ML20247D010
| ML20247D010 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 03/24/1989 |
| From: | Kingsley O TENNESSEE VALLEY AUTHORITY |
| To: | Lieberman J NRC OFFICE OF ENFORCEMENT (OE), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| EA-88-253, NUDOCS 8903300348 | |
| Download: ML20247D010 (6) | |
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l TENNESSEE VALLEY AUTHCRITY CHATTANOOGA, TENNESSEE 37401 i
6N 38A Lookout Place March 24, 1989 Mr. James Lieberman Director, Office of Enforcement U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Attention: Document Control Desk
Dear Mr. Lieberman:
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Subject:
EA-88-253 Followup Report - Results from Review of Procedures for Ensuring that S,ubmittals to NRC are Complete and Accurate
Reference:
Letter from Marvin Runyon to James Lieberman dated November 21, 1988; Response to Notice of Violation (EA 88-253)
(L44 881121 800)
In the referenced letter, the Tennessee Valley Authority (TVA) committed that I would personally supervise a review of procedures-governing submittals to the NRC and implementation of those procedures in order to ensure that submittals to the.NRC are complete and accurate in all material respects.
TVA further committed that the review would be completed by January 31, 1989.
This letter provides a general description of the review process, principal findings and actions TVA has completed and is taking to address those findings
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and enhance its process for ensuring the completeness and accuracy of information contained in submittals to NRC.
Upon completion of the subject review, I commissioned a special review of Sequoyah submittals to provide added assurance that the results of the restart verification activities at
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Sequoyah were not compromised by the findings. Now that this special review q
has been completed, I am also providing the results of this review.
1 Review Process Under my personal supervision, a task force was formed and given instructions necessary to develop a detailed action plan and schedule for performing the review. Following development of the review plan, I met with the task force j
to discuss elements of the plan necessary for ensuring its successful i
implementation and to ensure the purpose of the review was clearly 1
understood.
The task force included representation froia L' censing, Quality Assurance, Engineering Assurance, Plant Operating Revir.< Staff (PORS),
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Training, and line Engineering.
In order to accompli o the review, the task 1
force was divided into teams, with one team perfor W.g the review at each major nuclear power location (i.e., Chattanooga, Knoxville, Hatts Bar, Sequoyah, and Browns Ferry).
To monitor status during execution of the plan, I held meetings and progress briefings with the project manager and members of h33OO348890324
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Mr. James Lieberman March 24, 1989 the task force. Overall consistency was maintained by establishing a licensing lead for each team, using uniform review criteria, and-holding frequent meetings and communications with the project manager. On January 6,1989, the final task force report was completed and transmitted to me.
The review plan called for identifying the various types of submittals from TVA to the NRC and categorizing them into " families" based on procedural similarities in how they are prepared by TVA. The five families which were identified and examples of the submittal types included in each are:
(1) Generic - Generic Letters and Bulletins.
(2) Reports - Periodic reports such as Monthly Operating Reports, and annual FSAR Updates.
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- Event reports such as Radiation Exposure Reports and Licensee 3
Event Reports.
(3) Training-Operator training, operator license applications and renewals.
(4) License - License amendments and Technical Specification changes.
1 (5) Other
- Other submittals, such as Requests for Additional Information and responses to Notices of Violation.
Procedures applicable to the submittal and report preparation processes were identified and reviewed for adequacy of controls to ensure submittals would be complete and accurate. These controls included such items as verification of information contained in submittals, concurrence responsibilities and signatuces, and the requirement for providing supporting documentation.
This review phase also included a comparison with selected industry procedures pertaining to completeness and accuracy in the submittal process. A checklist containing key control points was used by the teams to ensure that a i
consistent review was performed.
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Additionally, the task force focused on the implementation of identified l
procedures by (1) reviewing representative samples of submittals to determine J
procedural adherence, and (2) conducting interviews with key individuals involved in the submittal process to ascertain their understanding of the terms " complete and accurate" and " material false statement" and of their l
responsibilities and accountabilities relative to submittals.
