Tanner, Alabama -Thursday, August 9, 2012. The Nuclear Regulatory Commission (NRC) conducted a Supplemental Inspection Status reporting session to the "Red Flag" finding which the NRC placed on Tennessee Valley Authority's (TVA) Browns Ferry Nuclear Power Plant operators for failing to correct reoccurring problems of a stuck valve in the Residual Heat Removal (RHR) System of Browns Ferry Unit 1.The purpose of the meeting was to discuss the status of TVA’s preparations for Part 3 of the NRC’s supplemental inspections of the plant associated with the "Red Flag" finding. Public input was allowed at the end of the business session.
The supplemental inspection processes are called a 95003 process - it is a 3 part process: Part 1- Component Testing Programs, completed September 2011; Part 2- Maintenance Programs, completed December 2011, according to the TVA and the NRC; Part 3 formal 95003 completion - the TVA will notify the NRC when they are ready for the final part 3 inspection process.
The entire process includes a series of comprehensive, intrusive and diagnostic procedures and inspections which are performed by the NRC to insure the nuclear reactor problem(s) identified are corrected; all programs and processes are reviewed during the final inspection.
According to the NRC, the program's correction process is also designed to insure the nuclear facility operator does not repeat the same failure. Athens News Courier report of the session: http://enewscourier.com/local/x1555256858/TVA-says-no-inspection-until-improvement-at-Browns-Ferry-plant
Present at the Supplemental Inspection Status report session were the NRC Region 2 officials (pictured below)
(photo by G. Morgan)
and TVA Nuclear Power Executives (pictured below).
(photo by G. Morgan)
IS PART 2 OF THE 95003 PROCESS ACTUALLY COMPLETE?
A control room fire occurred at the Unit 3 Reactor in January 2012 due to a capacitor failure in the antiquated analog "Warning/Annunciator Panel's" power supply. The TVA reported in its Corrective Action Plan the capacitors have a life expectancy of 8 years. The parts had been in place for more than 30 years. Repetitive failures of the parts were reported in 2008 and 2009. A Corrective Action Program was established in 2011, but no corrective action was taken to replace the antiquated part. (Huntsville Times article by Brian Lawson with official TVA & NRC documentation attached: http://blog.al.com/breaking/2012/07/browns_ferry_nuclear_plant_had.html )
Prior and after the NRC scheduled meeting I had a discussion about the January Unit 3 control room fire issue with the NRC Public Relations representative and the NRC Senior Resident Inspector assigned to Browns Ferry. The NRC Senior Resident Inspector stated to me," the problem with antiquated capacitors is a problem throughout the Browns Ferry Nuclear Facility." The official report indicates the Maintenance Portion of the 95003 Inspection is complete. Do antiquated capacitors in relays or other power supplies exist in the critical actuators and safety valve systems of the nuclear reactor's Residual Heat Removal system or the High Pressure Cooling Injection systems integral to the reactors safety system?
Relating to the January 2012 Unit 3 Control Room fire: It is significant the NRC does not consider all "Warning/Annunciator Panels" part of the plants safety system, only some panels are chosen to be part of the safety system. The NRC Senior Resident Inspector informed me during our conversation the specific warning panel indicated failures of ventilation systems within the plant. Accordingly, this was a reason not to require the immediate reporting of the power supply fire disabling the warning panel in January of this year in accordance with nuclear safety law.
NRC's 95003 INSPECTION OVERVIEW OF PERFORMANCE INDICATORS
The NRC has stated they will evaluate TVA's corrective actions and the long term plan for improvement relating to the repetitive Residual Heat Removal system valve failure. TVA's implementation of an Integrated Improvement Plan which follows industry standards established for similar inspections is the basis for improving the degraded plant systems.
Corrective actions displayed by the TVA in improving the Browns Ferry Nuclear facility's performance and a display of positive actions regarding performance improvement will be how the NRC measures TVA's success. All corrective action programs as part of the ongoing reactor oversight process will continuously by verified by the NRC.
TVA's POSITION AND CORRECTIVE ACTION PLANS
TVA's Integrated Improvement Plan addresses 5 focus areas of fundamental problems relating to on site safety culture weaknesses. Moving from center, then left to right within the pink area on the slide- Accountability, Corrective Actions Program, Fire Risk Reduction, Equipment Reliability, Organizational Decision Making. (Click on image for an expanded view.)
The Integrated Improvement Plan is finalized. As indicated on the TVA slide: -"A living plan;" -consists of 1000 action items; -40% of the plans actions are complete; - 75% of the plans actions will be complete by years end. (Click on image for an expanded view.)
During the public input session I asked of the TVA executives present whether a contractor or the TVA executives prepared the Performance Metrics system. Keith Polson, TVA Vice President of Browns Ferry replied: "A TVA contractor and our executive staff developed the Performance Metrics program."
Mr. Polson further commented, "there were 45 performance metrics tied to 18 performance areas, 15 major areas to be evaluated and 3 additional areas, identified for performance evaluations."
Improvements needed - improvements realized: Operational improvements were not meeting established goals; Corrective Actions Program Health guidelines were below goals (radiation exposures); equipment reliability was improving but still is below goals. The industry standard for equipment reliability is 90%. I asked the TVA staff present, "due to the aging state of Browns Ferry do you think it is possible to reach the industry standard of 90%?" Mr. Polson replied, "we intend on being at 80% equipment reliability by years end and we will reach a 90% equipment reliability rate." It was reported that Browns Ferry equipment reliability was at 55% when the process began and is currently at 75%. Further information reported by the TVA executives present- Unit 2 has operated for 427 days continuously without an outage or SCRAM. Browns Ferry has operated over 5 million man hours without an on the job injury.
