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EA-04-063- Browns Ferry (Tennessee Valley Authority)May 12, 2004 EA-04-063 Tennessee Valley Authority
Dear Mr. Scalice: This refers to the inspection completed on February 13, 2004, involving recovery activities at Tennessee Valley Authority's (TVA) Browns Ferry 1 (BF1) reactor facility. The results of the inspection, including the identification of an apparent violation of 10 CFR 50, Appendix B, Criterion V, were forwarded to you by NRC letter dated April 6, 2004. Based on the results of the inspection, a pre-decisional enforcement conference was held on April 28, 2004, in the NRC's Region II Office in Atlanta, Georgia, with members of your staff to discuss the apparent violation, its significance, root causes, and your corrective actions. A listing of conference attendees, material presented by the NRC, and material presented by TVA are included as Enclosures 2, 3, and 4, respectively. Based on the information developed during the inspection, and the information presented at the conference, the NRC has determined that a violation of NRC requirements occurred. The violation is cited in the enclosed Notice of Violation (Notice), and the circumstances surrounding it are described in detail in the subject inspection report. The violation involves four examples of a failure to adhere to the requirements of 10 CFR 50, Appendix B, Criterion V. All four examples were associated with the BF1 Long-Term Torus Integrity Program, and involved: failure to evaluate or incorporate numerous deficient welds into Deficiency Fix Requests sketches; failure to perform numerous repairs on the correct welds; omission of numerous welds requiring repair from Work Orders, and failure of Quality Control (QC) to independently verify the correct location of numerous weld repairs. At the conference, TVA acknowledged the errors, discussed its root cause and extent of condition reviews, and corrective actions. As described in NRC Manual Chapter 2509, "Browns Ferry Unit 1 Restart Project Inspection Program", and explained during the conference, BF1 is not considered to fall within the scope of the Commission's current "General Statement of Policy and Procedures for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600, for commercially operating nuclear power plants. As such, traditional enforcement is in effect for the restart of BF1 for violations in those cornerstones which cannot be monitored under the Reactor Oversight Program. The significance of violations will be evaluated in accordance with 10 CFR Part 2 and other applicable enforcement guidance, including Supplement II of the Enforcement Policy. In this case, the violation identified above involves TVA's Quality Assurance program for construction related to a single work activity (BF1 Long-Term Torus Integrity Program), and involves a failure to conduct adequate audits/reviews and take prompt corrective action on the basis of such audits/reviews. In addition, the errors were associated with multiple examples of deficient construction due to inadequate program implementation. As such, the NRC has concluded that the violation is appropriately characterized at Severity Level III. In accordance with the Enforcement Policy, a base civil penalty in the amount of $60,000 is considered for a Severity Level III violation. Because your facility has not been the subject of escalated enforcement action within the last 2 years, the NRC considered whether credit was warranted for Corrective Action in accordance with the civil penalty assessment process in Section VI.C.2 of the Enforcement Policy. TVA's immediate corrective actions included the development and implementation of a plan to systematically verify the scope of torus weld problems. The plan consisted of training personnel on torus orientation and the proper use of sketches, independent review of the welds that were to be repaired to ensure they were identified in work documents, a walk-down of the torus welds that did not require repair to verify acceptability, and a determination of the cause of each example of the violation. Other corrective actions included the verification and revision of torus sketches, the placement of placards inside the torus to aid in orientation, revision of weld data sheets and weld maps, establishment of a single point of contact to control sketches, meetings with QC inspectors to stress the critical importance of independence, additional training for QC inspectors, increased Nuclear Assurance oversight of field activities, the assignment of dedicated resources for focused oversight of QC and other disciplines, and the conduct of a self-assessment of BF1 Nuclear Assurance oversight effectiveness. Based on these and other corrective actions discussed at the conference, the NRC concluded that credit was warranted for the factor of Corrective Action. Therefore, to encourage prompt and comprehensive correction of violations and in recognition of the absence of previous escalated enforcement action, I have been authorized to propose that no civil penalty be assessed in this case. However, similar violations in the future could result in further escalated enforcement action. Issuance of this Notice constitutes escalated enforcement action, that may subject you to increased inspection effort. You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. The NRC will use your response, in part, to determine whether further enforcement action is necessary to ensure compliance with regulatory requirements. In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosures, and your response will be made available electronically for public inspection in the NRC Public Document Room or from the NRC's document system (ADAMS), which is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, the response should not include any personal privacy, proprietary, classified, or safeguards information so that it can be made available to the Public without redaction. The NRC also includes significant enforcement actions on its Web site at www.nrc.gov; select What We Do, Enforcement, then Significant Enforcement Actions.
Docket No. 50-259 Enclosures: James E. Maddox, Vice President Ashok S. Bhatnagar General Counsel Thomas Niessen, Acting General Manager Michael D. Skaggs, Plant Manager Mark J. Burzynski, Manager Timothy E. Abney, Manager State Health OfficerAlabama Dept. of Public
Health Chairman Jon R. Rupert, Vice President Robert G. Jones, Restart Manager
NOTICE
OF VIOLATION
During an NRC inspection completed on February 13, 2004, a violation of NRC requirements was identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below. 10 CFR 50, Appendix B, Criterion V, requires activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances, and shall be accomplished in accordance with these instructions, procedures, or drawings. Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished. Contrary to the above, as of February 13, 2004, instructions, procedures, or drawings were inadequate or were not implemented for weld repairs to ECN P-0093 torus modifications as described below:
This is a Severity Level III Violation (Supplement II). Pursuant to the provisions of 10 CFR 2.201, Tennessee Valley Authority is hereby required to submit a written statement or explanation to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, within 30 days of the date of this Notice of Violation and Proposed Imposition of Civil Penalty (Notice). This reply should be clearly marked as a "Reply to a Notice of Violation; EA-04-063" and should include: (1) admission or denial of the alleged violation, (2) the reasons for the violation if admitted, and if denied, the reasons why, (3) the corrective steps that have been taken and the results achieved, (4) the corrective steps that will be taken to avoid further violations, and (5) the date when full compliance will be achieved. Your response may reference or include previously docketed correspondence, if the correspondence adequately addresses the required response. If an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked or why such other action as may be proper should not be taken. Consideration may be given to extending the response time for good cause shown. Because your response will be made available electronically for public inspection in the NRC Public Document Room or from the NRC's document system (ADAMS), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the public without redaction. ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.390(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21. In accordance with 10 CFR 19.11, you may be required to post this Notice within two working days. Dated this 12th day of May 2004 |
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