ML18033A441

Responds to s Black 880929 Ltr Re Plant Surveillance Program Safety Evaluation Open Items.Response to Open Items Encl

ML18033A441
Person / Time
Site:	Browns Ferry
Issue date:	10/31/1988
From:	Gridley R TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
TAC-62252, NUDOCS 8811040041
Download: ML18033A441 (13)

Text

AC CEL'ERATO DISTRIBUTION DEMONSTRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:8811040041 DOC.DATE: 88/10/31 NOTARIZED: NO DOCKET.g FACIL:50-260 Browns Ferry Nuclear Power Station, Unit 2, Tennessee 05000260 AUTH. NAME AUTHOR AFFILIATION GRIDLEY,R. Tennessee Valley Authority RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Responds to S Black 880929 ltr re plant surveillance program safety evaluation open items. R DISTRIBUTION CODE: D030D COPIES RECEIVED:LTR ENCL SIZE: I TITLE: TVA Facilities Routine Correspondence NOTES:1 Copy each to: S.Black, J.G.Partlow, S.Richardson 05000260 B.D.Llaw,F.McCoy. 'S RECIPIENT COPIES RECIPIENT ID COPIES ij ID CODE/NAME LTTR ENCL CODE/NAME" LTTR ENCL SIMMS,M 1 1 PD 1 1 A GEARS,G 1 1 D

INTERNAL: ACRS= 1 1 ADM/LFMB 1 0 NUDOCS~STRACT 1 1 OGC/HDS2 1 0 D

G FI 01 1 1 EXTERNAL: LPDR 1 1 NRC PDR 1 1 S NSIC, 1 1 NOTES 5 5 R

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NOZE TO ALL "RIDS" RECIPZERIS:

PIZASE HELP US TO REDUCE HASTE CXKIRCZ IHE DOCUMENT COPED)L DESK~

RCCM Pl-37 (EXT. 20079) TO ELIKBVZE MUR NAME FROM DISTRIKEXGN LISTS FOR DOCUMENXS YOU DON'T MEEDf TOTAL NUMBER OF COPIES REQUIRED: LTTR 16 ENCL 14

TENNESSEE VALLEY AUTHORITY CHATTANOOGA. TENNESSEE 37401 SN 1578 Lookout Place OIT ai II!

U.S. Nuclear Regulatory Commission ATTN: Document Control Desk llashington, D.C. 20555 Gentlemen:

In the Matter of Docket Nos. 50-260 Tennessee Valley Authority BROHNS FERRY NUCLEAR PLANT (BFN) RESPONSE TO PLANT SURVEILLANCE PROGRAM SAFETY EVALUATION OPEN ITEMS (TAC 62252)

This letter provides TVA's response to your letter from Suzanne Black to S. A. Nhite dated September 29, 1988. In your letter, TVA was requested to address the staff's open items including a proposed schedule for resolution of these open items no later than October 31, 1988. TVA's response to each of these open items is provided as enclosure 1 to this letter. Summary statements of commitments contained in this submittal are provided in enclosure 2.

Please refer any questions regarding this submittal to Patrick Cari er, Acting Manager of Site Licensing, BFN, (205) 729-3566.

Very truly yours, TENNESSEE VALLEY AUTHORITY l

R. Gr ey, Manage Nuclear Licensing apd Regulatory Affairs Enclosures cc: See page 2 gg8 88ii04004i, 88i03i I~

PDR ADOCK 05000260 PDC An Equal Opportunity Employer

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U.S. Nuclear Regulatory Commission cc (Enclosures):

Ms. S. C. Black, Assistant Director for Projects TVA Projects Division U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockvi lie Pike Rockville, Maryland 20852 Mr. F. R. McCoy, Assistant Director for Inspection Programs TVA Projects Division UPS. Nuclear Regulatory 'Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Browns Ferry Resident Inspector Browns Ferry Nuclear Plant Route 12, Box 637 Athens, Alabama 35611

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ENCLOSURE 1 BRONNS FERRY NUCLEAR PLANT (BFN)

PLANT SURVEILLANCE PROGRAM RESPONSE TO OPEN ITEMS IN THE NRC-OFFICE OF SPECIAL PROJECTS SAFETY EVALUATION I

NRC Issue (Item 3.2.a, excerpt from Safety Evaluation Section 2.4))

"The Systems Engineer (SE or SEs) concept was intended, with respect to the Surveillance Program, to ensure that SI data would be reviewed, trended, and, where required, in-depth technical reviews and timely effective corrective action executed. At the time of the staff review of the upgraded surveillance program at BFN, the SE group had been established, but was not constituted to adequately address the root causes identified in the NPP. Specific staff concerns in this area follow.

