ML18033B051

Responds to NRC 891021 Ltr Re Violations Noted in Insp Repts 50-259/89-47,50-260/89-47 & 50-296/89-47.Corrective Actions: 100% Assessment of Controlled Sets of Tech Specs Conducted & self-assessment Program Implemented

ML18033B051
Person / Time
Site:	Browns Ferry
Issue date:	11/20/1989
From:	Medford M TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 8911270107
Download: ML18033B051 (12)

Text

ACCELERATED DISTRIBUTION DEMONSTPA.TION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ESSION NBR:8911270107 DOC.DATE: 89/11/20 NOTARIZED: NO g FACIL:50-259 Browns Ferry Nuclear Power Station, Unit 1, Tennessee 05000259 50-260 Browns Ferry Nuclear Power Station, Unit 2, Tennessee 05000260 50-296 Browns Ferry Nuclear Power Station,,Unit 3, Tennessee 05000296 AUTH. NAME . AUTHOR AFFILIATION Desk)'OCKET MEDFORD,M.O. Tennessee Valley Authority RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document'ontrol

SUBJECT:

Responds to NRC 891021 ltr re violations noted in Insp Repts 50 259/89 47150 260/89 47 & 50 296/89 47 CODE: IEOlD COPIES RECEIVED:LTR ~ ENCL i SIZE:

'ISTRIBUTION TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:1 Copy each to: B.Wilson,D.M.Crutchfield,B.D.Liaw,S.Black 05000259 R. Pierson, 1 Copy each to: S.Black,D.M.Crutchfield,B.D.Liaw, 05000260 R. Pierson,B.Wilson 1 Copy each to: S. Black,D.M.Crutchfield,B.D.Liaw, 05000296 R. Pierson,B.Wilson RECIPIENT RECIPIENT COPIES ID CODE/NAME LTTR ENCL 1 1 ID CODE/NAME GEARS,G LTTR ENCL 1 1 PD I ERNAL: ACRS 2 2 AEOD 1 1 AEOD/DE IIB 1 1 1

AEOD/TPAD NRR SHANKMAN,S 1

1 1

1 DEDRO 1 NRR/DEST DIR 1 1 NRR/DLPQ/PEB 1 1 NRR/DOEA DIR 11 1 1 NRR/DREP/EPB 10 1 1 NOTES'OPIES NRR/DREP/RPB 10 NRR/PMAS/I LRB12 L N,J

'E 2,

1 1

2

.1 1

NRR/DRIS/DIR NUDOCS-ABSTRACT OGC/HDS2 1

1 1

1 1

1 RE FILE 1 1 RES MORISSEAU i D 1 1 01 1 1 EXTERNAL: LPDR 1 1 NRC PDR 1 1 NSIC 1 1 5 5 NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

TAL NUMBER OF COPIES REQUIRED: LTTR 31 ENCL 31

0'

'0 TENNESSEE VALLEY AUTHORlTY CHATTANOOGA. TENNESSEE 37401 6N 38A Lookout Place NOV 20 888 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Gentlemen:

In the Hatter of Docket Nos. 50-259 Tennessee Valley Authority 50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN) UNITS 1, 2, AND 3 NRC INSPECTION REPORT NOS. 50-259/89-47, 50-260/89-47, AND 50-296/89-47 RESPONSE TO NOTICE OF VIOLATION This letter is to provide TVA's response to your letter from Bruce Wilson to Oliver D. Kingsley, Jr. dated October 21, 1989, which transmitted the subject report. This report cited TVA with one Severity Level V Violation O.

'nspection (Supplement I) in accordance with 10 CFR Part 2, Appen~ix C.

Enclosure 1 provides background information and TVA's response to the violation cited in the subject report.

A list of commitments is provided in Enclosure 2.

If you have any questions, please telephone Patrick P. Carier, BFN, at (205) 729-3570.

