ML20151R044

Forwards Response to NRC Insp Repts 50-327/88-23 & 50-328/88-23 Recommendations.Future Audits of LER Program Will Include Evaluation of Effectiveness of Event Analysis & Reporting

ML20151R044
Person / Time
Site:	Sequoyah
Issue date:	04/20/1988
From:	Gridley R TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NUDOCS 8804270223
Download: ML20151R044 (4)

Text

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, TENNESSEE VALLEY AUTHORITY CH ATTANOOG A, TENNESSEE 37401 SN 1578 Lookout Place APR 201988 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington. 0.C. 20555 Gentlemen:

In the Matter of ) Docket Nos. 50-327 Tennessee Valley Authority ) 50-328 SEQUOYAH NUCLEAR PLANT (SON) UNITS 1 AND 2 - NRC INSPECTION REPORT NOS. 50-327, AND 50-328/88 RESPONSE TO RECOMMENDATIONS Enclosed is TVA's response to S. D. Richardson's March 17, 1988 letter to S. A. White that transmitted the subject recommendations.

Enclosure 1 provides TVA's response to the recommendations. Enclosure 2 provides the commitment in this response.

If you have any questions, please telephone M. R. Harding at (615) 870-6422.

Very truly yours, TEN ESSEE EY AUTHORITY R.dridley, rector Nuclear Licensing and Regulatory Affairs Enclosures cc (Enclosures):

Mr. K. P. Barr, Acting Assistant Director for Inspection Programs TVA Projects Division U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NH, 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 Sequoyah Resident Inspector lgf2[O$fg$$0h27 N Sequoyah Nuclear Plant a $

2600 Igou Ferry Road Ig Soddy Daisy, Tennessee 37379 An Equal Opportunity Employer

ENCLOSURE 1 RESPONSE TO NRC INSPECTION REPORT NOS. 50-327, AND 50-328/88-23 REQUEST FOR RESPONSE TO RECOMMENDATI0tS NRC RECOMMENDATIONS "1. TVA should have periodic audits of its LER generation process, conducted by the QA or EA organizations, to evaluate the effectiveness of TVA's event analysis and reporting, to ensure continued compliance with the regulations, and to ensure high quality and accurate e"ent reporting.

This is especially important since there have been a ntmber of personnel, organizational, and programmatic changes in TVA's event analysis and reporting process. TVA should determine whether or not they feel these changes have had a positive impact on their LER reporting.

2. TVA should formalize what are currently considered 'gooc' practices'.

Examples of these ,nact!ces are: a) reporting events ' voluntarily' based on the worst-case results of ongoing evaluations; b) the addition of recurrencu control to LERs, and; c) reduction in the use of compensatory measures as a means to correct design deficiencies.

3. TVA should eshblish a process that would provide a timetable for event evaluation and reporting. Establishing milestones for generating LERs would ensure that PORC has sufficient time to correct any deficient LERs before they are due to the NRC.

4. TVA should establish a program or process to follow through on LER corrective action to assure that root causes are corrected. The audit team suggested that the items be placed in the appropriate tracking system (CCTS, CAQR, etc.), and the tracking system item written trito the LER to establish an auditable trail for tracking correction of root causes. This reduces the likelihood of ' throwing the LER over the wall' once it is issued."

TVA'S RESPONSE

1. TVA has, as part of its overall Quality Assurance (QA) program, periodic audits of the Licensee Event Report (LER) process, which includes evaluation of the effectiveness of TVA's compliance with the regulations. These audits include a review of event analysis, root cause deterninations, and adequacy of corrective actions performed in t association with LERs, but do not include evaluation of the effectiveness

! of programmatic changes in TVA's event analysis and reporting process l because these were programmatic changes recently implemented. Future i audits of the LER program will include the evaluation of the effectiveness of event analysis and reporting as appropriate.

2. TVA has a formalized condition adverse to quality repcrt (CAQR) and potential reportable occurrence (PRO) process. During the review of a CAQR or PRO, reporting of operational events that do not meet the requirements found in 10 CFR 50.73 are considered, and based on the l worst-case results of ongoing evaluation, may be reported voluntarily, i

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Thirteen LERs have been submitted as voluntary LERs. The process of reporting LERs voluntarily based on the worst-case results of ongoing evaluations was deemed necessary because of the large number of "indeterminate" issues outstanding at that time. Currently, with SQN in the restart phase, the number of indeterminate issues has decreased, and new indeterminate issues are resolved expeditiously in support of unit operations.

Sequoyah Standard Practice SQA186, "Root Cause Assessment For Adverse Actions / Condition," provides the formalized methods for determining root causes and recurrence controls to events. Administrative Instruction 49 provides formalized control in order to minimize the use of compensatory measures.

3. 10 CFR 50.73 states that LERs are to be submitted to NRC within 30 days of discovery of the event or condition. SQN has consistently met this requirement. Plant Operations Review Staff management has set a timetable to prepare LERs and present for Plant Operatiens Review Committee (PORC) approval, at approximately 25 days, so that PORC will have sufficient time to review LERs before they are due to NRC. A recent trend of the timetable of LER evaluation and reporting has shown that, on the average, LERs are reviewed by PORC at least three days before they are due to NRC. A number of these LERs are ones that have been to PORC earlier and are being returned for formal review.

4. As stated in our Nuclear Performance Plan, Corporate Commitment Tracking System (CCTS) was implemented in January 1986, and one of its functions is to track action items associated with LERs. This program provides an auditable trail for tracking corrective action of root causes.

Additionally, PR0s that initiate LERS are tracked and trended in Tracking and Reporting of Open Items. An auditable trail exists between LERs and PR0s and between LERs and CCTS by doing sorts on the PR0 and CCTS systems without having to write / record the PRO and CCTS numbers on the LER.

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ENCLOSURE'2 List of Connitments

1. . Future audits of the LER program will include the evaluation of the.

effectiveness of event analysis and reporting as appropriate.

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