ML18033B272

Responds to NRC 900326 Ltr Re Violations Noted in Insp Repts 50-259/89-56,50-260/89-56 & 50-296/89-56.Corrective Actions: Administrative Control Sdsp 29.1 Revised to Provide Guidance on Process to Evaluate Measuring & Test Equipment

ML18033B272
Person / Time
Site:	Browns Ferry
Issue date:	04/25/1990
From:	Medford M TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9004270289
Download: ML18033B272 (7)

See also: IR 05000259/1989056

Text

ACCELERATED

DISTjUBUTION

DEMONSTjRATION

SYSTEM REGULATORY

INFORMATION

DISTRIBUTION

SYSTEM (RIDS)CESSION NBR:9004270289

DOC.DATE: 90/04/25 NOTARIZED:

NO FACIL:50-259

Browns Ferry Nuclear Power Station, Unit 1, Tennessee 50-260 Browns Ferry Nuclear Power Station, Unit 2, Tennessee 50-296 Browns Ferry Nuclear Power Station, Unit 3, Tennessee AUTH.NAME AUTHOR AFFILIATION

MEDFORD,M.O.

Tennessee Valley Authority RECIP.NAME

RECXPIENT AFFILIATION

Document Control Branch (Document Control Desk)DOCKET 05000259 05000260 05000296 SUBJECT: Responds to NRC 900326 ltr re violations

noted in Insp Repts 50-259/89-56,50-260/89-56

&50-296/89-56.

DISTRIBUTION

CODE: IE01D COPIES RECEIVED:LTR

ENCL SIZE: TITLE: General (50 Dkt)-Insp Rept/Notice

of Violation Response NOTES:1 on, 1 Copy each to: S.Black,D.M.Crutchfield,B.D.Liaw, R.Pierson,B.Wilson

05000259 05000260 05000296 RECIPIENT ID CODE/NAME PD ACRS AEOD/DEIXB

DEDRO NRR/DLPQ/LPEB10

NRR/DREP/PEPB9D

NRR/DST/DIR

8E2 NUDOCS-ABSTRACT

OGC/HDS2 RES/DSR/HFB/HFS

EXTERNAL: LPDR NSIC NOTES'OPXES

LTTR ENCL 2 2 1 1 1 1 1 1 1 1 1 1 1 1<<1 1 1 1 1 1 1 1 5 5 RECIPIENT ID CODE/NAME ROSS,T.AEOD AEOD/TPAD NRR SHANKMAN,S

NRR/DOEA DIR 11 NRR/DRI S/DIR NRR/PMAS/I LRB 1 2 BI REG FIL 02 RGN'ILE 01 NRC PDR COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 NVIZ TO ALL"RIDS" RECIPIENIS:

P~HELP US TO REDUCE WASTE!CONTACT THE.DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT.20079)TO ELIMINATE YOUR NAME FROM DISTRIBUTION

TOTAL NUMBER OF COPXES REQUIRED: LTTR 29 ENCL 29

if

TENNESSEE VALLEY AUTHORITY CHATTANOOGA.

TENNESSEE 37401 6N 38A Lookout Place APR 25 III U.S.Nuclear Regulatory

Commission

ATTN: Document Control Desk Hashington, D.C.20555 Gentlemen:

In the Matter of Tennessee Valley Authority Docket Nos.50-259 50-260 50-296 BRONNS FERRY NUCLEAR PLANT (BFN)-NRC INSPECTION

REPORTS NOS.50-259/89-56, 50-260/89-56, AND 50-296/89-56

-RESPONSE TO NOTICE OF VIOLATION This letter provides TVA's response to the notice of violation transmitted

by letter from B.A.Hilson to 0.D.Kingsley, Jr.dated March 26, 1990.NRC cited TVA with a Sever>ty Level IV violation pertaining

to calibration

of measuring and test equipment (I'&TE).In the example given, two pieces of'&TE were not calibrated

with a standard at least four times as accurate as the M&TE being calibrated.

A justification

for use of the M&I'E was not documented

by responsible

management

as required by procedure.

TVA.has reviewed this event and is taking appropriate

corrective

actions.Enclosure 1 contains TVA's response to the notice of violation.

