ML18036A794

Responds to NRC Re Violations Noted in Insp Repts 50-259/92-21,50-260/92-21 & 50-296/92-21 on 920516-0616. Corrective Actions:Tva Assigned Overall Responsibility for M&TE Program to Manager in Instrument Maint Section

ML18036A794
Person / Time
Site:	Browns Ferry
Issue date:	08/03/1992
From:	Zeringue O TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9208070175
Download: ML18036A794 (13)

Text

ACCELERATED DISTRIBUTION DEMONSTF&TION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR'.9208070175 DOC.DATE: 92/08/03 NOTARIZED: NO ACIL:50-259 Browns Ferry Nuclear Power Station, Unit 1, Tennessee 50-260 Browns Ferry Nuclear Power Station, Unit 2i Tennessee 50-296 Browns Ferry Nuclear Power Station, Unit 3, Tennessee AUTH.NAME AUTHOR AFFILIATION ZERINGUE,O.J.

Tennessee Valley Authority RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Responds to NRC 920702 ltr re violations noted in insp rept 50-259/92-21,50-260/92-21

& 50-296/92-12 on 920516-0616.

Corrective actions:TVA assigned overall responsibility for MaTE program to manager in Instrument Maint section.

DISTRIBUTION CODE:

IE01D COPIES RECEIVED:LTR 3 ENCL SIZE:

TITLE: General (50 Dkt)-Insp Rept/Notice of Violatioq Response C

NOTES:

DOCKET 05000259 05000260 05000296 RECIPIENT ID CODE/NAME HEBDON,F WILLIAMSiJ.

INTERNAL: ACRS AEOD/DEIIB DEDRO t

NRR/DLPQ/LHFBPT NRR/DOEA/OEAB NRR/PMAS/ILRB12 OE REG FILE EXTERNAL: EG&G/BRYCEiJ.H.

NSIC COPIES LTTR ENCL 1

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1 RECIPIENT ID CODE/NAME ROSS,T.

AEOD AEOD/DSP/TPAB NRR MORISSEAUiD NRR/DLPQ/LPEB10 NRR/DREP/PEPB9H NUDOCS-ABSTRACT OGC/HDS3 RGN2 FILE. 01 NRC PDR COPIES LTTR ENCL 1

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NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTEl CONTACTTHE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAMEFROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED:

LTTR 23 ENCL 23

Tennessee Valley Authority, Post Office Bow 2000. Decatur,'Alabama 35609 O. J. 'Ike'eringue Vice President. Browns Ferry Operations AUG 03

>ggg U.S. Nuclear Regulatory Commission ATTN:

Document Control Desk P

Washington, D.C.

20555 Gentlemen:

In the Matter of Tennessee Valley Authority Docket Nos.

50-259 50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN) NRC INSPECTION REPORT 50-259, 50-260, 50-296/92-21 REPLY TO NOTICE OF VIOLATION (NOV)

This letter provides TVA's reply to the NOV transmitted by letter from B. A. Wilson to M. 0. Medford on July 2, 1992.

NRC cited TVA with a violation for failure to control Measuring and Test Equipment (M&TE).

TVA shares the staff's concern on this issue because of the potential adverse effect that nonconforming test equipment could have on safety related equipment and agrees with the staff that the problems identified in the NOV were indicative of insufficient management oversight in the control of M&TE.

Accordingly, TVA initiated immediate corrective actions to rectify both, the programmatic issues and the specific examples.

TVA con'siders that these actions (discussed subsequently in Enclosure

1) will lead to continued improvement in the control and performance of M&TE.

TVA agrees that the examples noted in the NOV violated regulatory requirements.

Enclosure 1 to this letter provides TVA's "Reply to the Notice of Violation" (10 CFR 2.201).

Enclosure 2 to this letter provides a listing of a TVA commitment made in the response to the NOV.

9208070175 920803 PDR ADOCK 05000259 8

PDR

U.S. Nuclear Regulatory Commission AUG 03

)9'f you have any questions regarding this reply, please telephone Raul R.

Baron at (205) 729-7566.

Sincerely, e(+

0 J. Zeringue Enclosures

,cc (Enclosures):

NRC Resident Inspector Browns Ferry Nuclear Plant Route 12,'ox 637

Athens, Alabama 35611 Mr. Thierry M. Ross, Project Manager U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Mr. B. A. Wilson, Project Chief U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323

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ENCLOSURE 1 Tennessee Valley Authority Browns Ferry Nuclear Plant (BFN)

Reply to Notice of Violation (NOV)

Inspection Report Number "During the Nuclear Regulatory Commission (NRC) inspection conducted on May 16-June 16,,1992, a violation of NRC requirements was identified.

In, accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the violation is listed

'below:

10 CFR 50, Appendix B, Criterion XII requires that measures shall be established to assure that tools,

gauges, instruments, and other measuring and testing devices used in activities affecting quality are properly controlled, calibrated, and adjusted to maintain accuracy within specified limits.

t Nuclear Quality Assurance (NQA) Plan, Section 9.5.2.B.3 implements these requirements and establishes methods to identify previous usage of Measuring and Testing Equipment, (M&TE) found to be in nonconformance.

Site Standard Practice 6.7, Control of Measuring and Test Equipment implements the NQA Plan requirement, and states that activities associated with M&TE found to be nonconforming shall be investigated and

,dispositioned for each use subsequent to the previous calibration.

Contrary to,the above, these requirements were not met for dispositioning the following three examples of M&TE Nonconformance

Packages, concerning previous usage of suspect equipment.

1.

- Seven packages out of 14 did not contain documentation of investigating all previous uses of M&TE.

For example package 91-00486.1, completed January 14, 1992, for an out of tolerance flowmeter transducer assembly listed ten previous uses of the instrument, but only one was documented as dispositioned.

The other

uses, including surveillances on critical systems, structures, and components, (CSSC), required by Technical Specifications, were not investigated.

Package 91-00332.1 listed work order 90-23710 on the usage log, however work order 90-23718 was actually investigated.

2.

Package 91-00504.1, generated due to an out of tolerance multimeter, was completed on February 10,

1992, 29 days past the required 30 day time limit.

Five other packages, 91-00486.1, 92-00002.1, 91-00355.1, 91-00355.3, and 91-00175.1, all of which were used to perform surveillances and maintenance on CSSC, were also late.

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' Package 91-00355.3, for a defective digital caliper used on CSSC, documented a two week period to be investigated rather than the entire period since the last calibration which covered a seven month period.

This is a Severity Level IV Violation (Supplement I) applicable to all three units."

The reason for the violation was insufficient management oversight.

As a result, an approved site procedure was not being properly implemented.

Contributing to this condition was the fragmentation of responsibilities for the M&TE program among several different; groups at BFN.

20 t v t

v In order to correct the fragmentation of responsibilities, TVA has assigned overall responsibility for the M&TE program to a manager in the Instrument Maintenance section.

Among this manager's duties is the responsibility for providing the Plant Manager with a monthly status report on the Out-of-Tolerance (OOT) program.

The first report was provided to the Plant Manager on July 10, 1992.

In addition to the organizational realignment,- TVA has made other changes to the M&TE program to address the findings corresponding to the three examples noted by the NRC staff.

These changes are described below.

The reason that certain METE nonconformance packages did not contain documentation on previous uses was the ineffective processing of the documentation.

Specifically, M&TE 00T documentation was sent to various site groups for review.

In turn, some groups copied the documentation and redistributed it to many evaluators.

During this redistribution, administrative errors were made and accountability for the M&TE usage was lost.

In order to evaluate the adequacy of previous M&TE uses, TVA will review by September,30,

1992, OOT investigations completed since January 22, 1992 (when fragmented reviews started).

This evaluation will ensure that each usage for the noted seven packages will be investigated.

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In order to prevent recurrence of this problem, each section has assigned a M&TE coordinator as a single point of contact to track OOT review packages.

The coordinators are responsible for ensuring that M&TE evaluations are logged in and out, each usage is properly

reviewed, QA requirements are maintained, and evaluation due dates are met.

Additionally, the coordinator is responsible for ensuring that a complete'OOT review package is submitted back to the M&TE Group.

The late OOT reviews noted by the staff were the result of an ineffective manual tracking system.

In order to prevent recurrence of this problem, OOTs are now tracked in a computer tracking system.

This system identifies, any OOT packages approaching the 30-day time limit to ensure the 30-day time limit is not exceeded without prior'anagement approval.

The reason package 91-00355.3 was not reviewed for the entire calibration period was that the checkout logs only documented the use during the noted two-week period.

However, TVA acknowledges that the reviewed pages may not have been inclusive since the pages were not paginated or clearly identified.

In order to prevent recurrence start date and start statement accountability of the complete Additionally, the new checkout pages are accounted for.

of this problem, TVA is documenting a

for each checkout log to ensure the usage history of an instrument.

logs are now paginated to ensure all t v t

]gsggttgag TVA will review OOT investigations completed since January 22, 1992.

This review will be completed by September 30, 1992.

Full compliance will be achieved by September 30, 1992.

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ENCLOSURE 2 Tennessee Valley Authority Browns Ferry Nuclear Riant (BFN)

Reply to Notice of Violation (NOV)

Inspection Report Nuniber TVA will review OOT investigations completed since January 22, 1992.

This review will be completed by September 30, 1992.

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