ML20058G944
| ML20058G944 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 12/07/1993 |
| From: | Trimble D Office of Nuclear Reactor Regulation |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 9312100189 | |
| Download: ML20058G944 (13) | |
Text
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. l December 7, 1993
'l Docket Nos.60-259, 50-260 l and 50-296 l
LICENSEE: Tennessee Valley Authority (TVA) l FACILITY: Browns Ferry Nuclear Plant, Units 1, 2, and 3 l
SUBJECT:
SUMMARY
OF A NOVEMBER 10, 1993, MEETING REGARDING TVA'S ACTION PLAN i TO IMPROVE THE QUALITY OF LICENSING SUBMITTALS FOR THE BROWNS FERRY NUCLEAR PLANT ,
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On November 10, 1993, representatives of the U.S. Nuclear Regulatory '
Commission (NRC) staff and the Tennessee Valley Authority (TVA) met in Rockville, Maryland, to discuss the licensee's plans to improve the quality of ,
licensing submittals for the Browns Ferry Nuclear Plant (BFN). Meeting :
attendees are listed in Enclosure 1. Enclosure 2 is TVA's detailed action plan for improving the quality of licensing submittals, which was provided by the licensee as a handout at the meeting.
The action plan was developed in response to NRC concerns regarding the ;
adequacy of TVA licensing submittals. Those concerns were identified to the licensee in a public meeting on September 3, 1993.
While the action plan is largely directed toward improvement of BFN Site Licensing Group performance, the Site Engineering Manager acknowledged that ,
the engineering group bears some of the responsibility for deficiencies in submittals, such as.the failure, in some cases, to provide sufficient technical information to support regulatory action. The Site Engineering Manager further stated his intention to develop performance standards in this area for his employees and to provide additional management oversight of engineering activities supporting licensing actions.
Original signed by David C. Trimble, Project Manager Project Directorate II-4 Division of Reactor Projects - I/II <
090000 Office of Nuclear Reactor Regulation
Enclosures:
- 1. Attendance List -i
- 2. Licensee Action Plan ;
cc w/ enclosures: ,
See next page j OFC PDII-4/LA PDII-4/PM PDII-4/PM -PDII-4/D NAME BClaytebf DTrimble d JWillip[d Fd$ don :
DATE 12/rf/93 DOCUMENT NAMEi 12/ 7 /93 12/ 7 /93 12/ '7 /93 ( g.
G:\BFN\LICSUBMT. SUM l R 59 P PDR
BROWNS FERRY NUCLEAR PLANT cc:
Mr. Craven Crowell, Chairman TVA Representative Tennessee Valley Authority Tennessee Valley Authority ET 12A 11921 Rockville Pike, Suite 402 400 West Summit Hill Drive Rockville, MD 20852 Knoxville, TN 37902 General Counsel Mr. W. H. Kennoy, Director Tennessee Valley Authority Tennessee Valley Authority ET 11H ET 12A 400 West Summit Hill Drive 400 West Summit Hill Drive Knoxville, TN 37902 Knoxville, TN 37902 Chairman Mr. Johnny H. Hayes, Director Limestone County Commission Tennessee Valley Authority P.O. Box 188 ET 12A Athens, AL 35611
- 400 West Summit Hill Drive Knoxville, TN 37902 State Health Officer Alabama Department of Public Health Mr. R. M. Eytchison, Vice President 434 Monroe Street Nuclear Operations Montgomery, AL 36130-1701 Tennessee Valley Authority i
3B Lookout Place Regional Administrator 1101 Market Street U.S. Nuclear Regulatory Commission
, Chattanooga, TN 37402-2801 Region II 101 Marietta Street, NW., Suite 2900 Mr. Pedro Salas Atlanta, GA 30323 Site Licensing Manager Browns Ferry Nuclear Plant Mr. Charles Patterson i Tennessee Valley Authority Senior Resident Inspector l P.O. Box 2000 Browns Ferry Nuclear Plant Decatur, AL 35602 U.S. Nuclear Regulatory Commission Route 12, Box 637 Mr. O. J. Zeringue, Vice President Athens, AL 35611 Browns Ferry Nuclear Plant Tennessee Valley Authority Mr. T. D. Shriver P.O. Box 2000 Site Quality Manager Decatur, AL 35602 Browns Ferry Nuclear Plant Tennessee Valley Authority Mr. B. S. Schofield, Manager P.O. Box 2000 Nuclear Licensing and Regulatory Affairs Decatur, AL 35602 Tennessee Valley Authority 4G Blue Ridge Mr. D. E. Nunn, Vice President 1101 Market Street Tennessee Valley Authority Chattanooga, TN 37402-2801 3B Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 F