The SE organization found to exist at BFN was a loosely constituted group of apparently well-qualified individuals who were frequently called upon to solve a wide variety of engineering problems. This SE group had existed for over a year, yet had neither an organizational charter nor formally defined responsibilities . The plant management was aware of this situation, yet did not have any specific plan to correct the problems with the SE organization.

Concerning the role of'he SEs in the surveillance program, the SEs had been given cognizance over about 70 SIs, which was about 10% of the SIs which were to have been implemented prior to plant restart. The functions of the SI reviews were still mostly under the cognizance of the various engineering groups on site which had traditionally had responsibility for technical review and corrective action associated with those SIs. In essence, the root causes meant to be corrected by the implementation of the SE concept were still in existence. . . Effective implementation of the SE concept to address the identified root causes would require, as a minimum, that the SE organization be formally chartered and that its Charter should include, as SE responsibilities, those functions envisioned for this organization in Section II.5.0 of NPP Volume 3."

TVA Res onse Implementation of the SE concept is not the only corrective action taken for the deficiencies noted in the Surveillance Instruction (SI) program, but rather an integral part of the corrective actions. As stated in the Nuclear Performance Plan (NPP) Volume 3 Section II.S.O,,the root causes for past SI program deficiencies were ". . . (1) unclear, difficult-to-use surveillance procedures and (2) insufficient attention to detail by persons reviewing and performing surveillances and reviewing surveillance results." The corrective action taken to resolve item ( 1) was to institute a review and upgrade program for the BFN SIs. Several corrective actions were taken to ensure resolution of item (2), with implementation of the SE concept being an integral part.

These corrective actions included BFN management placing additional emphasis on the importance of following procedures, correcting procedures which could not be followed, and holding employees accountable for the quality of their work.

The statement in Section II.5.0 of the NPP, Volume 3, was not intended to mean that system engineers would review all SIs, but rather that implementation of the system engineering concept would improve the review process because:

1. The most qualified individuals would review SIs and the system engineering concept would provide a more qualified review of integrated system-related SIs.

2. More time for review of SIs would be available to responsible personnel because of the significant workload associated with system engineering responsibilities being removed from other plant organizations.

TVA's intent with respect to review of SIs is to have the most qualified personnel responsible for SI review. The sta'tement in Section II.5.0 of the" NPP, Volume 3, regarding system engineer review of SIs is consistent with this intent. For example, American Society of Mechanical EngineersSection XI SIs are reviewed by the Mechanical Test Section engineers who have responsibility for the Section XI program. This ensures that the Section XI program requirements are fully met and maintains consistency in the program.

Similarly, the Instrument and Controls Technical Section engineers are most qualified to review instrument calibrations.

The SIs that are most applicable to system engineering responsibilities are the systems operability SIs and some of the functional SIs. These SIs typically involve integrated system operation with multiple system components, instrumentation, and logic. Currently, system engineering is cognizant of about 110 of the SIs. The remainder of the SIs have been reviewed and are assigned to the appropriate cognizant organizations.

NRC Issue (Item 3.2.b, excerpt from Safety Evaluation Section 2.1)

. there exists no requirement for a qualified third party to observe the execution of all SI validations in order to provide a quality check on the ability of SI performers to perform every procedure precisely as wr'i tten. The staff' underlying concern is that, with an essentially new surveillance program being implemented in a substantially modified plant, there appears to exist insufficient provisions to assure the quality necessary to guarantee the workability and repeatability of every SI."

"TVA has initiated a limited third party observation of SI validations. The staff has noted that this limited scope third party review may not produce the consistency and quality required for the level of correctness and procedure repeatability necessary for an effective surveillance program. Alternatives discussed with TVA included the concept of increasing the third party review to a more significant percentage of SI validation."

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Enc. 1-3 TVA Res onse Site Director Standard Practice (SDSP) 2.14, "Surveillance Instruction Evaluation," was developed to provide a mechanism for evaluating plant SIs .

This evaluation includes guidelines,.for the review, verification, walkdown, and performance validation to ensure a consistent level of accuracy and performability. TVA will revise SDSP 2. 14 to require a qualified individual in the respective cognizant'rea be present during the first performance of at least ten percent of the upgraded SIs. This individual will be in addition to the normal contingent of personnel required for performance of the SI. The revision to SDSP 2.14 will be accomplished no later than December 5, 1988.

The selection of SIs requiring this third party independent review will address the different types of surveillance requirements. This determination will be made by the cognizant section supervisor.

