The proposed program will establish a high degree of confidence that the facility and perconnel are ready to restart and operate Units 1 and 3 in a safe and reliable manner, and promote the efficient utilization of TVA and NRC resources. *VA's plans for the restart of Units 1 and 3 are based on the regulatory requirements, corrective action programs, commitments, technical specification improvements, and internally identified deficiencies and concerns that wer resolved prior to the restart of Unit 2. Additional details for each of those categories and a response to the NRC's March 14, 1991 request for additional information on management issues and Operational Readiness are presented in Enclosure 1. The major points of TVA's proposed regulatory framework are:
o .TVA will not restart BFN Units 1 or 3 without prior NRC approval, o For BFNpp special programs that TVA will impicment on Units 1 and 3 in accordance with the Unit 2 criteria and-implementation precedent, no additional NRC programmatic evaluations are required.
o TVA has and will continue to provido informational submittals to WRC for BFNpp special programa that deviate from the Unit 2 implementation prec edent. TV.- requests timely notification of any concernu resulting from NRC review of these submittals, o For special programs that deviate from the Unit 2 criteria pcecedent TVA has or will proposo revised criteria for NRC staff review and approval. TVA requesta expeditious NRC review of there criteria and 4.ssuance of suppicmental Safety Evaluation Reports in order to support the design of modificationn that are required to be completed on Unit 2 prior to the restart from the next refueling outage and prior to the restart of Units I and 3.
TVA has begun detailed walkdowns on Unit 3 and has made several submittals that defined and justified deviations from the Unit 2 precedent for these BFNPp special programs. TVA requests expeditious NRC review and concurrence with this proposed overall regulatory framework in order to proceed with the resolution of the detailed criteria, programmatic, and compliance issues.
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N.P #2c) ear Regulatory Comission j!nW91 A e ss.T ist of comitments contained -in this letter is provided 'in --
-knolos.co 2. If:you have any questions, Please telephone Joseph E. McCarthy, Unit 3 Restart Licensing Manager, at (205) 729-3604.
Very truly yours.
TENNESSEE VALLEY AUTHORITY h r hk/
Mark O.-Medford
-Enclosures
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ec:(Enclosures):
- Ms.-S. C. Black.,iDeputy-Director Project Directorate 11-4 U.S. Nuclear Regulatory Comission
- One-White Flint, Nort.h
- 11555 Rockville Pike Rockville, Maryland 20852 WRC Resident Insoector Browns-Ferry Nuclear Plant-Route 12,. Box 637 Athens, Alabama -35609-2000 Mr.- Thierry. M, Ross, Project Manager U.S. Nuclear Regulatory Commlssion One White Flint, North-
'11555 Rockville Pike Rockville, Maryland 20852-
- Mr. ' B. A. Wilson, Project Chief -
- U.S. Nuclear. Regulatory Comission Region II.
101--Marietta Street,-NW,-Suite 2900 Atlanta, Ceorgia 30323 l
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ENCLOSURE 1-BROWNS FERRY NUCLEAR PLANT (BFN) '
REGULATORY FRAMEWORK OF THE RESTART OF UNITS 1 AND 3 UNIT 2 RESTART PROCESS t
Browns Ferry Units l'and 3 were voluntarily shut down by TVA in March 1985 because of questions about the primary containment isolation leak rate testing for Unit 1 and reactor water level instrumentation for Unit 3. Unit 2 was in a refueling outage at that time. Additional questions and concerns were
- subsequently raised about the overall adequacy of TVA's nuclear program.
By letter, dated September 17, 1985, the NRC requested, purbaant to 10 CFR 50.54(f), that TVA specify the corrective actions which would be completed prior to the restart of arV of the TVA operating facilities and a
-schedule for longer term actions. his letter also confirmed TVA's verbal commltment not to_ restart any of TV 's operating plants without prior NRC concurrence. TVA responded for '..ie irowns Ferry Plant with the submittal and subsequent revisions to the Co'.porat : Nuclear Performance Plan (CNPP) and the
. Browns Ferry Nuclear Performaace Plan (BFNPP).. The CNPP addressed the NRC'c concerns with TVA's corporate management. The BFNPP addressed Browns Ferry
-site specific issues, with an emphasis of the actions required to restart Unit 2. In these documents, the root causes of Browns Ferry's problems wero identified as:
- A lack of clear assignment of responsibility and authority to managers and their organizations that clearly established accountability for performance.
. - Insufficient management involvement and control in the work place, leading;to a failure to adequately establish the highestnquality of
. performance.
.- - The failure to consistently maintain a documented design basis for the plant and to control the plant's configuration in accordance with that basis.
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- ENCLOSURE 1 #'S' # #"
BROWNS FERRY NUCLEAR PLANT (BFN)
REGULATORY FRAMEWORK 0F-THE RESTART OF UNITS 1 AND 3 (CONTINUED)
The BFNPP was originally. issued in August of 1986 and was last revised in October of 1988. Separate TVA submittals revised the proposed corrective
. action programs and submitted detailed design criteria for several issues, especially in the seismic area. Numerous inspections were conducted to verify
- the effectiveness and thoroughness of the implementation of these corrective action programs and TVA docketed several responses to open items contained in the inspection reports. Consequently, the final corrective action programa may be significantly different from the description contained in the last revision of the BFNPP and the complete description of each program consists of the complete set of documents docketed for Unit 2. NRC evaluation of.the
- BFNPP special programs was-documented by the iissuance of issue specific Safety Evaluation Reports-(SERs) or.in NUREG-1232, Volume 3, Safety Evaluation Report on the Browns Ferry Nuclear Performance Plan, and its supplements.