Very truly yours, goal TENNESSEE VALLEY AUTHORITY Mark O. Medford, Vice esident, Nuclear Technology and Licensing Enclosures cc: See page 2 85'11270 g 07 g.-.0

~E1OCr, <~.",iaoc>- ~-a i3 F'DC An Equal Opportunity Frnployer

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

Ms. S. C. Black, Assistant Director for Projects TVA Projects Division U.S. Nuclear Regulatory Commission One Hhite Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Mr. B. A. Nilson, Assistant Director for Inspection Programs TVA Projects Division U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NH, Suite 2900 Atlanta, Georgia 30323 NRC Resident Inspector Browns Ferry Nuclear Plant Route- 12, Box 637 Athens, Alabama 35609-2000

ENCLOSURE 1

RESPONSE

NRC INSPECTION REPORT NOS. 50-259/89-47, 50-260/89-47, AND 50-296/89-47 LETTER FROM B. A. HILSON TO O. D. KINGSLEY, JR.

DATED OCTOBER 21, 1989 Statement of Violation 10 CFR 50 Appendix B Criterion VI, Document Control, requires that measures shall be established to control the issuance of documents including changes thereto, which prescribe all activities affecting quality. These measures shall assure that documents, including changes, are reviewed for adequacy and are distributed to the location where the prescribed activity is performed.

Nuclear Quality Assurance Manual Part I, Section 2.6, Document Control, Paragraph 5.1.1, requires that programs and procedures shall be established for the control of documents for activities that affect safety-related functions.

Site Directors Standard Practice 2.12, Controlling Documents, establishes the requirements for the processing of controlled documents to ensure that the latest applicable controlled documents are available and distributed to identified recipients and to minimize the inadvertent use of voided or superseded documents.

Contrary to the above, these requirements were not met in that adequate document control was not maintained for a TS amendment and controlled copies of TS for the following three examples:

l. Adequate document control was not maintained for TS Amendment 135, 131, 106, dated August 20, 1987, which revised TS definition 1.0.C.2 to.

clarify its applicability during Cold Shutdown or Refueling. On September 26, 1989, the inspector identified that page 1.0-2 located in controlled copies of the TS did not reflect the approved and issued change. The correct wording had been incorporated into controlled copies of the TS but not into the plant licensing's staff master copy. In February 1989, TS Amendment 158, 157, 129 revised different information contained on the same page in TS definition 1.0.C.2.

2. Unit 2 TS controlled copy 52 was not properly maintained with the latest amendment to TS. On September 27, 1989, the inspector identified that existing pages 1.1/2.1-2 through 1.1/2.1-4 of copy 52 reflected the original amendment dated March 19, 1987, instead of amendment 143 dated March 3, 1989.

3. Unit 2 TS Control Room copy 40 was not properly maintained. On September 27, 1989, the inspector identified that two copies of page 3.7/4.7-16 existed but only one of which was annotated with information pertaining to compensatory measures 88-64-2-007, in effect at the time.

The above instances are examples of a Severity Level V Violation (Supplement I) and is applicable to all three units.

Page 2 of 4 T VA Response

l. Admission or Denial of the Alleged Violation TVA admits the violation occurred as stated. Due to the difference in the three examples, TVA will discuss the reasons for the violation, corrective steps which have been taken and results achieved, corrective steps which will be taken to avoid further violations, and date of full compliance separately for each example.

2. Reasons for the Violation A. TVA BFN uses a computer master TS file to store NRC approved TS's.

This file is updated by the BFN Licensing Speciali.st when the NRC approved TS change is received. The master file can only be accessed through a security code which is controlled by the Licensing Specialist. In investigating this specific example, it is apparent that the computer master file was not updated after the issuance of TS Amendment 135, 131, 106 dated August 20, 1987. As a result, when this specific page was revised (TS Amendment 158, 157, and 129), the original TS words were inadvertently incorporated. Therefore, when TS Amendment 158, 157, and 129 was issued, the previously approved changes in TS Amendment 135, 131, and 106 were not contained. This resulted in inadvertent use of the outdated wording in TS definition 1 ~ 0.C.2, however, use of the outdated wording did not decrease any margin of safety. The outdated words were minor in nature and were changed to only provide additional clarification.

B., BFN Document Control uses two methods of updating controlled documents. The first method utilizes Document Control staff to physically insert the revised pages in the controlled document. In the second method, the revised pages are submitted to the document holder with instructions of how to update their controlled documents. Upon completion of either process, documentation of completion is returned to Document Control. The subject controlled document, TS copy 52, is updated by the BFN Document Control staff.

