ML18037A479

Provides Description of Drawing Upgrade Process Intended for Use During Restart Activities for Units 1 & 3,in Ref to 930806 Response to NRC Re Violations & Deviations Noted in Insp Rept 50-259/93-23 & 50-296/93-23

ML18037A479
Person / Time
Site:	Browns Ferry
Issue date:	09/30/1993
From:	Salas P TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9310040395
Download: ML18037A479 (9)

Text

ACCELERATED DOCUMENT DISItutu I Iuz SX S IXm REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9310040395 DOC.DATE: 93/09/30 NOTARIZED: NO DOCKET ¹ FACIL:50-259 Browns Ferry Nuclear Power Station, Unit 1, Tennessee 05000259 50-296 Browns Ferry Nuclear Power Station, Unit 3, Tennessee 05000296 AUTH.NAME AUTHOR AFFILIATION

'ALASgP.

Tennessee Valley Authority RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Provides description of drawing upgrade process intended for use during restart activities for Units 1

& 3,in ref to 930806 response to NRC 930713 ltr re violations

& deviations noted in Insp Rept 50-259/93-23

& 50-296/93-23.

DISTR1BUTION CODE:

IE01D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:

D RECIPIENT ID CODE/NAME PD2-4-PD WILLIAMSgJ.

INTERNAL: ACRS AEOD/DSP/ROAB AEOD/TTC NRR/DORS/OEAB NRR/DRIL/RPEB NRR/PMAS/ILPBl NUDOCS-ABSTRACT OGC/HDS3 RES/HFB EXTERNAL: EG&G/BRYCEgJ.H.

NSIC COPIES LTTR ENCL 1

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1 2

2 1

1 1

1 1

1 1

1 1

1 1

1 1

1l,l 1

1 1

1 RECIPIENT ID CODE/NAME ROSSiT.

AEOD/DEIB AEOD/DSP/TPAB DEDRO NRR/DRCH/HHFB NRR/DRSS/PEPB NRR/PMAS/ILPB2 OB D'G FILE 02 RGN2 FILE 01 NRC PDR COPIES LTTR ENCL 1

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NOTE TO ALL"RIDS" RECIPIENTS PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMEN'I'ONTROL DI:.SI',

ROOM P1.37 (EXT. 504-206)5) TO ELIMINATEYOUR NAME FROM DIST)MIDI "I ION LISTS FOR DOCUMENTS YOU DON'T NEEDi D

TOTAL NUMBER OF COPIES REQUIRED:

LTTR 25 ENCL 25

Tennessee valley Authority. Post Office Box 2000, Decatur. Alabama 35609 SEP 30 1993 U.S. Nuclear Regulatory Commission ATTN:

Document Control Desk Washington, D.C.

20555 Gentlemen:

In the Natter of

~

)

Tennessee Valley Authority

)

Docket Nos.

50-259 50-260 50-296 s

BROWNS FERRY NUCLEAR PLANT (BFN) - NRC INSPECTION REPORT 50 259I 50 260I 50 296/93 23'EPLY TO NOTICE OF DEVIATION (NOD)i DESCRIPTION OF DRAWING UPGRADE PROCESS FOR UNITS 1

AND 3

Reference:

1. Letter from NRC to TVA, dated July 13,

1993, Notice of Violation and Deviation (NRC Inspection Report Nos.

50-259, 50-260, 50-296/93-23)

2. Letter from TVA To NRC, dated August 6,

1993, NRC Inspection Report 50-259, 50-260, 50-296/93-23 Reply to Notice of Violation (NOV) and Notice of Deviation (NOD)

This letter provides a description of BFN's drawing upgrade process intended for use during the restart activities for Units 1 and 3.

In Reference 1,

NRC identified a NOD consisting of two examples related to the issuance of Configuration Control Drawings (CCDs).

The first example concerned the issuance of CCDs following modification activities.

This example was addressed in TVA's reply to) the NOD (Reference 2).