Dr. Mark 0. Medford, Vice President Technical Support Tennessee Valley Authority 3B Lookout Place 1101 Market Street Chattanooga, Tennessee 37402-2801
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ENCLOSURE I ATTENDELS NOVEMBER 10, 1993 TVA/NRC MEETING LICENSEE ACTION PLAN TO IMPROVE LICENSING SUBMITTALS NAME ORGANIZATION Joe Williams NRR/PD II-4 Pedro Salas TVA/BFNP Site Licensing Jim Maddox TVA/BFNP Site Engineering Dave Trimble NRR/PD II-4 Fred Hebdon NRR/PD II-4 Roger Huston TVA
UNITED STATES
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[d2g%[k c NUCLEAR REGULATORY COMMISSION wAsmucion, o.c. 2ases om gv ,
- December 7, 1993 1
Docket Nos. 50-259, 50-260 and 50-296 LICENSEE: Tennessee Valley Authority (TVA)
FACILITY: Browns Ferry Nuclear Plant, Units 1, 2, and 3
SUBJECT:
SUMMARY
OF A NOVEMBER 10, 1993, MEETING REGARDING TVA'S ACTION PLAN TO IMPROVE THE QUALITY OF LICENSING SUBMITTALS FOR THE BROWNS FERRY NUCLEAR PLANT On November 10, 1993, representatives of the U.S. Nuclear Regulatory Commission (NRC) staff and the Tennessee Valley Authority (TVA) met in Rockville, Maryland, to discuss the licensee's plans to improve the quality of licensing submittals for the Browns Ferry Nuclear Plant (BFN). Meeting attendees are listed in Enclosure 1. Enclosure 2 is TVA's detailed action plan for improving the quality of licensing submittals, which was provided by the licensee as a handout at the meeting.
The action plan was developed in response to NRC concerns regarding the adequacy of TVA licensing submittals. Those concerns were identified to the licensee in a public meeting on September 3, 1993.
While the action plan is largely directed toward improvement of BFN Site Licensing Group performance, the Site Engineering Manager acknowledged that the engineering group bears some of the responsibility for deficiencies in submittals, such as the failure, in some cases, to provide sufficient technical information to support regulatory action. The Site Engineering Manager further stated his intention to develop performance standards in this area for his employees and to provide additional management oversight of engineering activities supporting licensing actions.
l OcQ 0 SdIE David C. Trimble, Project Manager Project Directorate II-4 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation
Enclosures:
- 1. Attendance List
- 2. Licensee Action Plan cc w/ enclosures:
See next page l
d ENCLOSURE 2 ACTION PLAN FOR IMPROVING QUALITY OF LICENSING BUBMITTAL I. DACKGROUND On August 26, 1993, NRC Project Manager, Thierry Ross, contacted TVA and said that his input for the current SALP report would contain negative comments related to the quality of TVA submittals. TVA met with Mr. Ross on September, 1993 to obtain specific details of the problems that NRC had encountered during their review of submittals.
To independently assess the extent of the problem, QA and Licensing conducted an assessment to evaluate the quality and adequacy of submittals. From this assessment, the team concluded that there was sufficient evidence to indicate that improvements are needed in the quality of Licensing submittals.
As a result of the meeting with Mr. Ross and the independent assessment, Licensing was chartered to develop an action plan containing a comprehensive set of corrective actions. The purpose of this action plan is to improve the quality of BFN Licensing submittals to become among the best in the industry.
II. LICENSING INTERNAL ASSESSMENT To ensure employee acceptance, every engineer was asked to participate in the identification of the problems. To figure out the causes, the group used the first steps of the problem solving process from TVA's Total Quality, Tools and Techniques training.
With the assistance of facilitators from the Total Quality Organization, Licensing managers, and engineers met and "brainstormed" causes of the problem. Over 50 potential causes were identified. Group consensus was used to eliminate causes that were either of very minor effect or not within Licensing's control. This resulted in twelve causes that were prioritized based on the need for improvement, effect of improvement on the problem, and ability to solve. Two causes were eliminated based on relatively low impact and need for improvement. The remaining ten are included in this action plan.
