ML20214H014
| ML20214H014 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 05/15/1987 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8705270244 | |
| Download: ML20214H014 (6) | |
Text
TENNESSEE VALLEY AUTH'ORITY CH ATTANOOGA. TENNESSEE 37401 SN 157B Lookout Place MAY 151987 U.S. Nuclear Regulatory Conuaission ATTN: Document Control Desk Washington, D.C.
20555 Gentlemen:
In the Matter of
)
Docket Nos. 50-259 Tennessee Valley Authority.
)
50-260 50-296 BROWNS FERRY NUCLEAR PLANT UNITS 1, 2, AND 3 - NRC OIE INSPECTION REGION II INSPECTION REPORT NOS. 50-259/87-08, 50-260/87-08, AND 50-296/87-08 RESPONSE TO VIOLATION Enclosed is TVA's response to the letter from C. G. Zech to S. A. White dated April 14, 1987, which transmitted IE Inspection Report Nos. 50-259/87-08, 50-260/87-08, and 50-296/87-08 for TVA's Browns Ferry Nuclear Plant units 1, 2, and 3.
This report cited TVA with one Severity Level V Violation, 260/87-08-01, " Failure to Follow Instruction PMI-8.2."
Our response to this violation is contained in enclosure 1.
A list of commitments is provided in enclosure 2.
Please refer any questions to M. J. May, at (205) 729-3566.
To the best.of my knowledge, I declare the statements contained herein are complete and true.
.Very truly yours, TENNESSEE VALLEY AUTHORITY
-~k i
R. Gridley, Di rector Nuclear Safety and Licensing Enclosures cc:
See page 2 8705270244 87051S PDR ADOCK 05000259 6
G PDR ti An Equal Opportunity Employer
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' AY 15 587 U.S. Nuclear Regulatory Commission cc (Enclosures):
Mr. G. G. Zech, Assistant Director Regional Inspections Division of TVA Projects Office of Special Projects U.S. Nuclear Regulatory Commission Region _II.
101 Marietta St., NW, Suite 2900 Atlanta, Georgia 30323 Browns Ferry Resident Inspector Browns Ferry Nuclear Plant P.O. Box 311 Athens, Alabama 35611 Mr. J. A. Zwolinski, Assistant Director for Projects Division of TVA Projects Office of Special. Projects U.S. Nuclear Regulatory Commission 4350 East West Highway EWW 322 Bethesda, Maryland 20814
l' ENCLOSURE 1
RESPONSE
NRC INSPECTION REPORT NOS.
50-259/87-08.-50-260/87-08, AND 50-296/87-08 LETTER FROM G. G. ZECH TO S. A. WHITE DATED APRIL 14, 1987 4
Example A 10 CFR 50, Appendix B, Criterion V, and the accepted Quality Assurance (QA)
Program (TVA-TR75-1A, Revision 9) collectively require that activities affecting quality be prescribed by procedures and be accomplished in accordance with these procedures.
Plant Manager Instruction (PMI) 8.2 Plant Design Change Review, Revision 0 (July 9-21, 1986), paragraph 4.2, states that the cognizant system engineer will complete a review of the Engineering Change Notice (ECN) package for technical accuracy, operability considerations, Technical Specification impact, installation feasibility, restrictions, and document the completion of this review on ECN Review Form PMI-2.
Contrary to the above, on July 15, 1986, the Assistant Plant Manager signed for the review of ECW P-0859.
1.
Admission or Denial of the Allened Violation (or Finding)
TVA admits the violation as stated.
2.
Reasons For the Violations (or Findinz) If Admitted ECW P-0859 authorized a modification to the control rod drive (CRD) insert and withdrawal pipe supports to comply with seismic qualifications. While.
there is a system engineer for the CRD system, there was not and still is not a system engineer for pipe supports. Based on his personal review of the package, his related experience and expertise, and his knowledge of PMI-8.2, Revision 0, the Assistant Plant Manager felt comfortable in signing the PMI-2 sheet. His signature denoted it was "for" the cognizant / system engineer rather than attesting to his being this individual.
3.
Corrective Steps Which Have Been Taken and Results Achieved PMI-8.2, Revision 0, was revised to allow a knowledgeable individual designated by the Plant Manager to perform a technical review instead of the cognizant / system engineer.