By letter, dated April 16 1991, TVA provided the status of the completion of Unit 2 restart corrective actions' identified in the DFNPP. Notification of the completion of the remaining restart corrective actions was provided by TVA
- letter, dated May 14,-1991. TVA has previously committed to provide NRC with a schedule for the implementation of post-restart Unit 2 commitments by j
september 20, 1991. .It is TVA's position that this set of documents collectively satisfied the requirements of the NRC's September 17, 1985 10 CFR 50.54(f) letter for Browns Ferry. . Programs and commitments contained in the BFNPP, including those applicable to Units 1 and 3, will be tracked to completion as part of TVA's normal. commitment tracking system.
LESSONS' LEARNED FROM UNIT 2 RESTART The regulatory framework for the restart of Unit 2 was atypical. TVA's j submittal of *;he BFNPP and MC's review and issuance of . Safety Evaluation
[ Feport '-* each individual program was unique. Normally, the licensee and NRC identify the problems that lead to the shutdown of a plant. The licenseo l develops and implements appropriate corrective action programs. Then the NRC performs a post-implementation inspection to verify that the identified problems have been corrected.
ENCLOSURE 1 BROWNS FERRY NUCLEAR PLANT (BFN)
REGULATORY FRAMEWORK OF THE RESTART OF UNITS 1 AND 3 (CONTINUED) '
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Obtaining NRC approval of the adequacy of the Unit 2 corrective action programs and criteria had the following impacts:
1)- While this level of HRC involvement did result in added confidence for the approval of Unit 2 restart, it required significant TVA and NRC resources to negotiate the approval of individual programs and criteria.
TVA is minimizing the resources required to obtain NRC approval of programa on Unita 1 andR3 by using the Unit 2 criteria and implementation precedent unless significant improvements in program efficiency can be obtained.
2)- In most cases, TVA began the implementation of these programa "at risk",
which meant prior to NRC approval. Significant redesign and additional modifications were required whenever the criteria was changed during the
-approval process. TVA is minimizing the risk of implementing programs on Units 1 and 3 prior to obtaining NRC approval by prioritizing program implementation and by.using the Unit 2 criteria and implementation precedent unless significant improvements in program efficiency can be obtained.
- 3) TVA used an interim (one cycle) operability criteria as part of the corrective action program for some commodities, especially in the seismic area. TVA also partially completed some corrective action programs prior to restart (e.g., design baseline, procedures upgrades, and fire protection). The use of interim criteria and partial completion of programs resulted in a loss of personnel continuity at the working. level. TVA does not intend to use interim criteria or partial programmatic completions prior to the restart of Unite 1 and 3, except for issues related to the-final implementation of Unresolved Safety Issue A'-46,-Verification of Seismic Adequacy of Mechanical and Electrical Equipment in Operating Reactors.
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. ENCLOSURE 1-BROWNS FERRY NUCLEAR PLANT (BFN)
REGULATORY: FRAMEWORK OF THE-RESTART OF UNITS 1 AND 3 (CONTINUED)
During the extended Unit 2 outage, TVA informed the NRC Staff of several changes which were_ being made to design comn'itmento or criteria contained in the~BFN Final: Safety Analysis _ Report (FSAR) (e.g., seismic qualification of
= reactor building flood level switches). This resulted in NRC review of
-changes.which would normally be dispositioned by a licensee under the provisions of 10 CFR 50.59. TVA proposed that Units _1 and 3 design changes be evaluated in accordance with normal industry practice. In accordance with-10 CFR 50.59, TVA will submit an annual summary of the changes made under the provisions of this-section. Changes which constitute an unreviewed safety fquestion will be-provided for NRC review and approval as required by.
PBQPOSED UNITS 1 AND 3 RESTART PROCESS TVA's plans for the restart of Unita 1 and 3 are based on the regulatory requirements, corrective. action programs, commitments, technical specit . cation improvements, and internally identified deficiencies and concerns which were resolved prior to the restart of Unit 2. A discussion =and-the proposed regulatory framework.for addressing each of these. categories is presented below. In accordance with the Unit 2 precedent, TVA expects NRC to perform any required post-implamentation inspections to document the closure of these items prior to the restart of Units.1 and 3 and TVA will not restart Browns
' Ferry Units 1 or 3 without prior NRC approval.
Recuirements Enclosure 5 to TVA*o January 9, 1991 letter 1provided a list of the NUREG-0737 Action Items,. Bulletins, Generic Letters, Unresolved Safety Issues (USIs),
Generic Safety' Issues (GSIs), Multi-Plant Action Items (HPAs), and other regulatory requirements which will be resolved prior to the restart of Unita 1 and 3. For convenience, this list has also been included as Table 1 to this enclosure. New Generic Letterc, Bulletins, and regulatory requirements will be resolved on Units 1 and 3 prior to restart or-in accordance with their generic schedular requirements. However, consideration will be given to expedited completion of long lead time issues identified early in the Units 1 and 3 restart process.
