ML20247R156
| ML20247R156 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 07/19/1989 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 8908070372 | |
| Download: ML20247R156 (116) | |
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j TP.AHSMITTAl. TO: Document Control Desk, 016 Phillips
- ADVANCED COPY TO: The Public Document Room l DATE: #[3 1 vi i l FROM: SECY Correspondence & Records Branch
.I I Attached are copies of a Commission meeting transcript and related meeting l, document (s). They are being forwarded for entry on the Daily Accession t.ist and l
placement in the Public Document Room. No other distribution is requested or j required.
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t . %^ 3 D UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMIS SION '
r ff(1$l BRIEFING O'.' STATUS OF BROWNS FERRY-2 ROCKVILLE, MARYLAND LOCatiOII: ..
Nte: JULY 19,.1989 Pages: 56 PAGES NEALR.GROSSANDC0.,INC.
covat acrontras Awo taANSCRISER8 1323 Rhode Island Avenue, Ecrthwest Washington, D.C. 20005 (202) 234-4433 l \ ,. '
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@ DISCLAIMER This is an unofficial transcript of a meeting of the United states Nuc1sar Regulatory Commission held on July 19, 1989 in the Commission's of fice . at One White Flint
- North, Rockville, Maryland. The meeting was
. open to public attendance and observation. This transcript has not been reviewed, consct ed or edited, and it may contain inaccuracies.
The transcript is intended solely for general
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3 informational purposes. As provided by 10 CFR 9.103, it is not part of the formal or informal record of decision of the matters discussed. Expressions of opinion in this transcript do not necessarily reflect final determination or beliefs. No pleading or other paper may be filed with the Commission in any' proceeding as the result of, or o
addressed to, any statement or argument contained herein, except as the Commission may authorize.
s e-NEAL R. GROSS court REPORTERS AND TRAMSCRisFRS 1313 RHoDE ISLAND AVENUE, N.W.
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UNITED STATES OF' AMERICA
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!1p BRIEFING ON STATUS OF BROWNS FERRY-2 PUBLIC HEETING Nuclear Regulatory Commission One White Flint North Rockville, Maryland I
i Wednesday, July 19, 1989
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The Commission met in open session, pursuant l to notice, at 2:30 p.m., Kenneth M. Carr, Chairman, presiding. 'I i
COMMISSIONERS PRESENT:
i KENNETH M. CARR, Chairman of the Commission THOMAS M. ROBERTS, Commissioner l KENNETH C. ROGERS, Commissioner ,,
JAMES R. CURTISS, Commissioner s
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.a STAFF'AND PRESENTERS SEATED'AT' THE COMMISSION TABLE:
. j..~, SAMUEL J. CHILK, Secretary
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WILLIAM C. PARLER, General. Counsel OLIVER'D. KINGSLEY, JR., Sr. V.P., TVA OSWALD J. ZERINGUE, Site Director, Browns Ferry HENRY WEBER, . Engineering & Modifications Restart Manager, TVA DR. MARK O. MEDFORD, V.P. & Nuclear Director, TVA RON SMITH, Project Engineer,' Browns Ferry.
GUY CAMPBELL, Plant Manager, Browns Ferry JAMES TAYLOR, Deputy-Executive Director for Operations THOMAS MURLEY, Director, NRR DAN CARPENTER, Senior Resident
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DENNY CRUTCHFIELD, Associate Director for Special N -
Projects i
JERRY GEARS, Senior PM for Browns Ferry 1:
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3 CHAIRMAN CARR: Good afternoon, ladies and 4 gentlemen.
5 The purpose of today's meeting is for the 6 Tennessee Valley Authority and the NRC staff to brief 7 the Commission on the status of Browns Ferry Unit 2 8 relative to its readiness to restart after a four year 9 shutdown.
10 The Commission was last briefed on the 11 subject of TVA organizational changes in Browns Ferry 12 Plant status by TVA on June 21st, 1988.
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13 Copies of the slide presentation and the s .-
10 related staf f ' paper presented to the Commissien for 15 information, SECY-89-207, should be available at the 16 entrance to the meeting room.
17 Do my fellow Commissioners have any opening 18 comments?
19 COMMISSIONER ROBERTS: I have an irreverent 1
20 comment, not about this meeting and this is sort of an 21 inside joke, but I want to make sure all of my fellows 22 have the necessary equipment to perform their job j 23 properly, at least as our principal Senate oversight ,
24 committee sees it. That's a Mark I, Mod O matchbook. 1 l
J 25 COMMISSIONER ROGERS: So we can communicate NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W-WASHINGTON, D C. 20005 (202) N (202) 232-6000 l
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.2 CHAIRMAN CARR: And now we need a cup . of.
3 coffee, right?
- 4. Any other comments? ,
5 Mr. Kingsley, you'r.ay proceed.
6 MR. KINGSLEY:. Thank you very much, Chairman 7 Carr.
I 8 I,'d like to start today's meeting and 9 introduce the management team that we have at Browns 10- Ferry, starting with Ike Zeringue, who is- the Site l
l 11- Director, here on my left. He came to us as plant 12 manager from'Palo Verde 3. Prior to that, he had all 19 technical. support for all three units at the Palo
'14- Verde Nuclear Power Plant. ,
In addition to that, Ike 15 has been involved in some ten startups on a number of
.16 different plants, BWRs and pressurized water reactors.
17 To Ike's left we have the Plant Manager, Guy 18 Campbell.. Guy Campbell comes to us from Carolina -
19 Power and Light. He was licensed on the boiling water 20 plant there, Brunswick Plant. 'After he left there, he 21 went to' the Sharon Harris Plant where he was .
22 maintenance superintendent, all the way through the 23' restart, joined us and was named Plant Manager last 24 summer.
., 25 We have Henry Weber. He came to us from t-v, NEAL R. GROSS COURT REPORTERS AND TRAN$CRISER5 1323 RHoDE ISLAND AVENUE, N.W.
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'l Bechtel. He's our Engineering and Modifications i
[ 2 Restart Manager, having principal responsibilities for ]
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some'of those activities at Palo Verde, Grand Gulf. f i
4 He's been involved in some ten startups in nuclear 15 power plants.
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-- 6 Ron Smith came to us from his own private 7 ._ company. Previous to that he'd worked for Gilbert 3 Commonwealth, had been the project engineer for a 9 restart effort on Three Mile Ia, land Unit 1 and carried 10 them through two refuelings, when they put in all the 11 extensive modifications on that unit.
12 And we have Doctor Mark Medford, who just
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13 came to us. He's our Vice President and Nuclear
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10 Technical Director from Southern California Edison, 15 having previous responsibility for their licensing and 16 regulatory affairs.
17 Behind me we have Bus Cobean, who is advisor 18 to the Board. We have Fred Moreadith, who is our Vice 19 President of Engineering, Pat Carrier who is the 20 Browns Ferry Licensing Manager; and Lawrence Martin, 21 who is the Manager of Quality Assurance.
22 I wanted to bring the team. All of us will 23 be happy to answer any questions that you might have 24 today.
b 25 COMMISSIONER ROBERTS: I want to make sure I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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1 understand. All of these people you've just 2 introduced are employees of TVA?
3 MR. KINGSLEY: Every person, with the 4 exception of Mr. Cobean, who is advisor to the Board.
5 So, he would be a contractor. But everybody else is a 6 full-time employee of Tennessee Valley Authority.
7 COMMISSIONER ROBERTS: Thank you.
8 MR. KINGSLEY: (Slide) I'd like to go on 9 now to slide number 2 and talk a little bit about the 10 agenda. I'm going to talk about the recovery program 11 status. Ike Zeringue will talk about the site and how 12 we're doing. Henry Weber will talk about technical 13 issues and I'll do the summary and conclusions.
14- (Slide) Slide 3, the purpose of this visit 15 is, of course, to talk about the recovery program .rl th 16 specific emphaais on the Unit 2 restart preparations.
17 (Slide) On Slide 4, I would like to have 18 just a little bit of history. You gave some of this, 19 Chairman Carr. 3 20 The Unit 2 was shut down for refuelling in 21 March of 1985. We filed the overall corporate 22 recovery program in March of 1986, followed that in 23 August of 1986 with Volume 3 of the Nuclear 24 Performance Plan. There have been a number of l i
1 25 meetings with the full Commission, principally for the I I
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1 restart efforts on Sequoyah Units 1 and Unit 2. The j l
[ 2- other milestone here that has changed since we've been d
'l 3 with you, in the past we have loaded fuel on the unit.
4 (Slide) Going on now to slide 5, I'm going 4 5 to cover five-principal subjects. We're going.to talk ,
l 6 about..the organization, give you'a progress update on i 7 that. I'm going to talk specifically about what we're j 8 doing about site management. I'm going to talk about 9 operations readiness, I'm going to talk about various 10 programs related to running a nuclear power program 11 and what we're doing about that. And last, I'm going 12 to talk about our project planning and scheduling.
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13 Also, Mr. Zeringue and Mr. Weber will talk h
14' aDout some of ~ these subjects in some detail and be 15 prepared to answer your questions. '
26 (Slide) Moving on now to specifically what 17 I'd like to address is our organizational progress.
18 When I came to TVA, there were a large number of 19 people in acting positions. Since that period of 20 time, we've had these people professionally evaluated.
21 We sat down as management and carefully reviewed them.
22 I'm now happy to repor t that at Browns Ferry we have 23 no principal individuals in acting positions. We do 24 have some approximately 20 at other sites in acting
's 25 positions, primarily at Watts Bar, but we're moving NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W.
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' ' 4' ,: 1 'out;of that situation-also.
'2 When I go t. .t o . TVA , . we had five contract 3 managers filling TVA jobs. We.have now replaced'all 4 of those individuals and we have ' full-time TVA-5 . employees filling those jobs.
6 There was a number of advisors over a period 7 of time that was used. I do not have any advisors. I 8 do have one~ individual who is looking at specific:
1 9 technical problems for'BWR Mark I containments, but I 10 do not have any advisors on my staff.
11 The last item on organizational ' progress 12 that I thought you would be interested in, since it's 1S tied :directly in our ability to attract qualified 14- ,
personnel and ret'ain qualified personnel, is l
15 compensation. We were able to put in an improved l 16 compensation plan, with our Chairman's leadership, in l
17 March and we have used that and will be using that in 18 the future.
19 (Slide) I'd like to move on now to slide 1 20. number 7 and talk a little bit more about our 21 organizational progress. .
22 When I got to TVA and met with a number of 23 the. people, it was very clear to me that I had to 24 stabilize the organization. So, what I did, I went in i
25 and did a very careful review. We tried to do as much NEAL R. GROSS court REPORTERS AND TRANSCRIBER 5 1323 RHOOf ISLAND AVENUE, N.W.
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1 of this from the bottom up as we possibly could. Out 2 of that came out what I call a standardized i
i 3 organization and staffing plan. We have now put that j 4 in place and we have communicated that to the 1
5 organization. 1 6 As far as site personnel at the Browns Ferry {
7 Nuclear Power Plant, in January of 1989 we had 8 approximately 5800 people at that site. These are TVA 9 employees and their contractors. As of today, we have 10 approximately 3900 people. We have reduced that by 11 some 1700 people, 900 TVA employees and 800 12 contractors. It was simply too many people there for 1S us to effectively manage.
14- But I would also like to inform you and 15 state that in the announcements that we made back in 16 April of the long-term staffing goals, what we were 17 doing primarily at Sequoyah and in the corporate 18 support groups, that we excluded the Browns Ferry 19 Nuclear Power Plant from that so there would not be 20 perturbations in this restart effort of going through 21 a massive downsizing. The cuts that we made were 4
22 principally around the first of the year and in the 23 January time frame. So that's behind us there and we 1
24 are not asking Mr. Zeringue or the engineering people 25 to go through any type of downsizing until we get this NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoDE 15 LAND AVENUE, N.W.
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47 ' i , , l' unit back'on the line.
2 .Another key factor in our recovery program 3 and what we've been trying to do with the organization 4 is to ~' clearly -define and increase the focus on j
.j 5 functional responsibilities. 'I've spent a lot of time l 6 -in doing this and I'm talking about what che' engineers ;
7' do, what the modifications personnel do, what the j 8 . plant .staf f ' does and what those relationships are.
9 I'm going to talk a little bit more on some team 10 meetings and. one-on-one . ' meetings that I've 'had to 11 bring that about.
12 Another item that I found in standing back 13 and looking at the organization that needed some 14- improvement was this combination of engineering and 15 modifications. You might ask, "Well, why did you do 16 that?" I found the site director was principally 17 pushing engineering and pushing modifications and did 18 not have sufficient time to focus on the operational 19 side of the house. The key management for the 20 engineering and the modifications groups were located 21 in Knoxville.
22 So, I said, "We have to change this." So, 23 we came in, created a job and put Henry Weber in it. l 24 We now have the engineering hard line to him as far as 25 budget cost and schedule. Mr. Moreadith is still HEAL R. GROSS court REPORTERS AND TRANSCRIBERS 1323 RHODE 1$ LAND AVENUE, N.W.
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.. 1 responsible for the technical integrity and t e.chnical 2 guidelines.- So, we do not deviate across the TVA 3 plants for that. We put modifications there and now 4' this frees up'Mr. Zeringue to of course focus'on the 5 engineering and. modifications, but to also spend the
'6 time and attention on getting that plant ready to 7 operate, which we have is do and. clearly demonstrate 8' to you before'we come back and ask for permission to 9 restart.
10 COMMISSIONER ROGERS: Just before you leave 11 that, I wonder if it's possible for you to say just a 12 little bit about y our philosophy of organization, if 13 it was substantially different from what you acquired 1p when you showed up on site, and to what~ extent this 15 organization is one that has been put together to 16 address getting ready for operation as contrasted with 17 actually operating a plant once it comes on line.
18 MR. KINGSLEY: As far as from a site
'i 19 director standpoint, I thought that there were too 20 many direct reports to the si*,e director. '"here were 21 some dotted lines to the site director that we talked l:
1 22 about and what we've done with that. So we're moving 23 in to correct that so Mr. Zeringue does not have a j 24 large number of reports.
