IR 05000259/1988031

Insp Repts 50-259/88-31,50-260/88-31 & 50-296/88-31 on 880719-22 & 0907-08.No Violations or Deviations Noted.Major Areas Inspected:Plant Regulatory Performance Improvement Program Action Item Implementation

ML20195B965
Person / Time
Site:	Browns Ferry
Issue date:	10/24/1988
From:	Ignatonis A, Little W NRC OFFICE OF SPECIAL PROJECTS
To:
Shared Package
ML20195B962	List: IR 05000259/1988031 ML20195B958
References
50-259-88-31, 50-260-88-31, 50-296-88-31, NUDOCS 8811020270
Download: ML20195B965 (15)

Text

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UNITED STATES j, o

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j, f NUCLEAR REOULATORY COMMISSION REGION 11

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a 101 M ARIETTA ST., . ' , , , j, ATLANT A. GEORGIA 30323 Report Nos.: 50-259/88-31, 50-260/88-31, and 50-296/8S-31 Licensee: Tennessee Valley Authority 6N 38A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Docket No , 50-260, and 50-296 License No DPR-33, DPR-52, and OPR-68 Facility Name: Browns Ferry 1, 2, and 3  ! Inspection at Browns Ferry Site near Decatur, Alabama '

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Inspection Conducte& July 19-22 and September 7-8, 1988 ( Inspecto : $ 0 e-{ A. J. Ignitonis,'lechnical. Assistant n*& & L,

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Jt - Al- f f Date Signed Approved by:_I / /6 M 66 W. 5. Littli,'Section Chief ' W.e Sig'ned ; Inspection Programs TVA Projects Division SUMARY Scope: This special, announced inspection was conducted in the areas of Browns Ferry Regulatory Performance Improvement Program (RPIP) action item implementation, t Results: The licensee has satisfactorily implemented all short-term RPIP action items and eight long-term RPIP action items described in Appendix A of the Browns Ferry Nuclear Performance Plan (BFN NPP) Volume 3, Revision 1. The remaining eight open long-term RPIP action items are broad based programs covered in various sections of BFN NPP Volume 3, and have not yet been fully implemented. No violations or deviations were identifie ; L 8811020270 001024 PDR ADOCK 05000259 l 0 PNV [ l

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REPORT DETAILS Licensee Employees Contacted

*R. M. McKeon, Assistant to the Plant Manager
*J. W. Hutton, Operations Superintendent M. J. May, Manager of Site Licensing
*B. C. Morris, Support Licensing Manager
*C. G. Wages, Maintenance Projects Supervisor
*J. D. Allen, Site Procedure Staff Supervisor
*R. D. Erickson, Plant Operations Review Staff Supervisor R. E. Burns, Maintenance Engineering Section Supervisor T. L. Chinn, Operations Support Group Supervisor B. Willis, Site Independent Safety Review Group Supervisor R. W. Griffith, Site Licensing Engineer Other licensee employees contacted included licensee reactor operators, craftsmen, craft foremen, technicians, training coordinators, and the site procedures staf * Attended exit interview l Acronyms and abbreviations used throughout this report are listed in the last paragraph.

' Regulatory Performance Improvement Program items In a letter from R. L. Gridley of TVA to J. N. Grace, dated March 18, 1986, the Itcensee proposed action to close Confirmatory Order EA 84-54 issued on July 13, 1984, which pertains to the implementation of commit-l ments made by TVA in the Browns Ferry Regulatory Performance Improvement i l Program (RPIP). The TVA status of remaining short-term and long-term open RP!P items is provided in Appendix A of the Browns Ferry Nuclear Perfor-mance Plan (NNP), Volume 3. Revision Previous RPIP action item inspec-tion followup and status reports are addressed in Inspection Reports 85-28, 85-35, 85-36, 85-45, 85-49, 86-22, 86-32, and 88-05. A followup inppection on selected open RPIP items was performed and the current I status is shown belo The inspector concluded that the licensee satisfactorily implemented required actions for all short-term RPIP and eight long-term RP!P action i items described in Appendix A of Browns Ferry hPP Volume 3, Revision 1.

