ML20236F780
| ML20236F780 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 10/28/1987 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8711020292 | |
| Download: ML20236F780 (7) | |
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10.S.'Nuciear. Regulatory Commission
. ATTN:. Document Control Desk-Washington, D.C.
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-Gentlemen:
In the Matter of
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Docket Nos. 50-259 Tennessee. Valley Authority
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50-260-
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50-296 BROWNS FERRY. NUCLEAR PLANT (BFN) UNITS 1, 2, AND 3 - NRC INSPECTION REPORT-NOS. 259/87-22,~50-260/87-22, AND 50-296/87 RESPONSE TO NRC CONCERNS This letter is to provide.TVA's response to NRC's concerns regarding the authorization and performance of. unapproved work.
These concerns were expressed to.TVA in a' letter from G. G. Zech to S. A. White dated August 24,.1987, which transmitted the subject report.
i provides background information and TVA's response to NRC concerns raised in.the subject report.
Subsequent to the 1983 incident,.BFN initiated a policy of strict compliance to-procedures and initiated training _for all. site personnel stressing regulatory compliance. Also, the Modifications process has been greatly strengthened since 1983 when these events occurred. Modifications places procedural compliance ahead of the production schedule, and all Modifications management, engineers, craftsmen, and craft supervision understand this policy.
1 TVA's Employee Concern Program (ECP) has been established to ensure all employee concerns are handled in a timely manner.
We believe the combination of an improved Modifications program and an effective ECP will prevent a j
-reoccurrence of the events that led to NRC's concerns.
I B711020292 871028' j
PDR ADOCK 05000259 t
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{l An Equal Opportunity Employer i
OST 281987 U~S. Nuclear Regulatory Commission A: list of commitments is provided in enclosure'2. We.do not recognize any
.Other items described herein 'as comitments.
Please refer any questions to M. J..May at (205) 729-3566.
iTo'the best of.my knowledge,'I declare the statements contained herein are
. complete and true.
Very truly yours,
..TENNES EE VALLEY AUTHORITY
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R.
ridley,.
rector Nuclear Lice sing and Regulatory Affairs
--i Enclosures cc (Enclosure):
Mr. G. G. Zech, Assistant Director
' Regional Inspections Division of TVA Projects Office of Special Projects U.S. Nuclear Regulatory Commission Region II j
101 Marietta St., NW, Suite 2900 i
Atlanta, Georgia 30323 j
Browns Ferry Resident Inspector Browns' Ferry Nuclear Plant P.O. Box 311 Athens,-Alabama 35611 Mr. J A. Zwolinski, Assistant Director
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~for Projects Division of TVA Projects Office of Special Projects U.S. Nuclear Regulatory Commission l
l 4350 East West Highway EHH 322 l-
.Bethesda, Maryland 20814 1
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ENCLOSURE 1-BROWNS FERRY NUCLEAR PLA[NT (SFN)
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m NRC INSPECTION REPORT NOS. 50-25'9/87.22
'1 50-200/Q7-22 AND 50-296/87-?2 y LETTER 7RGA O. G. ZECHaTO S. A.' WHITE:
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JDAlE0. AUGUST?$,31987-
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SUMMARY
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A former BFN steamfi_tter foreman made'several allegations about-l safety-related activities-during-torus modification Vork in 1983.
One
.of-these allegations concerned work which had been tothorized and
- pErforikdusingunapprovedworkplans.
This wa's folldwed up by two TVA g
1,n h1gatigs, both of which concluded that ?Als allegation was correct.
itq second TD investigation verified that th$ old supports on a 40-foot-
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'jection of Reskdual Heat Removal (RHR) pipink hefehached before the
' approval of a workplan.
However, there wu dWritten or confirmable evidence to indicate that the old hanger & Wre' remon d while this RHR l
' loop was in service.
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LThr Modif/cptions process has been greatly strengthened since 1983 when these events occurred. Modifications philosophy places-importance on procedural cor.pliance ahead.of production schedulec.. This"is ' emphasized i'
from mariagement down' the line to all employees. - Modifications' procedures 3 I
are much more prescriptive than when these events occurred.