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12 1 seven direct reports reporting to Mr. Campbell. That 2 being maintenance, modifications, technical, a support 3 group, a PORs group, chemistry and health physics. We 4 are moving with a standard model to reduce that.
5 We're. creating an operations manager job. Maintenance 6 will stand by itself. The Radcon will stand by itself 7 and all of' technical support. So we're going to be 8 putting that in. We're essentially there now at 9 Sequoyah. This..is a much more classical organization .
i 10 than what I've had at the Farley Plant and what we've 11 had at Grand Gulf and we're 2:.oving into that.
12 It also will add a good deal of depth within
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13 the organization such that he's got backup people
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14' there to be the on-call duty managar.
15 Classically, how you run these plants is you L
16 have an on-call group, like the Op Superintendent.
17 They're the immediate interface with the main control 18 room and that type of thing. Then you have a higher 19 level of management that you have to put in place.
20 So, these are some of the things that I saw 21 that needed te be changed and we're in the process of 22 doing.that.
23 (Slide) I'd like to move on now to slide 8 24 and talk to you a little bit about site management. A 25 principal job of mine is to get the right people with NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W.
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1- the right' attitude that have'a proven record. I hope u; : ; .
2- to*show you'that we're doing that. We've spent hours 3 ldoing - that. We've had . these people professionally 4 evaluated, as I've talked, and it's vitally important 5 that we.hsve tnis type people to do.this.
6 We're ' emphasizing a very - prof essional r-
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approach, a no nonsense, very thorough, very complete-8 and'it's the only way you can operate these plants and 9 'we're pushing this. We're pushing this in a number of
'10' programs that I'll show you as I get to that.
11 We very clearly define the expectations of.
12- holding line management accountable, putting them in
. 13 charge and very carefully laying out what the support if- functions are to do. Of ' course they're going to 15 assist us in setting policy, but primarily they're 16 going to exist to help these plants solve problems and 17 take that burden off of them for these longstanding or 18 long-tern problems.
19 We've emphasized a lot of accountability. I 20 like to call it what I call the tennis management 21 syndrome effect, something that was very evident to me .
22 in a number of areas and tennis management is where
~23 the ball is in your court'instead of, "I've got that 24 problem and I'm going to get it solved." So, we're 25 continuing to emphasize this and Mr. Zeringue has NEAL R. GROSS COURT RE80RTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W.
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- 1. helped immensely as we have moved 'to eliminate that 1 ,.
I J 2- and create a.better teamwork approach.
'3 (Slide) I'd like to move-on now to slide 9 4 and talk about operational readiness. I have held 5 individual, one-on-one meetings with all site I
6- management - I'm talking down under the plant manager
- 7. Land the site directer s taf f -- to emphasize my' 8 philosophy. We've had a number. of meetings that I j-9 .. personally chaired. where I make assignments, team l
10 meetings, action plans and relationships and then we 11 come back and fellow up on that to see if we get these
! 32 items complete.
L 13 We've established, since I've come aboard, 1[ an_ operations improvement plan. It covers all primary 15 aspects of how you need to operate the plant, who's in 16 charge of.the plant, various aspects of training the 17 people, logging, what have you.
1 18 , We've activated the maintenance improvement 19 program. We had a maintenance improvement program, 20 but we had a very high turnover rate in the 21 maintenance superintendent position So, it was 22 languishing.
1 23 We've established a system engineer .
24 ownership of plant systems.
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1 lcame a number of ' problemt, as you well know. We're
- bi 2 quite embarrassed by the fact of not properly I '3 monitoring the core,.but we've used that as lessons L
4 learned and there are a number of programmatic items l .5 .- that came out of J:. hat.
1 6 We're treating INPO 'a lot more seriously.
7 .A4.one manager told me, it was an occasional 8 acquaintance or relationship. I intend to make this a 9 love affair with INPO because you've got to go by.
10 those criteria. You've got to treat it very
.11 seriously. We're even tracking the responses to'our 12 previous evaluation in our morning meeting that we 4
13 heve.
14' We'v~e completed our operational readiness 15 review, which was a commitment made in volume 1 and 16- Volume 3. The team, which is essentially the group 17 that did Sequoyah, says we're ahead of where Sequoyah 18 was in' 1987, but there's still a lot of work to do 19 there. We'll bring that team back in for a phase II 20 prior to coming back to you people and asking for 21- permission to restart.
22 (Slide) Moving on to slide number 10 here, 23 programmatic progress that we've made, we've changed 24 our incident investigation procedure and we now'have 25 line management versus staff investigating events in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W WASHINGTON, D.C. 20006 (202) N (202) 232-6800
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2 We made significant improvement in our 50.59 l
3 safety assessment program, where we're now <
4 implementing the NUMARC guidelines. We've put 5 additional _ training in for our. people and we've 6 reduced the population of people who can do the safety {
7 assessments. j l
8 We have formalized a number of vendor !
9 interfaces, principally with General Electric Company, 10 where that tie had almost been broken there. General 11 Electric Co':1pany had essentially left the site, except 12 for a couple of people. I started bringing them back
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13 in prior to fuel load. I just wish we'd have hcd a 14' good deal more active involvement on monitoring the 15 core, but they were actually riding the refueling 16 bridges when we loaded fuel there.
17 We've implemented a major upgrade in our 18 operating experience program. We're in the process of 19 re-reviewing all the General Electric service 20 information letters. We're still having to clean this 21 program up, but we now have people at the sites who 22 get this, get it right into line management so we act 23 on this vendor information.
24 (Slide) Moving on to slide 11, our 25 procedures program needed a great deal of work. We NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W WASHINGTON, O C. 20005 (202) N . (202) 232 6600
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17 1- have upgraded our technical review and validation of I
2 procedures. Our original program, particularly in the 3 surveillance instructions and some of the operating 4 procedures was not working. We've increased the user
.5 . involvement in this upgrade process.
6 The last item here is what we call our 7 conditions adverse to quality where we document 8 problems in the plant. We are very aggressively 9 pursuing working out the backlog and promptly 10 resolving issues as they come up instead of having 11 them hang around for a period of a year, 16 months, 12 what have you.
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13 (Slide) I'd like now to shift over to the 14 project planniisg and scheduling progress. We've made 15 significant progress in resolvinj major issues with 16 the NRC staff, which you have in your SECY paper. I 17 think we're there as far as the major technical 18 issues. Now we just have io produce.
19 We developed an integrated startup schedule.
20 We're monitoring this on a 60-day bases. We've also .
21 established a milestone for condenser vacuum, which I 22 think is vitally important that we properly check out 23 the balance of plant on this system in addition to all 24 the primary systems and particularly on a boiling 25 water reactor. 1 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS f 1323 RHODE ISLAND AVENUE, N W. )
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. 1 We are reviewing this schedule progress-on a E ,f '
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' 2' weekly. cycle. Of course there are daily: meetings, but. .
3 I go down at least~once a week where we go into the 4 schedule in depth. We've improved our contract 5 management, which has been a significant problem at r
6 TVA. Mr. Weber will talk about that. We've improved 7 the definition of our task and we are now accepting 8 and holding contractors responsible for delivered' 9 products.
10 This concludes what I have. I'd like to now 11 turn to Ike Zeringue, Site Director, and let him talk 12 more specifically about the site.
13 -
Ike?
14- MR. ZERINGUE: (Slide) Although there's a 15 large-amount of physical work yet to be done at Browns 16 Ferry to prepare the unit for restart, our biggest 17 hurdle is to prepare ourselves and our employees to 18 operate the plant. To do this, we're going-to have to 19 change our organizational culture. We're defensive, 20 we're often inattentive to detail, often protective of 21 our own old ways of doing business, somewhat resistent .
22 to change, and shallow in our investigations and 23 evaluations.
24 , To insure that we establish a safety 25 conscious culture, we're going to have to first HEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVENUE, N.W.
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l' establish expectations, clearly defined expectations.
2 Specifically, management will have to insure that each
- 3. 'of us. takes the time to do each task'right each time 4 we'do it, regardless of the . impact ~ on ' schedule' . or
.5 capacity. factor.
6 - Secondly, we need to be fully prepared for 7 -_each task we undertake. That is, we need to 8 understand enactly what we're intending to do and its 9 impact on the plant, understand exactly how to do it, 10 know exactly what is expected to occur in the plant at 11 each step and be alert for any unusual' response that
'12 we're capable of mitigating it.
~
13 Most importantly, we need to become brutally i .L 14' self-critical in all aspects of plant ~ operation. We 15 need to thoroughly investigate and determine the root 16 cause of any component system f ailure, both NSSSI and 17 BOP.
18 We need to thoroughly evaluate and determine 29 the cause of all events or human arrors, regardless of 20 the magnitude of that error.
21 Finally, management must continually 22 communicate and reinforce expectations through 23- detailed involvement in all plant activities.
24 If we can effectively accomplish this, the 25 employees at Browns Ferry will be both mentally and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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~~ 30 ,
- 1 emotionally ready to operate this. facility in a se.fe, l g,
y 2~ efficient manner. That is indeed our biggest l-
! 3 challenge.
4 (Slide) I'd like to move to the next slide 5- and discuss some of the lessons learned from Sequoyah.
6 CHAIRMAN CARR: What percentage of the way 7 are you through that long. list of things you'va got to 8 do, would you say?
9 MR. ZERINGUE: I don't know, sir, if I can 10 ' weigh it on a percentage basis.
CHAIRMAN CARR: Have you started?
12 MR. ZERINGUE: Yes, we've started and i 13 through our operational readiness review, it's clear 14- that-the expectations have reached the people. Now, I 15 can't sit here and tell you that those expectations
.16 are fully being carried out.
17 CHAIRMAN CARR: But --
18 MR. ZERINGUE: But at this point, they know 19 what is expected.
I 20 CHAIRMAN CARR: As I read you, this, in your 21 opinion, is the controlling path?
-22 MR. ZERINGUE: Yes, sir.
23 CHAIRMAN CARR: Okay.
24 MR. ZERINGUE: In preparing ourselves for 25 operation, we're utilizing the lessons learned, NEAL R. GROSS COURT REPORTER $ AND TRANSCRIBERS 1323 RNODE ISLAND AVENUE, N.W. J WA$NINGTON, D.C. 20005 (202) 232-6600 j (202) 234-4433
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. 1 experience gained at Sequoyah. I'd like to briefly 2 touch on four areas, operations, work control, BOP 3 systems and incident investigations.
4 Our conduct of operations procedure is based 5 on a Sequoyah procedure, the lessons learned there and 6 INPO guidelines. As Sequoyah has done, we've provided 7 professionalism training to all our on-shift operators 8 and, as Oliver has just mentioned, we've had our first 9 phase of our operational readiness review by
. 10 essentially the same team and that will occur again in 11 the future.
12 In the work control area, we're utilizing an 13 integrated work schedule concept to insure that all 1.4- work activities and test activities identified prior 15 to taking the system out of service or maintenance are 16 tested. To support this concept, we now have system 17 evaluators whose function is to identify all work 18 items and evaluate the impact of that work item on the 19 plant and the particular syster. Additionally, we've 20 instituted the position of shift work control manager.
21 That's to provide 24-hour coordination and management 22 overview of work activities in the plant.
23 CHAIRMAN CARR: Is he licensed? I mean has 24 he been licensed?
25 MR. ZERINGUE: Some of them have been NEAL R. GROSS COURT REPORTER $ AND TRANSCRIBER $
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,. 1 licensed, not all of them.
l .' 2 Oliver mentioned that it's our intent to l
3 increase our emphasis on the BOP side of the plant.
4 In order to do this, we're maximizing the testing we 5 can do prior to restart en the secondary site. As an 6 example, our condenser vacuum evaluation and vacuum l
l 7 pull.
8 We're instituting what we refer to as our 9 SPOC process. That's a system operability check list.
10 It establishes the engineering baseline for the 11 system, assures system integrity, verifying all 12 maintenance, modification and testing activities are l
l'3 complete and it verifies the configuration of the 1.4- system and places that system under our configuration 15 control processes. We're doing this not only on the 16 NSSSI but on the BOP side as well.
17 The fourth area I'd like to discuss is 18 incident investigations and that goes back somewhat to 19 the culture we're trying to establish. We want to 20 initiate incident investigations at a very, very low 21 threshold, so we ca'n stop problems when they're little 22 problems and prevent them from becoming big problems.
23 We're using clearly defined processes, accepted root 24 cause techniques as a part of this program.
25 The program also requires that the senior NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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e * ,
- 4 23 1 management be notified of all events. That's V.P. and 2 Senior V.P. level. Additionally, line management is 3 assigned responsibility for the completion of these 4 event investigations, clearly to insure that they are 5 involved, they understand what occurs, and that action 6 is taken to prevent it from occurring again.
7 Essentially, the bases of the process is to insure 8 that we know what we're doing and we take action, put 9 programs in place that wiu prevent recurrence.
10 (Slide) I'd like to move on now to our 11 schedule overview. Over the past few :::onths , we've 12 been evaluating the Browns Ferry restart schedule. We I
13 developed what I'll refer to as a Level I milestone I f( .-
14' schedule, very', very major events. From that we've 15 developed integrated Level II schetules for all major 16 activities. That's not simply engineering activities 17 such as equipment qualifications or seismic. It also 18 includes employee concerns, CAQR work-off --
that's 19 our corrective actions system --
and licensing 20 commitment. So, it's an all-encompassing process.
21 In doing so, we optimize our man loading.
I 22 We wanted to make sure that the man icvels are such I i
I 23 that we can effectively manage the tasks that are 24 taking place there. We did not want the up and down ,
1 25 approach and a swing in people. We wanted a level of l
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.gg' 1 manpower that was consistent and easily managed.
.s '2 Additionally, all these tasks have been
'3 logically tied together and we utilize these Level.II
.4 schedules to logically develop system return to 5 service schedules based on major plant milestones such 6 as condenser vacuum, dry well closure, integrated leak 7 - rate - testing. And again we're utilizing our SPOC 8 system as we return each system to service.