Findings Our review of procedure 0602.01 (" Management of TVA's Interface with NRC")
indicated that this procedure is adequate when properly implemented to produce complete and accurate submittals.
However, our review found that this
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procedure had not been serving as the single document governing all submittals i
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Mr. James Lieberman March 24, 1989 l
to the NRC and that not all submittals to the NRC were processed through TVA's licensing organization (for example, Annual Operating Reports, Operator License Applications, and Licensee Event Reports).
Several' additional j
procedures were reviewed which were applicable to various types of reports and submittals TVA provides to the NRC.
These procedures were not always completely clear and consistent with the primary procedure.
Examples of these findings are:
Corporate procedure " Regulatory Reporting Requirements," governs preparation and submittal of reports.
This procedure did not contain sufficient guidance on completeness and accuracy.
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Sequoyah procedure " Plant Reporting Requirements" provides instructions for the content, preparation responsibility, and interface responsibilities for report preparation.
This procedure did not address review, approval, verification, or documentation responsibilities.
,l Browns Ferry procedure " Technical Specification Changes and Operating License Amendments" provides instructions for making revisions to Technical Specifications and the Operating License. The procedure did not contain guidance on reconcurrence and clear signature l
responsibilities.
In certain areas, it was determined the guidance provided by. procedure 0602.01 needed improvement to strengthen the submittal process. Areas identified included:
Assignment and Documentation Example - Requirements that assignments be made in writing and that objective evidence be provided as proof of accuracy of information
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were not specified.
1 Certification of Prepared Information i
Example - Specific responsibility and accountability for accuracy of i
information provided to support a submittal were not required.
1 Signature Responsibilities Example - Specific responsibilities to differentiate between 1
preparer, verifier, and concurrence signature requirements were not l
clear.
Reconcurrence Example - Guidelines for conducting reconcurrence following changes to a concurred document were not included.
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Mr. James Lieberman March 24, 1989 In the review for implementation, it was found that responsibilities for ensuring completeness and accuracy of information were not fully understood by all key individuals.
In addition, a general need was identified for better understanding of specific procedural requirements of individual responsibilities and of Nuclear Power's licensing organization role in the overall management of the interface between TVA and the NRC.
In its review of submittals, the task force found some evidence that procedures had not been followed, but the task force did not identify any significant problems affecting the material content of past submittals.
Special Sequoyah Review As a result of the findings from this evaluation and since Sequoyah had been allowed to restart by the NRC, TVA undertook-the following special review:
(1) An additional sample of Sequoyah submit.tals from the " Generic,"
" Licensing," and "Other" families were checked to verify they had been processed through TVA's licensing organization under procedure 0602.01.
This was confirmed by a check of fifty-two submittals (approximately a ten percent sample) sent to NRC in 1987 and 1988 which showed that they had received concurrence in accordance with the procedure.
(2) In view of the conclusion that procedure 0602.01 had not been serving as the single document governing all submittals to the NRC, TVA reviewed other selected submittals which were not processed through TVA's licensing 1
organization to ascertain whether the controls over the information submitted to NRC outside the licensing submittal process were adequate.
To do this, a I
sampling of submittals or procedures used to prepare them was conducted for the " Reports" and " Training" families.
The results of the sampling of these f
two families are as follows:
Twenty Licensee Event Reports (LERs) were checked.
TVA has procedures i
that govern the preparation of LERs and require an independent review by licensing.
The procedures also require that each LER be reviewed by the applicable Plant Operations Review Committee (PORC).
Each of the LERs checked were found to have been prepared, reviewed, and approved as required by the Sequoyah procedure.
The Sequoyah PORC review and recommendation for approval was documented in PORC meeting minutes.
This review in the Sequoyah PORC gave added assurance, over and above the in-line reviews during preparation, that the facts and actions reported to NRC were accurate.
Those periodic and special reports which have been submitted to NRC and
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which were not processed under 0602.01 are generally of a statistical nature.