1 ENCLOSURE 1 #'8* # #
BROWNS FERRY NUCLEAR PLANT (BFN)
REGULATORY FRAMEWORK 0F THE RESTART OF UNITS 1 AND 3 (CONTINUED)
For regulatory issues in Table 1 which:
- 1) Were addressed specifically for Unit 2 and received Unit 2 specific NRC Safety Evaluation Reports (SERs), and
- 2) Will be implemented on Units 1 and 3 in accordance with the Unit 2 criteria and implementation precedent.
For issues in this category, TVA propor,es a subeequent submittal to NRC. This submittal will review the regulatory issues in Table 1 and identify those issues that are in this category. This submittal will summarize each issue, identify the major TVA/NRC correspondence associated with the resolution of the issue, review the TVA actions taken to resolvt 'he issue on Unit 2, commit to perform similar actions for Units 1 and 3, and request a letter from the NRC Staff which states that the Unit 2 specific SERs are also applicable to Units 1 and 3.
TVA will review the issues in Table 1 and identify those issues whose closure for Unit 2 was predicated on the assumption that Units 1 and 3 were shutdown and defueled (e.g., station blackout). TVA will re-evaluate these issues to assume the operation of each unit prior to its return to service. TVA will submit the results of these re-evaluations on an issue specific basis and request supplemental SERs. These commitments are contingent upon NRC acceptance of TVA's proposed regulatory framework.
TVA will provide notification to NRC when the regulatory issues in Table 1 are implemented on Units 1 and 3.
Corrective Action Procrams TVA's January 9, 1991 letter also addressed the BFNPP special programs and their applicability to the restart of Units 1 and 3. Subsequent submittals have revised this tabulation, therefore a revised summary of the applicability of the NPP special programs is included as Table 2. These NPP special programs are being addressed for Units 1 and 3 in four categories:
- 1) Programs considered complete for all three units.
- 2) Programs which will be implemented on Units 1 and 3 in accordance with the Unit 2 criteria and implementation precedent.
s ENCLOSURE-l #' ' #
BROWNS FERRY NUCLEAR PLANT (BFN)
REGULATORY FRAMEWORK OF THE RESTART OF UNITS 1 AND 3 (CONTINbED)
-3) Programs which will be implemented on Units 1 and 3 in accordance with the Unit 2 criteria precedent. However, TVA will take advantage of lessons learned from the implementation of these programs.on Unit 2 to implement the program more efficiently.
- 4) ' Programs which TVA will' implement on Units 1 and 3 using criteria which deviates from the Unit 2 precedent.
A discussion of;these categories-and the proposed regulatory framework for each is provided as follows.
Completed Programs -
There:are~four BFNPP special programs which TVA considers complete for Browns Ferry _ Units 1, 2,-and 3. Each is briefly discussed below. TVA proposes-that no further regulatory programmatic reviews be performed on these programe.
'TVA's program for resolving heat code traceability concerns addressed all three units. NRC's May 31, 1990 SER on the TVA employee concerns subcategory reports applied to all three units and-concluded;that TVA had adequately addressed the issues raised by the eighteen concerns in this Material Subcategory Report.
TVA's submittals and the NRC's April 11, 1988 SER-for the secondary containment penetrations program addressed all three units. The work for this program was completed _for all three units prior to the-restart of_ Unit 2..
TVA's submittals and the'NRC's August 31, 1988 SER for Bulletin 87-01, Thinning of. Pipe Walls in Nuclear Power Plants,. addressed all three units.
The initial inspections were completed and the monitoring program was established for-all three units prior to'the restart of Unit 2.
-The TVA subm'ittals for the welding program addressed'all three units. NRC's May 31, 1990. SER ~ on the T';A employee concerne subcategory reports applied to all-three_ units and concluded that TVA had adequately addressed welding
. related employee concerne. However, the NRC*r overall conclusion that TVA has adequately-reviewed _and addressed welding related concerns at BFN is documented in NUREG-1232, Volume 3, Supplement 1, dated October 24, 1989 and is-only applicable to the Unit 2 docket.
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BROWNS FERRY: NUCLEAR- PLANT- (BFN)
REGULATORY FRAMEWORK OF THE RESTART OF UNITS 1 AND 3 (CONTINUED)
-Programs Implemented in Accordance with the Unit 2 Precedent -
Thtre-are twenty BFNPP special programs which TVA will implement on Units 1 and 3 in accordance with the' Unit 2 criteria and implementation precedens. In general, the TVA:submittals for those programs were addressed specifically for Unit 2 and.TVA received Unit 2 specific SERs in NUREG-1232, Volume 3 and its supplements. Since corrective action programs do not normally receive SERs and since TVA=is not proposing changes to the programs which were approved on Unit 2, TVA proposes no additional NRC programmatic evaluations be performed
-for these programs on Units 1 and 3. TVA will provide notification to NRC when these corrective action programs are implemented on Units 1 and 3. TVA expects- NRC to perform any required post-implementation inspections to document the closure of the issue prior to the restart of Units 1 and 3.
Programs which Daviate from the Unit 2 Implementation Precedent -
There are eight.BFNPP_special programs which TVA will implement on Unita 1 and 3 in accordance with the-Unit 2. criteria precedent. However, TVA will
,take advantage of lessons learned from the implementation of these programs on Unit 2 and will implement the program more-efficiently. InLorder to notify ,
NRC of TVA's intent'.ons to deviate from the previously reviewed Unit 2 implementation precedent, TVA has and will continue to provide. informational submittals to NRC. TVA proposes that the NRC Staff review the deviations from the' Unit 2 implementation precedent. TVA should be notified of any NRC concerns either-through a request for a meeting or for additional information.