l They are considered closed. The remaining eight open long-term RPIP action items cover broad based programs not yet ccmpleted. They include vendor manual upgrade, closecut of Engineering Change Notice (ECN) docu-mentation, plant orocedure upgrade, corrective action for procurement activities, and implementation of progratmatic improvement plans in the functional areas of chemistry, fire protection, plant security, QA, and radiological control __

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, L l Short-Term l l l Item ' Quality and Regulatory Compliance Training '

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i l The required licensee action for this item was to ensure l that the craft personnel understand their responsibility ! l regarding quality awareness and regulatory complianc In l response to this item the licensee has developed and ( ' implemented a formal training program on QA/QC, plant [ procedures and regulatory compliance for all personne l The inspector reviewed training records of arbitrarily i selected craft personnel during the last inspection (see ! Inspection Report 88-05) and found that the licensee failed to adhere to the required retraining frequency for certain ! personne This resulted in a violation (259,260,296/ l' 88-05-08) in wnich the licensee responded to on June 24, ; 198 The licensee admitted to the violation and plans to com- l plete corrective actions by October 1,1988. The licen- ! see's response is acceptable and a followup inspection will ! be performed to verify licensee's implementation of com- t pleted corrective action For the purpose of the RPIP ! inspection, this item is considered close (CLOSED). l l Item I- Organization Licensee action for this item is to review and revise , appropriate documents that define and describe the new l organization, i Although this action item remained open for some time in order to satisfy the short-term RPIP objective of plant ! reorganization (1984-1985), additional reorganizations ! occurred since then including the ones described in the BFN l Nuclear Performance Plan (NNP) Voluma 3. Revision 1, and [ the more recent TVA upper management structure realignment i described in the licensee June 3,1988 letter to 5. Fbneter of NRC. For the latter, TVA stated that the . implementation of organizational changes will nec*..sitate revision of the Corporate Nuclear Performance Plan (CNPP), the QA Topical Report, the Technical Specifications (TS), ( and other controlling document [ i On June 17, 1988. TVA requested NRC for an amendment to I change the BFN TS Section 6, deleting the organization ! charts in accordance with Generic Letter 88-06. The NRC f reviewed and approved the proposed TS change and issued TS l Amendment Nos. 149,145, and 120 for Units 1, 2, and 3 l

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e respectively, on June 30, 1988. Per the amended TS 6.2.1, the licensee's operating organization requirements shall bs documented in the FSA The inspector reviewed the site organization described in Chapter 13 of the FSAR, Revision 6, and the revised organization charts provided in Revision - 10 to TVA's Topical Report, TVA-TR 75-1A, dated May 6, 1988. Both documents address the relationship of various j organitation positions in chart and functional description " form. The licensee has met the intent of this RPIP action item and the inspector considers it closed. (CLOSED) j I-4.11 Independent Safety Engineering Group l t Licensee action for this item is to implement an Indepen-  !

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dent Safety Engineering Group (ISEG).

The BFN ISEG staffing level and experience ancern was  ; previously raised in Inspection Report 87-14. The licensee

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responded to this concern in their letter to the NRC dated  : June 6, 1988. In sum TVA's position is that they compiy l with NUREG 0737 Item I.B.1.2 which provides the exception  : of having less than five onsite dedicated engineers for  ! utilities with multiple sites because it may be possible  !

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for the licensee to perform portions of the independent safety assessrrent function in a central locatio TVA e stated that they have five ISEG reviewers in the central  ! office who may be called upon for support by the BFN ISEG j staf The BFN onsite ISEG staff will consist of four members - one lead reviewer, two reviewers, and one staff specialis The inspector followed up on the status of the site ISEG i staffing. Current site ISEG staff composition consists of  ; a lead reviewer (supervisor), two full-time engineers, and , a clerk. The ISEG reviewers have more than twelve years of  ; esperience. Also, the licensee is attempting to obtain an a

additional reviewer. Furthermore, during June 1988 inspec- l tion (see Inspection Report 8S-18) ths resident staff

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l ' reviewed the last three monthly ISEG reports and found them  ! l to be well focused on current industry problems as well is l l specific site weaknesses. The NRC's review and determina-  ! I tion of BFN ISEG acceptability will be addressed separately  ! in a safety evaluation report of the BFN NNP Volume 3;  ! however, for the purpose of RPIP inspection, the licensee * has met the intent of the RPIP action item in which the task was to develop i long term ISEG staf fing plan. The j inspector considers this RPIP item closed. (CLO5ED) l l