It was found that the collection of data for these reports is governed by specific site procedures which identify the data and source of the data to be included in each report.
Mr. James Lieberman March 24, 1989 1
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Eleven " Training" submittals regarding operator license applications and renewals were checked.
These consisted of standard NRC forms.
The forms themselves required review and signature by the applicant and other appropriate TVA personnel.
Proper signatures were found on each of the sample submittals.
A sampling of thirteen submittals from the Employee Concern Task Group (ECTG) was also reviewed.
Eleven of these had documentation to support a review of the attached reports by the Senior Review Panel and ECTG management. The remaining two submittals were not given this review because they were primarily intended to transmit internal documents for use in identifying the scope of work to be scheduled for completing Employee Concern efforts. -
The documentation that NRC relied on when authorizing restart of Sequoyah l
comprised, among other things, TVA's submittals to NRC describing TVA's restart programs, including agreements regarding the resolution of technical issues and the quality records and other objective evidence that the restart I
corrective actions were complete.
In the Sequoyah Nuclear Performance Plan j
and other submittals to NRC, TVA described its methods for verifying that each Sequoyah Nuclear Plant was ready for restart.
These methods and the actual i
completion documentation for restart program actions have been the subject of l
reviews by TVA licensing and quality assurance organizations through which the l
status was verified to be consistent with representations made to NRC.
The task force, therefore, did not review these earlier verification activities, rather they addressed the processes for ensuring completeness and accuracy of submittals to NRC.
The review concluded that, based on the sample population looked at in this review, the in place procedural requirements had been followed for review of and concurrence with information and reports submitted to NRC.
There is, therefore, no apparent basis to further question the adequacy of previous submittals.
Overall Conclusions and Actions TVA management has reviewed the findings of the task force and the special Sequoyah review and found nothing in them that would erode TVA's confidence that the restart verification actions were fully adequate. 11owever, given the added importance placed on formal verification of information provided to NRC since the promulgation of 10 CFR 50.9 in late 1987, TVA has determined that the following actions to standardize the review and verification process for all submittals and reports to NRC are warranted.
Accordingly, the following activities have been undertaken:
(1) Issuance of a memorandum dated January 9,1989, to Nuclear Power managers reporting to the Senior Vice President, Nuclear Power emphasizing the requirement to provide complete and accurate information to the NRC.
(2) Issuance of a Policy on February 13, 1989, clarifying TVA's commitment to provide complete and accurate information and addressing the role of TVA's licensing organization to implement and manage the interface program with the NRC.
Mr. James Lieberman March 24, 1989 (3) Improvements to the primary governing procedure (0602.01) and related procedures adding clarity and more positive controls.
These improvements wil_1 add clarity where currently only abbreviated descriptions are 4
presented and more positive controls through the use of consistent
. guidelines and better defined responsibilities. Our scheduled date for implementation is March 31, 1989.
(4) Improving the understanding of individual responsibilities and accountabilities through training on requirements for completeness and accuracy.
Initial training of Licensing personnel has been conducted on the revised primary procedure and on the requirement for completeness and accuracy of information.
Training of other personnel on revised implementing. procedures will cupport full implementation of revised procedures by March 31, 1989.
In addition, special training modules are currently being developed for integration into regular training programs given to Nuclear Power personnel.
These modules are intended to familiarize Nuclear Power personnel with requirements pertaining to communication of complete and accurate information to the NRC.
The modules are scheduled to be completed by March 31, 1989.
I have briefed the TVA Board members on the initial review effort and the improvements being implemented.
Should you have any questions, please contact me.
Yours truly, l
TENNE VALLEY AUTHORITY l
' J/s
. D.
ings e,
Senior Vic n,
s Nuclear P r
Enclosures cc (Enclosures):
Mr. James G. Partlow Director, Office of Special Projects U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Mr. Stewart D. Ebneter Regional Administrator, Region II U.S. Nuclear Regulatory Commission Room 2900, 101 Marietta Street, NH.
Atlanta, Georgia 30323
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