ML20204H283
| ML20204H283 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 10/18/1988 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8810240373 | |
| Download: ML20204H283 (6) | |
Text
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TENNECCEE VALLEY AUTHORITY
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CHATTANOOGA. TENNES$tt 37401 l
J SN 1578 Lookout Place l
00T.181988 i
U.S. Nuclear Regulktory Commission
(
j ATTN: Document Control Desk Washington, D.C.
20555 Gentlemen:
t In the Matter of
)
Docket Nos. 50-259 Tennessee Valley Authority
)
50-260 l
)
50-296 i
BROWNS FERRY NUCLEAR PLANT (BFN) UNITS 1, 2 AND 3 - NRC INSPECTION REPORT NOS. 50-259/88-22, 50-260/88-22, AND 50-295/88-22. - RESPCNSE TO NOTICE OF VIOLATION - 10 CFR 50, APPENDIX B, CRITER!ON XVI l
i l
This letter provides TVA's response to the letter from F. R. McCoy to l
l S. A. White dated September 19, 1988, which transmitted the subject repert
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citing TVA with one Severity Level IV Violation concerning inadequate l
corrective actions in the area of operator qualifications.
i 4
- contains TVA's response to the violation, Enclosure 2 cortains a
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i list of the commitments made in this submittal.
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If you have any questions, please telephone Clare Hsieh at (205) 729-2a35.
Very truly yours, l
TENNESSEE VAM;EY AUTHORITY 6
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R. Gridley, Manager
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Nuclear Licen Ing and i
4 Regulatory ffairs t
f Enclosure cc:
See page 2
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U.S. Nuclear Regulatory Commission NT 18 28 cc (Enclosuie):
Ms. S. C. Black, Assistant Director for Projects TVA Projects Olvision U.S. Nuclear Regulatory Commission One White Fitnt, North 11555 Rockville Pike Rockville, Maryland 20852 Mr. F. R. McCoy, Acting Assistant Director
'or Inspection Programs TVA Projects Division U.S. Nuclear Regulatory Commission Region !!
101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Browns Ferry Resident Inspector Browns Ferry Nuclear Plant Route 12, Box 637 Athens, Alabara 35611 1,
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ENCLOSURE I
RESPONSE
NRC INSPECTION REPORT NOS. r'.-254/88-22, 50-260/88-22, AND 50-296/88-22 E
'1 FROM F. R. McC0Y TO S. A. WHITE
)ATED SEPTEMBER 19, 1988 Violation During the NRC 1.
conducted July 11-15, 1988, one violatior, of NRC requirements was.:
.ed.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Action," 10 CFR Part 2, Appendix C (1988), the violation is listed below:
10 CFR 50, Appendix B, Criterton XVI, Corrective Action, requires that measures be established to assure that conditions adverse to quality are promptly identified and corrected.
The licensee's Nuclear Quality Assurance Manual (NQAM), Part III, Section 6.1, addre;ses the qualifications of Shift Engineers as follows:
At the time of initial core loading or appointment to the active position, shift engineers shali satisfy the minimum qualifications delineated in Nuclear Plant Operator Training Program Procedure PHP 0202.05.
PHP 0202.05 requires that the candidate for the position of shift engineer must pass the shift engineer accrediting examination unless waived by the Chief, Operator Training Branch, and the Plant Training Review Board or Accrediting Subcommittee.
The licensee's Final S1fety Analysis Report, section 13.2.1.2.5, states that the shift engineers are quallfled for their supervisory positions by fulfilling the requirements of TVA's formal operator training pri. gram.
This is a comprehensive work-study training and advancement program with rigorous qualifying examinations administered by a central accrediting committee.
i Contrary to the above, in approximately January 1987, the licensee's line canagement became aware that four temporarily proinoted shif t engineers did not meet the abovt standards, and did not adequately disposition the issue.