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TVA will provide notification to NRC when these corrective action programs are implemented on Units 1 and 3.
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ENCLOSURE 1 #89* 8 of M BROWNS FERRY NUCLEAR. PLANT (BFN)
REGULATORY FRAMEWORK OF THE RESTART OF UNITS 1 AND 3 (CONTINUED)
Programs which Deviate from the Unit 2 Criteria Precedent -
There are two BFNPP.special programs which TVA will implement on Units 1 and 3 using criteria which deviates from the Unit 2 precedent. TVA has or will propose revised criteria for NRC Staff review which will become the design criteria applicable to all three Browns Ferry units. TVA will request expeditious NRC review of this criteria and issuance cf supplemental SERs in-order to support the design of modifications which are required to be
. completed on Unit 2 prior to the restart from the next refueling outage and prior to the restart of Unit'3. TVA will provide notification to NRC when these correctire action programs are implemented on Units 1 and 3.
Commitment _q TVA has reviewed the applicability of Unit 2 restart commitments to the rertart of Units 1 and 3. The applicable commitments are incorporated into the Unit 3 restart scope. In accordance with the previous precedent for the majority of-Unit 2 restart commitments and in-accordance with normal industry practice, TVA doce not intend to formtlly notify NRC upon completion of every
' Units 1 and 3 restart commitment. TVA is obligated to notify NRC in the event of significant changes to the commitment or its schedule for implementation (i.e., restart versus post-restart). TVA's commitment control procedures and pre-restart checks will ensure that Units 1 and 3 restart commitments are completed prior to the. restart.of the applicable unit. TVA does not propose specific NRC action regarding the verification of completion of each specific TVA restart commitment.
1 ENCLOSURE 1-
' BROWNS FERRY NUCLEAR PLANT-(BFN) -
REGULATORY FRAMEWORK OF THE RESTART OF UNITS 1 AND (CONTINUED) _
Technical Soecification Improvements IIn the January 9, 1991 letter, TVA stated its plans were to "Pc 3 the custom
'- Browns Ferry Technical Specifications to the Improved BWR Standard Technical Specifications ~(ISTS)' prior to_the restart of Units 1 and 3. Due to delays in the. approval' schedule-for the ISTS, TVA will not be able to implement them prior to the restart of Unit'3. Instead, TVA will review the pre-restart i
changes made to the Unit _2 technice1 specifications-but not incorporated into
- the_ Unit 3 technical. specification. TVA will. propose technical specification amendments to incorporate these changes into the Unit.3, and Unit 1 where possible, technical specifications. TVA intends to consolidate appropriate amendment requests and reference the prior Unit 2 TVA/NRC correspondence in order _to minimize the-impact on the NRC resources required to review and approve these amendments.
Internally Identified Deficiencies and concerne
- Internally identified deficiencies (Significant condit.%n Reports, Nonconformance Reports, and Condition Adverse to Quality Reports) are currently being reviewed'for.their applicability to the restart of Units 1 and.3. Newly identiff.ed issues will be-addressed and scheduled on a case by
- case basis.-
AREAS Ot' NRC STAFF INTEREST
- By letter dated January 9, 1991, TVA provided an evaluation of the BFNPP special programs and an outline of their applicability to the restart of Units 1 and 3. NRC provided an initial response-to this' letter on March 14, 1991 and requested additional information regarding the management programs addressed in Section'II of the BFNPP. Specifically, NRC requested.
. < that-TVA document the extent to which the management programs are applicable to BFN Units 1 and 3. NRC also asked if~TVA planned to conduct an Operational
- Leadiness Review prior to the restart of Unit 3. TVA's response to these items is provided below.
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Page so or u ENCLOSURE 1 BROWNS FERRY NUCLEAR PLANT (BFN)
REGULATORY FRAMEWORK OF THE RESTART-0F UNITS 1 AND 3 (CONTINUED)
Manaoement Issues The NRC's September 17, 1985 letter requested TVA identify corrective actions for man &gement deficiencies that contributed to poor direction and control of nuclear activities. The CNPP outlined TVA's approach to solving the problems
-with its nuclear program. In general, the approach to resolving management
' issues consisted of the 6ddition of experienced managers, the clarification of management-lines of authority and responsibility, the restoration of employeo
- trust in management, and changes in the management of plant activities. The corporate managerial issues were resolved prior to the restart of the Sequoyah nuclear plants as documented in NUREG-1232, Volume 1, Safety Evaluation Report on the Tennessee Valley Authority Revised Corporate Nuclear Perfortaance Plan, dated July 28, 1987. In this document, the staff concluded that the organization and staffing of the Office of Nuclear Power and the programmatic improvements in place or under way were sufficient to resolve the concerns at the corporate level that led to the issuance of the NRC Staff's 10 CFR 50.54(f) letter, dated September 17, 1985. This SER was applicable to all three Browns Ferry dockets. Therefore, TVA considers the corporate managerial issues resolved for all three Browns Ferry units.
