ML18033B272

Responds to NRC 900326 Ltr Re Violations Noted in Insp Repts 50-259/89-56,50-260/89-56 & 50-296/89-56.Corrective Actions: Administrative Control Sdsp 29.1 Revised to Provide Guidance on Process to Evaluate Measuring & Test Equipment

ML18033B272
Person / Time
Site:	Browns Ferry
Issue date:	04/25/1990
From:	Medford M TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9004270289
Download: ML18033B272 (7)

Text

ACCELERATED DISTjUBUTION DEMONSTjRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

CESSION NBR:9004270289 DOC.DATE: 90/04/25 NOTARIZED: NO DOCKET 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 MEDFORD,M.O. Tennessee Valley Authority RECIP.NAME RECXPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Responds to NRC 900326 50-259/89-56,50-260/89-56 ltr &

re violations noted in Insp Repts 50-296/89-56.

DISTRIBUTION CODE: IE01D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:1 05000259 on, 05000260 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 ID CODE/NAME LTTR ENCL PD ROSS,T. 1 1 ACRS 2 2 AEOD 1 1 AEOD/DEIXB 1 1 AEOD/TPAD 1 1 DEDRO 1 1 NRR SHANKMAN,S 1 1 NRR/DLPQ/LPEB10 1 1 NRR/DOEA DIR 11 1 1 NOTES'OPXES NRR/DREP/PEPB9D NRR/DST/DIR 8E2 NUDOCS-ABSTRACT 1

1 1

1 1

1 NRR/ DRI S/ DIR BI I

NRR/PMAS/ LRB1 2 1

1 1

1 1

1 OGC/HDS2 <<1 1 REG FIL 02 1 1 RES/DSR/HFB/HFS 1 1 RGN'ILE 01 1 1 EXTERNAL: LPDR 1 1 NRC PDR 1 1 NSIC 1 1 5 5 NVIZTO ALL "RIDS" RECIPIENIS:

P~ HELP US TO REDUCE WASTE! CONTACT THE. DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION TOTAL NUMBER OF COPXES REQUIRED: LTTR 29 ENCL 29

if TENNESSEE VALLEY AUTHORITY CHATTANOOGA. TENNESSEE 37401 6N 38A Lookout Place APR 25 III U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Hashington, D.C. 20555 Gentlemen:

In the Matter of Docket Nos. 50-259 Tennessee Valley Authority 50-260 50-296 BRONNS FERRY NUCLEAR PLANT (BFN) NRC INSPECTION REPORTS NOS. 50-259/89-56, 50-260/89-56, AND 50-296/89-56 RESPONSE TO NOTICE OF VIOLATION This letter provides TVA's response to the notice of violation transmitted by letter from B. A. Hilson to 0. D. Kingsley, Jr. dated March 26, 1990. NRC cited TVA with a Sever>ty Level IV violation pertaining to calibration of measuring and test equipment (I'&TE). In the example given, two pieces of'&TE were not calibrated with a standard at least four times as accurate as the M&TE being calibrated. A justification for use of the M&I'E was not documented by responsible management as required by procedure. TVA. has reviewed this event and is taking appropriate corrective actions. contains TVA's response to the notice of violation. The violation is discussed along with the corrective actions taken. Enclosure 2 is a listing of the commitments made in this response.

If you have any questions regarding this response, please contact Patrick P. Carier at (205) 729-3570.

Very truly yours, TENNESSEE VALLEY AUTHORITY Mark 0.'edford, 1 e President Nuclear Technology nd Licensing Enclosures cc: See page 2 9C) 0425 9r) 042702~'9 05'.)

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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 Rockvi lie, Maryland 20852 NRC Resident Inspector Browns Ferry Nuclear Plant Route 12, Box 637 Athens, Alabama 35609-2000 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

ENCLOSURE 1 RESPONSE BROWNS FERRY NUCLEAR PLANT (BFN)

NRC INSPECTION REPORT NOS. 50-259/89-56, 50-260/89-56, AND 50-296/89-56 LETTER FROM B. A. WILSON TO O. D. KINGSLEY, JR.