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Long Term i Item !!-1,1 Vendor Manual Upgrade Program Licensee action for this item is to review and resolve o,nen inspection and audit findings on the vendor manual control progra TVA plans to complete this RPIP item as part of a long-term i 1 program implementation addressed in BFN NPP Volume 3.The r Vendor Manual Control Program (VMCP) is discussed in Sections II.2.4 and !!.5.1. of BFN NPP Volume 3. VMCP was initiated to correct past inef fective control of vendor information that contributed to inconsistent acceptance ' criteria being applied in Surve'llance Instructions (sis).

The VMCP is basically comprised of verdor manual update and incorporattoa of that information into appropriate f.lant procedures and maiatenance instrtetion The licensee's progress of the procedurc upgrade and incorporation of vendor manual information. into the procedures was reviewed and is addressed in Inspection Report Numbers 87-27, 88-02 and 88-24 A small sample of licensee vendor manual certified elec- ' trical and mechanical maintenance instructions were re-viewed by the inspectors. The instructions were reviewed for correct vendor manual reference and acceptable incor- ' poration of vendor informatio Some discrepancies were i identified and conveyed to the licensee, hswever, the methodology and reviews utilized in the procedure upgrade process to ensure that acceptable instructions will be ' available to perform corrective mechanical activtties were j concluded to be acceptabl : A programmatic assessment of the plant S!s and the VMCP was i also performed by the 05P staff during the August 1988 .

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inspection (Inspection Report 88-24) and its evaluation is

addressed in the OSP Safety Evaluation (SE) of BFN NPP I

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Volume 3. Section 11.5.0, Plant Surveillance Program, dated September 29, 1988. It that SE, the OSP staff concluded I that management controls established by the VMPCP, as they i apply to SI procedures and acceptance criteria, are accept- l able. Also, the methodology outlined in 50$P 10.1, Vendor ! Manual Control Program, appears to meet the need to have

   *he correct vendor manual information properly reflected in
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51 procedures and acceptance criteria. Further inspections - " are planned in the maintengnce area which include mainte- [

nance instructions review and acceptable incorporation of vendor manual information into the procedures.

] This RPIP item remains open pending further inspectio ; (OPEN). l i

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l l \ Closuut of QA Audit Findings

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i' Item !!-1,2 Licensee action for this item is to close out two remaining QA audit findings. The first one is for TVA to triplement a L technical training program for the Modification and Plant l Engineering sections in preparation of work plans. The ! other action item pertains to improvement of inadequate , corporate procedure TVA's QA audit findings on failure to establish a technical training program foi field services group (Modifications) and Plant Engineering sections in the preparation of work plans was identified as a restart issue. It is tracked in Appendix D-DNOA and other TVA Audits of the BFN NPP Volume l 3 ur. der the neadings BFC-86-0055-005 and BFC-86-055-006.

1 For corrective action, the licensee implemented a training ! program back in 1987 entitled MGIL T-1, "Training Require- i ments within the Modification Branch", and revised appli- t

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l cable procedures on workplans. On July 2,1987, TVA closed l out this audit finding (Audit No. 055-A-81-0006, Deviation No. 001). The inspector frilowed up on this matter and ! coted some changes since TVA's closure of this concer l They are the use of $1te Director Standard Practice !

 (505P)-8.4, Modification Workplans which supersedes '
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SD5P-8.3, Pltnt Modifications and itt substitution of a new l training program on work plans fo" modifications group ; initiated in April 198 The new courso number is PPT-108.001 er. titled 505P-8.4, Modifications Workplan The plant engineering staff receives similar technical training, three days in length, under course number EGT 121. IS, Plant Modifications and Work Control. Both j courses given to mMifications personnel and plant engi- i neers use the in .ation proviced in 505P- Tne inspector concluded that the licensee's corrective action : on this item is Complet On the issue of TVA's QA audit finc'ings regarding inade- I quate corporate procedures, the inspector noted that ieprovement of corporate procedures is discussed in CNPP l' Volume Per CNPP Volume 1. TVA comitted to correct identified weaknesses in programs and procedures. Proce- , dures are being upgraded through short- and long-term i programs. The NRC reviewed CNPp Volume 1 and concluded in the July 28, 1987, SER that TVA's effort t,o upgrade pro- [ cedures and to establish uniform controls and centralized & direction is an acceptable program for procedure develop-r.en Based on the above, the inspector considers this RPIP item closed. (CLOSED). ' I