9- .Now, this is an important aspect of our 10 schedule development in that we're transitioning at 11 this point from what I refer to as a bolt construction 12 engineering mode to a system return to service mode.
13 Clea'rly, bringing the systems back is how we're going I t- to have'to bring the plant back.
15 Now, to support our system return to service 16' process, we're refining our site and master.punchlist.
17 The punchlist is a listing of all..open items on every 18 system. Essentially, it is a single place where you 19 can find out exactly what has to be done on a system 20 on an individual basis. The required completion dates 21 for various activities are again tied back to the' .
22 system, return to- service dates and the major 23 milestones.
24 COMMISSIONER ROGERS: How many systems are ;
i 25 in that inventory?
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. .. 25 l
. 1 MR. ZERING1TE : All systems, 66 systems.
l 2 Je've reevaluated our scheduled management processes 3 to insure we provide adequate management overview of 4 what's taking place at the plant. During fuel load, 5 there was a lot of emphasis on preparing systems for 6 fuel load. As a result of that, a lot of the other 7 activities that were not associated with fuel load 8 dropped behind significantly.
9 We're doing, on a weekly basis, a review of 10 our Level II schedules to assist the progress in that 11 regard. The systems that are associated with the next 12 milestone, in thic particular case condenser vacuum, 13 w e ' r-e reviewing these on a daily basis to assist our 14.- progress.
15 On a daily basis, we have a punchlist 16 meeting which utilizes our site master punchlist.
17 Essentially, what we do in this regard is look at 18 things that are coming due within the next 60-day 19 period. Are there material e>nstraints? Are the 20 designs being issued on time? These kinds of things.
21 Also, we're looking at bulk work-off rates.
22 For instance, we have X number of maintenance 23 activities that need to be completed prior to restart.
24 That will translate to so many maintenance activities I
25 being done per week or per day. So, we're looking at 1 DEAL R GROSS COURY ltEPoRYERS AND TRANSCRIBf R5 1323 kHoDE ISLAND AVENU[, N.W.
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....',.. 15 our bulk work-off' rates to see if'those work-off rates
- 3. . .
~
2 are consistently with our schedule assumptions.- By 3 doing so, this allows us to focus on the milestones 4 that are.in front of us, but also gives us a good feel 5 for what else is happening with regard to our schedule 6 progress.
7 (Slide) Now, with regard to our present 60--
8' day schedule, we developed within that schedule a-i- -9 condenser vacuum milestone. The condenser vacuum 10 milestone was intended to evaluate our maintenance
'11 department's ability to complete work.
12 Now, please understand that these were not 19 schedules' that any of us here dictated. The
'i le- activities were identified and the people responsible 15' for completing those activities told us how long it 16- would take for them to do it. So, this is not in any 17 way an imposed schsdule.
18 Again, as part of the 60-day schedule cut, 19 we're attempting to evaluate not only the maintenance 20 area with regard to the 60-day schedule, but our 21 ability to communicate; our ability to produce designs 22 on time and our ability to complete modifications on 23 time; and truly, our ability to coordinate a large 24 amount of activity within the facility.
25 With regard to status on our condenser NEAL R. GROSS Couai REPoaTERS AND TR ANSCRIBER$
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! , (,, ... ,
- i
,. \ 1~ vacuum.f miles tone , the physical work. activities are
- 2= within three days of the ' schedule. However, at . the 3 'last. minute, after ' development. of that: 60-day !
, a
~
4 __ schedule, ,we elected _to_ apply our.SPOC process to all I' 5 BOP systems to insure that those' systems ;were
- 6 functionally ready to support operation. That has 7 impacted' our engineering _ resources and .. will delay 8 formal' completion of the condenser vacuum milestone by 9 approximately three weeks. However, the plant will be 10 ready to pull vacuum within a f ew days of
- schedule 'and 11 we intend to initiate that task to evaluate system and 12 equipment performance, evaluate the adequacy of our 13 . procedure'and our operator performance.
1p We're now approximately half way through our t -
15' 60-day schedule . evaluation cut and critical path
'16 activities in this regard are within two to three days
_ 17 of the schedule. However, assessment of our Level II 18 major project schedules and our bulk work-off rates 19 indicates that we're falling behind in the design 20 area, particularly in electrical issues.
21 While that's disappointing from a schedule
- 22 adherence perspective, the evaluation process has been 23 successful in its readily identified areas that need 24 additional management attention and rhows that our 25 schedule monitoring progress is effective.
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. .- 1- ' N( w , from a work completioniperspective, we
[
2 have. increased the output'in the maintenance area 200 -
p 3 , to. 300 ' percent. in . the last two months and just . as 4' significantly in the engineering ' area. Two months-5 ago, engineering was putting out .three to-five L
- 6 modifications a week. Statistically now they're i
7 putting out 3.1 a day.
8 So we're moving ahead. We're progressing.
9 We will have this facility ready for restart. Now, 1
l 10 clearly, there's.a lot of work taking place and it's 11 incumbent upon us to insure that these work activities 12 are being effectively monitored. When we started our 13 60-day schedule push and our push to condenser vacuum, 14 ' we instituted shift coverage of the senior managers on 15 site. So, through this process, we will have senior 16 management shift coverage to insure that the 17 activities are taking place in a safe quality fashion.
18 I'd like to introduce Henry Weber now.
19 CHAIRMAN CARR: Before you do that, let me i
(
20 ask you, is your condenser vacuum milestone inside the 21 60-day schedule status or outside? .
22 MR. ZERINGUE: Inside.
23 CHAIRMAN CARR: Inside. So you pick one 24 milestone inside the 60-day status to shoot for?
25 MR. ZERINGUE: Yes, sir. We wanted to
)
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0- L t '
. establish a : milestone ! that would allow us. to bringl 7 1 2 _ systems' in,to service . so we. could- evaluate that 4j 3. process. We'also wanted - to assess how well we 4 identified the task completion times for the overall 5 60-day period.
6 CHAIRMAN CARR:. I understand-that. Now, is 7' this a first cut or have you had one milestone you've 8' already met inside of some 60-day or is this the first-9 time you've tried the system?
10 MR. ZERINGUE: This is the first time we've 11- tried the system.
12 CHAIRMAN CARR: Okay.
13 -
MR. WEBER: During the schedule review on
- 1 +- the overall schedule, we identified four major design 15 issues that were on the critical path and, in fact, 16 have been driving the critical path. We'll briefly 17 discuss the status .of .these major design issues and 18 then discuss the resolution of our engineering 19 performance problems.
20 In addition, I would like to address the l.
21 concerns that were expressed or raised in the June l- 22 staff presentation on status of operating plants in 23 which you were advised that the implementation 24 continues to be a major problem and factor at Browns 25 Ferry. I'13 address that in regard to engineering and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBER 5 1323 RHODE $$ LAND AVENUE, N.W.
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L 7 l' ' modifications.
.A In that application, implementation, reality 2
3 covers -. discovery, .. the - engineering design portion and 4 -the implementation.of~the mod.itself.- I'll be giving 5 you status of what we've been doing in that area.and 6 some of the progress we've made.
l 7 (Slide) ~0n slide 19, you can see the 8 overview. of our problems and we're RAD on . these. We 9 are happy to state that we have reached basic 10 agreement with your staff on all of our design issues 11' and we have finished our discovery phase and we are 12' ' clearly into the implementation ph'ase of the work
~
13 process.
30 (Slide) Next slide, please.
15~ As we went through and evaluated the 16 schedule, we had basically five generic problems that 17 kept reoccurring that we could see within our issues 18 and what, in fact, was causing our problem. The first 19 one was a repeated underestimating of the scope. The 20 primary cause of this was the fact that we were still 21 in the discovery phase. We were trying to say we had
-22 fixed scope and make schedules that reflected that 23 and, in reality, we did not have a fixed scope. Until 24 we finished the discovery phase, we were continually 25 identifying additional work and then having to factor NEAL R. GROSS COURT REPORTERS AND TRANSCR3BERS 1323 RHODE ISLAND AVENUE. N W (202)234 4 33 WASHINGTON. D.C. 20005 (202) 232.6600 a__--__--_-._. _ . _
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~. )r., o 31, 1 ..
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fli that inland that, in turn, keeps driving you.
. 2 With ' the : finish 1 of the discovery phase, we-
'3 have got-a very clear picture, we feel, of the scope.
We have laid it out, we have scheduled it.
~
'4 We have:
~5 developed quite a bit of additional confidence in our
'6 ' definition of scope with the return of a number of the 7 experienced engineers from Sequoyah into Browns' Ferry.
- 8 What this meant is they were bringing .back the 9 experience they learned on these issues-in the restart
'10 'there. They have looked at the to go scope and are-11 pr'etty 'well in agreement that we have covered the 12 different areas and we have included that within our
- 13 . work.
1p_ The ,second area is in the management of 15 contractors. It's not reAly in a commercial sense.
16 It is the fact that we had a large number of 17 contractors over the last few years being worked en i
.I 18 the different issues or the different tasks. I t' 19 caused a number of continuity problems in the fact 20 that we were overlapping some redundancy. The 21 confusion is you were trying to analyze the data.
j 22 That portion is behind us. Also behind us is the l
23 discovery -- it's all the same issue. !
24 The other portion we had in this area is the j i
I 25 fact that down at the engineer level there was a lack l
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- 4 1 of identity with the task the contractors were doing 2 themselves because most of this work was oeing l 3 administered at an engineering supervisory level. We 4 have since taken and pushed this responsibility down 5 at the engineer level on the task. This, in turn, has 6 had the positive results we've wanted. The engineers 7 are now on a daily basis involved with the contractors 8 that are performing this work. They're reviewing the 9 work as it progresses, not waiting until the whole 10 product is done and then reviewing it and having 11 problems digesting it.
12 As we see problems in the product as it's 13 being developed, we resolve them on a very rapid 16- basis. We have eliminated a lot of the impacts we 15 were seeing in trying to perform the schedule by 16 waiting, sitting back and waiting for a total product 17 to be handed to us.
18 The next area is in what we've classified as 19 defense of our positions versus getting technical 20 resolution to t.h e positions. I would have to say 1 21 we've had a history of spending a lot of time and !
1 22 resources in trying to defend our positions on 1 23 different issues, running additional cales, tests, et 24 cetera. The solution to that has been very simple and i 25 very straightforward. We have worked hard to come to NEAL R. GROSS court REPORTERS AND TRANSCRIBER 5 1323 RHoDE ISLAND AVINUE, N.W.
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< , ./.> .
H wqA [ 331 9' u. , - l agreement! with the staff on the technical criteria,,. ]
D 4.- .
eq 2- taking that criteria '.and going and turning that-'into -l
.3. work'and.getting on with.it. 'I quit doing the pencil .,
1 4 whipping and I'm trying' to : make things disappear, go 5 : solve the problems. Put the ef fort on solving- the 6 problems.
7 The impact from doing a pencil whip is it 8- ' takes a long. time to come down to what's the true work 9 you're going to have to go do on it. By. resolving 10 that-- type of philosophy, we've come to very rapid 11 agreement. Define the scope, go perform the secpe.
12 On the engineering management at site, we've 13 had>over the last five years six project engineers.
1,k- It's been a combination of contract engineers versus 15 direct TVA engineers. We have now brought in, this-16 spring, Ron Smith. He's brought with him his 17 experience from TMI Unit 1, which really- covered an.
18 area we had. We had very good qualified nuclear 19 engineers previously. They had very little restart 20 experience. We were constantly trying to reinvent 21 wheels, learn what the wheels were. We have 22 eliminated that interface, that delay problem.
23 We've additionally brought down a number of 24 key supervisors on a permanent basis from Knoxville.
25 They are now assigned as Ron's discipline leads.
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', 1 We've brought in a few additional direct higher 2 engineers from other areas that had previous restar+
l l 3 experience to supplement a staff. As a result of l
4 this, Ron and his staff are able to do the problem 5 solving and the production work directly at the site.
l l 6 It gives us very fast turnaround to resolutions of our 7 problems. He has full access to the corporate staff 8 in Knoxville and he can pull those people in as needed 9 to solve the problems. It took a large time delay out 10 of our ability to respond.
11 The last area is what I would classify as a 12 very typical problem at most any site I've ever been 13 involved with, and that was the engineering versus 17 construction, or we call them modification here.
When 15 you have the two separate organizations, every problem 16 is a unique problem and every problem has two unique 17 solutions. We've solved it very easily when they 18 combined both organizations into one department. We 19 work our problems as a team. We ecme to team 20 solutions to the pro'clems and we integrate into the 21 schedule a team effort to resolve the work. Taking 22 those interfaces away ;;,robably *-as the last major area 23 I could see out there where we had a built-in delay by 24 approaching it from two or more directions.
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35 ,
1 coordination with the plant staff, that they don't 2 have to negotiate with multi-entities when something 3 is going to be done. It's basically brought into the 4 plant as a total cradle to grave, from start of design 5 to the finish of implementation. It allows them much 6 better ability to schedule and to factor this into I 7 when it will be worked at the plant.
8 With that, I'd like to return back to 9 Oliver.
10 MR. KINGSLEY: Thank you, Henry.
11 (Slide) I'd like to now shift to our last 12 slide and conclude, Chairman Carr, and talk to you 13 princir ally --
that's slide 22 -- talk to you 1,4- principally about three items that I feel like some of 15 this that we have to complete, some of it we're 16 partially there, what have you.
17 But the first item is our culture. Mr.
18 Zeringue talked about that. It is my personal l 19 experience that it takes on the order of two years, 20 two to three years to get that culture where you can 21 actually restart and on the order of about five years 22 to take it from a very poor performer up to a l 23 classical high performer.
1 1
24 As an example, Grand Gulf was just recently i
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, 36 ,
1 back in 1984. I mention that because I had a great 2 deal of personal experience and invested a lot of my i
3 life in bringing that plant up over there.