In addition, the NRC safety evaluation requested TVA to provide ".

justification of the acceptability of completed SI evaluations on those systems required for fuel loading." In response to this issue, it should be noted that the SI upgrade program is an extensive process directed at ensuring consistent and quality instructions. This program has mandated guidelines covering the following elements:

SI preparation Independent second party review for all SIs Independent third party review for 20 percent of the SIs Walkdown of all SIs Validation of all SIs The SI upgrades have been through a number of reviews and validation performance observations by such groups as the Independent Review Group (no longer in operation) and the Quality Surveillance Section. The Restart Test Plogram and Systems Engineering Section have also provided added assurance of quality instructions by observation of many of the validation performances.

As noted above, TVA has taken a strong stand by demanding that instructions be performed as written. TVA has directed personnel involved in the performance of instructions to delay completion if procedural problems arise. Most problems with the performance of the SIs will be identified during the validation performance runs. Consequently, sufficient justification exists to demonstrate that the completed SI evaluations for systems required for fuel loading are acceptable.

NRC Issue (Item 3.2.c, excerpt from Safety Evaluation Section 2.1)

. there is no requirement for personnel reviewing SIs to verify the circuit or piping flow paths used in SIs. The lack of such a requirement means that, programmatically, there is an incomplete second check of the SI drafter's work. Any drafter' errors in tracing the proper path would most likely become apparent only during the validation run of an SI. The modes of discovery of such errors during validation could range from simple nonreceipt of expected indications to possible personnel injury or equipment damage."

Enc. 1-4 TVA Res onse TVA does not agree that a programmatic deficiency exists concerning personnel reviewing SIs. During the upgrade process, the SIs were rewritten using the Plant Manager's Instructions (PMI)-2.3 (Style Guide) and PMI-2.5 (Nriter's Guide). The rewritten SI was then evaluated using the appropriate checklists in SDSP 2.14 which requires an independent technical review. PMI-2.5 gives specific guidance to the wr'iter and reviewer for verification of circuitry and piping flow paths. The requirements of PMI-2.5 cannot be accomplished by the writer or the reviewer without in-depth use of the appropriate drawings.

In addition, SDSP-7.4, "Onsite Technical Review and Approval of Procedures,"

implements the onsite technical review required by BFN Technical Specification 6.8.1. This standard practice requires the review of all design documents, of which drawings are included. The reviewer cannot ensure technical adequacy without the appropriate drawings.

NRC Issue (Item 3.2.d, excerpt from Safety Evaluation Section 2.5)

"A final concern developed during the staff's review of the BFN Surveillance Program was that commitments made in the NPP do not seem to be tracked by the licensee. Of the four programs identified in the Introduction to this Safety Evaluation to correct the root causes of the problems previously existing with the BFN Surveillance Program, only two are being tracked on the licensee's Corporate Commitment Tracking System (CCTS). The Improved Management Practices and the implementation of the Systems Engineering role with respect to the surveillance program are not being tracked using the CCTS.

This deficiency may be indicative of a possible generic problem with the commitments made in the NPP not specifically being tracked as licensing commitments, even though the NPP was submitted to the NRC in response to a 10 CFR 50.5'4(f) letter."

TVA Res onse At the time. of submittal of the NPP to NRC, TVA identified many of the more significant programmatic improvement statements contained therein as being formal commitments to NRC. These commitments are enumerated in Attachment IV-2 of the NPP and are tracked to closure by CCTS. The NPP implementation element of the BFN Unit 2 Operational Readiness (OR) Program also tracks these items to closure along with other significant NPP statements of actions to improve programmatic performance at BFN. The BFN Unit 2 OR Program is described in Section V of the NPP. Specifically, in response to NRC's stated concerns, improved management practices and implementation of the SE role as they relate to the BFN Surveillance Program are tracked by the NPP implementation element of the BFN OR Program. Closure folders are being developed as auditable records of satisfactory completion of these NPP statements.

Enc. 1-5 In summary, the CCTS tracking program in conjunction with the OR Program tracking and closure program provide adequate assurance that NPP commitments and other significant statements of action are being adequately tracked to closure.

ENCLOSURE 2 BROWNS FERRY NUCLEAR PLANT (BFN)

PLANT SURVEILLANCE PROGRAM RESPONSE TO OPEN ITEMS IN THE NRC-OFFICE OF SPECIAL PROJECTS'AFETY EVALUATION

SUMMARY

STATEMENTS OF COMMITMENTS TVA will revise Site Director Standard Practice (SDSP) 2.14 to require a qualified individual in the" respective cognizant to be present during the first performance of at least ten percent of the area upgraded SIs. This individual will be in addition to the normal contingent of personnel required for performance of the SI. The revision to SDSP 2.14 will be accomplished no later than December 5, 1988.

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