ML13092A362

Tennessee Valley Authority Public Meeting Summary

ML13092A362
Person / Time
Site:	Browns Ferry, Watts Bar, Sequoyah
Issue date:	04/02/2013
From:	Scott Shaeffer Reactor Projects Region 2 Branch 6
To:	James Shea Tennessee Valley Authority
References
Download: ML13092A362 (33)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257 April 2, 2013 Mr. Joseph W. Shea Vice President, Nuclear Licensing Tennessee Valley Authority 1101 Market Street, LP 3D-C Chattanooga, TN 37402-2801

SUBJECT:

PUBLIC MEETING

SUMMARY

- BROWNS FERRY NUCLEAR PLANT -

DOCKET NOS. 50-259, 50-260, 50-296; SEQUOYAH NUCLEAR PLANT - DOCKET NOS. 50-327, 50-328; WATTS BAR NUCLEAR PLANT - DOCKET NOS. 50-390, 50-391

Dear Shea:

This refers to the meeting conducted, at your request, at the NRC Region II office, Atlanta GA, on March 28, 2013, at 10:00 a.m. EDT. The meeting's purpose was to discuss the TVA commercial grade dedication program. Enclosed are a list of attendees and the presentation handouts.

Topics discussed included: The NRC concern with TVAs commercial grade dedication program, initial action taken by TVA in response to our concern, description of the current recovery projects, and remaining actions to be taken by TVA. TVA intends to complete a comprehensive evaluation of commercial grade dedicated items installed between 1995 and 2011 for the operating fleet, and correct any identified deficiencies by December 31, 2014.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter will be available electronically for public inspection in the NRC Public Document Room (PDR) or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS).

ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). Should you have any questions concerning this meeting, please contact me at 404-997-4521.

Sincerely,

/Gerald McCoy RA for/

Scott M. Shaeffer, Chief Reactor Projects Branch 6 Division of Reactor Projects

Enclosures:

1. List of Attendees

2. Handout - TVA Nuclear Fleet Commercial Grade Dedication Recovery Project cc w/encls: (See page 2)

X SUNSI REVIEW COMPLETE G FORM 665 ATTACHED OFFICE RII:DRP RII:DRP SIGNATURE JDH /RA/

GJM /RA for/

NAME JHamman SShaeffer DATE 04/02/2013 04/02/2013 E-MAIL COPY?

YES NO YES NO YES NO YES NO YES NO YES NO YES NO

J. Shea 2

cc w/encl:

K. J. Polson Site Vice President Browns Ferry Nuclear Plant Tennessee Valley Authority Electronic Mail Distribution S. M. Bono Plant Manager Browns Ferry Nuclear Plant Tennessee Valley Authority Electronic Mail Distribution James E. Emens Manager, Licensing Browns Ferry Nuclear Plant Tennessee Valley Authority Electronic Mail Distribution E. W. Cobey Manager, Corporate Licensing Browns Ferry Nuclear Plant Tennessee Valley Authority Electronic Mail Distribution T. A. Hess Program Manager Corporate Licensing Tennessee Valley Authority Electronic Mail Distribution Edward J. Vigluicci Associate General Counsel, Nuclear Tennessee Valley Authority Electronic Mail Distribution Chairman Limestone County Commission 310 West Washington Street Athens, AL 35611 State Health Officer Alabama Dept. of Public Health P.O. Box 303017 Montgomery, AL 36130-3017 Ann Harris 341 Swing Loop Rockwood, TN 37854 J. T. Carlin Site Vice President Sequoyah Nuclear Plant Tennessee Valley Authority Electronic Mail Distribution P. R. Simmons Plant Manager Sequoyah Nuclear Plant Tennessee Valley Authority Electronic Mail Distribution J. W. Proffitt Manager, Site Licensing Sequoyah Nuclear Plant Electronic Mail Distribution C. D. Mackaman Program Manager, Corporate Licensing Tennessee Valley Authority Electronic Mail Distribution County Mayor 208 Courthouse 625 Georgia Avenue Chattanooga, TN 37402-2801 Site Vice President Watts Bar Nuclear Plant Tennessee Valley Authority Electronic Mail Distribution David H. Gronek Plant Manager Watts Bar Nuclear Plant Tennessee Valley Authority Electronic Mail Distribution County Mayor P.O. Box 156 Decatur, TN 37322 (cc w/encl continued next page)