4 We're going to continue to set very high 5 expectations. We're going to have a total intolerance 6 for people who do not conform or perform. We're going 7 to emphasize a very thorough approach. We're going to 8 continue to work at strengthening our msnagement team l 1
9 that I've talked about in the question that Commission
)
Rogers asked about that. We should be able to add j 10 l
11 some more quality management so that we can have the i
12 appropriate management there and have a good 13 succession planning process so that we can carry 1{ ourselves through and not be in extremis if we lose 15 one key manager at that site.
16 We want to continue to hold line management 17 responsible, emphasize the role of the support staffs.
18 With respect to the schedule, we're doing a very 19 careful evaluation of that, but we're going t c, base 20 our schedule on actual production.
21 The September date is an embarrassment to me 22 personally, that we have not produced. There are a 23 lot ut reasons for that, in not completing discovery 24 and then in not basing a schedule on our actual l 25 production. But we're not going to make that mistake NEAL R. GROSS COURT REPORTERS AND TRANSCRIBER 5 1323 RHODE 15 LAND AVEM*JE, N.W WASH)NGToN, D C. 20005 (202) 232-6600 (202) 234-4433 N-_____ _ _
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':.= -
1 againt TWe will not- announce. a schedule until we've:
, 2' -done this evaluation. However, we expect to.have it-L 3 complete in August and'1 come up with - a . ' firm restart 4 date/ 'o n e : that. we can make and actually have
- 5' confidence in.
6: Now, at this time, we'll be happy to answer i
7 .any questions that you might'have.
8 CHAIRMAN CARR: Commissioner Roberts?.
l l 9 Commissioner Rogers?-
l 3 10 COMMISSIONER ROGERS: Just a 'little bit on 1
11 the system engineer ownership plant systems. The-66 12 systems that you said that you had on your punchlist, 13 do they match up with the systems engineers? There's.
1 k- a one-to-one relationship? How many systems does c 15 typical system engineer look at?
, 16 MR. CAMPBELL: A system engineer might lave 17 anywhere from two to five systems. It depende on'the 18 size and the complexity of a system. Say, for 19 example, the engineer that has the heat removal i
20 system. That's such a large, complex system. That's 21 just too much for one person. I've actually got two.
22 But some of the other systems can be handled by one 23 engineer up to a maximum of five or six systems.
24 COMMISSIONER ROGERS: So these system 25 engineers are all identified now and they're all HEAL R. GROSS COURT REPORTERS AND TRANSCRtetR$
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+.
38
- .+.
,. 1 plugged in? They're all.in place and they're involved 2 with this refinement of the punchlist?
3 MR. CAMPBELL: All system engineers have 4 been identified. We are currently filling about two 5 or three positions from outside that will conclude the 6 complete staffing of the system engineering group.
7 But all the systems are presently covered.
8 COMMISSIONER ROGERS: And who do they report 9 to?
10 MR. CAMPBELL: They report to my tech 11 support manager.
12 -
COMMISSIONER ROGERS: Is he in charge of all
~
13 engineering as well?
- i. .--
14' .MR. ' CAMPBELL: He is in charge of all the 15 technical support for the plant organization. He has 36 'the systems engineers. He has the reactor 17 engineering, the STAS, the plant testing program, if 18 you will.
19 COMMISSIONER ROGERS: Good.
20 You mentioned ycur vendor interface, that l'
l 21 you've formalized that. Have you systematically gone 22 back to your major vendors and checked to see what 23 documents that they have sent you or thought they sent 24 you and that you have them?
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. ', 1 of the major items that came out of the fuel load 2 event. In looking at that, there was a RAP cell that 3 came out of General Electric Company in around the 4 middle of December that, if properly acted upon, would 5 have, in my mind, prevented this unmonitoring of the 6 core that we had there.
7 As a Jesult of that, and of course we didn't 8 actually get that cell until the day we started 9 loading the core, we've gone back to the major vendors 10 and requested this information, diesel manufacturers, 11 what have you. It's very difficult to get all of 12 that, from my past experience, but we have attempted 13 to do that and we put a very high-level manager in 10- charge of that program now.
15 COMMISSIONER ROGERS: A very elementary kind 16 of thing, but it's a place where there can easily be 17 miscommunications, if they t hi. they sant you 18 something and you never got it or you don't have it in 19 your records.
20 MR. KINGSLEY: Well, we found this in this 21 process tsa, a secretary signing it out, going into 22 our corporate office. The plant manager wasn't even 23 copied on the report. So, there's been a lot of j j
24 straightening out to do there too in the l 1
a 25 correspondence of that. (
1 l
NEAL R. GROSS !
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-**' .- - .1 ' COMMISSIONER ROGERS: Good. Thank you'. ,
- . (
.- :2' CHAIRMAN-CARR: Commissioner Curtiss?
- 3 COMMISSIONER CURTISS : I don't. have any 4 . questions. Thank you.
5 'CHAIPMAN CARR: When I visited there last 6 was over a year ago now. One of the things that I 7 took note of was the backlog, which you've-mentioned, v.
i 8 of maintenance items and the high rate of turnover of 9 personnel maintenance, which at that time was about 20
'10 percent. How do'they stand now?
11 MR. CAMPBELL: I can speak to backlog- and 12 maintenance. Currently, for Unit 2 restart, there are 19- approximately 1700 work requests that are required.
x
. 14- The actual total Unit 2 in common is about 2300. To 15 compare you where we ware, say, two months ago, those-16 numbers were in the 3500 range. So we have made a 17 marked difference in accomplishing work.
18 We expect to have, based on my previous .
19 experience, about a 50 percent increase or influx of 20 work as we go through the restart process as classical 21 emergent work. You go test it, it breaks, you need to ,
22 go fix it, that kind of thing. So, I think that the
. 23 MR backlog and what we've done in improvement in our 24 work ethic and how we plan and stage and the -
j 25 managensent team that we've put in place in maintenance NEAl. R. GROSS COURT REPORTERS AND TRANSCRIBER $
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- 7 J -l, . 1-. has had a significant effect on getting us started.in 9 j.
- 2 the right directionzin maintenance from an MR. backlog _
'. 3' . point of view.
4 Speaking of organization, we have brought in
.5 two gentlemen ' f rom out' side TVA that are very 6- e.ggressive gentlemen, have got good qualifications.
7 We've' supplemented that with one of my o t h e r.-
8 superintendent's direct reports. .3e.'s ac tu ally 9 ;formerly the Radeon manager but he has' very high 10 integrity in terms of organization and management and 11 insuring follow-up. He's added a lot of stability to 12 how that organization is run as a.businesa.
.. 13 Other things that we plan on doing from an 1[ organizational point of view in maintenance. is 15 insuring that 'the first-line supervisor understands 16 clearly what his responsibilities and accountabilities
~
17 are. We've gone too long with letting things go.
18' It's' time to say, "If you can't meet the expectations, 19 then we must remove you from your job and put you 20 someplace else where you can be of benefit," and we're 21 doing that process and we are making some changes at 32 the first and second line supervisors.
23 CHAIRMAN CARR: And how is the turnover 24 these days in the maintenance organization?
25 MR. CAMPBELL: Pretty good. I don't have f
i HEAL R. GROSS COURT REPORTER 5 AND TRANSCRIBER 5 1323 RHODE ISLAND AVENUE, N.W.
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real, percentages , . but .it's nowhere near ' the 20
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2 percent. We've been' pretty-stable in the maintenance 3 , organization now for, I guesa, about - the past six 4 -months.
5 MR. KINGSLEY: The area that we .had a ;4 6 ' problem'with was'in the top job --
7 MR. CAMPBELL: Yes, sir.
8 MR. KINGSLEY: --
there where we had 9 extremely high turnover of some six jobs, some 'six 10 ' incumbents in that job. We think we have now 11- stabilized that. Very essential to the restart effort 12 to put that in place.
13 CHAIRMAN CARR: Well, I must say that we've 1h heard all the right words.- As I told other people 15' what I'll tell you, the menu looks good but we've got 16 to see how the food is. .It's a little bit of time-
.17 Ibefore you're going t o '. ge t there. You.'re just 18 starting into this phase. So, we look f orward to
'19 monitoring your progress.
20 Unless tnere are any other questions --
21 COMMISSIONER ROGERS: Yes, just on this
.22 adequacy of cable installation. Where does that 23 stand? Where are your examinations and inspections on 24 that?
25 MR. SMITH: With respect to ampacity of NEAL R. GROSS COURT REPORTERS AND TRAN5CRISER$
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,. 1- cable operations or which aspect of.it?
(I 2 COMMISSIONER ROGERS: No, the. cable 3 installation. Not the ampaci ty , -but- the cable .l 4 insta11ation. The questions about whether there . was l
5 ..-. damage to the cable in pulling them in and so on.
6 MR. SMITH: The review has been completed at 7 Browns Ferry. There has been modifications issued to 8 correct the deficiencies, similar to what was done in 9 Sequoyah. We have long cable drops and radius side 10 wall tension pressures and things like that. We've 11 gone through and high phonic cables and we have not 12 identified any major technical problems in'that area.
13 COMMISSIONER ROGERS: Did the use of that
( .--
14' flamastic mateiial interfere in any way with verifying 15 the installation adequacy?
38 MR. SMITH: I don't really know how to l
17 answer that question. The cable trays, where they are !
i 18 flamastic, are totally inaccessible. You cannot view 19 the cable. All you can do is -- where it comes out of 20 that tray into the device would lay by the component.
21 There is no way to physically inspect that cable and 22 that tray.
23 COMMISSIONER ROGERS: Well, is there any 24 possibility of concerns with respect to installation 25 of those cables that are buried in flamastic?
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- 44 ,
1 MR. SMITH: I'd have to go back and get the 2 technical --
3 MR. KINGSLEY: If you want to go ahead and 4 talk about it.
5 MR. ZERINGUE: We've spent a large effort in 6 verifying, not simply by walkdown, into the tray, out 7 of the tray. Also with cable tracing techniques, 8 where you can physically trace the location of the 9 cable. So, there's been a rather large effort in that 10 regard to establish the validity of the cable runs.
11 MR. KINGSLEY: We're also talking a 12 difference here between the trays which the cable is 13 traditionally laid in there and not pull versus what i you do through conduit or condolet. So, it is not a if 15 flamastic problem in my opinion.
16 COMMISSIONER ROGERS: But they're separate.
l 17 The areas where there might be a concern with respect 18 to installation are nct in the tray areas that are 19 buried in flamastic? Is that what you're saying?
20 MR. KINGSLEY: That's my understanding on 21 the pulls. We could ask a member of the staff to ta.1k ,
22 about that.
23 COMMISSIONER ROGERS: I'd like to hear on 24 that one because that's been an issue and that's one 25 question that bothered me a bit when I was down there.
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f 1 MR. KINGSLEY: Yes,- there' cre - now a number 2 of' questions about . over-pulling, over-stressing und 3 t' hat: type;-
4~ COMMISSIONER ROGERS: Whether there are any 5' areas,where the flamastic'has covered your ability lto 6 inspect those cables, that might pcssibly have been 7 subject'to an' installation damage.
8 MR. ZERINGUE: Well, clearly, as Ron-said, 9 'once the tray-is covered with the flamastic, the cable 10 is. . essentially - inaccessible. The'only . way _ to try to 11 follow it is to pass a signal through the cable and 12- try to trace the signal.
l'3 . COMMISSIONER ROGERS: I guess I don't know
'If what the answer is then.
15 MR. SMITH: I don't have a . f ully adequate 16 technical answer for you at this time. I'd have to-go 17- back and ask the question --
18 COMMISSIONER ROGERS: I'd be interested if 19 you could just be specific on that one, whether you 20 can separate those areas where there might be possible 21 . evidence of cable pulling problems from those areas 22 where the cables are inaccessible because of the 23 flamastic, to give us some comfort on that.
24 MR. SMITH: Thank you.
25 MR. KINGSLEY: We'll provide it.
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, j '1' CHAIRMAN ~CARR: Do you want'to provide that
- 7 w 2 for the record-then?
"3:
MR. KINGSLEY: . We'll provide that' f or the 4 record.-
5 CHAIRMAN CARR: Okay.. Thank you very much.
i 61 h appreciate it.
~7. I guess we'can assemble the staff.
L 8 Mr. Taylor, do you want to introduce your l' 9 people.and proceed?
'10 MR. TAYLOR: Yes, sir.
' ll- Good afternoon. With me at the tab 1', e with 12 Tom Murley on my right, to the right of Tom is Dan-
.. 1h Carp' enter, who's a Senior Resident. On my left' is-V if' Denny Crutchfield, the Associate Director for Special 15' Projects and the Senicr PM for Browns Ferry, Jerry 16 Gears.
17 I would like to start by noting that I was 18 at Browns Ferry in May of this year. I . toured the 19 unit and then met with some of the key management in 20 the afternoon to talk about a number of the technical 21 issues that they outlined. In a gener al sense, I was 22 heartened by that discussion with management there. I.
'23 detected an attitude of facing the issues that the 24 staff had, taking the responsibility to inske the 25 appropriate decisions and, to borrow a word from Mr. ,
1 NEAL R. GROSS COURT REPORTER $ AND TRANSCRIBERS
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^ * -1:- , ' weber, sort of'no.moreiof this pencil whipping, but' 2 get.on with~the. job. The plant and the ' attitude- of -
13
' people I' talked to in the plant was good. I talked to 4 a number of people as I walked.through.
5 - J. . do believe . that the unit is _ reflecting l
-. 6 that.and the solutions to the problems that are~ ahead, 7 theLequipment problems, the technical problems-are yet; .c 8 to be resolved, which the staff will-talk about. But'
~
9 I .did detect this strong sense of responsibility to 30 get'these-issues solved.
11- I'll now turn the detailed briefing over to
'12 Mr. Crutchfield.
~
13 MR. CRUTCHFIELD: You've heard essentially 1 .
14' the - status ' from TVA as to what's going on at Browns 15 Ferry. You've received our-Commission paper,89-207,
.16 .which lays out pretty well the status of the technical 17 issues as we see it.