In addition, it was identifled that four other permanently assigned shif t engineers did not have records to show that their certification examinations were successfully passed.
This is a Severity Level IV Violation.
TV? Response Example 1 1.
Admission or Den,tal of Example 1 of the Alleged Violation TVA admits that examole 1 of the violation occurred as stated in that corrective actions were not taken in a timely manner.
/ - 2 2.
Reason for Examole I of the Violation The absence of a timely resolution of this issue was the result.of the generic nature of the corporate standard on the nuclear plant operator training program.
Revision to the PMP 0202.05 has required extensive coordination between Browns Ferry, Power Operations Training Center, and the other three TVA's nuclear plants (Bellefonte, Sequoyah, and Hatts Bar). As stated in the discussion provided below, TVA was made aware of this issue but failed to ensure that the proposed resolution was implemented in a judicious manner.
On January 12, 1907, four Assistant Shift Operations Supervisors (ASOSs) were temporary promoted to Shif t Operations Supervisors (S055) in order to meet shift staffing requirements. At the time, there was an insufficient number of qualified E03s available for shift coverage because of the number of 503s participating in the accelerated requalification program.
On January 28, 1987, the Employee Concern Program (ECP) received an employee concern on the four temporary promoted ASOSs, and in a detalled followup investigation report issued in May 1987 made the following recommendations:
"No later than July 13, 1987 (the date that four shift cngineers are to be returned to their regular positions), the procedural questions should be resolved by changing the procedural requirements in PHP 0202.05 to permit temporary promotion consistent with the NQAM or by eliminating the inconsistanen within the BFN Final Safety Analysis Report (FSAR).
If procedural resolution is not attained by this date, th< shift engineers should be returned to their regular positions or should b.
required to take the accredicing examination to remain in shift engineer positions."
BFN responded to the recommendations given above on memorandums frem the BFN Site Director to the Employee Concerns Program Manager dated September 17 and November 9, 1987.
The latter memorandum stated that BFN management recognizes the inconsistencies between the UQAM, PMP 0202.05 and the BFN FSAR, and that steps would be taken to resolve this issuo through a revision to the PHP.
This memorandum further stated that in as much as the temporary promotions met the requirements of the tlQAH and that the personnel involved satisfied all regulatory requirements, the Individuals would continue to fill the position of SOS on a temporary basis for a period not to extend beyond August 1988.
3.
Corrective Actions Hhich Have Been Taken and Results Achieved In August 1988, the four AS0Ss received and passed the Accrediting Examination for the SOS position and were interviewed by the site director.
The ASOSs have been made permanent SOSs.
No other ASOSs are Involved in this issue.
' - 3 4.
Corrective Actions Which Hill Be Taken to Avoid Further 'llo1ations L
The corporate standard on operator training is being revised to provide additional instructions to be followed on extended temporary promotions.
Revision to PHP 0202.05 will be completed by March 31, 1989.
5.
Date When Full Compilance Will Be Achieved PHP 0202.05 will be revised by March 31, 1989.
Example 2 1.
Admission or Dental of Example 2 of the Alleged Violation TVA donles example 2 of the violation.
2.
Reason for the Dental Operations training has completed a review of the SOSs records for their Accrediting Examinations.
The examination cover sheets were found on microfiche and provided the records to show that their certification examinations were successfully passed. All accreditation examinations are given by the Non-license Operator Training Group at the Power Operations Training Center, and the required documentation is controlled by Non-license Operator Training Instruction Letter 17 as part of the upgrade examination process.
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ENCLOSURE 2 i
RESPONSE
NRC INSPECTION REPORT NOS. 50-259/88-22, 50-260/88-22, AND 50-296/88-22 LETTER FROM F. R. McC0Y TO S. A. WHITE DATED SEPTEMBER 19, 1988 List of Commitments PHP 0202.05 will be revised by March 31, 1989 to incorporate additional instructions to be followed on extended temporary promotions.
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