IR 05000259/1992022
| ML18036A905 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 10/20/1992 |
| From: | Gibson A NRC Office of Inspection & Enforcement (IE Region II) |
| To: | Medford M Tennessee Valley Authority |
| References | |
| NUDOCS 9210270004 | |
| Download: ML18036A905 (11) | |
Text
OCT pp l992 Docket Nos.
50-259, 50-260, 50-296 License Nos.
DPR-33, DPR-52, DPR-68 Tennessee Valley Authority ATTN:
Dr. Mark O. Medford Vice President, Nuclear Assurance, Licensing E Fuels 3B Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Gentlemen:
SUBJECT:
NRC INSPECTION REPORT NO. 50-259/92-22, 50-260/92-22, AND 50-296/92-22 Thank you for your response of August 5, 1992, to our Notice of violation issued on July 6, 1992; concerning activities conducted at your Browns Ferry facility.
We have evaluated your response and found that it meets the requirements of 10 CFR 2.201.
We will examine the implementation of your corrective actions during future inspections.
We have evaluated your request for withdrawal of this matter as a
t cited violation, and for the reasons stated in the enclosure to this letter, have determined that the violation stands as issued.
We appreciate your cooperation in this matter.
Sincerely,
/s/
Albert F. Gibson, Director Division of Reactor Safety Enclosure:
Evaluation of TVA Request for Reclassification of the Violation (cc w/encl
- See page 2)
S'210270004 921020 PDR ADOCK 05000259
'
Tennessee Valley Authority cc w/encl:
J.
B. Waters, Chairman Tennessee Valley Authority ET 12A 400 West Summit Hill Drive Knoxville, TN 37902 J.
R.
Bynum, Vice President Nuclear Operations Tennessee Valley Authority 3B Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Site Licensing Manager Browns Ferry Nuclear Plant Tennessee Valley Authority P.
O. Box 2000 Decatur, AL 35602 O. J. Zeringue, Vice President Browns Ferry Operations Tennessee Valley Authority P.
O. Box 2000 Decatur, AL 35602 Mark J. Burzynski, Manager Nuclear Licensing and Regulatory Affairs Tennessee Valley Authority SB Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Site Quality Manager Browns Ferry Nuclear Plant Tennessee Valley Authority P.
O. Box 2000 Decatur, AL 35602 TVA Representative Rockville Office 11921 Rockville Pike Suite 402 Rockville, MD 20852 (cc w/encl cont'd
- See page 3)'CT pp Ig92
Tennessee Valley Authority CC:
(cc cont'd)
Chairman, Limestone County Commission P.
O. Box 188 Athens, AL 35611 Claude Earl Fox, M.D.
State Health Officer State Department of Public Health
,State Office Building Montgomery, AL 36130 bcc:
B. A. Wilson, RII P. J. Kellogg, RII B. Bordenick, OGC M. S. Callahan, GPA/CA R.
H. Bernhard, RII T.
M. Ross, NRR Document Control Desk NRC Senior Resident Inspector U.S.. Nuclear Regulatory Commission Route 12, Box 637 Athens, AL 35611
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RII:DRP BWilson 09/
/92
'
ENCLOSURE EVALUATION OF LICENSEE REQUEST =FOR RECLASSIFICATION OF INSPECTION REPORT 50-259,260,296/92-22 NOTICE OF VIOLATION The Region II.staff has reviewed the licensee's arguments for reclassification of the violation.
The results of the review are as follows:
TVA ARGUMENT:
"A.
NRC Should Reclassify The Violation At Severity Level V Because The Violation Is Of Minor Safety Significance."
STAFF DISCUSSION:
The licensee 'provides several arguments for the reclassification-of the violation.
The salient points are discussed below.
The licensee includes reference to section 6.1.1 of the NRC Enforcement Manual, but takes the guidance out of context for the sake of their argument.
The licensee quotes the NRC Enforcement Manual as saying:
"[a]n isolated quality assurance (QA) violation involving documentation for a QA audit".
The guidance in the NRC Manual is as follows: "An isolated quality assurance (QA) violation for a QA audit that was performed may be assessed at Severity Level V."
While the difference in the quotations may appear to be trivial, the absence of the words "...that was performed..."
would imply that the violation was the finding of a licensee QA audit and was therefore fully documented in the licensee's QA.
corrective action program.
This was not the case; the only argument that is provided for classification as "licensee identified" is presented on page 6 of the response to the violation, with the following statement:
"TVA first identified this event in December 1991, when a document control individual realized that the latest revision was not properly updated.
This individual subsequently updated four G-29's in areas maintained by Document Control.
The individual also notified a supervisor who determined that the remaining manuals could be assessed as time permitted."
The staff does not agree with the application of the referenced NRC Enforcement Manual guidanc S
't.
Enclosure Xn an attempt to show the minor significance of the violation, the licensee makes the following statements:
"...First, the violation is an. isolated concern since it involves only ten controlled copy documents.
BFN has over 140,000 controlled copy documents, 1500 vendor manuals, and 350, 000 controlled drawings... "
"...Second, the violation only involved documentation deficiencies and did not affect the, technical adequacy of welds performed in the field..."
and
"...Third, TVA has performed an assessment of the remaining General Construction Specifications in two separate locations to ensure a similar condition did not exist in these locations."
The staff feels that the arguments presented are misleading.
First, the violation involved ten of fourteen copies of the controlled document in question, not ten of 491;000.
Second, the product affected by the violation.was the controlled copies of the procedure not the welds.
Third, the reference to an assessment by TVA is vague.
Zt does not.
state if it was an assessment of copies of G-29 at two separate locations at Browns Ferry; an assessment of copies of other G-specs at two locations at Browns Ferry; or an assessment of copies of G-29 at two other TVA facilities.
The controlled document involved is the licensee's specification for the control of safety-related welding.
This safety related activity is particularly important at TVA facilities where the welding programs have been the subject of several comprehensive programs to correct previously identified deficiencies.
The staff position is that the severity level is correct for the relative importance of the controlled documents involve Enclosure TVA ARGUMENT:
"B.
Regardless of Classification At Either Severity Level IV or V, NRC 'Should Withdraw The Violation Because The Criteria For Enforcement Discretion Are Satisfied" STAFF DISCUSSION:
The staff does not agree that the criteria for enforcement discretion are satisfied in this case.
The reason for the staff opinion is that even though the licensee apparently identified the problem, there has been no evidence provided that would indicate that the licensee was "effectively correcting" the violation.
In fact, as shown above by the quotation from page 6 of the. licensees response, the violation was being handled rather informally by the personnel aware of the problem.
Therefore, the staff feels that NRC Enforcement Manual, paragraph S.l.d. is the appropriate guidance when it states:
"From an enforcement perspective, Severity Level IV violations should be issued to licensees who are not exercising initiative and identifying and effectively correcting violations without NRC involvement..."