The corrective actions taken to-a'rengthen the Browns Ferry site management and organization and to increase management control and involvement were addressed in Section II of the BFNPP. Overall, the BFN nuclear site support organizations were strengthened by a reorganization along functional lines
-that generally parallelled the functional departments in TVA's Nuclear Power organization. Where applicable, each site support organization received
- technical direction from its respective Nuclear Power department while y receiving direction on priorities and day to day functions from the Site Director. In a number of areas, BFN managers and their organizations lacked a clear assignment of responsibility and authority. Accordingly, position
' descriptions were revised o~ developed to clarify each manager's area of responsibility and establish accountability. The organizational structure was subsequently refined so.that personnel on site reported to the Site Director, except for Quality Assurance, Human Resources, Medical Services, Employee concerns, Information System Services, and the Site Training organization. A description of the Brown Ferry organization is included in Topical y Report TVA-NPOD89-A, Nuclear Power Organization Description, which was originally. submitted in June 1989, last updated in April 1991, and is updated annually.
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-ENCLOSURE 1 BROWNS FERRY NUCLEAR PLANT (BFN)
REGULATORY FRAMEWORK OF-THE RESTART OF UNITS 1 AND 3 (CONTINUED)
In. studying the problem of management involvement at Browns Ferry, TVA identified the following contributing factors e An absence of effective organizational structure with clear lines of
! responsibility, authority, and accountability.
e A lack of-srfficient numbers of experienced managers to provide the necessary leadership and direction.
. A lack of commitment to, and responsibility for, achieving excellence in performance.
. Insufficient follow-up to verify proper implementation of goals and directives, e The f ailure to adequately scope, plan, and apply resources to emerging problems.
TVA determined that there was no single root cause to the management problems, Jather it was a result of a general attitude that required correction. This attitude was corrected by_ obtaining experienced nuclear managers from outside
- /7A to assist in adopting and implementing a philosophy of involvement and f;11ow-through.
The detailed corrective actions taken to increase the Browns Ferry site
. management control and involvement included:
- Establishing clear management goals and objectives. g e .Enhencing communication with employees.
. Implementing training initiatives in the areas of engineer and manager training, technical training for non-licensed plant pernonnel, accreditation of training programs by the Institute for Nuclear Power operatiens, and upgrades to the site training facilities, e Instituting a procedures upgrade program.
e Committing to take action to ensure that conditions adverse to quality P
are resolved in a timely manner.
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ENCLOSURE 1 BROWNS FERRY NUCLEAR PLANT (BFN) :
REGULATORY FRAMEWORK OF THE RESTART OF UNITS 1 AND 3
-(CONTINUED) e Implemented commitments to consolidate the Quality Assurance
- organization and ensure that BFN organizations, managers, and employees share _the responsibility for implementing the Quality Assurance program.
- Instituted a new Employee Concern Program.
- Developed a Plant Performance Monitoring Program.
e Upgrade the Fitness for Duty Program.
- Established a Work Control Group.
TVA's program for improving management control at Browns Ferry was substantial in its impact and caused real change to take place. It was structured to provide continuing follow-up over a significant time period and was intended to support sustained improvements in performance.
The'NRC's July 31, _1990 SER documents the evaluation of the authorities, responsibilities, and-structure of the site organization and the position description.for the managers _and_ supervisors described on the organizational charts. Also reviewed-was the management control system with respect to-planning, release, and tracking of work. The NRC Staff concluded that the resultant Browns Ferry management organization and associated control systems could support the restart and safe operation of Unit 2.
Subsequent to these organizational. changes and the NRC evaluation described abcVe, -BFN wasEreorganized to more effectively manage the operation of BrN-Unit,2_and the. return to service of BFN Units 1 and 3. The Units 1 and 3 Resttrt organization.was established to allow the BFN Operations organization the opportunity to focus on operations and programs at the Browns Ferry Nuclear Plant which: affect the licensing, operations, and maintenance of the units.
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ENCLOSURE 1 BROWNS FERRY NUCLEAR PLANT (DFN)
REGULATORY FRAMEWORK OF Tile RESTART OF UNITS 1 AND 3 (CONTINUED)
The DFN Restart organization providos services to ItFN management for implementing modifications to Unita 1 and 3 based on NRJ rommitments and outablished criteria, using BFN procedures. This includes planning, baselining design requirements and plant configuration, developing required design changos, implementing modifications, and pericrming post-modification testing of systems required for the safe and efficient restart of Units 1 and 3. Personnel with adequete qualifications and experience are assigned to key UFN Restart management positions. Position descriptions were revised or developed to clarify each manager's area of responsibility and establish dCCountability. When the DFH Rostart organization has completed its efforts, the upgraded Units 1 and 3 will be turned over to DFN Operations.
In order to assure that the DFN Restart mar.ngers 3nd their organisations have a clear assignment of responsibility, authority, and to define lines of communication between DFN Operations and BFN Rostart, Site SLandard Pract ice (SSP) 1.51, Unit 1 and 3 Restart Administration and Control, was issued. Excerpted from this procedure is the attached Figure 1. Figure 1 represents the responsibilities between the organizations and their vorking relationships.
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The positions of Rostart Licensing Manager, Restart operations Manager, Restart Engineering Managor, and Restart Project Procedures Manager are matrimed to the Vice President - Browns Ferry Restart (VP-DTR). In this organization, they receive technical direction from their respective B owns Ferry Operations managers and are responsible to the VP-BPR for budget, performance, and schodule. The Ecstart Engineering Manager receives technical requirements and criteria from DFN Operations Engineering ar.d is responsible for the implementation of the requiromonts and criteria. The Rectart Quality Managet reporte dirnetly to, and roccives technical direction from, Site Quality Managor. Ito is responsible for budget, performance, and schedule to Site Quality and communicates directly to the VP-UFR on quality related metters.
