ML18033A953
| ML18033A953 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 09/18/1989 |
| From: | Michael Ray TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8909210097 | |
| Download: ML18033A953 (9) | |
Text
TENNESSEE VALLEYAUTHORITY CHATTANOOGA. TENNESSEE 37401 5N 157B Lookout Place SEP l8 II U. S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D.C.
20555 Gentlemen:
In the Matter of Tennessee Valley Authority Docket Nos. 50-259 50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN) UNITS 1, 2, AND '.3= NRC INSPECTION, REPORT NOS. 50-259/89-20, 50-260/89-20, AND 50-296/89-20
.RESPONSE.TO DEVIATION=-
TECHNICAL STAFF AND MANAGERS ORIENTATION TRAINING This letter provides TVA's response to the deviation transmitted by letter from BE A. Wilson to O.
D. Kingsley, Jr. dated August 4, 1989.
The report cited TVA with a deviation on the failure to conduct technical staff and managers orientation training for modification engineers as committed in TVA's Nuclear Performance Plan (NPP) Volume 3, Revision 2.
TVA notes that the oral commitments discussed in the exit interview and enclosed in the inspection report are documented correctly as requested by NRC.
In addition, increased management attention on technical staff -and managers training ensures that TVA will continue to comply with the commitments described in NPP Volume 3, Revision 2, on engineer and technical training.
Enclosure 1 provides TVA's response to the deviation from commitments made in TVA NPP Volume 3, Revision 2.
A list of commitments is provided in Enclosure 2 ~
On August 29,
- 1989, a telephone call was made to William S. Little of your staff to extend the due date of this response from September 3,
1989 to September 17, 1989.
If you have any questions, please telephone Patrick P. Carier, BFN, at (205) 729-3570.
Very truly yours, TENNESSEE VALLEY AUTHORITY
- Manager, Nuclear censing and Regulatory Affairs Enclosures cc:
See page 2
890'92 }00v7
~cg0P lq PDR ADOCK 05000259 Q
PDC An Equal Opportunity Ernployar
U.S. Nuclear Regulatory Commission
~
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SFP i8 $88 cc (Enclosures):
Ms.
S.
C. Black, Assistant Director for Projects TVA Projects Division U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Mr. B. A. Wilson, Assistant Director for Inspection Programs TVA Projects Division U.S. Nuclear Regulatory Commission Region II 101.Marietta Street,<NW,,~Suite. 2900 Atlanta, Georgia 30323 NRC Resident Inspector Browns Ferry Nuclear Plant Route 12, Box 637
- Athens, Alabama 35609-2000
ENCLOSURE 1
RESPONSE
TO DEVIATION NRC INSPECTION REPORT NOS. 50-259/89-20, 50-260/89-20, AND 50-296/89-20 LETTER FROM B. A.
NILSON TO 0.
D.
KINGSLEY, JR.
DATED AUGUST 4, 1989 Deviation TVA committed in the Nuclear Performance
- Plan, Volume 3, Revision 2, which is the Browns Ferry Nuclear Performance Plan (BFNPP), to a Training Program for Technical Staff and Managers.
The commitments in Section II.2.3.2 of the BFNPP included completion of orientation phase training by all technical staff and managers whose responsibilities may affect the day-to-day safe operation of the plant and the safety of plant personnel or the general public.
C 1 ti f the orientation phase training was required. before any te'chni'ca'1 omp e
on o e
staff member or manager was to be allowed full unreviewed respon
'sibilitin
.areas;concerned-with !the 'training not completed.
The BFNPP stated that plant technical staff managers and engineers, incumbent as of March 28,
- 1986, wer required to have completed the orientation phase training by August 1,
- 1987, or have a waiver or limited assigned duties.
Newly assigned plant technical staff managers and engineers were required to complete the orientation phase training within 18 months of assignment to BFN, unless a waiver had been granted.
The BFNPP commitment for Technical Staff and Manager training was implemented by Program Manual Procedure (PMP) 0202.17, "Technical Staff and Manager Training for Nuclear Plant Site Personnel,"
and by Site Director's Standard Practice (SDSP) 4.9, "Training Program for Technical Staff and Managers,"
(formerly BF 4.14).
Both of these procedures included modification engineers/site construction personnel among the personnel who were required to complete orientation phase training prior to being granted independent unreviewed work responsibilities.
Contrary to the above, as of May 10,
- 1989, 167 modifications engineers had not completed orientation phase training or been granted waivers within the time limits established in the BFNPP commitment and the implementing procedures.
A i t tions were not taken to assure'that these individuals had no independent unreviewed work responsibilities in areas affected by e
g th trainin courses prior to completing the training.