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, f 6 i b i 11- Close-out of ECN Occumentation ] i Licensee action for this item is to assign management  ! priority to the BFN As-Constructed Drawing Task Force for l resolution of open/ incomplete ECNs, workplans, as-con-  !

structed drawings, and resolve open FCRs under the old [

l workplan prograrr, l This is t bread o long-term effort in which consider- ,

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able amoant of wi<t - ns in close out of ECN documenta- ' tion, particular Jnit 2 restar Previous inspec-tions perforn.'d i.. . area are addressed in Insp*ction Report cumbers S6-36, 87-0S, 87-27, 87-33, 87-#.2, and 88-02. Inspections will continue in this area. This RPIP l Item remains open (OPEN).  : i 11- Corporate Procedures Up,rade f l Licensee ac. tion for th.s item is to revise and upgrade i upper-tier (corporate) ps'ocedures, j TVA plans to complete this AP!P item as part of near-term I and long-term ONP procedures upgrade program addressed in f BFN NPP Volume 3 Section II.2.4. The near-term program I calls for the licensee to establish a cedicated BFN pro- [ cGdures group, interface with GNP Nuclear Procedures staff, snd ensure that the requirements of ONP procedures ,

    (upper-tier) which are issued prior to BFN Un.5 2 ri start   !

and applicable to BFN are appropriately incorporatto into  ! the site procedures system. The long-term program involvus  ; the establishment of a new ONP procedure hierarchy which  ! will later require further realignment of site procedure The ONP documentation hierarchy consists of Policies, i Directives, and standard l

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The inspector followed up on licensee's near-term and long-term program efforts. For the near-term, the BFN Site Procedures staff is in place and functionin The BFN Unit 2 Headquarters $tartup Procedure List has been esta- t blished in which the Site Procedures staff uses and keeps [ track on status of site procedures that may be tepacted by l ONP procedure changes. For the long-ters, CNP PMP type of I procedures are being converted to CNP Standards. The f

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summary status of ONP issued nuclear procedures ending August 31, 1988, is shown below: Document To be Issued Total Issued Directives 50 21 Standards 316 43 Licensee implementation of this activity continues and will be ascertained by seph-ate inspectio This RPIP item remains ope (OPEN) II-3.2 Management Observation and Craftsmen or Operator Involvement in Procedures Licensee action for this item is to have management involve-ment in the improvement and useability of procedures. And, assign senior craftsmen in each section to work with engineering personnel on procedure revisions to ensura that they are written for the person performing the work and not the reviewe The inspector noted that mcre than a majority of mainte-nance procedures have been upgraded in electrical, I&C, and mechanical areas. The intent of this inspection was to assess TVA's management, craft, and reviewer involvement in the procedures upgrade effort. Interviews were held with several procedure revision supervisors, craf tsmen involved with procedure revisions, and general foremen out in the fiel Based on these interviews the inspector concluded that craft interaction and participation in procedures upgrade was good in electrical and I&C areas, but consid-etably weaker in the mechanical section. There appeared to be less communications among mechanical maintenance per-sonnel exhibited by a slowdown in periodic meetings to discuss and inform the staf f on revised procedures, and craft involvement in procedure revisions. This concern was expressed to the licensee. Nevertheless, the licensee has met the intent of this RPIP action item and the inspector considers it close (CLOSED) 11- Intent /Non-Intent Revisions to Procedure Licensee action for this item is to define clearly the method and limitation imposed to revise procedures on the spot and also ensure proper review of the chang SDSP-2,11, Revision 8, Implementation and Change of Site Procedure, describes how to make Immediate Temporary Changes (ITCs). ITCs are also referred to as non-intent changes. They are .oreally used for completing a procedure