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i ENCLOSURE 1 ' " # " ,
BROWNS FERRY NUCLEAR PLANT (BFN)
REGULATORY FRAMEWORK OF THE RESTART OF UNITS 1 AND 3 (CONTINUED) i t
l In summary, ti.e. management deficiencies which led to the voluntary shutdown of ;
Browes Ferry _were corrected at the corporate level prior to the restart of l Sequoyah and at the dite level prior to the restart of Browra Ferry Unit 2.
The BFN Restart organization was. established ;
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- 1) As a special pruject within the DFN site organisation with clear -
assignmente of responsibility and authority.
- 2) To relieve Browns Ferry Operations of most of the day to day Units 1 and 3 restart responsibilities and to allow them to concentrate on safe and efficient operation of Unit 2.
The corrective actions implemented to resolve the Browns Ferry site specific-management problems have not been diluted by the implementation of the BFN l Restart organisation. -The management issues raised in the NRC's r September 17, 1965 letter are closed for all Browns Ferry units. TVA has ,
committed to provide the NRC Staff with annual updates of.the topical report which describes the TVA Nuclear Pover organization. Future NRC staff review ;
of management issues at Browns Fe,.ry_should be addressed through review of thdt document and the norma 1' systematic Assessment of Licensee Performance process. ,
ppgIntional Readiness 4
The overall goal of the. operational readiness assessment program for Unit 2 was to establish:a'high degree of confidence that the plant and personnel were ready.to restart and operate Unit.2 in a safe and reliable manner. The operational readiness -)rogram had three distinct parts:
- 1) A site managed operational readiness assessment,
- 2) .An independent corporate operational readiness review, and
-3) A senior Management Assessment et Readiness Team (SMART) review which was directed by corporate management.
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s ENCLOSURE 1 # ' " #" i BROWNS FERRY NUCLEAR PLANT (BFN)
REGULATORY FRAMEWORK OF THE RESTART OF UNITS 1 AND 3 (CONTINUED) ,
The BTN Unit 2 Power Ascension program is in progress and is being closely monitored by the restart organization in order to incorporate lessons learned into the process for the restart of Unito 1 and 3. Within ntnoty days after the Unit 2 power ascension program is completed, TVA will submit to NRC a Units 1 and 3 operational readiness program description. This submittal will includes-
- 1) An outline of the program which will be used to transfer Unit 3 to Browns Ferry operations.
- 2) A review the Unit 2 operational readiness program to identify lessons learned which would improve the Unit 3 restart process, and t
- 3) -Identify th1 an1f, independent-TVA, and outside (such as INTO and ,
ANI) assessments, procedures, programs, and management reviews and '
approvals which will constitute the Units 1 and 3 operational readiness assessment.
CONCLUSlQN_S The regulatory framework for the restart of Unit 2 was unuoual. TVA's submittal of the Browns Ferry Nuclear Performance Plan and NRC's review and issuance of Safety Evaluation Reports for each individual program was atypical. While this level of NRC involvement did result in added confidence for the approval of Unit 2 restart, it required significant TVA and NRC :
resources to negotiate the approval of individual programs and criteria. In most cases,-TVA began the implementation of these programa "at risk", which meant prior to NRC approval. Significant redesign and addition..
modifications were required whenever the criteria was changed during the approval process.
. - . - - - ~ - . - . - - . . - - - _ . - - - . - . - - - -
(
- ENCLOSURE 1 *8' '"
BROWNS FERRY NUCLEAR PLANT (BFN)
REGULATORY FRAMEWORK OF THE RESTART OF UNITS 1 AND 3 (CONTINUED)
TVA's proposed overall regulatory framework for the restart of Units 1 and 3 is consistent with normal industry practice. The proposed program will establish a high degree of confidence that the facility and personnel are
- ready to restart and operate Units 1 and 3 in a safe and reliable manner, and '
promote the-efficient utilization of TVA a;.d NRC resources. TVA's plans for the restart of Units 1 and 3 ars' based on the corrective action programs, i
- commitments, technical apecification improvements, and internally idertified deficiencies and concersa which were resolved prior to the restart of Unit 2. j TVA has begun detailed nalkdowns of Unit 3 and has made several submittals l which defined nr.d just'fied deviations from the Unit 2 precedent for these !
BFNPP special programs. Expeditious NRC review and concurrence with this ,
proposed overall regulatory framework is requested in order to proceed with j the resolution of the detailed criteria, programmatic, and compliance issues, i
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, l 1
ENCLOSURE 1 - TABLE 1 !
BROWNS FERRY NUCLEAR PLANT i UNITS 1 AND 3 RESTART COMMITMENTS OR REGULATORY ISSUES {
The following is.a list of previous commitments or regulatory issues which I will be resolved prior to the restart of Units 1 and 3. This list ine.iudes j HUREG-0737 Action Items, Bulletins, Generic Letters, Unresolved Safety Issues, '
Generic Safety Issues, Hulti-Plant Action Items, and other regulatory reqeirements.