This revision was issued on October 24, 1986, as PMI-8.2, Revision 1.
4.
Corrective Steps Which Will Be Taken to Avoid Further Violations (or Findinas)
This is considered to be an isolated event.
The October 24, 1986 revision 1 to PMI-8.2 will prevent recurre*nce of this violation.
5.
Date When Full Compliance Will Be Achieved Full compliance has been achieved.
.. _. _. _. ~ _ _ _ _ _ _.
Example B 10 CFR 50, Appendix B. Criterion V,.and the accepted QA Program (TVA-TR75-1A, Revision 9) collectively require that activities affecting quality be 6-prescribed by procedures and be accomplished in accordance with these procedures.
Instruction PMI-8.2, Plant Design Change Review, Revision 1 (October 24, 1986 to present), paragraph 4.4 states that the Shift Engineer will maintain a file containing the signed PMI-2 and PMI-3 forms and any other pertinent ECE information deemed necessary. It also states that the Shift Engineer is responsible for documenting the approval to work the specific Work Plans and Inspection Reports (WP & irs) associated with an approved ECN on a WP & IR Work in Progress Form (PMI-3).
Contrary to the above, an inspection of the Unit 2 Shift Engineer's ECN files on February 11, 1987, indicated that these files did not contain the ECN approval forms PMI-2 and PMI-3, the unreviewed safety question determination form work, and the ECN package P-0859.
1.
Admission or Denial of the Allened Violation (or Findina)
TVA admits the violation as stated.
2.
Reasons For the Violations (or Finding) If Admitted PMI-8.2, Revision 1, was issued without giving proper notification and training to personnel responsible for meeting the requirements of the procedure.
3.
Correctivr. Steps Which Fave Been Taken and Results Achieved An individual has been given the task of updating the Shif t Engineer's filos to comply with the requirements of PMI-8.2, Revision 1.
4.
Corrective Steps Which Will Be Taken to Avoid Further Violations (or Findinas)
Instruction PMI-8.2, Revision 1, will be revised to delete the requirement I
to maintain a file of approved ECN packages in the Shift Engineer's office. The procedure will also be revised to require that copies of form PMI-2 ECN Review Form, be attached to form BF-23, ECN/USQD Review and Approval Form. Because form BF-23 is already required to be included in j
the WP & irs (which are lifetime records), no additional recordkeeping is required.
l The operations section will provide and maintain a Shift Engineer's ECN I'
information file which will contain copies of the approved fona BF-23 (with attached forms PMI-2), the'USQD, and any other information deemed
.necessary by operations.
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Since this activity is redundant with the tracking responsibility of the ~
Site Project Control Manager, the requirement to log WP & irs on form PMI-3 will be deleted.
Shift Engineers will be provided with a training memorandum describing the revised program requirements of Instruction PMI-8.2, Revision 1, after it.
has been revised.
5.
Date When Full Compliance Will Be Achieved PMI-8.2, Revision 1, will be revised by June 30, 1987.
Shift Engineers will be provided with the revision and complete the training memorandum by July 15, 1987.
4 e
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ENCLOSURE 2 LIST OF COMMITMENTS Example A Revise PMI-8.2, Revision 0, to allow a knowledgeable individual designated by the Plant Manger to perform technical reviews.
NOTE: The Commitment, Example A, was achieved on October 24, 1986.
Example B 1.
Update the Shif t Engineer's fi?es to comply with the current requirements of PMI-8.2, Revision 1.
NOTE: Update is currently an ongoing activity.
2.
Revise PMI-8.2, Revision 1, as follows:
a.
Delete the requirement to maintain a file of approved ECN packages in the Shift Engineers office, b.
Require copies of form PMI-2 to be attached to form BF-23.
c.
Delete requirement to log WPs & irs on form PMI-3.
d.
Require the operations section to provide and maintain a Shift Engineer's ECN information file.
3.
Commitment Item, Example B2 revision to PMI-8.2, will be completed by June 30, 1987.
4.
Provide the Shift Engineert with a training memorandum describing the revised PMI-8.2 requirements of commitment Example B2.
5.
Ensure that all the Shift Engineer's training of commitment Example B4 has been completed and documented by July 15, 1987.
.