 'n progress requiring an immediate revision in which the change does not alter the intent of the original procedur .
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Guidelines for determining an intent change are provided in Form SDSP-16 and this form must be completed for each IT In response to a Watts Bar (WBN) violation (WBN inspection report 50-390 and - 391/86-20), TVA committed to make certain programmatic corrective actions on a corporate level including a revision of criteria for intent change The NQAM was to be used as the vehicle for affecting site procedure changes and its BFN date for licensee compliance with revised NQAM requirements was July 1,1988 (reference TVA correspondence to NRC dated April 5, 1988 and June 30, 1988). The inspector verified licensee's imple-mentation of the TVA defined intent changes (i.e. guide-lines) shown in Form SDSP-16, dated June 23, 1988. Also, the inspector noted that the BFN section supervisors were infermed of the procedure change via licensee's letter from BFN Site Procedures Staff to Section Supervisors dated July 6, 198 The licensee has met the intent of this RPIP action item and the inspector considers it close (CLOSED) II-3.5 Modification Control Process Licensee action for this item is to revise modification control procedures to ensure completion of work, post-modification testing, configuration control, and training documents before a modification is placed in servic This item covering a broad scope of activities and improve-ments for the modification control process is discussed in Sections III.2.3 and III.2.4 of BFN NPP Volume 3. Several inspections were performed in this area and are addressed in BFN Inspection Reports 86-40, 87-42, and 88-0 TVA work is ongoing and NRC inspections will continue in this area. This RPIP item remains open pending further inspec-tio (OPEN) II-3.6 Programmatic Improvements Licensee action for this item is to implement programmatic improvement plans in the areas of Radiological Control, Security, Quality Assurance, Chemistry, and Fire Pro-tectio Program improvements in the above stated functional areas are discussed in various sections of BFN NPP Volume Inspections were performed and will continue to be per-formed in these areas. This RPIP item remains open pending further inspectio (OPEN) - _ _ _ _ _

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II- Plant Procedures Upgrade License action for this item is to revise and upgrade plant procedure This item is discussed in Section II.2.4 of BFN NPP Volume The type of procedures the licensee committed to upgrade in the near-term include Standard Practices, Operating Instructions (01s), General Operating Instruc-tions, (GOIs), Abnormal Operating Instructions (A01s), Surveillance Instructions (sis), and Maintenance Instruce tions (mis). Previous NRC inspection findings in the area of plant procedures upgrade are addressed in Inspection Report numbers 86-14, 87-09, 87-14, 87-27, 87-30, 88-02, and 88-24. Team inspections were conducted on upgraded Ols, AOIs, sis, mis, and E01s (Emergency Operating Instruc-  ! tions). The results of the inspections indicate that the Ols, sis and E01s were found to be much improved and i adequate with some exception Further NRC team inspec- i tions for these type of procedures are not planned. It is the inspector's understanding that the licensee plans to review / revise a certain number of A01s prior to Unit 2 restar As these procedures become finalized, the NRC will inspect them during operational readiness review and during routine resident inspection The mis will be reviewed as part of the maintenance team inspectio As discussed in RPIP item 11-1.1, the OSP staff reviewed the Plant Surveillance Program and issued an SE dated September 29, 1988. In that SE, open items were identified in this area requiring further information from TVA and fallowup for: M validations, use of systems engineers for SI review, and verification of circuit or piping flowpaths for SI developmen Pending further NRC review this RPIP item remains ope (OPEN) II- Streamline the Procurement Process ) L License action for this item was to create a joint task force to study and recommend corrective actions in pro-curement proces , t Tnis is a long-term licensee effu t covered by the piece-parts replacement items progra The activity will . be inspected as part of the Master Inspection Plan veri-fying readiness for restart. Thus, this RPIP item remains , ope (OPEN) [