For the specific example cited in the subject inspection report, the pages were either inadvertently replaced with the original pages 1.1/2.1-2 through 1.1/2.1-4 or those revised pages were not inserted when the controlled document was being updated. Controlled copy 52 is the Site Residents copy of the BFN TS. This copy is not used to perform any safety analysis or operation of the plant, therefore, this specific issue did not decrease any margin of safety.

C. The Unit 2 Control Room TS copy 40 is updated by the Document Control staff. When this copy was updated, the existing, page 3.7/4.7-16 was measured'his to be replaced. When the revised page was placed in the document, the existing page was not removed. This resulted in two page 3.7/4.7-16's left in the document. The only difference in the two pages was the revised page had an annotation pertaining to a compensatory is an additional requirement implemented by BFN. The Limiting Condition of Operation (LCO) and the Surveillance Requirement (SR) were the same on both pages therefor e, there was no decrease in the margin of safety.

Page 3 of 4

3. Corrective Steps Which Have Been Taken and Results Achieved TVA reviewed these three examples to determine the reason for error.

Based on this review it was determined that these were isolated issues and there is not a programmatic problem. In all three cases personnel error was identified to be the reason for the error.

When TS Amendment 158, 157, and 129 was issued (February 1989), BFN typically reviewed only those parts of the LCOs or SRs that were being revised. In early spring 1989, BFN started to review not only those sections being revised but the entire page. This provided additional checks and balances to ensure that the entire page reflects not only those sections being revised but ensures the rest of the page reflects what has been approved by NRC in previous changes. Since'his practice was implemented, BFN has minimized such errors.

As a result of the subject inspection report, BFN Document Control Records Management (DCRM) conducted a 100% assessment (51 copies) of the controlled sets of TS's on site and 2 additional sets in Chattanooga. The scope of this assessment was to see if any other controlled copies of the BFN TS's contained the same page errors identified in controlled copy 52. The results of the assessment demonstrated that the page errors were unique to controlled copy 52.

This is considered an isolated case which resulted from personnel error.

In early 1989, DCRM implemented a self-assessment program, improved transmittal receipt acknowledgment tracking system, and a reduction in the number of controlled manuals in an effort to enhance the overall document control process at BFN. DCRM instruction DCRMI 302.2 was also updated to require that an audit of selected controlled documents (including the Technical Specifications) be performed on an annual basis. These steps, in addition to the actions discussed above, have enhanced the overall control process of these documents.

After NRC identified that two copies of the same page existed in Unit 2 TS Control Room copy 40, one of the pages was deleted to correct the problem. Upon correcting this problem, DCRM instructed their personnel of the importance of correctly updating controlled manuals. In addition, DCRM performed a 100% audit of controlled copies of the TSs on site to ensure that the same problem did not exist (two copies of the same page 3.7/4.7-16). This audit did not identify any other copies with the same problem, therefore, this is con'sidered an isolated case which resulted from personnel error.

Page 4 of 4

4. Corrective Steps Hhich Hill Be Taken to Avoid Further Violations A. To correct the specific problem, BFN will resubmit the correct page 1.0-2 in a subsequent TS submittal to NRC. This has been discussed and approved by the NRC/TVA Project Manager.

B. The continued implementation of the corrective steps discussed in section 3.B above are considered adequate to avoid further violations. No other steps are being considered at this time.

C. As stated above, DCRM procedure DCRM 302.2 was revised to require an annual audit be performed on specified controlled documents to minimize such errors. In addition, continued emphasis to the DCRM employees on the importance of correctly updating these documents is expected to avoid further violations of this nature.

5. Date Hhen Full Compliance Hill Be Achieved A. The correct page 1.0-2 wi 11 be submitted to NRC by January 5, 1990.

B. BFN is in full compliance with the steps stated abov'e.

C. BFN is in full compliance with the steps stated above.

ENCLOSURE 2 LIST OF COMMITMENTS

1. TVA will submit the correct page 1.0.2 to NRC by January 5, 1990.