ML20236S092

Audit Rept,Commitment Mgt for Tva,Sequoyah Nuclear Plants, Units 1 & 2

ML20236S092
Person / Time
Site:	Sequoyah
Issue date:	07/17/1998
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20236S089	List: ML20236S087 ML20236S092
References
NUDOCS 9807240121
Download: ML20236S092 (7)

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AUDIT REPORT COMMITMENT MANAGEMENT IENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT. UNITS 1 AND 2 DOCKET NOS. 50-327 AND 50-328

1. INTRODUCTION As part of the staff's activities related to improving the management of licensing basis information, audits of commitment management programs have been performed at eight reactor facilities. The audits assess licensees' implementation of commitments made to the U.S. Nuclear Regulatory Commission (NRC) and also assess the long-term control of commitments as a follow-up to the issuance of industry guidance for evaluating and reporting changes to commitments made to the NRC. Seqyoyah Nuclear Plant, Units 1 and 2 (SON) was selected as one of eight facilities whose commitment management programs were audited by the staff. The Tennessee Valley Authority (TVA) is the licensee for SON.

The audits and other staff efforts related to managing licensee commitments made to the NRC are intended to improve the (1) identification of important licensee commitments or other supporting design features or operational practices used by the licensee to justify a proposed change or address design or operational problems, (2) determination of the most appropriate means for verifying important commitments or other supporting information, and (3) determination of the appropriate placement of the information within the various licensing basis documents associated with the affected facility; i.e., the license or technical specifications, the Final Safety Analysis Report (FSAR), program description documents, or docketed correspondence without formal regulatory controls. The findings from the audits will be used in the staff's development of recommendations to the Commission regarding the need for further staff actions in the area of commitment management.

The audit of SON was performed from March 17 through May 28,1998, by Ronald Hernan, the SON Project Manager, of the Division of Reactor Projects, Office of Nuclear Reactor Regulation (NRR). The onsite portions of the review were performed during site visits on March 17-19 and April 20-22,1998. Additional discussions between TVA and the NRC staff took place by telephone, and additional review of material provided by the licensee was performed in the NRC/NRR offices in Rockville, Maryland. The audit consisted of interviewing personnel and

< reviewing procedures, guidance documents, and other documentation related to the l commitment management process used by the licensee at SON. Additional reviews of work

< records, procedure changes, and other documentation were performed to verify that commitments, and cheriges to commitments, had been implemented.

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o II. VERIFICATION OF LICENSEE IMPLEMENTATION OF PAST COMMITMENTS in order to verify that the licensee effectively implements commitments made to the NRC related to licensing actions and licensing activities, the auditor selected a sample of these types of commitments. No commitments were noted that formed part of the basis for an NRC decision to approve a license amendment or exemption, or to grant American Society of Mechanical Engineers (ASME) Code relief. The auditor's findings regarding the licensee's implementation of the selected commitments are described below (the 9-digit numbers are the identifiers used in the WA commitment tracking system):

1. 900006006/900006007 (Units 1 and 2, respectively)

Commitment: The SON Generic Letter 89-10 program implementation will be completed by the end of the Units 1 and 2 Cycle 7 Refueling Outager Generic Letter 89-10 required development and implementation of a program for testing safety-related motor-operated valves (MOVs). These commitments were made in the TVA response to Generic Letter 89-10 in a letter dated November 26,1991 and stated that the SON Generic Letter 89-10 programs would be completed by the end of the Cycle 7 refueling outages for each unit. The Unit 1 Cycle 7 Refueling Outage was completed on November 11,1995, and TVA informed the NRC by letter dated December 11,1995, that the design-basis reviews, analyses, verifications, tests and inspections required by the generic letter had been completed. The Unit 2 Cycle 7 Refueling Outage was completed on June 9,1996, and TVA informed the NRC by letter dated July 1,1996, that the design-basis '

reviews, analyses, verifications, tests and inspections required by the generic letter had been completed

2. 970024002/970024003 Commitment: SON will implement the JOG [ Joint Owners Group]-recommended Generic Letter 96-05 MOV periodic verification program, as described in Topical Report OG-97-018. . and begin MOV testing during the 1997 Fall outage (Unit 2) and 1998 Fall outage (Unit 1).