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11-9.1 Review of Control Room Activities Licensee action -is to assign a trained individual to conduct daily reviews of control room and other operational activitie Although TVA considers it unnecessary to assign a specific individual to conduct daily review, they have stated in BFN NPP Volume 3 that measures to monitor and improve control room activities (including logging practices) have been implemented and are being performed on a routine basi The inspector reviewed the Shift Operations Supervisor (SOS) and Unit Operator (U0) log entries and verified that they were in compliance with procedure PMI-12.12, Revision 1, Conduct of Operations, dated July 8,1988. PMI-12.12 supersedes information contained in Standard Practice BF-12.24 pertaining to the same subject matte Per 1 PMI-12.12 all log entries (505 and U0) must be writtca clearly, precisely and completely. Further, step 4.4.9 of PMI-12.12 requires all logs and turnover sheets to be forwarded to the Operations Supervisor for review each da Also, per step 4.4.13, the SOS or ASOS (Assistant Shift Operations Supervisor) shall periodically, at least once per shift, review all logs required to be taken during the shif Satisfactory implementation of PMI-12.12 by the licensee negates the need for an additional individual to conduct daily reviews of control room operations. Licensee action for closure of this RPIP item is acceptable and the inspector considers it closed. (CLOSED) II-9.2 Valve Status Alignment Licensee action is to develop routine verification of the ' physical status of abnormal valve The inspector verified licensee's commitment for issuance and implementation of a revised procedure dealing with valve alignment controls and valve position verificatio Standard Practice BF-12.17, Revision 4, Administrative Controls for Plant Operation, provides instructions on valve positioning requirement The revised Operations Section Instruction Letter (OSIL) Number 43, System Status Control, dated August 19, 1988, provides instructions on maintenance and documentation of system status contro Equipment checklists are required to be maintained in individual system status files in the control roo Equipment lineups are independently verified and a set of system status files are assigned for each operations group to review on a weekly basi The inspector reviewed

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several valve checklists and verified that copies o'l current valve checklist are kept in individual system status file No discrepancies were identifie For independent verification, OSIL No. 43 references the more recently issued procedure SDSP-3.15, Independent Verification. Per OSIL'No. 43, independent verifications are performed by operators of the 4th period student classification or abov The inspector queried the li-censee on 4th period students qualifications performing independent verifications. He was informed that the 4th period students are individuals who receive on-the-job training and have already satisfactorily completed all formal training on system operations, know where the equipment is located and how it operates, and have been qualification card certified for the system they can work o The independent verifier qualifications described in SOSP-3.15 are similar to the ones described in Admini-strative Instruction AI-37, Revision 5, Independent Veri-fication for the Sequoyah facilit Furthermore, the inspectors will ascertain the adequacy of configuration control in future inspection Based on the above, the inspector concluded that the licensee met the intent of the RPIP action items, and considers it close (CLOSED) 11-9.3 Second Party Verification Program Licensee action for this item is to develop procedures consistent with INPO and NRC positions on second party verificatio The term second party verification is synonymous with independent verificatio During the RPIP inspection the inspector was informed by the licensee that they have issued a new procedure SDSP-3.15, entitled Independent Verificatio Thi s pro-cedure replaces the existing procedure BF-3.11, and the < basis for its revision was to meet INPO guidelines for independent verificatio The inspectors reviewed the contents of 50SP-3.15 and determined that SOSP-3.15 incor-porates INPO and 'RC position The inspector followed up on licensee administered training or indoctrination of the new procedure to the plant staf SDSP-3.15 was placed on urgent reading assignment as a part of requalification training for all licensed and non-licensed operator personnel. The inspector reviewed  ; the training department records and noted that just about all of the operators have acknowledged their completion of this reading assignmen In the ma'ntenance departmen l

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the licensee'is conducting training sessions on SOSP-3.15 for the electrical, I&C, and mechanical craft. Currently, about 60 I&C technicians received training and training sessions are continuing for the remainder of the craf The inspector considers this RPIP action item close (CLOSED) II- Contractor Recommendations on NSSS

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Licensee action for this item is to review and implement, if necessary, recommendations from the General Electric (GE) Company relating to the operation of the Nuclear Steam Supply System (NSSS).