HUREG-0737 (THI Action Plan) Action Itemet Item I.D.1 - Control Room Design Review (Sare.., Significant (Category 1 and 2)
Human Engineering Deficiencies (HEDs) and those additional HEDs which were required for Unit 2 restart) ,
Item I.D.2 - Safety Parameter Display Console I L
Item II.B.3 - Post-Accident Sampling System i
f Item II.E.4.2.1 Containment Isolation Dependability - Implement Diverse Isolation l
Item II.E.4.2.6 - Containment Isolation Dependability - Containment Purge 1 Valves (Unit 3 only - Unit 1 Previously Completed)
Item II.F.1.2.A - Accident - Honitoring - Noble Gas Monitor Item II.F.1.2.B - Accident - Monitoring - Iodine / Particulate Monitor Item II.F.1.2.C - Accident - Monitoring - Containment High Range Radiation Monitor Item II.F.1.2.D - Accident - Honitoring - Containment' Pressure (Unit 3 only - i
-Unit 1.Previously Completed) ;
Item II.F.1.2.E - Accident - Monitoring - Containment Water Level (Unit 1 '
only - Unit 1 Previously Completed) i Item II.F.2.4 (Generic Letter 84-23)~ Instrumentation for Detection of Inadequate Core Cooling i Itee II.K.3.13 - HPCI/RCIC Initiation Levels
-Item II.K.3.18 - ADS Actuation Modifications.
i Item II.K.3.28 - Qualification of ADS Accumulators v
t _ _ _ . _ . . __ _ _ . . _ _ _ _ _ _ . . _ . _ . _ _ . _ . _ _ . _ _ _ _ . . .
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Page 2 of 5 ENCLOSURE 1 - TABLE 1 (CONTINUED)
BROWNS FERRY NUCLEAR PLANT UNITS 1 AND 3 RESTART COMMITMENTS OR REGULATORY ISSUES Bulletins (B):
TVA has reviewed the Bulletins which were addressed during the current Unit 2 ottage. The following list includes those Bulletine which TVA will complete prior to restart of Units 1 and 3:
B 79 Pipe support Base Plate Designs Using Concrete Expansion Anchor Bolts
- B 79-12.- short Period scrams at BWR Facilities B 79 seismic Analysis for As-Built safety-Related Piping systems B 79 Audibility Problems B 80 Engineered safety Feature (ESP) Roset Controle B 83 Electrical Circuit Breakers with an Undervoltage Trip Feature in use in safety-Related Applications other that the Reactor Trip system B 84 Failures of General Electric Type HFA Relays in Use in Class 1E safety systems B 86 static "O" Ring Differential Pressure switches B 88 Inadequate Latch Engagement in HFA type Relays Manufactured by General Electric Company
'B 88 Power oscillations in-Boiling Water Reactors B 90 Loss of Fill 011-in Rosemount Transmitters
= _
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Page 3 of 5 ENCLOSURE 1 - TABLE 1 (CONTINUED)
BROWNS FERRY NUCLEAR PLANT UNITS 1 AND 3 RESTART COMMITMENTS OR REGULATORY ISSUES Generic Letters (GL):
TVA has reviewed the Generic Letters which were addressed during the current Unit 2 outage. The following list includes those Generic Letters which TVA will complete prior to restart of Units 1 and 3 :
. GL 82 Instrumentation to Follow the Course of an Accident - Regulatory Guide 1.97 GL 83 Modification of vacuum Breakers on Mark I containments (open on Unit 1 only)
GL 83 Salem ATWS GL 83 NUREG-0737 Technical Specifications CL 88 NRC Position on ICSCC in b h Austenitic Stainless Steel Piping GL 88 Radiation Embrittlement of Reactor Ves'21 Materiale and its Impact on Plant Operations GL 88 Instrument Air supply System Problems Affecting Safety-Related Equipment GL 88 Initiation of the Individual Plant Examination for Severe Accident Vulnerabilities GL 89-06'- Safety Parameter Display System - 10 CFR 50.54(f)
GL 89 Safety-Related Motor-Operated Valyc Testing and Surveillance.
~GL 89 Service Water Systems Problems Affecting Safety-Related Equipment GL 89-16.--Installation of a Hardened Wetwell Vent GL 89 Request Nr Action Related to Resolution of Unresolved Safety Issue A-47, " Safety Implication of Control Systems in LWR Nuclear Power Plants", Pursuant to 10 CFR 50.54(f)
. -..-~ . .. ~ - . - - . . - - - . - - ~ ~ - - . . - . - . . . . . - . . - . - . - . _ - . . . - . - -
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Page 4 of 5 i
ENCLOSURE 1 - TABLE 1 (CONTINUED) '
l BROWNS FERRY NUCLEAR PLANT UNITS 1 AND 3 RESTART COMMITMENTS OR REGULATORY ISSUES Unresolved Safety Issues (USIs) (Associated Multi-Plant Action Item (MPA)):
The- following list of USIs which TVA will complete prior to restart of Units 1 and 3:
USI A-7 (MPA D-01) - Mark I Long-Term Program l
USI A Anticipated Transients Without Scram (10 CFR 50.62) )
USI A-24 (MPA B-60) - Qualification of Class IE Safety-Polated Equipment.