The identified causes were grouped in three general categories; Teamwork / Interface, Personnel Performance, and Technical ;
Specification Issues. The following is a description of the findings in each category and corresponding corrective actions.
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- 1. Teamwork / Interface Two problem interface areas were identified: Licensing's interface with other site organizations during the development of submittals, and lack of interface with NRC.
Typically, Licensing issues a Licensing Information Request (LIR) or makes a verbal request to site organizations for information needed to prepare a submittal. In some cases, inadequate communication between licensing and site organizations results in an inferior product.
There has been little communication with NRC reviewers during development of submittals in the past partially due to NRC's reluctance to appear to be assisting or advising TVA. Additionally, Licensing engineers have not always done adequate research to identify existing NRC guidance for submittal (e.g., Generic Letters, SERs, Reg. Guides, SRP, etc.).
Corrective Actions (a) For significant NRC submittal, a strategy meeting and mid-course meeting will be held with all involved site organizations during the development of the submittal.
The strategy meeting will define objectives of the submittal, define actions, determine level of detail needed by NRC, and clarify information needed. Any clarification needed from NRC will be identified and Licensing will hold telecons with NRC and involved site organizations to obtain the required information. The
, mid-course meeting will be used to monitor progress on l actions, discuss new information, and verify that objectives of the submittal will be met.
Status: Complete. Licensing engineers have been instructed to initiate these meetings.
(b) Issue memorandum to site organizations explaining the process above. l Status: Complete Responsibility: Abney (c) Obtain concurrence of NRR Project Manager to identify reviewers of submittal and discuss expectations prior l to developing submittal and during review of the
( submittal.
Status: Complete. Joe Williams has agreed to this action.
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(d) Conduct meeting with Licensing engineers and NRR Project. Managers to discuss past problem areas with BFN submittal.
Status: Complete. Joe Williams and Dave Trimble met with Licensing engineers on September 8, 1993.
I (e) Modify existing licensing databases to allow comments from NRC on submittals to be fedback to responsible site organizations.
Status: Due November 30, 1993 Responsibility: Abney (f) State management expectations regarding research for submittal.
Status: Due November 12, 1993 Responsibility: Salas (g) Add item to Independent Review Checklist (Action 3(g)) i to verify that. applicable references were reviewed. !
Status: Complete l
Responsibility: Wells (h) Conduct training with site line managers to make them l aware of the importance of accurate and complete {
information submitted to NRC. 1 Status: Complete Responsibility: Salas (i) Obtain commitment from NRR Project Managers to provide periodic feedback on quality of submittal.
Status: Complete. Joe williams has agreed to this action. q (j) Conduct meetings with Licensing engineers and Licensing managers prior to beginning work on each submittal for
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the next six months to define strategy, identify issues i
to be considered, and verify that required research is I- done.
Status: Started September 27, 1993 l
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Responsibility: Salas/Abney/ Wells l l
i (k) Conduct periodic meetings with site managers ;
responsible for input to licensing submittals. The purpose of these meetings is to inform managers of plans, schedules and problem areas (See Action 1 (e))
and improve communication. Meetings will be held on an !
as-needed basis. !
Status: Due to start November 30, 1993 i Responsibility: Salas ,
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- 2. Technical Specification Issues For 1993 to date, sixteen Technical Specification amendments have been submitted to NRC, and seven Request's for 1 Additional Information (RAI) for Technical' Specification ,
amendments have been received from NRC. The reasons for the !
RAIs have been primarily lack of adequate and complete justification, failure to follow existing NRC guidance, and l administrative errors due to lack of attention to detail.
There have also been some errors and time wasted in ;
preparation of Technical Specification amendments due to ;
engineers not fully understanding the process. The large number of potential Technical Specification changes and pending changes with NRC also introduces a potential for error when changes are submitted and other pending changes-exist on the same Technical Specification page. There is currently no individual in Site Licensing with overall responsibility for coordinating Technical Specification changes.
Corrective Actions (a) Instruct Licensing engineers to ensure that complete a justification is provided for each Technical _,
Specification amendment submittal and discuss problem ,
areas identified by NRC.
Status: Complete t
Responsibility: Abney/ Wells (b) Assign a Licensing engineer to act as coordinator for !
all Technical Specification amendments. ;
Responsibilities will be to understand the process and ,
advise other engineers, track potential changes and ;
consolidate to minimize the number of amendment '
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b requests, and maintain priority list of amendment i requests. .