Reasons for the Deviation The
- NPP, Volume 3, Revision 2, states:
Newly assigned plant technical staff managers and engineers are required to complete
[the3 orientation phase training within 18 months of assignment to BFN unless a waiver is granted per defined criteria from SDSP 4.9 (formerly Standard Practice BF 4.14).
Plant Technical staff managers and engineers, identified as of the effective date of Standard Practice BF 4.14, were required to complete this training by August 1,
- 1987, have an approved waiver or have limited duties.
Technical staff and managers to whom this training requirement applies are those whose responsibilities may affect the day-to-day safe operation of the plant and the safety of plant personnel or the general public.
Enclosure 1
Page 2 of 3 Reasons for the Deviation (Continued)
SDSP 4.9 clarifies the commitment regarding "limited duties."
It states that supervisors shall "ensure that technical staff and managers newly assigned to the site receive orientation training prior to being allowed full unreviewed responsibility in areas related to the training topic."
At Browns Ferry, Modifications personnel were not considered to have responsibilities affecting the day-to-day safe operation of the plant and the safety of plant personnel or the general public.
All work performed by Modifications was considered to be controlled by a proceduralized work process involving review and approval by other plant organizations.
- Thus, Modifications personnel were presumed to have limited work responsibiliti.es with respect to this program.
In November,
- 1988, TVA management directed that Modifications be included in the Technical Staff and Manager training program.
As a result, appropriate Modifications engineers and managers were placed on the list of personnel requiring the training.
Because such a large number of people who were not originally part of the incumbent population were added to the list at one
- time, and due to the work schedule required to support startup activities, insufficient progress was made in completing the training requirements.
TVA acknowledges that Modifications engineers have not completed orientation phase training within the time limit established in the BFNPP.
- However, existing checks and balances on quality and approvals provide assurance that work performed by Modifications did not compromise the quality of safety-related work performed at the plant.
Hhi le Modifications personnel have only limited responsibilities, TVA recognizes the benefit of the Technical Staff and Manager training and intends to continue requiring the training for Modifications engineers and managers who deal wi;'h technical areas.
Corrective Ste s Nhich Have Been Taken and Results Achieved The Site Director has issued a memorandum to each major organization's principal managers, This memorandum reiterated the requirements specified in SDSP-4.9 and emphasized the responsibility of line management to ensure that required training is completed.
All Site Principal
- Managers, including the Modification Manager, have responded in writing to the training department the specific personnel and job positions to which the Technical Staff and Managers Orientation Training requirements apply.
The training department maintains the list of technical staff and managers requiring this training and provides quarterly training status to managers responsible for these personnel.
Although the Modification staff does not have full unreviewed responsibilities as noted
- above, TVA recognizes the value associated with providing orientation training to the Modification staff.
Accordingly, an action plan for the completion of the Modification staff training has been developed and presented to NRC, This action plan has been implemented on schedule as follows:
Enclosure 1
Page 3 of 3 By June 2,
1989 l.
Establish a date for training classes or obtain a waiver in accordance with SDSP-4.9 (Priorities to be based on criticality of job position>.
2.
Modifications manager and critical senior Modifications supervisors to attend training module on configuration control.
3.
All Modifications employees to be reevaluated on need for additional technical training.
4.
Identify those functions performed by Modifications personnel that do not, but should, have an overview by qualified individuals or organizations.
5.
Identify those functions performed by Modifications personnel that require training and are not a current part of the four courses for technical staff training.
By July 3, 1989 1.
All remaining Modifications employees performing technical assignments to attend training module on configuration control.
By September 3,
1989 1.
Review overall training criteria for Modifications employees.
2.
Revise and schedule Modifications employees in applicable training modules.
As of August 23, 1989, approximately 58 percent of the current Modifications staff is in full compliance with the technical staff training requirements.
Corrective Ste s Nhich Nill Be Taken to Avoid Further Deviation In accordance with the goals set in Cond> tion Adverse to Quality Report (CAQR)
- 88069SP, TVA wi 11 complete by March 9, 1990 any required technical staff training for Modifications employees.
Newly assigned technical managers and engineers within the Modifications organization will continue to receive required Technical Staff and Manager training in accordance'with SOSP-4.9.
Date Nhen Full Com liance Nill Be Achieved In accordance with the goals set in CAQR 880695P, TVA will complete by March 9, 1990 any required technical staff training for Modifications employees.
ENCLOSURE 2
RESPONSE
NRC INSPECTION REPORT NOS. 50-259/89-20, 50-260/89-20, AND 50-296/89-20 LETTER FROM B. A. HILSON TO O.
D.
KINGSLEY, JR.
DATED AUGUST 4, 1988 COMMITMENT In accordance with the goals set in Condition Adverse to Quality Report
- 880695P, TVA will complete by March 9, 1990 any required technical staff training for Modifications employees.
J, J