18 There's one item in the table, I believe, 19 that has moved over-from a difficult category to an 20 easier category for us, and that's the cable ampacity 21 question. We've recently reached an agreement where 22 that item now moves over to probably into Column A, at 23 the worst. More likely into that column than any 24 other column. So, that's the most difficult issue 1
25 that we saw that was remain!ng fur us from a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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' . ' "; 1: programmatic standpoint.
w, 2' As indicated l generally,- 't h e . o t h e r A
3 progranimatic issues , we're in . basic agreement with
~4 them and we're just' working out some of the minor -
5- details.
6 'The management situation at TVA . as' we : see 7- it, and as ' at Browns Ferry, is that we've indicated 8 generally that corporate TVA management, we're 9 satisfied - with. They've made a number of changes 10- th er e -. We'made some approvals relative to the restart 11 of Sequoyah, so we're generally satisfied with the 12 corporate activities. They 've made a number of 13 changes at Browns Ferry site to improve the management i t- activity that they have there. We believe we begin to 15 see that it's having an impact on Browns Ferry and 16 that they're turning around. The culture is beginning.
17 to turn.
18 We still see pockets of old TVA that the j i
19 nanagers there are working on and I think are bringing <
1l 20 about progress. But it will take some time.
l l 21 As I indicated, the programmatic issues, as l l
'22 far as we're concerned, are generally pretty well 23 resolved. Periodically in their discovery phase or 24 their implementation phase, we see an issue that comes ]
25 up where we discuss it with them. !
I i
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1 Recently we went through a couple of EQ 2 issues on motor control centers and some beta doses to 3 cables in the dry well. I think those issues are 4 being addressed and resolved to our satisfaction at
. ---S this time.
6 As indicated also, impicmentation remains to 7 be the major item that's necessary to be done. It is j 8 having an impact an us in that we would previously 9 schedule an inspection activity for a particular time 10 frame. We have had to put off a number of those 11 inspection activities because TVA wasn't ready for us.
12 What ' we ' ve done is highlight now some prerequisites 13 that we wish to see before we go down there so that 1 .-
1[ TVA knows whers they need to be before we'll come down 15 and do our inspection. This saves both of us a lot of 16 resources and a lot of time, a lot of problems.
17 Potential restart impact issues .are the 18 seismic program. They do need to get on with the 19 implementation. They have a great deal of work in 20 front of them. They have begun it as was indicated.
21 The engineering progression of work packages has 22 substantially improved over the past few months. They 23 need to continue that sort of activity so that they 24 can make a reasonable schedule for themselves.
25 EQ questions are still outstanding. I don't NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W (202) 234 4433 WASHINGTON. O C 20005 (202) 232-6600
50 ,
. . 1 think that the problems are more hardware problems. I 2 think the indications are that they need to get their 3 paperwork together. They need to get their binders in 4 shape so we can go down and take a look and make sure 5 we feel comfortable with what's going on.
6 The cable installation question that was 7 raised deals principally with our experience at 8 Sequoyah where there was a lot of silicone rubber 9 cable. They don't have that at Browns Ferry.
10 However, we're still concerned and we want to be sure 11 that sidewalk pressures, et cetera, do not get to the 12 position and the point where there is a problem.
. 13 The installation of a great deal of if* flamastic down there has certainly made their job of 15 checking out cables, doing cable runs and things like 16 that much more difficult. They have been doing some 17 signal tracing, however, and that helps identify what 18 cables are in what trays and that sort of thing. So, 19 there's been some positive steps there too.
20 As I indicated, the ampacity question has 21 been resolved. We enneluded that the consultant that 22 we were using was taking a very conservative approach I
23 to the issue. We are less conservative. T'7A is 24 somewhat less conservative than our consultant, but l
25 yet we still feel there's reasonable margins there and NEAL R. GROSS COURT REPORTERS A>4D TRANSCRIBER $
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, . . 1 we':ca satisfied with the approach.
l:
2 The inspection program, as I indicated, is 3 tied to prerequisites. We.do have an operational 4 readiness team inspection that will be going down 5 there also. One of the-reasons we permitted reload 1
j 6 was to encourage ther to get back into an operational
- 7. mentality. When they reloaded the core, that put 8 certain tech .7pecs in effect, so they're now minding 9 their LCOs and doing their surveillance in accordance 10 with those tech specs. So, we hope that smooths the 11 transition to a full operating plant for them.
12 -
As I indicated, we will be going down with
~
13 an operational readiness team inspection shortly, t .-
14' within the fall or so.
15 With that, unless there are any other 16 questions that you may have, that's all the 17 presentation that I hope to make.
18 CHAIRMAN CARR: Commissioner Roberts?
19 COMMISSIONER CURTISS: Just a quick question 20 on the ampacity issue. In the attachment to the 21 paper, you indicated that TVA was proposing credit for 22 load di 'ersity and time diversity. Is it on that 23 point that Sandia was being overly conservative?
24 MR. CRUTCHFIELD: Sandia's basic approach I 25 was to assume that the cables were in the minimum NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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.. .- 52 1 surface area that you can. In other words, confined 2 to a-circular arrangement. TVA has persuhded us that l-l 3 .in the actual physical plant they are not located that 1
4 way. They're spread out throughout the cable tray.
. _.5- So, once you.take that into account, the effects are a 6 lot less severe on the ampacity question.
7 COMMISSIONER CURTISS: That's all I have.
8 CHAIRMAN CARR: The asterisks on the 9 significant issue . list there that says " inspection 10' still necessary," is it your intention to complete all 11 those inspections prior to restart?
12 MR. CRUTCHFIELD: Yes, sir, it is.
- 13. CHAIRMAN CARR: I notice they've requested a
( .-
14' ' delay,of the maintenance inspection. Hav vou got a 15 reschedule on that or are we waiting for their -- have 16 you got . a milestone you're looking for them to pass 17 before you go down there?
18 MR. CRUTCHFIELD: We are waiting for them to 19 say that they're ready for us to come down and do the 20 inspection.
21 CHAIRMAN CARR: So, really, the ball is in 22 their court as to the tennis game went?
23 MR. CRUTCHFIELD: Yes, sir, tennis 24 management.
25 COMMISSIONER ROBER"S: That's a new buz NEAL R. GROSS COURT REPORTERS AND TRANSCRIBF 1S
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[ g -. '1' -phase. . I*ve . learned : a .. lot of them in the past few
'2 years..
3 CHAIRMAN CARR: We're not trying to shift 4, the responsibility, but the ball is . clearly in their -
5 court.
l 6, MR. '17.T L3R : We have our eye on it, but it 7 .happens'to be. on their side.
8 CHAIRMAN CARR: Okay. How about giving me 9 an assessment of post rertart operations at Sequoyah?
- 10. MR. CRUTCHFIELD: To date, what we've seen
'11 at Sequoyah is a willingness to learn from their 12 problems. We had some restart questions that they had
~
13 with aux ' f eedwater. When they initially restarted
(
14 Sequoyah Unit' 2 ' they had a number of trips. They 15 applied some resources to it and'they got themselves -
36 back in operation. They st9rted Unit i up. They did 17 it relatively successfully. They had a transformer 18 problem, but they fixed that. They ran, I believe, on 19 the order of 200 days or so.
20 During the refueling outage that Sequoyah, 21 Unit 2 had this past spring, performance was very 22 acceptable. They did it, I think, very well. Again, 23 sihen they came out from that outage, they had some 24 feedwater trip problems. Mr. Kingsley stopped all 25 activities. H( called in some support from other NEAL R. GROSS COURT REPORTERS AND TRANSCA$ERP l 1323 RHDDE ISLAND AVENUE, N W.
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, f. ' facilities, other utilities and: got to what he thinks-
'2 is the-root-cause of the problem. .We-agree with him.
)
3- -We think' he- has gotten to the root cause of the 4 problem. ,
l j l- 5 It's a more measured approach on'their.part .
\-
6 to restart. It's not a drive to hurry up, let'.s get 1
l 7 the plant up and running,.but it seems more considered
[
8 and'a more refined process.
H 9 So, I would have to assess that I th#nk the 10- ' restart activities and operations at . Sequo'.'ah have
- 11. 1 been ; average to above average. We gave thera a SALP 12- this past spring and it was all category 2s with some-
. l'3 .impr'oving trends. :They did have one category 3 in the k, if engineering area, but that had an improving trend.
15 CHAIRMAN CARR: And you think Browns Ferry 16 has learned from Sequoyah's problems?
17 MR. CR'JTCHFIELD : We're beginning to see the 18 transfer of experience from Sequoyah.to Browns Ferry.
19 EQ people are coming over from Sequoyah. It's a one I
20 time item, 'if you wil1~. Once you get yourself 21 together, you can maintain it a lot easier. So, 22 they're bringing the expertise to Browns Ferry to .
l So, the iterations that we had with TVA l 23, apply there.
I 24 at Sequoyah, we probably won't have to have in as much 25 detail at Browns Ferry. j NEAL R. GROSS court REPORTERS AND TRANSCR10ERS .
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CHAIRMAN CARR: Are you keeping. an eye on-
.+
4 2' the expertise that's'left at Sequoyah so we don't get 3 sandbagged'from behind?
4 MR. CRUTCHFIELD: Yes, sir, we are. That's
. 5. why I gave you the example of the EQ expertise. Once 6 you.get a decent program established, and the effort 7 and resources it took to establish that, program, then 6 .' you can transfer a lot of' that . experience and
,s 9 individuals - over to the next plant and yet maintain 10 some experience and knowledge at the exis, ting . site.
11 COMMISSIONER CURTISS: On that point, it 12 looks like they lost a good plant manager'down there
. 13 'at-Sequoyah. Have they filled that slot yet?
1[ MR. CRUTCHFIELD:
No, they haven't. They're 15 actively pursuing both a plant manager for that site 16 and for Watts Bar also.
17 CHAIRMAN CARR: Obviously, good plant 18 managers are hard to hang onto these days.
19 MR. CRUTCHFIELD: Yes, they are, a difficult 20 commodity to get.
21 CHAIRMAN CARR: What is the -- when do you 22 intend to do another -- or set the SALP schedule up 23 for Browns Ferry again?
24 l MR. CRUTCHFIELD: The SALP began with the
-25 refueling activities that occurred in January. Now, 4
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' " 56
. e 1 we told them that that's when the SALP period began.
2 We haven't established when it will end, but it will
- 3 be in time so that we can -- before we brief the l
l 4 Cornission on restart activities, we will have 5 completed a SALP period.
6 CHAIRMAN CARR: Okay. Any other questions?
7 Well, I'd lika to thank both the Tennessee 8 Valley Authority and the staff for the briefing. We 9 needed the update on the situation down at Browns 10 Ferry. A four year shutdown is certainly a long time 11 l tc be shut down. It's a tough problem to get back on 12 the line. I know TVA would like it back on the line 13 probably more than anybody else.
17 They have shown their ability to do it once 15 at Sequoyah. They've got both those plants on the 16 line and, as you've heard, they seem to be running 17 reasonably well. So, they've demonstrated they can do 18 it. Certainly, as I said, the words we've heard here 19 today are encouraging. They've taken a lot of lj 20 corrective action and put a lot of attention on the 21 plant. We'll be watching their progress intently.
i 22 Unless there are other concerns, why, we'll )
23 adjourn. )
24 (Whereupon, at 3:42 p.m., the briefing was 25 concluded.)
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CERTIFICATE OF TRANSCRIBER
'J This is to certify that the attached events of a meeting, of the United States Nuclear Regulatory. Commission entitled:.
TITLE OF-MEETING: BRIEFING ON STATUS OF BROWNS FERRY-2 FLACE OF MEETING: ' ROCKVILLE, MARYIMD t DATE OF MEETING; . JULY 19, 1989
~
were transcribed by me. I further cert 1fy that said transcription is accurate and complete, to the best of.my ability, and that the
]
transcript is a true and accurate record of the' foregoing events.
1
,7 g. l '
J 2 t h. ~~ ii A e f
()
f . , Reporter's name: Peter Lynch e
1 1
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SCHEDULING NOTES
TITLE: BRIEFING ON STATUS OF BROWNS FERRY-2 1
SCHEDULED: 2:30 P.M., WEDNESDAY, JULY 19, 1989 (OPEN)
I DURATION: APPROX l-1/2 HRS l
l PARTICIPANTS: LICENSEE (TENNESSEE VALLEY AUTHORITY) 45 MINS
- OLIVER D. KINGSLEY, JR. MANAGEMENT SENIOR VICE PRESIDENT, NUCLEAR POWER A3SESSMENT
- OSWALD (lKE) J. ZERINGUE SITE OVERVIEW SITE DIRECTOR, BROWNS FERRY NUCLEAR PLANT PLANT STATUS
- HENRY WEBER TECHNICAL ENGINEERING AND MODIFICATIONS ISSUES RESTART MANAGER
- DR. MARK 0. MEDFORD
. VICE PRESIDENT AND NUCLEAR TECHNICAL DIRECTOR i
- RON SMITH, PROJECT ENGINEER BROWNS PERRY NUCLEAR PLANT
- Guy CAMPBELL, PLANT MANAGER BROWNS FERRY NUCLEAR PLANT
- FRED L. MOREADITH, VICE PRESIDENT NUCl. EAR ENGINEERING
- NICHOLAS C. KAZANAS, VICE PRESIDENT NUCLEAR ASSURANCES AND SERVICES E 15 MINS
- VICTOR STELLO, ED0
- THOMAS E. MURLEY, DIRECTOR, NRR
- DENNIS M. CRUTCHFIELD, NRR
- IN AUDIENCE
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POLICY ISSUE July 11, 1989 SECY-89-207 For: The Commissioners From: Victor Stello, Jr. ,
Executive Director for Operations i
Subject:
STATUS OF STAFF ACTIONS REQUIRED TO BE COMPLETED BEFORE RESTART 0F BROWNS FERRY NUCLEAR PLANT, UNIT 2
Purpose:
To provide the Comission with a surrnary report on the status 1 of the restart effort for Browns Ferry Nuclear Plant, Unit 2.