The licensee has reviewed the GE report; covering 22 systems and scoped out the GE recommendations tnt they , plan to implement. These items were assigned to various

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categories for implementation including items required to be completed prior to unit restar Previous inspection findings in this are are addressed in Inspection Report Numbers 87-02, 87-20, 88-16 and 88-2 The resident inspectors are continuing to review the status and imple-mentation of licensee selected GE recommendations. This RPIP item remains open pending further inspection (OPEN) * II- Contractor Recommendations on Technical Specifications

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Licensee action for this item is to review and implement, if necessary, recommendations from the SAI Corporation relating to Technical Specification ;

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The SAI Corporation recommendations and its disposition are  ! discussed in BFN NPP, Volume 3, Appendix B. The inspector l noted that some of the recommendations such as re-issuance of "clean and legible Technical Specifications (TS) (rather than use of reproduced, older cut and pasted TS pages) and the review and update of BFN Surveillance Ir.structions and Operating Instructions have already been implemented or are - ongoin These areas are being covered by different inspections and NRC's acceptability of TVA's work in this area is expected to be addressed separately in a safety , evaluation report of the BFN NPP Volume In the inspec-tor's judgement, the licensee has met the intent of this l RPIP action item and considers it close (CLOSED) l

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11-9.9 Contractor Recommendatin s on Administrative Management LicensL action for this item was to utilize an outside  : contracto, (MAC) for an evaluation of the licensee's l administrative burden on the plan ; i I _____ _ __ _ - .

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MAC performed the evaluation .and identified 26 recom-mendations to TVA in their 1984 report. The MAC recom-mendations included such items as assignment of a respon-sible engineer to each modification, organize paper flow, t consider adoption of an HBO-type system of goal setting and accountability, correct weaknesses in document- control system, and develop a "sense of urgency" on the part of all-personnel to do the job right. BFN management re-evaluated MAC recommendations, correlated to appropriate sections of the BFN NPP Volume 3, and documented it in a separate report to the BFN Site Director dated October 13, 198 s The licensee dispositioned all of the items in which most I of them have been verified to be incorporated into various l sections of the revised BFN NPP Volume ~ The licensee has completed the committed tasks for this RPIP action item which were to reevaluate MAC recomm-endations for incorporation into their action plan ( BFN NPP Volume 3) and document the results of this re-evaluation. Appropriate elements of MAC recommendations incorporated in BFN NPP Volume 3 are broad in scope on licensee administrative management. Some of these elements are and will continue to be assessed by the NRC as part of licensee's operational readiness for Unit 2 restar The inspection considers this RPIP item close (CLOSED) 3. Exit Interview The inspection scope and results were summarized on July 22, 1980, with those persons indicated in paragraph Dissenting comments were not received from the license A followup inspection was preformed on September 7-8, 1988, and the inspector briefed the Support Licensing Manager on the scope and results of the his finding On October 21, 1988, the inspector informed the Support Licensing manager that following long-term RPIP action items have been changed to an open status rather than closed status mentioned in the July 22, 1988 exit meetin II - 1.1 Vendor Manual Upgrade Programs II - 2.1 Close-out of ECN Documentation II - 3.1 Corporate Procedures Upgrade II - 3.5 Modification Control Process II - 3.6 Programmatic Improvement II - 3.7 Plant Procedure Upgrade II - 6.2 Streamline the Procurement Process II - 9.2 Contractor Recommendations on NSSS (GE) __

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. Acronyms and Initialisms ASOS -

Assistant Shift Operations Supervisor BFN - Browns Ferry Nuclear CNPP - Corporate Nuclear Performance Flan ECN - Engineering Change Notice FCR - Field Change Request FSAR - Final Safety Analysis Report GE - General Electric I&C - Instrume,ntation and Controls INP0 - Institute of Nuclear Power Operations ISEG - Independent Safety Engineering Group ITC - Immediate Temporary Change MAC - Management Analysis Corporation HBO - Management by Objectives NQAM

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Nuclear Quality Assurance Manual NPP - Nuclear Performance Plan NSSS - Nuclear Steam System Supply ONP - Office of Nuclear Power OSP - Office of Special Projects OSIL - Operations Section Instruction Letter PMI - Plant Manager Instructions PMP - Program Manual Procedures QA/QC

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Quality Assurance / Quality Control RPIP - Regulatory Performance Improvement Program SDSP - Site Director Standard Practice SE - Safety Evaluation SOS - Shift Operations Supervisor TS - Technical Specifications TVA - Tennessee Valley Authority UO - Unit Operator VCMP - Vendor Manual Co trol Program }}