Strict.
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controls on the r h oval of pipe qupports as well as any wo d on safety-related equipment are in. place andrenforced.
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.TheRegulatory,PerformanceImprovement%!an(RPIP)programinitiated
'l regulatory coinpliance t aining for' all epployees including special 1
classes with more fetaihd instructions for supervisors (craft and engineering). 'As a resuir of this management emphasis on strict compliance with procedury,4?w worA controls were put into plack and andcomponents.,orkplyngwritte3,fFworkon' safety-relatedequipment more descriptive w JTVA initiated efforts fp impbyd the handling of employee concerns in' 1985. As a result, TVMs ECP was begun in February 1986.
This program i
established a numbei cf methods for receiv5ng employee concerns through.
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)the case of ECP and IG, confidentiality p[A Inspector General (IG).
supervision and maragement, ECP, or the !
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ovisions have been provided.
These methods provide an atmosphere where emp pyees m6y' express concerns without fear of reprisal.
We believe this has improved employees'
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-confidence in TVA's willingness to receive and resolve employee concerns j
in-house and without threat of recrimination.
Therefore' problems of i
this, type should be acted on more expedi,tiously and re olved in a timely p
manttr.
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TVA b ves the combination of t% se factors will prevent h reoccsi ence 3f eYents that led t(/ these concerns.
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ll II. ' BACKGROUND
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4 As a result of the BFN RPIP, there was a large reduction in force of BFN j
Modifications craftsmen in January 1984. A former steamfitter foreman, terminated in this reduction in force, met with a BFN Quality Control (QC) supervisor on August 1, 1984, and told him of several concerns he i
had involving safety-related activities at BFN. Among them was a i
concern that during' torus modifications in 1983, work had been
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authorized.and performed using unapproved workplans, contrary to j
-procedural requirements.
Based on this information, the QC supervisor began ~an investigation.into the allegations.
The'QC supervisor concluded.that some of the allegations did have' merit.
As-a result of the allegations and the QC supervisor's investigation,:the BFN Site Director requested the Nuclear Safety Review Staff (NSRS) to perform an investigation into the allegations.
The
' investigation was completed on October 19, 1984, and a report (NSRS Report No. I-84-30-BFN) was issued on December 7, 1984.
The report concluded,'among other things, that work on Category I supports had been performed without proper authorization.
Unresolved. item (URI) 85-07-01 (adequacy of actions taken with regard to y
allegations concerning Category I supports) was opened pending further i
investigation by TVA.
The resolution of URI 85-07-01 was taken as a personal action item by the BFN Plant Manager.
However, he left BFN
-site in July 1985 with no action having been taken.
Meanwhile, the Modifications manager in place at the time thought the NSRS would be 'doing a follow-up investigation to their December 7,1984 i
report.
Because of a change of personnel and organizational requirements, the follow-up investigation was not done.
Therefore, the Modifications manager requested the TVA ECP, which had been started in February 1986,.to perform a follow-up investigation on problems associated with Category I supports as identified in NRC Inspection Report 85-07 and NSRS Report I-84-30-BFN.
This led to the eventual resolution of this item.
III. RESPONSE TO NRC CONCERNS
'NRC unresolved item 85-07-01 was opened to track the adequacy of TVA's
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actions taken with regard to allegations concerning Category I pipe supports.
Following the completion of TVA's investigation of these employee concerns which was documented in the ECP report, NRC Inspection Report 87-22 was issued.
This report summarizes your inspector's conclusions following a review of the ECP report.
This inspection report raised concerns about' performance of unauthorized work, l
timeliness of TVA's corrective actions, and the adequacy of Modifications' response to the ECP. report.
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Concerning the apparent unauthorized work,.TVA concluded that a general foreman violated TVA procedural requirements given in BFN Standard Practice BF'8.3, by having work performed before associated workplans were approved. This occurred in 1983 during torus' modification work..
However, shortly after this incident, the'RPIP. program was initiated and
.a new emphasis was placed on strict compliance to procedures.
Training was accomplished for all managers and supervisors to monitor work in the plant for regulatory compliance.