Generic Letter 96-05 (issued on September 18,1996) required development and implementation of a program for periodic verification (PV) of design basis capability of safety-related MOVs. The above commitments were made in the WA response to Generic Letter 96-05 in a letter dated March 17,1997. The PV for Unit 2 was completed during the 1997 refueling outage and the commitment tracking sheet indicates completion on October 29,1997. The PV for Unit 1 is scheduled to be completed in October 1998.

3. 960038001 Commitment: TVA will revise the existing procedure or create a new procedure to perform a slave cycle current ... test each refueling outage. This commitment will be completed by February 15,1997.

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3-l This commitment was part of the TVA response to Generic Leiter 93-04, " Rod Control System Failure and Withdrawl of Rod Cluster Control Assemblies." The auditor verified that this commitment had been completed on February 6,1997.

4. 910172002 Commitment: TVA will provide quarterly assessments of the fire protection improvement plan to NRC.

This commitment was made at a meeting between TVA and the NRC on August 19,1991, to discuss the self-identified problems with the Sequoyah Fire Protection Program and the planned improvements by TVA. The TVA commitment tracking package had a clear record of all the submittals (periodic status reports) made to the NRC. The Fire Protection Report was submitted to the NRC by letter dated August 30,1996. A final periodic status report was submitted to the NRC on March 14,1997, completing this commitment. The auditor verified that the commitment tracking folder was complete.

5. 910172006 Commitment: Complete Fire Protection Improvement Plan, Phase IV, by December 1, 1994 This commitment was made at a meeting between TVA and the NRC on August 19,1991, to discuss the self-identified problems with the Sequoyah Fire Protection Program and the planned improvements by TVA. The commitment completion date was extended twice by TVA letters dated 6/9/94 and 12/1/95. Phase IV was completed, and the commitment closed out, on 8/29/96. The Fire Protection Report was submitted to the NRC by letter dated Augusi 30,1996. The auditor verified that the commitment tracking folder was complete.

6. 930071002 Commitment: Sequoyah Nuclear Plant will complete walkdowns, plant-specific analysis, additional testing (if necessary), and any required modification to upgrade the presently installed Thermo-Lag 330-1 by October 1,1996. This date is based upon material availability.

This commitment was part of TVA's response to Generic Letter 92-08 on Thermo-Lag barriers. This commitment was superseded in TVA's letter to the NRC dated September 9, 1996, and are being followed as commitments 930071004/5. The committed completion  !

date was changed to October 1999. Subsequently, TVA committed to a June 30,1999, completion date. A confirmatory order was issued by the NRC on June 18,1998. The  ;

auditor verified that the commitment tracking folder was complete, including the ,

Commitment Completion Verification Form (CCVF).  !

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7. 960019001 l Commitment: Simulator scenarios are being developed to address multiple partially stuck rods post trip. This new trainliig will be included in the next requalification cycle that begins frA!9 wiry the Spring Unit 2 Cycle 7 refueling outage and will be completed by July 29,1996.

This commitment was part of the licensee's response to NRC Bulletin 96-01, " Control Rod Insertion Problems," in a letter to the NRC dated April 5,1996. Review of the commitment file indicated that the commitment was completed on July 18,1996. The auditor also verified that the commitment tracking folder was complete, including the CCVF.

8. 930229002 Commitment: Rod control system logic control cabinet modifications (current order timing adjustments) will be performed during each unit's Cycle 7 refueling outage at Sequoyah.

This commitment was made in WA's September 20,1993, response to Generic Letter 93-04. The commitment is also discussed in the NRC closecut letter for this generic letter dated December 4,1994. Review of the commitment file indicated that the commitment was completed on June 6,1996. The auditor also verified that the commitment tracking folder was complete, including the CCVF.