J. Shea 3

(cc w/encl continued)

Donna K. Guinn Manager, Site Licensing Watts Bar Nuclear Plant Tennessee Valley Authority Electronic Mail Distribution Terry E. Cribbe Manager, Corporate Licensing Tennessee Valley Authority Electronic Mail Distribution Gordon P. Arent Senior Manager, Licensing WBN Unit 2 Watts Bar Nuclear Plant Tennessee Valley Authority Electronic Mail Distribution County Executive 375 Church Street Suite 215 Dayton, TN 37321 Tennessee Department of Environment &

Conservation Division of Radiological Health 401 Church Street Nashville, TN 37243

J. Shea 4

Letter to Joseph W. Shea from Scott M. Shaeffer dated April 2, 2013

SUBJECT:

MEETING ANNOUNCEMENT - PUBLIC MEETING BROWNS FERRY NUCLEAR PLANT - DOCKET NOS. 50-259, 50-260, 50-296; SEQUOYAH NUCLEAR PLANT - DOCKET NOS. 50-327, 50-328; WATTS BAR NUCLEAR PLANT - DOCKET NOS. 50-390, 50-391 Distribution w/encl:

OEMAIL L. Douglas, RII C. Evans, RII RIDSNRRDIRS RIDSNRRPMBrowns Ferry RIDSNRRPMSequoyah RIDSNRRPMWatts Bar PUBLIC

2

March 28, 2013 Nuclear TVA Nuclear Fleet Commercial Grade Dedication Recovery Project

TVA Commercial Grade Dedication Recovery Project 2

Nuclear Don Jernigan Senior Vice President, Nuclear Support Joe Calle Recovery Project Manager Steve Martin PEG Program Manager Joe Shea Vice President, Nuclear Licensing John Laffrey Licensing Program Manager

Agenda 3

Nuclear

• Purpose Don Jernigan

• Terminology Joe Calle

• Review NRC Concern Joe Calle

• Nuclear Power Group Initial Actions Joe Calle

• Current Recovery Project Joe Calle

• Actions Forward and Commitment Don Jernigan

• Closing Remarks Don Jernigan

Purpose 4

Nuclear To ensure NRC understands that:

TVA realizes the nature and significance of the NRC concern with the commercial grade dedication process.

TVA acknowledges that TVA Nuclear Power Groups initial response to the issue identified at Watts Bar Unit 2 (WBN2) was not comprehensive or timely.

TVA is dedicating the necessary resources to thoroughly evaluate the issue across the operating fleet in order to reinforce the basis for ensuring that commercial grade items will perform their intended safety function.

To ensure NRC has confidence that:

TVAs evaluations conducted to date provide reasonable assurance that installed commercial grade items will perform their intended safety function while TVA continues to conduct a comprehensive review of the commercial grade dedicated items in the operating units.

Terminology 5

Nuclear Critical Characteristics - Those important design, material, and performance characteristics of a commercial grade item that, once verified, will provide reasonable assurance that the item will perform its intended safety function.

Safety Function - The piece part or subcomponent has a safety function if its failure or malfunction will prevent the host/equipment/system from performing the satisfactory accomplishment of its safety-related function during or following design basis accidents and transients Commercial Grade Dedication (CGD) Package - CGD packages are developed for each commercial grade item where the item is not available for purchase from either the Original Equipment Manufacturer/Supplier or a Third Party Qualifier. The majority of CGD packages are for commodity items that are used in safety related end uses such as electrical tape, terminal lugs and fuses. Each CGD item has its own specific PDS that delineates the testing and acceptance criteria for the item.

TE - Technical Evaluation. The Procurement Engineering evaluation process that establishes the technical and quality procurement requirements as well as acceptance criteria for the procurement of CATIDs. The TE can address the technical and quality requirement, and acceptance criteria for multiple CATIDs.

PDS - Procurement Data Sheet. A form that is populated based on a specific CATID and an approved Procurement Engineering TE. It contains all the necessary information required for purchase. This form is used by the Purchasing Organization for the purpose of procuring the item/services when needed. It is also contains the receipt inspection requirements including all acceptance requirements. Each CATID has its own specific PDS.

CATID - Catalog Identification Number. It is the TVA assigned alpha-numeric designator for each piece part and/or assembly in the TVA portfolio. Each CATID is represented by its own specific PDS.

Item - Any level of unit assembly, including structures, systems, subsystems, subassembly, component, part, or material.