USI A-36 (MPA C-10) - Control of Heavy Loads Hear Spent Fuel Pool USI A-42 (MPA B-05) - Pipe Cracks in Boiling Water Reactors :
USI A Station Blackout [10 CFR 50.63)
USI A-48 (MPA A-19) - Hydrogen Control Measures and Effects of Hydrogen Burns Generic Safety. Issues (CSIs) [ Associated Multi-Plant Action Item (MPA)] ~
The following list of CSIs which TVA will complete prior to restart of' Units 1 and 3 '
Safety; concerns Associated with Pipe Breaks in the BWR Scram System CSI 41-(MPA B-058) - BWR Scram Discharge Volume System CSI 43 (MPA B-107) - Reliability of Air Systems CSI 51 (MPA L-913) -
Improving the Reliability of Open-Cycle Service.. Water Systems 9
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l Page $ of 5 ENCLOSURE 1 - TABLE 1 (CONTINUED)
BROWNS FERRY NUCLEAR PLANT UNITS 1-AND 3 RESTART COMMITMENTS OR REGULATORY ISSUES-Multi-Plant Action Items (Not Previously Listed):
l The following is a list of MPAs which TVA will complete prior to restart of l Units 1 and 3 r
MPA A-01.- 10 CFR 50955A(G) --Inservice Inspection ,
i MPA A 10 CFR 50, Appendix J - Containment Leak Testing HPA B 10 CFR 50,_ Appendix R - Fire Protection ,
i MPA C Control of Heavy Loads - Phase I (NUREG-0612) l Other Programs:
{
The following regulatory requirement will also be con;pleted prior to the I restart of Units 1 and 3:
10 CFR 55.45(B)(2)(III) and (IV) - Plant Simulator v
v
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a e ENCLOSURE 1 - TABLE 2 BROWNS FERRY NUCLEAR PERFORMANCE PLAN (BFNPP) SPECIAL PROGRAMS j
I COMPLETED ON UNIT!i 1. 2. AND 3 Heat Code Traceability Secondary Containment Penetrations
' Wall Thinning Assessment Program (Pipe Erosion / Corrosion)
Welding-UNITS 1 AND 3 IMPLEMENTATION IN ACCORDANCE WITH THE UNIT 2 PRECEDENT Cable Ampacity l
~ Cable Tray Supports ,
Component.and Piece Part Qualification Containment Coatings control Rod Drive (CRD) Insert and Withdrawal Piping Design Calculations Review Environmental Qualification ~l Flexible Conduits Fuses HVAC Duct Supports ;
Intergranular Stress Corrosion Cracking (ICSCC) ,
Large Bore Piping and Supports (Bulletins 79-02 and 79-14)
Hiscellaneous Steel Frames j Moderate Energy Line Break (MELB) !
Platform Thermal Growth Probabilistic Risk Assessment Q-List Seismic Class II Over Class I / Spacial System Interactions and Water Spray Splices Thermal overloads l
- ...- - .- -.. .... -- - . -- - . . - . . . - - - - . .~. -.- . - - . . . ..
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. l Page 2 of 2 l
ENCLOSURE 1 - TABLE 2 (CONTINUED) l BROWNS FERRY NUCLEAR PERFORMANCE PLAN (BFNPP) SPECIAL PROGRAMS - i UNITS 1 AND 3 PROGRAMS WHICH DEPART FROM THE UNIT 2 IMPLFMENTATION PRECEDENT l Cable Installation (Including cable separation) i Conduit Supports configuration Hanagement / Design Baseline I Instrument Tubing Instrument Sensing Lines
- Long Term Torus Integrity Program-Restart Test Program '
Small Bore Piping UNITS 1 AND 3 PROGRAMS WilICH DEPART FROM THE UNIT 2 CRITERI A PEECEDENT ,
Fire Protection / 10 CPR $0, Appendix R Lower Drywell Platforms and Miscellaneous Steel i.
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I ENCLOSURE 1 - FIGURE 1 BROWNS FERRY NUCLEAR PLANT OPERATIONS AND RESTART ORGANIZATIONS INTERFACE CHART ,
VICE-PRES !
, ~
VICE+RES BFN ,
BFN OPERATIONS 1 SERytcES TO RESTART stTE FOR RESTART
. RESTART MANAGER QA UCENSW3 SU RT EN38NEERIN3 g
pg MANAGER SERVICES i RESTART BECHTEL QA ale i
RESTART ;
MOOFICATION UCENWNG CONTMACTOR ,
I r GENERAL RESTART ELECTRIC OPERATIONS
$ 1
- " RESTART ENGINEERING PR M CT
- OCEDURES ,
PLANNWG/S SCHEDUUNG/ 3,g NPLEMENTATION ENGDEERWG ,
i
- RESPONS18UTIES ,
TECHNICAL l
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l ENCLOSURE 2 BROWNS FERRY NUCLEAR PLANT
SUMMARY
OF COMMITMENTS
- 1) In accordance with the Unit 2 precedent, TVA will not restart Browns Ferry Units 1 or 3 without prior NRC approval.
- 2) TVA will provide notification to NRC when the restart connitments or regulatory issues in Table 1 are implemented on Units 1 and 3.
- 3) Within ninety days after the Unit 2 power ascension program is completed, TVA will submit to NRC a Unito 1 and 3 operational readinhas program description.
- 4) TVA will review the pre-restart changes made to the Unit 2 technical specifications but not incorporated into the Unit 3 technical specification. TVA will propose technical specification amendments to incorporate those changes into the Unit 3, and Unit I where possible, technical specifications.
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