The Division of Nuclear Construction assumed responsibility for the Modifications activities at BFN in. June 1986. Modifications was previously under the direction of the BFN Site Director.
This resulted in a series of reorganization moves, one of which involved the general foreman involved with this work. General foremen are now directly responsible to craft supervisors who in turn report.to a Modifications section supervisor.
This provides more consistent and higher level supervision to general-foremen than was available in 1983.
.The general-foreman in question has been placed in a position which utilizes his technical knowledge but removes him from direct line supervision. A letter documenting the counseling he has received about the; errors made in performing unauthorized work has been placed in.his personal history record.
The philosophy of Modifications.now clearly. places procedural compliance j
- foremost.in managers' minds and ahead of production goals.
Procedural
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. compliance is' emphasized by the BFN Modifications manager at his staff meetings with instructions to' pass it down the line to all employees.
With regard to the lack.of timeliness of corrective action, TVA' agrees deficiencies.did exist in this particular instance.
The root'causes of
- 4 the timeliness problems were numerous management changes at BFN and.
reorganizations in the Office of Nuclear Power. As previously stated, l
the BFN Plant Manager who took URI 85-07-01 as an action item was replaced in July 1985 and adequate follow-up was not initiated to resolve the URI. Also as pointed out in the Nuclear Performance Plan, Volume 3,Section II.1.2.7, Site Licensing was formed to resolve the i
problems caused by lack of TVA attention "to aggressively pursue resolution of pending or unresolved issues" with NRC.
Presently, all
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NRC report findings as well as NRC's daily concerns are pursued to ensure resolution.
The management structure at BFN is now stable including new Modifications management.
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During the time-the allegations were made, there was no program in place j
l-to resolve employee concerns in a timely manner.
established in February 1986 because of past problems with confidentiality when employees expressed concerns and to ensure that.
concerns.were resolved in a timely manner.
This program established a:
1 inumber of methods for receiving employee concerns, for example, through supervision and management, ECP, or the TVA IG.
In the case of ECP.and IG, confidentiality provisions have been provid.ed and the BFN ECP has a i
staff dedicated to resolving employee concerns in a timely manner.
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Concurrent with the Modifications response to the ECP report for unapproved work being done on unit 1 RHR pipe, the Watts Bar Employee Concern Task Group (WBN ECTG) issued a similar report involving an employee concern related to unit 3 RHR piping.
The person responding to the ECP report was familiar with the WBN ECTG report involving the unit 3 RHR system.and erroneously concluded both reports referred to unit 3.
For this reason, the response from the Modifications Group to the ECP j
report incorrectly referred to corrective actions for the unit 3 RHR.
piping.
The following actions have been taken to address NRC concerns on the incorrect disposition of the ECP report:
'l Modifications now' reviews each employee concern thoroughly for-subject and scope.
Responses to employee concerns also receive an engineering review for technical content before submittal to the Modifications Manager.
Modifications has initiated Condition Adverse to Quality Report (CAQR) to address possible damage to the unit 1 RHR piping that may.
have occurred as a result of actions described in the ECP report.
The Modifications response to the ECP report was revised and now references the CAQR.
The Division of Nuclear Engineering (DNE) is evaluating the segment of the unit 1 RHR piping and supports discussed in the ECP report to determine potential damage resulting from the alleged adverse
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condition.
Potential pipe overstress and the effect on adjacent i
supports from load redistribution will be determined.
The effect of 1
additional spring support deflections on pipe and supports will be evaluated.
These evaluations will be completed by November 2, 1987.
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. ENCLOSURE 2 l]
LIST.0F COMMITMENTS MADE IN ENCLOSURE l'
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- DNE:is:evaluatingithe segment of the unit 1 RHR piping and supports discussed l
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' in the~ECP' report-to determine potential damage resulting fromLthe alleged adverse-condition, Potential pipe overstress and the effect on adjacent supports'from-load redistribution will be determined. The'effect of' y'
additional' spring. support ~ deflections on pipe and supports will be evaluated.
.These evaluations will be completed by November 2, 1987.
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