Component - Synonymous with CATID.

NRC Concern 6

Nuclear

• TVAs commercial grade dedication (CGD) program did not meet regulatory requirements resulting in numerous examples where CGD activities failed to adequately establish CGD items as basic components.

• Specific Issues

- Failure to use correct 10 CFR 21 definition to define critical characteristics of items

- Inadequate guidance to relate intended safety function with critical characteristics

- Inadequate verification that procured item would meet intended safety function

NRC Concern 7

Nuclear

• Chronology of NRC Concern

- September 2011

• NRC Issued an Unresolved Item at Watts Bar Unit 2 related to the CGD process.

- February 2012

• NRC issued a non-cited violation (NCV) of 10 CFR Part 50, Appendix B, Criterion III, Design Control, associated with the CGD process.

• Additional NRC Observations Limited QA Oversight Missed opportunities to identify programmatic weaknesses with the commercial grade dedication process Extent of Condition evaluation was limited

Nuclear Power Group Initial Response 8

Nuclear

• Initial Causal Analysis

- Completed Apparent Cause in September 2011

- Identified Corrective Actions

• Initiate Governance Actions and Organization

• Develop Benchmarking Schedule

• Rewrite Governing Procedure (NEDP-8)

• Sample Reviews Were Performed As Site Specific Actions

- Revised Apparent Cause in September 2012

• Focused Self Assessment Performed in August 2012

• Strengthened the Corrective Actions for the Apparent Cause

Nuclear Power Group Initial Response 9

Nuclear TVA Management Assessment of Initial Causal Analysis

- Actions Did Not Include a Rigorous Basis for Assessing Commercially Dedicated Components Installed in Operating Plants.

- Actions Did Not Include Controls for Ensuring No Affected Commercially Dedicated Components Were Withdrawn From Inventory Without Rigorous Re-Review of Dedication Documentation.

Nuclear Power Group Recovery Project 10 Nuclear

• TVA Management Assessed Initial Response Not Adequate

- December 2012

• Initiated More Comprehensive Response

- Enacted a Hold on All In-Stock Commercially Dedicated Items

- Began Development of Current Recovery Project

- Performed Root Cause Analysis Associated with CGD Program Issues Back to 1995; Reviewed Governing Procedure NEDP-8 from Revision 0 to Revision 18

Nuclear Power Group Recovery Project 11 Nuclear Root Cause Analysis - Completed March 2013 o Problem Statement:

Implementation of the NPG commercial grade dedication process (1995-2011) resulted in some critical characteristics defined under 10 CFR 21 not being sufficiently identified, verified or documented. The insufficient identification and verification of critical characteristics has reduced the assurance that dedicated items could perform their intended safety functions.

o Root Cause Latent organizational and programmatic shortfalls within Engineering, Supply Chain and Procurement Engineering did not account for monitoring or assessing PEG organizational health, commercial grade dedication program weaknesses and industry changes.

o Direct Cause The Procurement Engineering group did not always provide sufficient documentation for the critical characteristics justification when dedicating parts. Neither the software template nor the procedure contains direction for capturing critical thinking and justification.

Nuclear Power Group Recovery Project 12 Nuclear

• Key Elements of Comprehensive Response

- Basis for Reasonable Assurance That Items Evaluated Under TVAs Commercial Grade Dedication Program Will Perform Intended Safety Function

- Actions to Reassess Commercial Dedication Adequacy

• Components Currently Installed in Operating Units

• Components in Inventory

• Additional Programmatic Improvements

Nuclear Power Group Recovery Project 13 Nuclear

• Reasonable Assurance

- TVA uses industry standard approach when procuring items for use in a safety related application - embodied in current and historical procedure revisions:

Preferred method is to procure material as safety related from original equipment supplier or manufacturer.

If preferred method not available, procure the material from a qualified third party vendor that has an audited 10 CFR 50 Appendix B program.

If neither is available, procure the material as commercial grade and dedicate it using TVAs commercial grade dedication process.

- TVA has a sound relationship with many suppliers and vendors dating back many years.

Nuclear Power Group Recovery Project 14 Nuclear

• Reasonable Assurance (Continued)

- TVA Supply Chain organization provides a series of defense in depth measures to assure quality in the procurement of commercial items to be used in the CGD process, including:

Commercial vendors are chosen based on proven industry performance.

