ML18036A794

Responds to NRC 920702 Ltr 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 J TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9208070175
Download: ML18036A794 (13)

See also: IR 05000259/1992021

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 1 1 1 2 2 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 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 1 1 1 1 1 1'1 1 1 1 1 1 1 1 1 1 NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTEl CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT.20079)TO ELIMINATE YOUR NAME FROM 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

0

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.

0'

'-2-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.

0

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.

0'

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.

0'