ML20246F702
| ML20246F702 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 05/05/1989 |
| From: | Fox C TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8905150060 | |
| Download: ML20246F702 (4) | |
Text
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_e TENNESSEE VALLEY AUTHORITY CH ATTANOOGA.' TENNESSEE 37401 SN 1578 Lookout Place MAY 051989 U.S. N' clear Regulatory Commission u
ATIN: Document Control Desk Washington, D.C.
20555 Gentlemen:
In the Matter of
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Docket Nos. 50-259 Tennessee Valley Authority
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50-260 l
50-296 l
l BROWNS FERRY NUCLEAR PLANT (BFN) UNITS 1, 2, AND 3 - SUPPLEMENTAL RESPONSE TO H
NRC INSPECTION REPORT NOS.- 50-259/88-21, 50-260/88-21, AND 50-296/88-21
'The. purpose'of this letter.is to respond.to the' letter from L. J. Watson to 0.-D. Kingsley dated April 6, 1989, requesting a supplemental response to NRC Inspection Report Nos. 50-259/88-21, 50-260/88-21, and 50-296/88-21.
This d
revised response, which.specifically addresses your notice of violation issued on October 25, 1988, concerning activities conducted at BFN, describes.the corrective actions.to assure timely completion of the process of reviewing l
potentially generic Condition Adverse to Quality Reports.
The enclosure provides background information and TVA's response to NRC concern raised in the subject report.
If you'have any questions, please telephone Patrick P. Carier at (205) 729-3570.
Very truly yours, i
TENNESSEE VALLEY AUTHORITY f
C.H. Fox,Jr.,N},cePresidentand Nuclear Technical Director Enclosure cc:
See page 2 ypf 8905150060 890505 PDR ADOCK 05000259S Q
PDC ~
An Equal opportunity Employer
c U.S. Nuclear Regulatory Commission 64/0( 0 5 1989
.cc-(Enclosure):
Ms.:S. C. Black, Assistant Director for Projects
.TVA Projects Division U.S. Nuclear Regulatory Commission One White Flini, North 11555 Rockville Pike Rockville, Maryland 20852 Mr. B. A. Wilson, Assistant Director for Inspection Programs TVA Projects Division U.S. Nuclear Regulatory Commission l
Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323
-Browns Ferry Resident Inspector Browns Ferry Nuclear Plant Route-12,' Box 637 Athens, Alabama '35609-2000 l
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ENCLOSURE SUPPLEMENTAL RESPONSE NRC INSPECTION REPORT NOS. 50-259/88-21, 50-260/88-21, AND 50-296/88-21 LETTER FROM L. J. HATSON TO 0. D. KINGSLEY, JR.
DATED APRIL 6, 1989 Violation "10 CFR Part 50, Criterion V, as implemented by TVA's Quality Assurance (QA)
Topical Report, TVA-TR75-1A, Revision 9, Sections 17.16 and 17.2.5, Instructions, Procedures, and Drawings, requires that activities affecting quality be accomplished in accordance with instructions, procedures, or drawings.
NQAM Part 1, Section 2.16, Rev. 3, Corrective Action, Paragraph 10.5, requires that condition adverse to quality reports (CAQRs) classified as "potentially generic" be reviewed by the potentially affected organization within 70 calendar days from origination of the CAQR.
Contrary to the above, CAQRs SQN 871347, SQP 871003, SQP 871066, and SQT 871304, were classified as potentially affecting Browns Ferry and did not receive generic review within 70 days from the origination of the CAQRs.
This is a Severity Level IV violation and applies to all three Units."
TVA Response 1.
Admission or Denial of the Alleged Violation TVA admits the violation.
2.
Reasons for the Violation if Admitted Procedures did not take into account the affect of one organization's failure to meet time limits on other organization's activities.
The time limit for performing the generic review was 70 days from the CAQR initiation date and did not allow for adjustment in cases where the other organizations did not perform their activities in a timely manner.
In some cases, the generic review item was received at the site after the 70 day limit had expired.
Procedures did not specifically require escalation of late generic review items to higher levels of management resulting in inadequate management attention to meeting generic review timeframes.
3.
Corrective Steps Which Have Been Taken and Results Achieved Generic reviews have been completed at BFN for the CAQRs identified in the notice of violation.
t
, Immediately upon notification by NRC of this violation, organizations responsible for late generic review items were notified that the items would be escalated to higher levels of management if responses were not received by August 23, 1988. As of August 23, 1988, generic reviews had been completed for 18 of the 26 CAQRs that had late generic reviews at the end of July.
The remaining items were escalated to the Site Director's
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attention on August 24, 1988.
s TVA's Nuclear Quality Assurance Manual (NQAM) was revised to restructure the time limits for performing the review for generic implications.
The time limit is 30 days from receipt of the CAQR by the CAQ coordinator at the receiving site as opposed to the previous time limit of 70 days from the origination date.
The procedures were also revised to specifically require escalation of late generic reviews which are not progressing satisfactorily to higher levels of management for resolution.
NQAM, Part I, Section 2.16.4, which addresses CAQRs initiated before the implementation of NQAM Part I, Section 2.16, Revision 4, was issued on July 12, 1988, containing the restructured timeframes and escalation requirements.
Site Director Standard Practice (SDSP 3.7), Revision 8, which implemented this corporate procedure, was implemented on September 14, 1988 to' address these requirements at BFN.
NQAM, Part I, Section 2.16 Revision 4, addresses the revised CAQR format for CAQRs issued after its implementation.
It was issued on May 16, 1988 and contained the restructured timeframes and escalation requirements.
i SDSP 3.13, which implemented this corporate procedure, was implemented on August 16, 1988 to address these requirements.
1 Regular meetings are held with the Corrective Action Program Manager to discuss any late CAQRs. As a result of these actions, only four generic review responses were overdue as of April 20, 1989, and these had been escalated for management attention.
4.
Corrective Steps Which Will Be Taken To Avoid Violations No further corrective actions are deemed necessary.
5.
Date Hnen Full Compliance Will Be Achieved Full compliance has been achieved on the CAQRs identified during Inspection Report 88-21.
With the NQAM, Part I, Section 2.16, Revision 4 requirements for generic CAQR reviews implemented at BFN, the number of late generic reviews has decreased significantly and an escalation mechanism is in place and functioning.
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