ML20150B403
| ML20150B403 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 03/14/1988 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8803160368 | |
| Download: ML20150B403 (6) | |
Text
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G TENNESSEE VALLEY AUTHORITY CHATTANOOGA. TENNESSEE 374ot SU 157B Lookout Place MAR 141988 U.S. Nuclear Regulatory Comm'.ssion ATTN: Document Control Desk Washington, D.C.
20555 Gentlemen:
In the Matter of
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Docket Hos. 50-259 Tennessee Valley Authority
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50-260
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50-296 BROWNS FERRY N11 CLEAR PLANT (BFN) UNITS 1, 2, AND 3 - NRC INSPECTION REPORT NOS. 50-259/87-41, 50-260/87-41, AND 50-296/87 RESPONSE TO NOTICE OF VIOLATION This letter provides TVA's response to your letter from K. P. Bare to S. A. White dated January 21, 1988, which transmitted the subject report. The report cited TVt. with a violation in the area of corrective action. provides TVA's response to the violation. A list of commitments is provided in enclosure 2.
We do not recognize any other items described herein as commitments. An extension of the due date for this response to March 11, 1988, was agreed to by Al Ignatonis of your staf f on February 24, l
1988.
If you have any questions, please telephone N. Carroll McFall at (205) 729-2046.
Very truly yours, TENNESSEE VALLEY AUTHORITY
/
R. Geldley, Di ector Nuclear Licensing and Regulatory Affairs Enclosures ec:
See page 2
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8803160368 880314 PDR ADOCK 05000259 Q
DCD An Equal Opportunity Employer i
U.S. Nuclear Regulatory Commission MAR 141388 cc (Enclosure):
Mr. K. P. Barr, Acting Assistant Director for Inspection Prograns TVA Projects Division U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Mr. G. G. Zech, Assistant Director for Projects TVA Projects Division U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville,. Maryland 20852 Browns Ferry Resident Inspector Browns Ferry Nuclear Plant Route 12, P.O. Box 637 Athens, Alabama 35611 1
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ENCLOSURE 1 RESPONSE TO NRC INSPECTION REPORT.
NOS. 50-259/87-41, 50-260/87-41 AND 50-296/87-41 LETTER FROM K. P. BARR TO S. A. WHITE DATED JANUARY 21, 1988 Violation 10 CFR 50, Appendix B, Criterion XVI, and the licensee's eccepted Quality Assurance (QA) program (TVA Topical Report TVA-TR75-1A, "Quality Assurance Program Description for Design, Construction, and Operation of TVA Nuclear Power Plants" Revision 9, Section 17.2.16) collectively requiro that measures be established to assure that conditions adverse to quality are promptly identified and corrected.
In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.
Contrary to the above, although measures have been established for prompt problem identification, these problems have not been corrected nor has action been taken to preclude repetition.
Specifically in the instances cited below, the Division of Nuclear Engineering (DNE) has not taken action to correct or preclude repetition for conditions adverse to quality and also has not implemented effective corrective action when conditions adverse to quality are identified.
1.
The corrective action for a significant condition Adverse to Quality Report (CAQR) (BFP 870326) issued against DNE on June 5,1987, concerning the high number of delinquent CAQRs has not been effective in reducing the number of delinquent DNE CAQRs and is now itself dolinquent.
2.
Subsequent to the above significant CAQR concerning delinquency, two additional significant CAQRs have been issued to DNE (CAQRs BFP 870912 and BFP 870830) for delinquency in performing required CAQR reviews.
TVA Response 1.
Admission or Denial of the Alleged Violation TVA admits the violation as stated.
2.
Reasons For the Violation if Admitted TVA had previously documented an adverse trend in timeliness of DNE's CAQR processing on June 5, 1987, on CAQR BFP870326. The corrective action plan was executed as stated in the CAQR, but the corrective action was not effective. Additional CAQR processing delinquencies were later documented by CAQR BFP870830 concerning delinquent generic reviews and CAQR BFP870912 concerning delinquent management reviews.
The failure to meet procedurally required processing dates had three specific causes, each of which can be attributed to management in attention to changing workloads and staffing noeds. First, BFN started receiving the employee concern findings that resulted from reviews done at
Watts Bar Nuclear Plant.
Development of Corrective Action Plans (CAPS) for these concerns were given the highest priority since many of the concerns were related to existing CAQRs.
It was decided that the group dedicated to processing and tracking CAQRs would also prepare the employee concern CAPS.
No manpower adjustments were made to this group, thus causing them to fall behind in CAQR processing.
Second, TVA made a transition from staff augmentation contractors to task performance contractors during this timeframe.
Staff augmentation resources were terminated before replacement resources or task performance contracts.iere in place to pick up the workload. Third, the DNE CAQR manager resigned from TVA during this period and was not immediately replaced. A higher level manager with several other project responsibilities was filling this key position resulting in a lack of management attention to adverse trends.
A number of DNE's CAQR delinquencies are the result of missin, commitment dates for executing the CAQR corrective action plans rather than missing procedurally mandated dates. This has been primarily caused by changing priorities and adjustments to the unit 2 restart scheduling / manpower plan.
3.
Corrective Steps Which Have Been Taken and Results Achieved Considerable progress has been made in reducing the delinquencies caused by missing procedurally mandated processing dates. A full time CAQR manager has been assigned within DNE to replace the manager who resigned.
Staffing levels by permanent TVA employees within DNE assigned to CAQR processing and tracking activities have been increased to replace lost staff augmentation.
Production plans have been established to work off the large backlog of late DNE CAQR processing items. The DNE project engineer monitors progress weekly for any exceptions to the catchup plan for late items and any new items not meeting CAQR processing dates required by procedure.
Exceptions to the catchup plans and new item delinquencies within the CAQR program have resulted in some diversion of other engineering work.
Since October 16, 1987, the number of DNE CAQRs and generic reviews delinquent because procedurally mandated dates were missed has been reduced sharply.
4.
Corrective Steps Which Will Be Taken to Avoid Further Violations More progress must be made to reduce delinquencies caused by missed commitments made in corrective action plans and recurrence control plans.
DNE is currently entering schedules needed to support CAQR commitment dates into the project manpower scheduling system to provide manpower loaded schedules for these activities.
Any extensions required to make DNE CAQR corrective action commitment dates consistent with supportable schedules will be submitted for appropriate procedural approvals.
l The DNE Project Engineer will continue to monitor any exceptions to the CAQR commitment dates and procedurally mandated processing dates on a regular basis. He will take appropriate management action to correct any significant adverce trend in delinquent items including rescheduling with appropriato approvals or diverting resources from other work, if required to correct the trend.
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5.
Date When Full Compliance Will Be Achieved Program improvements needed to eliminate the adverse trends in DNE CAQRs will be fully implemented by May 13, 1983.
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ENCLOSURE 2 LIST OF COMMITMENTS The DNE Project Engineer will continue to monitor any exceptions to the CAQR commitment dates and procedurally mandated processing dates on a regular basis. He will take appropriate management action to correct any significant adverse trend in delinquent items including rescheduling with appropriate approvals or diverting resources from other work, if required to correct the trend.
Program improvements needed to eliminate the adverse trends in DNE CAQRs will be fully implemented by May 13, 1988.
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