Vendor performance is monitored by using ANSI N45.2.6, Level II, certified receipt inspectors and documentation is recorded, trended and reported.

- Common application for procurement through the CGD process is for commodity items such as terminal lugs, electrical fuses, electrical tape, bearings and drive belts.

Nuclear Power Group Recovery Project 15 Nuclear

• Reasonable Assurance (Continued)

- Other procedural requirements in NEDP-8 addressed selection of critical characteristics for acceptance based on safety functions and failure modes.

- TVA has issued a large quantity of CGD items for use in the TVA nuclear fleet since 1995.

• To date, no failures of installed items have been directly correlated to TVAs commercial grade dedication process.

- To date, TVAs ongoing review of CGD items has verified, through technical review and testing if the review indicated it was needed, that items in question will perform their intended safety function.

Nuclear Power Group Recovery Project 16 Nuclear

• Reasonable Assurance (Continued)

- TVA conducted a Root Cause Evaluation that reviewed the governing procedure of Commercial Grade Dedication. One of the conclusions identified by the team states:

From the beginning in 1997, the initial issue of the governing procedure for Commercial Grade Items stated that the PEG engineer shall Select Critical Characteristics for Acceptance based upon the items safety function. However, it is to be noted that the definition for Critical Characteristics for Acceptance in the governing procedure was not updated to reflect the last rule making decision of 10CFR21.

Nuclear Power Group Recovery Project 17 Nuclear

• Reassessment of Commercial Dedicated Items

- Items Currently Installed in Operating Units

- Items in Inventory

• Project Scope

- Defining Affected Population of Items

• Development of Reassessment Process

- Review Standards and Action Thresholds

- Significance Prioritization for Installed Items

Nuclear Power Group Recovery Project 18 Nuclear

• Project Scoping Parameters and Challenges

- 1995-2011

- Multiple Procurement Databases Used Over The Period

• Project Scope Determined to Be:

- Commercial Grade Dedicated Items identified in TVAs item database that have been issued to the plant.

- Approximately, 4600 unique items have been issued from November 2001 to December 2012.

- In addition, approximately 1600 unique items issued to the plant in the time frame prior to 2001 have been identified to date. TVA is continuing to search data bases for items issued to the plant in this time frame and expects to identify additional items for review.

Nuclear Power Group Recovery Project 19 Nuclear

• Reassessment Review Process

- Process Diagrams on Slide 16-19

- Applied to Review of Items in Plant and Items in Inventory

• Key Steps in Review Process

- Assessment of As-Found Dedication Documents

- Additional Technical Evaluation - If Required

- Additional Testing - If Required

• Example Application of Review Process (Next Slides)

Nuclear Power Group Recovery Project 20 Nuclear Appendix A: CGD Package Review Process

Nuclear Power Group Recovery Project 21 Nuclear

Nuclear Power Group Recovery Project 22 Nuclear

Nuclear Power Group Recovery Project 23 Nuclear

Nuclear Power Group Recovery Project 24 Nuclear

• Actions Taken to Date and Results

- Items in Inventory Placed on Hold - January 14, 2013

- Review of Items Prior to Release From Hold-Ongoing

• 728 Packages Reviewed - includes construction and fleet packages

• 374 Packages Found Acceptable As Written

• 354 Packages Determined to Require Critical Characteristics Re-verification which includes actual Testing of Items in some cases.

• To Date No Defective Items Have Been Identified

Nuclear Power Group Recovery Project 25 Nuclear

• Actions Taken to Date and Results (Continued)

- Identification of Items Installed in Operating Plants

• Items Installed Since 2001

• Identification of Data for Items Installed 1995-2001 - Ongoing, Due to the Archaic Nature of Historical Documentation Archival

- Development of Prioritization Approach for Installed Items

• Ongoing

• Development of Prioritization Approach Complete By April 30, 2013

- Recovery Project Resources and Support

• TVA Has Assembled Project Support Team of Internal TVA and External Expertise in Commercial Grade Dedication

• Procurement of Additional Project Support In Progress

Actions Forward and Commitment 26 Nuclear

• Commitment:

- Complete a comprehensive evaluation of commercial grade dedicated items installed between 1995 and 2011 for the operating fleet. Correct any identified deficiencies by December 31, 2014.

• Actions Going Forward

- Implement Recovery Project

- Submit Commitment Including Recovery Project Action Plan Summary-By April 30, 2013