Mr. Polson further commented, "we are developing a program to correct 'RAD Waste' problems at Browns Ferry." This was another area I asked the TVA staff present to clarify. Polson stated, "the rad waste problem I speak of relates to cooling water disposal. We will be developing a schedule to correct that problem."
TVA Vice President of Nuclear Operations Keith Swafford made 2 important commitments for improvements: "We will fix the safety culture failures which led to the Browns Ferry problems...it is our goal to rid the station of fire risk problems."
PUBLIC INPUT SESSION
5 citizens voiced their concerns to the TVA and NRC, Jackie Tipper, Nancy Muse, Stewart Horn, an unidentified lady and Garry Morgan spoke about several issues.
Nancy Muse, an area resident, pointed out that she knew several fire fighters and emergency responders in the area and they were not aware of any Emergency Plans or procedures or plans relative to the Browns Ferry Nuclear Plant where an evacuation might become necessary. Ms. Muse stated there is a serious lack of preparedness relating to disaster management. (photo by G. Morgan with Nancy Muse's permission)
Ms. Muse expressed other concerns which were reported in the Florence, Alabama Times Daily on line edition: "Florence resident Nancy Muse attended the meeting and was not impressed by TVA’s presentation. “I have been coming to these meetings for 30-something years,” she said.
“We were always led to think things were as they should be, when it is clear now that things are not as they should be.”Muse expressed concern about the plant’s age. She brought an article by The Associated Press that said most nuclear plants like Browns Ferry were only meant to last about 40 years. The plant began operation in 1974. “Browns Ferry does not get good reviews,” she said. “Now is the time to start decommissioning the aging plants.”" http://timesdaily.com/stories/Browns-Ferry-under-fire-from-public,194028
An online caller during the public input session of the meeting asked, "how long does the TVA have to complete the improvements and request the NRC's final inspection, will the process continue on indefinitely?" Ms. Jackie Tipper, a resident who lives across the river from Browns Ferry commented, "the NRC appears to be a tool of the nuclear power industry." Mr. Leonard Wert, NRC Region 2 Deputy Administrative Director replied, "the plant operator must make corrective actions. The NRC personnel are dedicated employees and we will not hesitate to close a nuclear facility if it becomes necessary."
SUMMARY
TVA is making long overdue improvements at Browns Ferry. Unfortunately, there seem to be lingering questions regarding management performance indicators, safety culture, maintenance and implementation of Corrective Action Programs. Obvious management problems which have been reported in the media: The January Control Room fire relates to a trend of continuing maintenance failures and the failure to implement Corrective Action Program plans in a timely fashion to correct known deficiencies. A lack of proper fire safety training resulted in a June White finding. The lack of management focus relating to continuous maintenance, safety and training failure issues are very bothersome. It is this continuous lack of attention to detail in the Browns Ferry Nuclear Facility which very well could begin a chain of non-anticipated events. Particularly when you consider the probability of a natural disaster such as an EF5 Tornado resulting in a station blackout and worse, a direct hit to the nuclear facility.
The TVA has set a performance standard concerning equipment reliability at 90% and they state that is the nuclear industry standard. Currently the TVA's equipment reliability rate is 75% at Browns Ferry and state they will achieve 80% by years end. Is a 10% to 20 equipment reliability failure actually acceptable at a nuclear facility? What if the 20% equipment failure is a critical safety system which must operate properly during a reactor SCRAM?
The official report indicates the Maintenance Portion, Part 2, of the 95003 process is complete. Do antiquated capacitors in electronic relays, switches or other power supplies exist in the critical actuators and safety valve systems of the nuclear reactor's Residual Heat Removal system or the High Pressure Cooling Injection systems integral to the reactors safety system? Although Browns Ferry Vice President Keith Polson indicated the analog systems were being changed out to modern digital systems, the NRC's Senior Resident Inspector indicated there were problems relating to analog system maintenance and the antiquated capacitor problem existing throughout the nuclear power facility.
There is a continuing failure at the Browns Ferry Nuclear facility to correct maintenance problems and follow through on corrective action plans. The long term nature of continuing maintenance and safety problems reflect a failure in oversight. This is an example of NRC's culture of support to the nuclear industry instead of public health and welfare.
A continuing lack of attention to detail coupled with a failure to adhere to preventive maintenance programs and corrective action plans are evident in the January Unit 3 control room fire and the recent White Finding issued on June 22, 2012 by the NRC.
The June 22nd White Finding indicated: 1) Operators were not familiar enough with fire safety requirements; 2) a systems approach to training was not properly implemented and the procedures could not be satisfactorily performed by plant operators and staff; 3) there was a failure to adequately identify and perform required training for implementation of procedures for combating plant fire events affected the licensee’s ability to respond to a plant fire.” Reference: http://www.isssource.com/safety-woes-at-browns-ferry-nuke/
The NRC is scheduled to announce later this month the result of the findings regarding the January Unit 3 Control Room Fire. The bottom line, maintenance and safety culture failures are still evident at Browns Ferry and the NRC continues to place the nuclear industry concerns before citizen health and welfare.
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