The violation is discussed along with the corrective

actions taken.Enclosure 2 is a listing of the commitments

made in this response.If you have any questions regarding this response, please contact Patrick P.Carier at (205)729-3570.Very truly yours, TENNESSEE VALLEY AUTHORITY Mark 0.'edford, 1 e President Enclosures

cc: See page 2 Nuclear Technology

nd Licensing 9r)042702~'9 05'.)Og25 c., 9C)0425 pDR pDQCK-1-@pc 0 An Equa)Opportunity

Emp)oyer ggo/I/(

APR RS 1SSO I cc (Enclosures):

Ms.S.C.Black, Assistant Director for Projects TVA Projects Division U.S.Nuclear Regulatory

Commission

One White Flint, North 11555 Rockville Pike Rockvi lie, Maryland 20852 NRC Resident Inspector Browns Ferry Nuclear Plant Route 12, Box 637 Athens, Alabama 35609-2000

Mr.B.A.Wilson, Assistant Director for Inspection

Programs TVA Projects Division U.S.Nuclear Regulatory

Commission

Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323

ENCLOSURE 1 RESPONSE-BROWNS FERRY NUCLEAR PLANT (BFN)NRC INSPECTION

REPORT NOS.50-259/89-56, 50-260/89-56, AND 50-296/89-56

LETTER FROM B.A.WILSON TO O.D.KINGSLEY, JR.DATED MARCH 26, 1990 Violation 10 CFR 50, Appendix B, Criteria V, as implemented

by TVA Topical Report TVA-TR75-1A, requires compliance

with procedures.

Procedure SDSP-29.1 states that measuring and test equipment must be calibrated

with standards which are at least four times as accurate as the equipment being calibrated.

It permits use of measuring and test equipr"ent

not meeting this requirement

if the basis for acceptance

is documented

and authorized

by responsible

management.

Contrary to the above, on January 9, 1990 this procedure requirement

had not been met for Browns Ferry meesuring and test equipment in that two pressure gauges (Serial Nos.US-TVA-522068

and 517116)had been released for use even though records on site showed that the four times accuracy requirements

had not been met in the calibration

and no justification

for use had been documented

by responsible

management.

t 1.Admission or Denial of the Violation TVA admits the violation.

2.Reason for the Violation This violation has been attributed

to inadequate

administrative

controls.SDSP 29.1"Control of Measuring and Test Equipment," required that MKTE be calibrated

by standards that are at least four times as accurate as the equipment being calibrated.

Deviations

from this requirement

were allowed if the basis for acceptance

was documented

and authorized.

However, SDSP 29.1 did not provide adequate guidance for the implementation

of this process.As a result, METE which did not meet this requirement

were issued for use without appropriate

justification

and authorization.

3.Corrective

Ste s Which Have Been Taken and Results Achieved SDSP 29.1 has been revised to provide guidance on the process to evaluate MKTE that was not calibrated

with a standard four times more accurate.Subsequent

management

review of SDSP 29.1 has identified

additional

changes that are needed to improve the process.These changes will ensure that calibrated

METE r;ceived at BFN that does not meet the four to one calibration

ratio and has not been calibrated

by a state-of-the-art

standard will be evaluated prior to use.

Enclosure 1 Page 2 For the two pressure gauges'specifically

identified

in this violation, a recalculation

of the accuracy of the standard used in their calibration

was performed.

This recalculation

demonstrated

that the calibration

standard was actually four times as accurate as the two pressure gauges.A review of other MINUTE in use at BFN has been performed to determine if any generic implications

existed.As a result of this review, additional

MINUTE was identified

to be evaluated.

A Condition Adverse to Quality Report was initiated to track the corrective

actions.An evaluation

process is in progress to determine the effects of these discrepancies

on plant equipment.

Approximately

270 pieces out of 3000 pieces of METE in use at BFN have been identified

with this type discrepancy.

A sample of M~TE will be evaluated by reviewing their use logs and assuring that their uses have been acceptable.

Based upon the results of this sample, evaluations

will be performed as necessary.

The MINUTE evaluated to date has determined

that all their uses have been acceptable.

4.Corrective

Ste s Which Will Be Taken to Avoid Further Violations

Future cases in which calibrated

MINUTE received by BFN do not meet the four to one calibration

ratio will be justified and authorized

prior to their use.METE currently in use that does not meet this requirement

will continue to be evaluated as discussed above.5.Date When Full Com.liance Will be Achieved The evaluation

process of MINUTE currently in use that does not meet the four to one calibration

accuracy requirement

will be completed prior to Unit 2 fuel load.Administrative

controls resulting from these reviews will be implemented

prior to Unit 2 fuel load.

ENCLOSURE 2 RESPONSE-BRONNS FERRY NUCLEAR PLANT (BFN)NRC INSPECTION

REPORT NOS.50-259/89-56, 50-260/89-56, AND 50-296/89-56

LETTER FROM B.A.NILSON TO 0.D.KINGSLEY, JR.DATED MARCH 26, 1990 COMMITMENTS

1.The evaluation

process for the METE that does not currently meet the four to one calibration

accuracy will be completed prior to Unit 2 fuel load.2.Administrative

controls resulting from the reviews will be implemented

prior to Unit 2 fuel load.