Bac':oround: The Browns Ferry Nuclear Plant consists of three units, each rated at 1098 megawatts electrical output. Units 1 and 3 were voluntarily shut down by the Tennessee Valley Authority (TVA) in March 1985 because of questions about the primary containment isolation leak rate testing for Unit I and reacter water level instrumentation for Unit 3. Unit 2 was in a ret cling outage at :
the time. Additional questions and concerns were subsequently raised abaut the overall adequacy of TVA's nuclear program, and Browns Ferry has remained shut down until adequate corrective actions have been defined and undertaken.
On September 17, 1985, the IUclear Reculatory Comission (hRC) i requested,pursuantto10CFR50.54(f),thatTVAsubmitinfor-l mation about its plans for correcting the problems at Browns l Ferry and for correcting problems in the overall management of l its nuclear program. The NRC also requested that this infor-J mation be submitted before TVA restarts Browns Ferry. In response to this request, TVA prepared a Nuclear Performance
. Plan, Volume 1, which identifies the root causes of the problems
' in the management of TVA's nuclear program and describes TVA's plans for correcting those problems. Additionally TVA prepared Nuclear Performance Flan, Volume 3 which identifies the root causes of problems specifically related to Browns Ferry, defines plans for correcting these problems, and respcnd. to NRC's request for information that is specific for Browns Ferry.
Taken together, these two plans provide an account of the actions that TVA is taking to improve its nuclear program for Browns Ferry. A'ithough many of the programs associated with Unit 2 are applicable to Units 1 and 3, Volume 3 is specifically directed to Unit 2. 'An evaluation of the results and conclu-sions drawn from the programs described in this volume will be
Contact:
S. C. Black, NRR/TVA 49-20796
h , % ,, .
. . 1
- 4 The Commissioners 2 necessary to determine applicability to Units 1 and 3. That evaluation will be completed before the restart of Units I and 3.
Discussion:- Since February 1967, the NRC staff and TVA have made progress in determining the issues to be resolved before the restart of Browns Ferry Unit 2. The staff has evaluated the Corporate Nuclear Performance Plan and documented its evaluation in a Safety Evaluation Report, NUREG-1232, Volume 1, dated July 1987.
The staff has been reviewing the Browns Ferry Nuclear Perfor-mance Plan, Volume 3, which identifies the root causes of prob-
- lems specifically related to Browns Ferry, describes plans for l correcting these problems, and responds to the Browns Ferry plant-specific issues raised in the 10 CFR 50.54(1) letter. The staff's safety _ evaluation report (SER) on this plan (NUREG-1232, Volume 3) was issued on April 14, 1989. However, the staff's evaluation of the plan is not complete, and supplements to this SER are scheduled. The staff also plans to closely monitor the l- plan's implementation at Browns Ferry.
Because of its continued inabi,lity to successfully meet its own projected dates for completing necessary engineering modifica-tions for Dr.it 2, TVA has concludec that it cannot meet a previously projected restart date of September 1989. A revised Unit 2 restart date will be announced in August of this year, following TVA's 60-day assessment of its ability to meet its current schedule for completing the work required for restart.
Enclosure I categorizes the status cf the key issues according tc one of the following 1our categories: (A) NRC and TVA are in agreement regarding handling cf.the probleu; hRC's review schecule is consistent with the licensee's schedule; (81) NRC and TVA are in agreement regardirg handling of the problem; TVA's schedule is not likely to be met; (02) NRC and TVA are in agreement regarding handling of the problem; NRC's review is behind schedule, or (C) questions exist regarding handling of the problem. Each issue is sumarized in Enclosure 2.
In the discussion that follows, the staff sumarizes the four major Browns Ferry issues that appear at this time to have the greatest potential for affecting the Browns Ferry restart:
environmental qualification of electrical equipment, adequacy of cable installation, cable ampacity and seismic issues.
(1) Environmental Qualification (EQ) of Electrical Equipment TVA conducted a nanagement review of the EQ programs at Sequoyah, browns Ferry, and Watts Bar in July and August 1985. This review indicated that much of the qualification i
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The Commissioners 3 documentation was not fully auditchle and, in some cases, the documentation did not fully demonstrate qualification.
To correct the EQ problem, TVA initiated an EQ project, I under which it began to evaluate, upgrade and consolidate documentation. Under this project entirely new reviews are being perfomed that are independent of previous EQ efforts at Browns Ferry. Inese reviews are now incorpo-rating expertise from TVA staff members who were instrumen-tal in the successful resolution of the EQ problem at TVA's Sequoyah facility. Significant hardware modifications still have to be implemented. The NRC staff's final inspection will be scheduled on the basis of TVA's projected date for completion of the project at Browns Ferry.
(2) Adequacy of Cable Installation Several cable-pulling concerns have been ioentified at Browns Ferry as a result of generic reviews of cenditions adverse to quality reports (CAQRs) issued at Sequoyah.
These concerns include the following:
Cable sidewall pressure may have been exceeded during installation.
Cables installed in conduits having long vertical runs may be dameged because of insufficient support.
Cable manufacturer's limitations for minimum bend radit.:. n.ay have been exceeded where pull boxes or condulets are used to facilitate installation.
TVA has ir.itiated a walkdown inspection program at Browns Ferry to evaluate each of the ebove concerns. Appropriate corrective action will bc taken where required. The program is based on test or analysis (as justified) and makes use of Sequoyah's experience.
I Most TVA inspections and walkdowns have been completed and most potential restart modifications have been identified.
l The staff is awaiting the final report from TVA.
1 (3) Cable Ampacity l
A finding by the Institute of Nuclear Power Operations '
pertaining to the Bellefonte Nuclear plant concerning the lack of design calculations shcwing the adequacy of cable arpacities resulted in a CAQR applicable to all TVA nuclear plants. As a result, TVA determined that its design l l
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The Connissioners 4-standards were incomplete and did not properly account for the effects of cable environment on cable ampacity. Since these standards were used for the initial design of cable installations 4t Browns Ferry, the potential exists for the undersizing of safety-related cable at Browns Ferry. -
Inadequate ampacity design calculations have resulted in the inability to determine if electrical current carried by cables will result in cable overheating and deterior-ation of insulation. A new electrical design standard based on various industry standards and test reports was subsequently developed and applied by TVA to cables rephced in safety-related circuits at Browns Ferry.
A program to determine the extent of non-conformance to the current standard has been developed and is being implemented. The program is based on walkdowns of in-stalled cable trays and conduits end includes 100 percent of the safety-related ac or de a Axiliary power cable in-stallations up to 15 kilovolts, Calculations are being performed to determine limiting ampacity values based on environn.ent and TVA standards. Nonconforming cable installations will be documented and tracked through the CAQR program. Appropriate corrective action related to cable empacity will be determined and planned through analysis of each nonconformance. The staff's review of this progran is underway. All potential problems and modifications have not yet been identified.
(4) Seismic Issues Concerns have surfaced related to the structural adequacy of various safety-related systems in nuclear facilities.
Some of these concerns were identified through nuclear incustry programs, such as the Long Term Torus Integrity Program and IE Bulletins 79-02 and 79-14. Other concerns were identified by TVA reviews or NRC inspections citing undocumented conditions. Resolution of these concerns will address loads oue to pressure, temperature, dead and live loads, es well as seismic loads.
TVA has undertaken programs to identify and correct deficiencies in the installed configuration. The staff has reviewed the seismic design program at Browns Ferry and agrees with the restart criteria to be used for Browns Ferry tinit 2. TVA is currently implementing these programs and undertaking the necessary modifications resulting from these programs.
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'The Commissioners 5 l'
1' The staff has performed a number of audits and inspections of the Seismic Design Program. In the civil / structural disciplines, the staff is closing the open items identi-
~fied'in its inspection reports. However, in the piping discipline, TVA's decision to change contractors has delayed the completion of the IE Bulletin 79-14 and 79-02 piping program. The staff's inspection of the implemen-tation of this piping program is required before restart of Browns Ferry Unit 2.
The fiRC staff has developed a Master Inspection Program.(MIP) for the restart of Browns Ferry Unit 2. This program has been designed to provide adequate assurance that programs in the'.
Nuclear Performance Plan, Volume 3, have been ddecuately imple-mented and that the unit can be safely started up and operated.
The stuff has identified for each major inspection activity specific prerequisites that TVA must satisfy before an inspec-tion can take place. These prerequisites will be incorporated into TVA's planning / scheduling process and when a restart schedule has been issued by TVA, the stLff will prepare a final schedule for its major inspection activities.
Conclusion:
Following the completion of the restart efforts for both of the Sequoyah units, TVA and the NRC staff have made substantial progress in resolving many of the issues required for the restart of Browns Ferry Unit 2. A small number of issues still need to be technically resolved and key program implementation must be completed before the staff will be able to determine if Browns Ferry Unit 2 is ready for restart. Major inspections must still be completed and are dependent on TVA's readiness.
~ .D mew Vic or Stello, dr.
Executive Director for Operations
Enclosures:
- 1. Status of Significant Issues Regarding Browns Ferry Unit 2
- 2. Technical Issues Summary Sheets DISTRIBUTION:
Commissioners OGC OIG GPA REGIONAL OFFICES ACRS ASLBP ASLAP SECY EDO
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ENCLOSURE I STATUS OF SIGNIFICANT ISSUES REGARDING BROWNS FERRY UNIT-2 I
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STATUS OF SIGNIFICANT ISSUES REGARDING BROWNS FERRY UNIT 2 A B1 B2 C ISSUE Browns Ferry Management Corporate Plan X Quality Assurance X Design Baseline and Verification Program /
Design Calculations Review X Seismic Design X Electrical Issues (Ampacity) X (Cable Installation and Separation) X Fire Protection X*
Environmental Qualification X*
Welding X Technical Specifications X Intergranular Stress Corrosion Cracking X Procurement Concerns X*
Maintenance X*
Restart Test Program X Procedure Upgrade X*
Operational Readiness X Operator Training X Emergency Operating Procedures X Employee Concerns X Risk Assessment (Single Foilure) X
- Inspection is still necessery a
NOTES:
A - NRC and TVA are in agreement regarding handling of the problem. NRC's review schedule is consistent with the licensee's schedule.
B1 - NRC and TVA are in agreement regerding handling of the problem. Licensee's schedule is not likely to be met (e.g., implementation problems).
B2 - NRC and TVA are in agreement regarding handling of the problem. NRC's review is behind schedule.
l C - Questions exist regarding handling of the problem (e.g., discovery stages).
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f' ENCLOSURE 2 TECHhlCAL ISSUES
SUMMARY
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. CONTENTS Page I. MANAGEMENT................................................. 1 Corporate' Plan.............................................. 1 Browns Ferry Site. Management................................ 2 Quality Assurance........................................... 3 II. ADEQUACY OF BROWNS FERRY DESIGN............................ 4 Design Buseline and Verification Program. . . . . . . . . . . . . . . . . . . 4 Design Calculations Review................................. 5 S e i sm i c De s 1 g n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 III. ELECTRICAL ISSUES.......................................... 7 Cable Installation......................................... 7 Ampacity................................................... 8 Cable Separation........................................... 10 IV. OTHER TECHNICAL ISSUES..................................... 11 Fire Protection............................................ 11 Environmental Quali fication. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 Welding.................................................... 13-Technical Specifications................................... 14 Intergranular Stress Corrosion Crecking (IGSCC)........... 15 L Procurement Concerns....................................... 16 Maintenance................................................ 17 V. RESTART READINESS.......................................... 18 Restart Test Frogram....................................... 18 Pro c edu re Upg ra de . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
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Operational Readiness...................................... 20 Operator Training.......................................... 21 Emergency Operating Procedures............................. 22 VI. EMPLOYEE C0NCERNS.......................................... 23 V I I . RI S K A SS ES SME NT. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24
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.4
- 1. MANAGEMENT ISSUE: Corporate Plan PROBLEM: In its 10 CFR 50.54(f) letter of. September 17, 1985, the NRC staff requested that TVA supply specific information regarding actions it has taken or is planning to take to improve Corporate oversight, direction, and support of nuclear power activities.
TVA ACTION: In response to the 10 CFR 50.54(f) letter, TVA submitted its r Corporate Nuclear Performance Plan (revised). This plan des-cribes actions TVA has taken to improve its overall management of its nuclear program. These actions include hiring, training, developing, and providing for the retention of experienced nuclear managers; restructuring the TVA organization to concen-trate authority for nuclear. operations under a manager of nuclear power and removing all non-nuclear activities from his purview; consolidating-the quality assurance / quality control functions; establishing clear lines of responsibility for engineering activities; reorganizing the training program; and centralizing licensing activities. In addition. TVA has' taken steps to imprave employee confidence in'TVA's nuclear management.
NRC RESPONSE: The staff has concluded that, from a programmatic stanopoint.
TVA has acceptably addressed the corporate-level concerns raised by the staff in the 10 CFR 50.54(f) letter. Since the TVA corporate plan is programmatic, its effectiveness depends on its implementation, which the staff is monitoring. Staff observations to date are generally favorable.
STATUS: The program review is complete. Implementation is currently being monitored. The staff's evaluation was issued in July 1987 in NUREG-1232, Volume 1.
POTENTIAL PROBLEMS: None are anticipated.
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ISSUE:- Browns Ferry Site Management PROBLEM:
In its 10 CFR 50.54(f) letter of. September 17, 1985, the NRC staff requested that TVA supply specific.information regarding actions it has taken or is planning to take to improve manage-ment oversight, direction, and support of Browns Ferry activities.
TVA ACTION: In response to the 10 CFR 50.54(f) letter, TVA submitted the Nuclear Performance Plan (NPP) for Browns Ferry-(Volume 3 of the NPP)...In this plan, TVA describes corrective actions to (1) restructure the Browns Ferry site organization so that it.is compatible with the revised corporate structure, (2) prepare position descriptions that delineate areas of responsibility and authority for site management, including reporting channels and-
-interfaces;,(3)definetrainingactivities,suchasshift technical advisor training or' senior reactor operator-license training for managers; and (4) establish specific site improve-ments, such as a site licensing group.
NRC RESPONSE: The staff is reviewing and monitoring its-implementation. The staff's evaluation' of Browns Ferry site management will be included in a supplement to NUREG-1232, Volume 3.
STATUS: The recent hiring of key senior managers is a strength, and it appears that a strong team is coalescing.