DATED MARCH 26, 1990 Violation 10 CFR 50, Appendix B, Criteria V, as implemented by TVA Topical Report TVA-TR75-1A, requires compliance with procedures. Procedure SDSP-29.1 states that measuring and test equipment must be calibrated with standards which are at least four times as accurate as the equipment being calibrated. It permits use of measuring and test equipr"ent not meeting this requirement if the basis for acceptance is documented and authorized by responsible management.

Contrary to the above, on January 9, 1990 this procedure requirement had not been met for Browns Ferry meesuring and test equipment in that two pressure gauges (Serial Nos. US-TVA-522068 and 517116) had been released for use even though records on site showed that the four times accuracy requirements had not been met in the calibration and no justification for use had been t

documented by responsible management.

1. Admission or Denial of the Violation TVA admits the violation.

2. Reason for the Violation This violation has been attributed to inadequate administrative controls. SDSP 29.1 "Control of Measuring and Test Equipment," required that MKTE be calibrated by standards that are at least four times as accurate as the equipment being calibrated. Deviations from this requirement were allowed if the basis for acceptance was documented and authorized. However, SDSP 29.1 did not provide adequate guidance for the implementation of this process. As a result, METE which did not meet this requirement were issued for use without appropriate justification and authorization.

3. Corrective Ste s Which Have Been Taken and Results Achieved SDSP 29.1 has been revised to provide guidance on the process to evaluate MKTE that was not calibrated with a standard four times more accurate.

Subsequent management review of SDSP 29.1 has identified additional changes that are needed to improve the process. These changes will ensure that calibrated METE r;ceived at BFN that does not meet the four to one calibration ratio and has not been calibrated by a state-of-the-art standard will be evaluated prior to use.

Enclosure 1 Page 2 For the two pressure gauges 'specifically identified in this violation, a recalculation of the accuracy of the standard used in their calibration was performed. This recalculation demonstrated that the calibration standard was actually four times as accurate as the two pressure gauges.

A review of other MINUTE in use at BFN has been performed to determine if any generic implications existed. As a result of this review, additional MINUTE was identified to be evaluated. A Condition Adverse to Quality Report was initiated to track the corrective actions.

An evaluation process is in progress to determine the effects of these discrepancies on plant equipment. Approximately 270 pieces out of 3000 pieces of METE in use at BFN have been identified with this type discrepancy. A sample of M~TE will be evaluated by reviewing their use logs and assuring that their uses have been acceptable. Based upon the results of this sample, evaluations will be performed as necessary. The MINUTE evaluated to date has determined that all their uses have been acceptable.

4. Corrective Ste s Which Will Be Taken to Avoid Further Violations Future cases in which calibrated MINUTE received by BFN do not meet the four to one calibration ratio will be justified and authorized prior to their use. METE currently in use that does not meet this requirement will continue to be evaluated as discussed above.

5. Date When Full Com .liance Will be Achieved The evaluation process of MINUTE currently in use that does not meet the four to one calibration accuracy requirement will be completed prior to Unit 2 fuel load. Administrative controls resulting from these reviews will be implemented prior to Unit 2 fuel load.

ENCLOSURE 2 RESPONSE BRONNS FERRY NUCLEAR PLANT (BFN)

NRC INSPECTION REPORT NOS. 50-259/89-56, 50-260/89-56, AND 50-296/89-56 LETTER FROM B. A. NILSON TO 0. D. KINGSLEY, JR.

DATED MARCH 26, 1990 COMMITMENTS

1. The evaluation process for the METE that does not currently meet the four to one calibration accuracy will be completed prior to Unit 2 fuel load.

2. Administrative controls resulting from the reviews will be implemented prior to Unit 2 fuel load.