9. 960021001/ 002/ 003/004 Commitment: For SON Units 1 and 2, TVA will evaluate site-specific reviews that have been conducted against the recommendations of Generic Letter 96-01.

Further reviews will be conducted for those areas that TVA determines do not meet the comprehensive reviews of GL 96-01. These actions will be completed by the startup from the first refueling outage after January 1997.

This commitrnent was made in TVA's April 18,1996, response to Generic Letter 96-01. The commitment is also discussed in the NRC closecut letter for this generic letter dated December 4,1994. Review of the commitment file indicated that the commitment was completed on June 6,1996. The auditor also verified that the commitment tracking folder was complete, including the CCVF.

10. 960033001 Commitment: Per NRC request in [a] letter to TVA dated April 26,1996 (re: Tech Spec Change Request 92-07, TAC Nos. M84390 and M84391), revise appropriate procedures to notify Site Licensing if any of the elbow tap flow correlation coefficients change.

This commitment was made in response to an NRC request in the safety evaluation and transmittal letter for License Amendment Nos. 221 (Unit 1) and 212 (Unit 2). Review of the commitment file indicated that the commitment was completed on July 24,1996. Revisions

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were issued to Surveillance Instructions 1-SI-SXX-068-155.0 and 2-SI-SXX-068-155.0. In fact, formal notification of a small change in one of the flow correlation coefficients was made to the NRC in a letter dated May 15,1997. The auditor also verified that the commitment tracking folder was complete, including the CCVF.

Ill. LICENSEE PROGRAMS FOR MANAGING AND CHANGING COMMITMENTS The primary focus of this part of the audit was to assess the licensee's program and performance related to incorporating controls for implementing and modifying or deleting commitments made to the NRC. The staff's interest in this matter is related to how it is assured that commitments are implemented, how changes to commitments (modifications or deletions) are evaluated and how the NRC is informed of commitment changes that have safety or regulatory significance.

WA uses a corporate-wide mainframe computer system called Tracking and Reporting of Open items (TROI). This system has been in use for several years. In January 1997, a new TVA corporate procedure, SPP-3.3, "NRC Commitment Management," was issued to supersede the site-specific procedures at the Sequoyah, Watts Bar, and Browns Ferry sites. Information regarding commitments to the NRC is entered into the database only by a Coordinator in the Licensing Departments at each site. TROI is used for tracking, among other things, TVA commitments related to responses to NRC generic letters and bulletins, responses to Notices of Violations, changes to procedures, and commitments made in Licensee Event Reports (LERs),

instruction 3.1.C (of SSP-3.3) requires a separate enclosure to TVA submittals to the NRC that specifically state what the commitments are and the projected completion date. The TVA procedure also requires documenting commitments associated with LERs in a special section (Section Vil) of the LER itself. This goes beyond the guidance provided in NUREG-1022, Revision 1. The procedure distinguishes between *C" commitments (firm) and "A" commitments (administrative).

The Site Nuclear Licensing Department is the focal point for establishing and managing commitments. A Lead Coordinator is assigned to each commitment. The TVA procedure is patterned after the Nuclear Energy institute's (NEI)

• Guideline for Managing NRC Commitments." When a commitment is established, a commitment tracking load sheet is completed. A commitment evaluation form, similar to the one in the NEl guidance, is used to evaluate disposition of the commitment. When the commitment has been completed, a commitment completion form is completed and submitted to the Site Nuclear Licensing Department for review and data entry. Each Wednesday, the Licensing Manager discusses current NRC commitments in the Plan-of-the-Day meeting. This discussion includes commitments due within the coming 4-week period and who is responsible.