POTENTIAL PROBLEMS: None are anticipated.
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' ISSUE: Quality Assurance' PROBLEM: .In its 10 CFR 50.54(f) letter of September 17, 1985, the NRC staff referred to a number of instances of poor performance in the quality assurance area, including three successive Systematic-Assessment of Licensee Performance periods during which the rating in this area was Category 3 (which means that increased NRC attention is warranted) at both Sequoyah and Browns Ferry.
TVA ACTION: In response to the 10 CFR 50.54(f) letter, TVA revised its QA-topical report to include the following changes:-(1) restructur-ing the nuclear QA organization to include a site representative.
at each site who reports to the Director of Nuclear Quality Assurance. (2) consolidating all nuclear QA and quality control (QC) functions under the Director of Nuclear Quality Assurance, (3) adding an engineering assurance organization for auditing TVA engineering work, and (4) increasing emphasis on corrective.
action and root cause analysis programs.
In March-1989. TVA submitted a new QA program plan designed to replace the approved topical report. This new plan represents a-significant change in philosophy of TVA's QA program, and-includes a reorientation of 0A/QC efforts toward a " graded approach.." ' Additionally, TVA submitted an organizational topical report that reflects recent changes in TVA's organi-zation including integration of the QA functions of the engineering assurance organization under. the nuclear QA organi-zation.
NRC RESPONSE: In January 1987, the staff approved the revised QA program and QA organization described in the revised QA topical report. It is conducting inspections to verify program implementation and to evaluate the conditions' adverse to quality report process.
The staff is reviewing the new QA program plan and the organi-zational topical report. The plan appears to reduce the scope of the previously approved 0A program.
STATUS: TVA has implemented the QA program approved in January 1987.
The staff has completed a quality verification functional inspection during which problems were identified that have to be resolved before restart.
The staff has performed an initial review of the new QA program plan and has directed TVA to not iaplement the new plan until NRC approval is granted. The st. '.f has requested additional information and expects to make a decision by late 1989. The organizational topical report is also undergoing staff review and approval is expected in the fall.
POTENT!AL PROBLEMS: Future inspections and staff review of the proposed QA plan and organizational changes may identify additional restart requirements.
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lb II. ADEQUACY.OF BROWNS FERRY DESIGN
.1SSUE: Design Baseline and Verification Program PROBLEM: Questions were raised during a review conducted'for TVA by-Gilbert Commonwealth in 1985 regarding the adequacy of the existing TVA design control process. Examples included missing calculations, incomplete design documentation, and failure to update as-built drawings to reflect plant configuration.
TVA ACTION: TVA developed the design baseline and verification program (DBVP) to reestablish the design baseline for the Browns Ferry facility. This pro configuration, (2) gram includes (1) establishing the plantreconstruct ing and evaluating modifications, (4) defining and performing required tests to verify the function of DBVP systems, and (5) implementing modifications developed from this program.
Under this' program, design criteria documents, as-configured drawings, and test requirement documents have been issued for the a:sociated DBVP systems.
NRC RESPONSE: The staff has conducted a limited-scope inspection of con-trolled configuration drawings and identified no significar.t concerns. It performed a programmatic inspection of the DBVP in.
October 1987 and April 1988. The staff concluded that the DBVP contains the essential elements and, if properly implemented, its goals and objectives will be achieved. It recently con-ducted an inspection of controlled drawings and the calcula-tional portion of the DBVP and determined that certain findings way require TVA followup before restart.
STATUS: The program review is complete. The staff's evaluation is included in the NUREG-1232, Volume 3.
POTENTIAL PROBLEMS: None are anticipated.
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-ISSUE: Design Calculations Review TVA instituted a review of essential design calculations to ~
PROBLEM: {
verify that-the calculations existed and were adequate to support the design of Browns Ferry. As a result of the "
review, TVA estimates that a large number of calculations are not retrievable.
TVA ACTION: TVA has initiated a review of the engineering calculations in
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the electrical, nuclear, mechanical, and civil areas. In the-electrical and mechanical areas, 100 percent of the calculations will be reviewed. The civil and nuclear I
calculations will be sampled in accordance with nationally l accepted sampling criteria (Nuclear Construction Issues Group,NCIG-02).
l NRC RESPONSE: The staff is reviewing TVA's calculations program. It con-ducted on inspection of the DBVP aspects of the calculations program in April 1988 and March 1989. The staff has not yet identified any major deficiencies essociated with the calculc-tions program.
1 STATUS: The program review is complete, POTENTIAL i
PROBLEMS: Review of the program implementation is still ongoing and may result in additional modifications that could affect restart.
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.l ISSUE: Seismic Design PP.3BLEM: Deficiencies were identified in regard to the torus; piping and piping supports; cable tray supports; conduit supports; heating, ventilation, and air conditioning ducvwork; drywell steel platforms; miscellaneous steel; Class II over I features; secondary containment penetrations; and miscellaneous civil design issues. In its 10 CFR 50.54(f) letter of September 17, 'i 1985, the NRC staff requested that TVA supply information regarding the programs being used to evaluate some of these issues in regard to seismic adequacy.
TVA ACTION:_ In response to tt 10 CFR 50.54(f) letter, TVA submitted program descriptions in/ ie August 1986 Nuclear Performance Plan (NPP) which was subseq.ently revised in July 1987, and in a-separate April 1987 submi "al. Program summary and review meetings were held with the.NR in September 1987 and February 1988. Ongoing dialogue cetween ivA and the staff. continues. TVA has initiated comprehensive programs to review these issues and determine acceptability for operation before restart.
NRC RESPONSE: The staff's review of TVA's program implementation is ongoing.
STATUS: TVA has identified a wide range of seismic design issues in Volume 3 of the NPP. It has submitted programs for the review and resolution of these issues to the NRC for review and appro-val, Additional resolution of outstanding items resulting from the staff review is still required. The staff has issued a safety evaluation (SE) for cable troy supports. The results of additional SEs will be included in supplements to NUREG-1232 Volume 3.
POTENTIAL PROBLEM!,: Most technical issues have been resolved, or the resolution required has been agreed to by TVA. Corrective actions are under way. The implementation of the piping program by TVA in response to IE Bulletins 79-14 and 79-02 has been further delayed, and final staff inspection is required before restart.
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III. ELECTRICAL ISSUES ISSUE: Cable Installation PROBLEM: A number of TVA employee concerns at Watts Bar and/or at Sequoyah indicated that cable-pulling practices violated pro-cedures and/or procedures were not adequate to ensure cable integrity following installation. Cable damage during instal-lation may have occurred from overtensioning of cables pulled through conduits or raceways, cables pulled through conduits-with existing cables' (pullbys) in the conduits, cable jamming, lack of support of cables in vertical conduits, and short radius bending of the cable. This condition may also 8 e applicable at
-Browns Ferry. No employee concerns exist that hre specific to Browns Ferry..
TVA ACTION: To ensure that cables were properly installed at Browns Ferry, TVA.is using the resolution for the cable installation issues at Sequoyah to bound the issue at Browns Ferry. To accomplish this, TVA is proposing to demonstrate that the Browns Ferry cable installation requirements and insulation material are similar to those at Sequoyah. During walkdowns conducted by TVA, damage has been observed in some cables.
i-NRC RESPONSE: The staff will review TVA's proposed resolution followinc submittal.of this resolution and receipt of TVA's final report on damaged cables. The staff has inspected the damaged cable at the site and preliminarily agrees with TVA's propesc:
resolution as conveyed to th.' ctaff in several meetings.
STATUS: TVA is preparing its final report on the cable installation issues.- The staff's evaluation will be included in a supplement to NUREG-1232, Volunie 3.
POTENTIAL PROBLEMS: None are anticipated.
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-ISSUE:. Ampacity PROBLEM: Findings by'the Institute of Nucleer Power Operation on the Bellefor,te plant revealed a lack of design calculations that demonstrate the adequacy of cable ampacity. These findings were confirmed by the Bellefonte electrical evaluation team and calcu-lations were performed to verify the adequacy of cable ampacity.
- As a result of the Bellefsnte review, cable ampacity was also evaluated at Browns Ferry and Sequoyah. These plants also did not have design calculations to demonstrate the adequacy of cable ampacity.
TVA ACTION: TVA has issued design standard ampacity tables for auxiliary and control power cables (0-15,000 volts) to provide the minimum requirements necessary for proper sizing of electrical cables.
TVA has established a two-part progran to determine the adegaacy of installed cables at Browns Ferry. In Part I, all Class 1E cables scparately routed and non-Class-IE cables routed with Class 1E cables are being reviewed. Specific criteria have been provided for the evaluation of the cables to substantiate their acceptability on the basis of actual and allowable ampacity requirements. The objective is to provide firm justification for operation. Those cables for which operation is not justi-fied will be replaced.
The ampacity program at Browns Ferry unlike the Sequoyah program assumes credit for load diversity of cable in raceways and time diversity for cables not simultaneously required to be energized.
TVA is conducting tests to justify the load diversity whereby some overloaded cables can remain acceptable when mixed with lightly loaded cables to ensure proper heat dissipation and prevent cable insulation damage.
Part II of the program will involve a detailed evaluation of all cables not reviewed in the Phase I sampling program. ~The purpose of Part II is to ensure that all plant power cables are adequately sized and appropriately documented.
NRC RESPONSE: The staff is continuing its review of the empacity program at Browns Ferry.
STATUS: TVA is performing calculations to determine limiting ampacity values based on environment. The edequacy of safety-related auxiliary power cable installations will be established before Unit 2 restart.
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Iu , .. l ISSUE: Ampacity(continued)
I POTENTIAL PROBLEMS: .TVA's cable ampacity program has not yet demonstrated adequately conservative bounding conditions for load diversity derating
. factors. The staff and its consultant (Sandia National Laboratory) have conducted cable-loading simulations similcr to those conducted by TVA, and the results do not agree with TVA's findings on the adequacy of derating factors. The staff and TVA are reviewing potential simulation modeling differences.
The operability of the cables supplying safety related equipment cannot be shown for the cables intended design life.
No basis exists which shows that cables can dissipate their generated heat during use, without overheating and thus over-stressing the cable insulation and causing cable insulation breakdown.
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' ISSUE:- Cable Separation ]
I PROBLEM: TVA has identified instances.uhere electrical cGle separation j 1:
i' requirements identified:in the Final Safety' Analysis Report have :i
'not been met. j TVA ACTION: TVA bcs evaluated a statistically significant sample of installed !
cabit s to confirm that cables that violate the separation requirements will not affect plant safety. TVA, by letter dated June 9,1989, has submitted the results of its evaluation for staff review. :3 1
i NRC RESPONSE: 'On May.11, 1989, TVA presented to'the staff its approach for !
resolving the issues and the preliminary results of its evaluation.
The staff, on the b' asis of TVA's presentation, has reached a preliminary conclusion that TVA's approach to resolving the issues and the evaluation results are acceptoble.
STATUS: The staff is reviewing TVA's submittal ' dated .bne 9,1989.
-POTENTIAL PROBLEMS: None are anticipated.
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- i. IV._.0THER TECHNICAL' ISSUES ISSUE:' Fire Protection
' PROBLEM: -NRC approval of the fire protection program in compliance with q 10 CFR Part S0, Appendix R. is required for restart of Unit 2. l TVA ACTION: TVA submitted its analyses of safe shutdown systems in compliance with Appendix R in January 1986. Five exemptions-from Appendix R requirements were requested and granted. TVA' has submitted revised technical specifications to support
- Appendix R compliance for Unit 2 operation with Units I and 3 shut down. TVA is also finishing extensive modifications in
. fire protection systems in preparation for the Appendix R fire protection inspection scheduled for July 1989.
NRC RESPONSE: The staff approved and granted exemptions to Appendix R requirements on October 21, 1988. In December 1988, it issued an SER on post-fire shutdown systems. It provided its review of deviations from the National Fire Protection Association (NFPA) ccdes to TVA on December 14, 1988. It completed an inspection l
._to determine compliance with Appendix R in regard to safe 1 shutdown capability _in May 1989. No significant findings or violations were noted.
STATUS: The staff has requested docketing of additional.information
-required to support the revised Appendix R technical specifica-tion submittal and the fire protection part of the Appendix R' inspection scheduled for July 1989.
The NRC staff has not approved:
(1) Appendix P. safe shutdown technical specifications (2) The fire protection program in compliance with Appendix R (3) NFPA code deviations in cable spreading room (TVA evaluation is needed)
In addition, nine inspection followup items and one unresolved issue outstanding from the May 1989 inspection need resolution.'
POTENTIAL PROBLU None are anticipated. ,
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.. ,n ISSUE: Environmental Qualification PROBLEM: Insufficient documentation existed to demonstrate that electrical equipment at the plant was environmentally qualified as required by 10 CFR 50.49.
TVA ACTION: TVA has developed an upgraded environmental qualification (EQ) program to identify equipmant, specify environments, verify equipment in the field, document equipment qualification, specify maintenance requirements, maintain EQ binders, and replace unqualified equipment if necessary. The necessary documentation is being completed and verified in the field.
Any required modifications will be completed before restart.
NRC RESPONSE: The staff will review TVA's EQ effort before restart.
STATUS: The staff performed one EQ inspection in May 1988. Some problems were identified, including a lack of lessons learned from Sequoyah, and as a result the program has not progressed sufficiently to support the anticipated restart schedule.
The stoff is waiting for TVA to further complete its program before scheduling another EQ inspection before restart. Com-pletion of the EQ program is the critical path for restart.
POTENTIAL PROBLEMS: Potential problems are qualification of motor control centers in the reactor building ar.d qualification of electrical cables located in the drywell, but not installed in conduits.
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. ISSUE: Welding PROBLEM:
Concerns were raised at the Watts Bar site regarding TVA's inspection practice and welding rod control program. These concerns implicated the quality of weldments and the capability of the welds to perform their function.
TVA ACTION: TVA is conducting a reassessment program in two basic phases.