The second example concerned the issuance of.CCDs without a system walkdown.

TVA's response, in Reference 2, stated that lessons learned during the restart of Unit 2 showed that once deviations from prior documentation were reconciled on plant

~ nnf:ts.

9310040395 930'930 PDR ADOCK 05000259 8

PDR

U.S. Nuclear Regulatory Commission Page 2

SEP 30 l993

drawings, the as-constructed drawings were technically equivalent to CCDs even though plant walkdowns may not have been completed.

TVA considered this to be a program improvement since a more accurate drawing was made available for use at an earlier date.

Additionally, TVA acknowledged that these program revisions made to the CCD process were not in strict accordance with previous NRC commitments.

As a

result, TVA committed to submit a description of the drawing upgrade process presently intended for use during the restart activities 'for Units 1 and 3.

The description is provided in the enclosure to this letter.

~

'here are no additional commitments, contained in this letter.

If you have any questions, please telephone me at (205) 729-2636.

Sincerely,

~

y I

C Salas Manager of Site Licensing Enclosure cc (Enclosure):

Mr. R. V. Crlenjak, Project Chief 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 35611 Mr. J.

F. Williams, Project Manager U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852

ENCLOBURE Browns Ferry Nuclear Plant (BFN)

Drawin U

rade Process for Units 1 and 3

The methodology for issuing configuration control drawings (CCDs) for BFN Unit 2, within the Design Baseline Verification Program (DBVP), was based on commitments contained in Volume 3 of the TVA Nuclear Performance Plan (NPP).

As a result of lessons learned from the Unit 2 DBVP, TVA submitted a letter to NRC dated June 13,

1991, "Design Baseline Verification Program," describing the process for completing the DBVP for BFN Units 1 and 3.

Enclosure 1 (page 11 of 14) of the referenced letter discussed lessons learned from the Unit 2 DBVP.

"The Units 1 and 3

DBVP will not explicitly identify and reconcile differences between the as-designed and as-constructed drawings.

Verified as-constructed drawings will be generated from walkdown data.

CCDs will be generated by evaluation of these verified as-constructed drawings against the design basis and reconciliation of any discrepancies identified."

As stated in the above referenced letter, the as-constructed (AC) and as-designed (AD) reconciliation review for Units 1 and 3

drawings, within the scope of DBVP, is not required.

However, TVA has implemented a drawing improvement program for Units 1 and 3 drawings which allows a review and reconciliation of AD and AC drawings for consistency,

accuracy, and to incorporate outstanding completed changes as a method to issue CCDs.. This reconciliation review does not eliminate any of the activities required by controlled programs (e.g.,

walkdowns for the DBVP).

The drawing improvement program described above has been included in design control procedure, Browns Ferry Engineering Project (BFEP), Project Instruction (PI) 89-06.

Accordingly, this procedure states that a

CCD may be issued when any of the criteria listed below are met:

a.

When a walkdown package showing the plant configuration and calculations and/or evaluations have been performed to support the walkdown configuration, other drawings may be superseded and the CCD produced from the walkdown results.

b.

When a controlled program (Baseline Verification

Program, System Plant Acceptance Evaluation, Drawing Improvement Program, etc.) performs a review of a drawing and resolves discrepancies to reflect plant configuration.

When a new drawing is issued with a Design Change Notice (DCN) or to incorporate installed and verified Drawing Change Authorizations (DCAs).

When AC and AD revisions of a drawing are reviewed,

scrubbed, and reconciled to ensure that installed and verified changes shown on the AD have been incorporated on the AC.

Note:

Since this review results in the best available single drawing on which to base future reviews and changes, a

CCD may be issued based on this reconciliation prior to the drawing being reviewed by a controlled program.

For drawings outside the scope of any System Plant Acceptance Evaluation (SPAE), the current AC drawing may be issued as a

CCD.

For drawings which are not required to reflect plant configuration, the AC or AD drawing may be issued as a

CCD.