IV. EVALUATION OF COMMITMENT CHANGES Some changes in commitments are made known to the NRC before they are made but most are included in a summary report submitted at the same time as the FSAR update. Some changes to commitments do not require informing the NRC. This is consistent with the NEl guidelines. The auditor reviewed commitment tracking folders for a number of commitments that were changed or dropped (recommitted). These included both changes that were required to be conveyed to the NRC and those that were not. A summary of commitment changes was I

9 submitted as Enclosure 3 to Amendment 14 of the FSAR, dated May 4,1998. A sampling of the changes to commitments follows:

1. Commitment: The Post Trip Report (PTR) process will be enhanced by revising the appropriate procedure to require an event critique with the involved personnel and PTR team before review by PORC [ Plant Operations Review Committee) and to requirs a completed event and causal chart for unit restart.

Change: Revision to decommit event and causal factor chart Basis An event and causal factor chart is just one of many techniques for developing a root cause analysis. Requiring it as the only allowed technique is not conductive to good root cause analysis. If it is not the appropriate technique for the event, it will not enhance PORC's understanding of the event or lead to the development of good corrective actions.

2. Comrnitment: The requirements to videotape the lower core plate inspection and to perform an independent party review of the videotape will be incorporated into the appropriate procedure by 12/15/93.

Change: Revised commitment to state that Reactor Engineering, along with an independent party, will inspect the lower core plate before fuelload. A videotape of the inspection will be made.

Basis The intent of the original commitment was having independent personnel view the lower core plate for foreign material. This can be performed concurrently from the video monitor on the manipulator crane and the videotape reviewed if desired.

3. Commitment: Signs will be installed at entrances to safety-related buildings to remind personnel that transient fire load permits may be required when combustibles are taken into the structure.

Change: Decommit Hans Signs are considered an enhancement to existing Transient Combustible Control Program. The presence of signs is no longer an enhancement based on current transient fire load controls.

4. Commitment: AUO [ Auxiliary Unit Operator] records temperatures once a shift (three 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> shifts per day)

Change: Revise Commitment to require AUO record specific plant temperature readings once a shift (two 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shifts per day).

Basis. The revised commitment preserves the intent for monitoring temperatures in safety related areas and initiating increased monitoring as needed until temperatures return within limits.

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5. Commitment: A review of the overtime procedure and form is being conducted to determine if the form can be made user friendly and if better guidance can be provided in completing the form. The procedure will be revisetl to disallow " blanket" approvals.

Chanae: Decommit Basts- New standard procedure SPP 1.5 provides approval on a group basis during extended shutdown periods consistent with GL 82-12.

6. Commitment: Sequoyah Nuclear Plant will complete walkdowns, plant-specific analysis, additional testing (if necessary), and any required modification to upgrade the presently installed Thermo-Lag 330-1 by October 1,1996. This date is based upon material availability.

Change: Completion date changed to June 30,1999.

Basis Original date could not be met because of the scope of the work and independent test program initiated by TVA.

V. LICENSEE SELF-ASSESSMENT TVA performed a self-assessment of the commitment management system at Sequoyah and documented the results in a report dated February 27,1998. This assessment was a licensee initiative to essess the commitment management process and the extent to which the NEl guidelines had been implemented. The assessment started well before NRC announced its plans to perform a pilot audit of this area at Sequoyah. The auditor reviewed the final report and found the report to be very thorough and listed 50 findings; some negative and some positive. Subsequently, the Sequoyah Quality Assurance (QA) Department reviewed the self-assessment report and the commitment management program, procedures, and tracking files.

The QA report, dated March 16,1998, was also very thorough and made nine recommendations to improve the program. Both reports concluded that the NEl guidelines had generally been successfully incorporated at Sequoyah.

VI. CONCLUSIONS /

SUMMARY

The auditor found that the commitment management system for Sequoyah is strongly geared to ensuring that actions are assigned and completed within established schedules. Sequoyah has 1 been successful in this regard since all of the commitments selected for audit have been i satisfactorily implemented or changes have been appropriately justified. The corporate procedure for commitment management at all1VA sites follows, very closely, the NEl

, guidelines and, in some aspects, improves upon them. The Sequoyah commitment coordinator l displayed an excellent understanding of the commitment control system and the records reviewed were essentially error-free. The Lead Coordinators appear to be knowledgeable of their responsibilities and take this area seriously. There was no evidence of any commitments being missed.

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