Phase I consists of programmatic review of commitments and procedures for implementing the commitments; Phase II consists of a physical reinspection of sample welds.- Phase II also consists of an evaluation of the implementation of procedures and the adequacy for service of installed weldments, including correction of any problems.
NRC RESPONSE: The TVA welding programs are administered by a common project group. The NRC staff has reviewed the Sequoyah program and found it acceptable. Phase I and Phase II of the welding project for Browns Ferry have been submitted and have been reviewed by the NRC staff. An NRC staff inspection of Phase I conducted in April 196' showed that the necessary elements existed to trans-late welding commitments into specifications and drawings. The staff conducted an inspection of Phase II in May and June 1988.
It did not note any significant deficiencies associated with TVA's welding reviews.
STATUS: The staff's. review of the welding' activities at Browns Ferry (Phases I and II) found the program and its implementation to be acceptable as supplemented by TVA's. followup corrective actions. The staff has prepared a safety evaluaticn report on the Browns Ferry welding activities.
POTENTIAL PROEi. EMS: None are anticipated.
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4:s : 3; ISSUE: Technical-Specifications PROBLEM:
TVA and the NRC have identified and agreed on a list of 36 technical specification (TS) changes requiring approval by-the NRC before Browns Ferry can enter the startup mode.- These' changes involve clarifications, corrections, modifications and organizational and regulatory changes.
TVA ACTION: TVA has submitted 32 of the required TS changes for staff-review. The other changes are scheduled to be submitted so as to allow time for NRC review and TVA implementation before restart.
NRC RESPONSE: Of the 32 restart TS changes submitted, the staff has approved 24 of them. Eight packages are still under' staff review.
STATUS: The preparation and review effort is in progress at TVA and the NRC. The staff expects to issue the last restart TS amend-ment in the fall of 1989. TVA implemented a TS verification program under its quality assurance organization. The staff will aucit TVA's program.
POTENTIAL PROBLEMS: All potential restart TS changes resulting from other programs (i.e., design baseline verification, calculations, ampacity) have not been identified.
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l .. . 3 a g 4 4 ISSUE: Intergranular Stress Corrosion Cracking PROBLEM: Intergranular Stress Corrosion Cracking (IGSCC) is evident to some degree at all three units. The IGSCC mitigation options are primarily replacement, weld overlay, induction heating stress improvement (IHSI), and/or hydrogen water chemistry. IE Bulletins 82-03 and 83-02 and Generic Letters 84-11 and 88-01 were issued by the NRC staff to address this problem.
TVA ACTION: TVA has inspected 100 percent of all accessible / susceptible welds in the recirculation, core spray, reactor water cleanup, and residual heat removal (RHR) systems for Units 1, 2, and 3.
Units 1 and 3 were inspected to the requirements of IE Bulletin 83-02 in 1983. The staff also recommended that all of the remaining IHSI-treated welds (71) be inspected before restart.
During this inspection, which TVA completed, additional flaws were identified.
The IGSCC mitigation and repair measures for the recirculation and RHR piping that are implemented at Unit 2 include weld overlay, weld replacement, and IHS1 treatment of welds with shallow cracks. IHSI was implemented on most susceptible welds that could be treated successfully. TVA has replaced all ten recirculation inlet safe ends and two jet pump instrumentation safe ends on Unit 2. Replaced safe ends have undergone IHSI.
Mitigation steps will be teken for Units 1 and 3 before restart.
TVA recognized the importance of hydrogen water chemistry in mitigating the IGSCC problem, and interface connections are being installed on Unit 2 this outage to allow introducti>n of hydrogen water chemistry in mid-cycle.
NRC RESPONSE: The staff performed an onsite review of the Browns Ferry IGSCC mitigation program. The staff has concluded that TVA must take some further actions in order to adequately address IGSCC at Browns Ferry. The staff has clso completed an inspec-tion of the implementation of Generic Letter 88-01 at Unit 2.
STATUS: k' eld inspections performed ef ter the post-replacement IHS1 of the Unit 2 safe ends are complete. Post-IHSI inspections have recently identified additional indications requiring repairs before restart.
POTENTIAL PROBLEMS: None are anticipated.
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l ISSUE: Procurement Concerns PROBLEM: From TVA Nuclear Safety Review Staff reports between 1983 and 1985 and during an inspection in November 1986, the NRC staff determined that TVA had procured replacement parts for safety-related equipment without appropriate procurement controls to ensure that replacement items were tested or qualified for their safety-related applications.
TVA ACTION: TVA has undertaken an extensive program to review and evaluate past and present procurement of replacement items. TVA is establishing qualification of items or replacing items on equipment required for restart on a priority basis.
NRC RESPONSE: The staff is reviewing TVA's programmatic approach. An inspec-tion of program implementation will be scheduled before restart.
STATUS: The program review is in progress. The staf f's safety evaluation will be included in a supplement to NUREG-1232.
Volume 3. The approach at Browns Ferry is similar to the approved approach at Sequoyah.
l POTENTIAL PROBLEMS: None are anticipated.
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-.. ;3 ISSUE: Maintenance l PROBLEM: Programmatic problems in site maintenance were previously identified in Systematic Assessment of Licensee Performance (SALP) and inspection reports. This area received repeated SALP Category 3 ratings. The problems were attributed to such factors as poor supervision of work activities, inadequate planning, ineffective root cause analysis, inadequate training, and poor coordination between different organizations to support maintenance activities.
TVA ACTION: TVA has developed and is implementing a comprehensive maintenance improvement program that identifies several essential improve-ments. The program encompasses needed improvements identified by TVA and by the Institute of Nuclear Power Operations in its evaluations and recommendations and deficiencies identified by the staff. Program elements being improved include programmatic espects of maintenance, preventive failure analysis, maintenance, procedures upgrade, training, personnel certification cualifica-tions, and facilities for the conduct of maintenance. To ensure success at Browns Ferry, TVA has committed resources and has established a staff of senior line managers with authority to develop and implement the maintenance improvement program.
NRC RESPONSE: TVA made a programmatic presentation to the NRC staff and the program was favorably received by the NRC. The staff is plonning individual and team inspections to verify program implementation.
STATUS: The program is ongoina. Implem3ntation is currently being monitored.
The staff's safety evaluation will be included in a supplement to NUREG-1232, Volume 3.
( POTENTIAL l PROBLEMS: Improvements have been made in the conduct of maintenance at Browns Ferry. However, the overall effectiveness of the maintenance program is being affected because of a lack of permanent maintenance manager. Implementation of improve-l ments in the area of maintenance naay adversely affect the l
restart schedule. Following a recent TVA audit of maintenance activities, they requested that the NRC Maintenance Team Inspection be delayed until at least the end of September 1989.
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V. RESTART READINESS ISSUE: Restart Test Program PROBLEM: Because of the prolonged plant shutdown and extensive modifica-tions, a comprehensive restart test program is required to s ensure plant systems are capable of meeting their safe shutdown
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TVA ACTION: TVA has developed a restart test program that includes individual and integrated system testing and backup control tests. Criticality and power ascension testing are implemented under separate test programs. Under the design baseline and verification program, TVA developed the system test requirements necessary to satisfy the safe shutdown analysis. The program involves the development of test procedures and where possible utilizes existing operation and surveillance instructions. A summary description cf the program was submitted on July 13, 1987.
NRC RESPONSE: The staff has reviewed and approved TVA's restart test program for Unit 2.
STATUS: Restart tests are being conducted and evaluated.
POTENTIAL PROBLEMS: Testing may revee' needed equipment modifications. For example, testing of the control air system and diesel generators identified equipment and system deficiencies.
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'Y 4 IS' SUE: Procedure Upgrade PROBLEM: TVA identified a number of deficiencies and weaknesses in the L procedures.
.TVA ACTION: TVA has implemented a procedures upgrade program to address'these problems. The near-term portion of this program is. focused on resolving deficiencies in the procedures that affect the safe L
. restart, operaticn, and shutdown of the plant. Procedures that are not required for restert, operation, and shutdown will be upgraded as part of the long-term program. The program requires a review of procedures for technical content, administrative controls, regulatory requirements' and performability.
NRC RESPONSE: The staff has conducted inspections of this program and will schedule additional inspections to review completed procedures ds they become available. The staff generally agrees with.the L TVA program.
STATUS: The NRC staff's evaluation of procedures is ongoing. The staff's safety' evaluation has identified weaknesses in the verification and validation (V&V) of procedures. TVA's response has been a limited enhancement of its V&V activities. Overall the pro-cedure upgrade program has resulted in some improvement in the workability of procedures. However, on the basis of the large number of safety system actuations resulting from' procedural problems and NRC inspection findings, the procedures at Browns Ferry require significant upgrade before restart. The staff has schedult d followup implementation inspection before restart.
POTENTIAL PROBLEMS: Upgraded procedures will be needed to support the restart effort. The schedule for restart may be offected if the program is not implemented in a timely manner.
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,, 5 ISSUE: Operational Readiness PROBLEM: A comprehensive effort to assess Browns ferry's material con-dition and personnel readiness to support safe plant restart and operation is required because of the extended outage changes in the site and support organizations, realignment of responsi-bilities, and implementation of new programs to correct past problems.
TVA ACTION: TVA has established programmatic guidance for verifying opera-tional readiness. TVA is currently documenting comitments c.nd statements of intention from the Browns Ferry Nuclear Performance Plan to be used to verify adequate implementation of {
the plan. TVA is also defining performance objectives, criteria, o and evaluation plans to ensure that site organizations function effectively and are prepared for plant restart and operation.
hRC RESPONSE: The staff will independently essess TVA's readiness for restart.
It is currently reviewing TVA plans for the operational readiness program as described in the Browns ferry Nuclear Performance Plan.
The staff's evaluation will be included in e supplement to NUREG-1232, Volume 3.
STATUS: Efforts are ongoing.
POTENTIAL PROBLEMS: None are anticipated.
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ISSUE: Operator Training PROBLEM:: From the results of NRC-administered requalification examinations, the NRC staff' determined that the TVA operator training program f had several programmatic weaknesses, i TVA ACTION: TVA has undertaken a comprehensive one-time training program to upgrade all licensed operators. .Beginning in 1987, TVA increased its annual requalification training for licensed operators from at least four to six weeks. The TVA Browns Ferry simulator was moved to the Browns Ferry site to improve operator access to.
the simulator and to ellow for more effective overall training.
The licensed operator training' program was accredited by the Institute of Nuclear Power Operation'in March 1986.
NRC RESPONSE: The' staff finds TVA's programmatic approach is acceptable.
Inspection of the reactor operator training program is complete.
Passing; rates on.the NRC-administered requalification examina-tions for TVA operators who completed the upgrade course were greatly improved. The overall passing rate was 80 percent or-better.
STATUS: NRC's requalification testing of TVA operators is ongoing. ..The staff's evaluation wili te included in a supplement to NUREG-1232, Volume 3. There are a sufficient number of operators qualified.
for Unit 2 restart.
POTENTIAL PROBLEMS: None are anticipated.
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ISSUE: ' Emergency Operating Procedures (EOPs)
PROBLEM: Browns Ferry, Units.I and 3 will not be operational when Unit 2 is restarted. The emergency operating procedures.(EOPs) which.
have been finalized were prepared for three operational units.
Some actions may be. required to assure that'the equipment, staffing and procedures will satisfy emergency requirements under the Unit 2 only startup conditions.
TVA ACTION: TVA has been modifying equipment and revising procedures for J emergency operation in response to regulatory requirements.
In the final E0Ps, TVA is including responses to an NRC inspection conducted in August 1988.
l NRC RESPONSE: An NRC inspection team conducted an onsite review and audit of
! the Browns Ferry E0Ps in . August 1988. This was one of the inspec--
tions being conducted by four NRC teams to examine the results of the NRC long-term program for upgrading E0Ps and the applica-tion of procedures generation packages. The staff proviced the
- findings of the inspection at Browns Ferry to TVA for action.
TVA's response to these fir. dings has been received and is under review.
l STATUS: The staff is planning a followup inspection to be conducted approximately two to three months before Unit 2 restart to confirm TVA's corrective actions and the readiness of the Browns Ferry staff for Unit 2 operation.
POTENTIAL PROBLEMS: None are anticipated.
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. 4 VI ' EMPLOYEE CONCERNS.
ISSUE:- - Employee Concerns
' PROBLEM: Under the employee concerns program initiated at Watts Bar in 1985 nore than 5800 employee concerns.were identified. Approxi--
mately 700 safety end non-safety-concerns identified under.the program were applicable to Browns Ferry by direct reference or generic applicability.
TVA RESPONSE: TVA has divided the concerns into .31ne categories: construc-tion, engineering, operations, materials control, welding, quality assurance, industrial safety, management and personnel, and harassment and intimidation. Investigations and corrective actions for Browns Ferry are being documented and submitted in
-subcategory reports. . Herassment and intimidation concerns are being addressed separately by the TVA Inspector General.
Concerns identified under the new employee concerns program, which was initiated on February 1,1986, are being investigated and resolved separately.
NRC RESPONSE: The staff's initial inspection in 1987 showed that there were no major findings.
STATUS: Preparation of the subcategory reports has resulted in the -
issuance of 224 corrective action tracking documents. The staff is beginning to review a sampling of the licensee's resolution of employee concerns.
POTENTIAL PROBLEMS: Resolution of some concerns may require TVA to do additional work before restart.
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- .A' 41 VII. RISK ASSESSMENT.
. ISSUE: Risk Assessment PROBLEM: The NRC staff requested, by letters dated June 17 and August 15,.
1986, that TVA provide the draft probabilistic risk assessment (PRA) for Browns Ferry.
TVA ACTION: TVA provided the draft PRA on November 20, 1986. It also.
.provided a. summary report of new calculations based on its revised draft PRA.
NRC RESPONSE: The NRC staff provided the results of its limited-scope review of the draft PRA to TVA on October 1, 1987, as well as its. review of the summary report that included an audit of the revised PRA.
STATUS: The staff performed an audit of the newly revised draft PRA in November 1988 and sent one significant finding of this audit to TVA for resolution before restart. .TVA's response to-this finding is currently under staff review..
POTENTIAL PROBLEMS: None are anticipated.
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