Status: Complete. Stewart Wetzel has been appointed ;
as coordinator.
Responsibility: Abney t
(c) Develop _a desktop procedure to guide Licensing >
engineers in processing Tech Spec amendments.
4 Status: Due November 30, 1993 Responsibility: Abney '
(d) Reduce errors caused by lack of attention to detail.
See Corrective Actions 3(a), 3(b), and 3(g).
(e) Develop a process to better track and prevent problems [
due to multiple pending changes. ~
Status: Due November 30, 1993 ;
l Responsibility: Abney l (f) Identify utilities that NRC considers best at Technical j specification amendments, survey them for their methods, and implement into BFN processes.
Status: Due January 14, 1994. Joe Williams has agreed i to provide a listing of those utilities they consider to produce quality Technical Specification amendments
-by November 12, 1993.
Responsibility: Abney
- 3. Personnel Performance ,
4 The need to improve the quality of Licensing submittal relates directly to the performance of Licensing personnel (managers and engineers). Licensing personnel have not always felt ownership of the submittal, and have not been held accountable for errors. This, in part, has been due to Licensing managers not clearly expressing expectations of :
the Licensing engineers.
Licensing engineers do not always have sufficient knowledge of plant systems / components to ask the right questions of ,
the organization providing the input. Additionally, the ]
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i training requirements and practical factors for Licensing i engineers to effectively perform their assigned tasks has -
c not been formalized. ;
The writing skills of Licensing engineers is an area which '
requires improvement. Some submittals have not been clearly written and there have been several instances of poor l sentence structure and grammatical errors.
The Independent Review (IR) of Licensing. submittal as '
defined in Business Practice 203 has been deficient in some '
cases. Licensing engineers have sometimes relied'on the IR as a " safety net" to identify errors in the NRC submittal.
The expectations of the individual performing the IR have not been clearly defined. ;
Corrective Actions I
(a) Licensing managers will emphasize to their personnel that Licensing is the primary owner of submittal (with appropriate technical ownership by responsible line organizations) and is accountable for deficiencies that are identified.
I Status: Complete. The Regulatory and Compliance ~j Licensing managers have discussed the issue at their staff meetings.
(b) Licensing managers will specify, in writing, their expectations of Licensing engineers. .
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Status: Due November 12, 1993 Responsibility: Salas (c) An INPO based Licensing Qualification procedure will be ,
developed in coordination with the Training Department.
l Status: Complete i
Responsibility: Wells (d) Licensing managers evaluate engineers against action ;
3(c) above to decide if further training courses should be required to improve engineers' knowledge of plant systems and components.
Status: Due November 15, 1993 i Responsibility: Abney/ Wells (e) Available advanced plant systems training (SRO i
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o certification, system engineer, etc.) will be evaluated (
and a long-term training plan established for Licensing l 1 engineers. !
l Status: Due November 29, 1993 Responsibility: Salas/Abney/ Wells 1 (f) A technical writing course for Licensing engineers / managers will be developed and presented. i Status: Due March 1, 1994 l Responsibility: Salas (g) An IR checklist will be developed which specifies the l expectations of irs for Licensing submittal. !
l Status: Complete i Responsibility: Wells (h) Licensing databases will be modified to allow quality !
problems, including RAIs, to be recorded and this data !
will be used as input to Licensing engineer service .!
reviews. !
I Status: Complete }
Responsibility: Abney/ Wells l i
(i) Licensing engineer service reviews will include an evaluation of quality of submittal based on accuracy !
and completeness of information. "
i Status: Started September 27, 1993 Responsibility: Abney/ Wells i i
III. INCREASED MANAGEMENT AND QA OVERSIGHT I
.i In order to assess the extent of the problem, Licensing will j review every Notice of Violation and LER still open. This .i assessment will be completed by November 5, 1993. QA will ;
independently review Licensing's assessment. From'the results, l
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it will be determined if the review should be expanded.
Additionally, in order to monitor to effectiveness of the ~I corrective actions, Licensing supervision will maintain increased l
, management participation in daily activities in every aspect of 1 '
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o submittal preparation. This will remain in effect until March 31, 1994 to ensure that a consistent level of performance has been achieved. Then, Licensing management will scale back its oversight over those engineers that show continued good performance. If individual performance problems continue, individual action plans will be develooed. QA monitoring will be used to independently assess the level of improvement.
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