ML20064A687

Requests Closure of Confirmatory Order EA-84-054 Re Regulatory Performance Improvement Program

ML20064A687
Person / Time
Site:	Browns Ferry
Issue date:	09/18/1990
From:	Wallace E TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
EA-84-054, EA-84-54, NUDOCS 9009270058
Download: ML20064A687 (13)

Text

.. .-= .

s l$% ;

-p

1. c . _

m TENNESSEE VALLEY AUTHORITY' R P. O. Box 2?00 Decatur,: Alabama SEP 181990 ,

.I ^

U.S. Nuclear Regulatory Commission ATTN L Document Control Desk l i Washington, D.C. 20555 Gentlemen:' U In the Matter'of ) Docket Nos. 50-259-Tennessee Valley Authority ) 50-260 i 50-296 I

'^

BROWNS FERRY NUCLEAR PLANT (BFN)'- REGULATORY PERFORMANCE IMPROVEMENT PROGRAM -

The purpose of this letter is to to request the closure of Confirmatory Order EA 84-54. . This Order was issued on July 13, 1984 and required the implementation of the Reg 1latory Performance Improvement Program (RPIP) for

.BFN. ,

i li LTheovers111objectiveoft.teRPIPwasto-provideaplanforensuringsafe ~!

- operation of the Browns Feiry Nuclear Plant.by achieving the improvements

considered necessary to mee: NRC regulatory requirements. By-. letter dated .

, l March.18, 1986, TVA providel a status update of the RPIP action items and j L; ' requeated'~that the action it ems which remained open af ter NRC's review be L . incorporated-in TVA's Nuclesr Performance Plant (NPP) forjBFN. The NPP-provided a1 comprehensive. pit.n for correcting the overall problems-with the TVA-nuclear program.and was much broader in scope than the RPIP. NRC last'

+

Linspected open RPIP action items in 1988 (Inspection Report 88-31, dated ,

p October-24, 1988) and in that report, indicated that the remaining'RPIP action-K . items =were covered in various sections of the NPP for BFN. Consequently, TVA ,

. considers'the=open action items contained-in the.RPIP to be. resolved by '

incorporation-into the NPP. The enclosure to this submittal provides the basis for the closure of each of the remaining open RPIP items tracked.by the b 4 NRC staff, t-1 l

There'are no commitments-contained in this letter. If you have any questions, .-

please contact Patrick P. Carier, Manager of Site Licensing, at (205) 729-3570. "}

p Very truly yours, }

w, P' -1' TE

~

SEE VALLEY AUTHORITY

, - - .~ b C220) [

E. G. Wal ace, Manager l' 9009270058 900918 Nuclear Licensing and DR- ADOCK 0500 9 A Regulatory Affairs  !

Enclosure cc: See page 2 u

An Equal Opportunity Employer ll00l f

~~-

r * .-

U.S. Nuclear Regulatory Commission b

SEP 181990 cc-(Enclosure):

.Ms. S.'C. Black, Deputy Director l Project Directorate II-4 U.S.- Nuclear Regulatory Commission

'One White Flint, North 11555 Rockville Pike,

- Rockville, Maryland 20852 NRC Resident Inspector  ;

Browns Ferry Nuclear Plant Route 12, Box 637 Athens, Alabama 35609-2000 Thierry M. Ross, Project Manager ,

U. S. Nuclear Regulatory Commission One W11te Flint, North- t 11555 Rockville Pike '

Rockville, Maryland 208-Mr. B. A. Wilson, Project Chief U.S. Nuclear Regulatory Commission i Region II 101 Marietta Street, NW,. Suite 2900 i Atlanta, Georgia 30323 .

-1 i

i 1

m-1 1

'.i:-

[

k

. n l

t ENCLOSURE BROWNS FERRY NUCLEAR PLANT-CLOSURE:0F REGULATORY PERFORMANCE IMPROVEMENT PROGRAM  :

Background:

]

TVA submitted the Regulatory Performance Improvement Plan (RPIP), by letter

• darsi 'ebruary 24, 1984, which described both short-range and long-range  :

objvN ives for achieving the improvements considered necessary to meet regulatory requirements at Browns. Ferry. On July 13, 1984, the NRC Region II office' issued Confirmatory Order EA 84-54. .The Order stated that the completion of those initiatives which were described in the RPIP were necessary and appropriate to the continued safe operation of the Browns Ferry

. Plant.

Subsequently, in March 1985, Browns Ferry was shut down.- On September 17,

'1985, the NRC staff requested, pursuant to 10 CFR 50.54(f), that TVA submit.

information about its plans for, among other things, correcting the Browns Ferry problems. 'In response, the Browns Ferry Nuclear Performance Plan (NPP)- '

was submitted on August 28, 1986 and revised.by letters dated July 16, 1987

.and October 24, 1968. r As discussed in Appendix _A of the NPP, many of the long-term RPIP action items  !

.were carried forward <into the-NPP as a superseding plan for tracking  !

programmatic-improvement efforts at BFN. The status of the RPIP items carried-as open by the NRC staff was listed in Appendix A of the NPP and discussed in Inspection Report 88-31, dated October 24, 1988. These items, the associated cactions, and a basis for the closure of each item is provide as follows:

a Open-Iterns and Basis for Closure: s Shod TerrN RPIP Action items:

' Item I-3.8,' Regulatory Compliance Training

- Actions- Ensure that each classification of employees understands his or her responsibilities and authority regarding quality and j ,

-compliance. Rigidly require the craftsman to certify all work for quality and completeness. The craftsman must understand that quality is.his responsibility and that quality control inspectors only verify the quality.

1 JClosuret- This RPIP item was closed in Inspection Report 88-31, dated October 24,.1988. The Inspection Report concluded that BFN l developed and implemented a-formal training program on QA/QC, plant procedures, and regulatory compliance for all personnel.

L l'.

l-5 L

L

- - . - - . . . ~ .

7

, 4 -

. . . . Y a  ;

Page 2 of 11; >

ENCLOSURE (CONTINUED)

BROWNS FERRY NUCLEAR PLANT CLOSURE OF, REGULATORY: PERFORMANCE. IMPROVEMENT: PROGRAM. 1 Short-Term RPIP. Action items (Continued):

Item I-4.5, organization 7

Action Review and revise appropriate documents to define and describe the new-organization.

Closures This' RPIP item was closed in Inspection Report 88-31, dated October 24, 1988. The Inspection Report concluded that the BFN Final Safety Analysis Report (FSAR) and TVA's Topical Report,

-TVA-TR 75-1A, dated.May 6, 1988, addressed the relationship of

-[

various organization positions.

Item I-4.ll, Independent Safety Engineering-Group

? ' Action: Implement an Independent Safety Engineering Group closure ~ This RPIP item was closed in Inspection Report 88-31, dated October. 24, 1988. 'The Inspection Report concluded that a long -I term stef fing plan was established and the NRC's review and -

determination of BFN ISEG acceptability would be addressed in a Safety Evaluation Report on the NPP. Supplement 1 to the Safety Evaluation Report on the Browns Ferry Nuclear Performanos Plan - NUREG 1232,_ Volume 3, was' issued on October 24, 198V.

Section 4.2.2, Independent Safety Engineering Group, concluded that the ISEG program for Browns Ferry was adequately constituted ,

and chartered to enhance the safety. posture of the-plant in_the_ s manner outlined by NUREG-0737 and SECY 80-242.- 0 l

I

)

a 4

k

_l

1 C Sii. .

I 1

Page 3 of 11 }

l

, ENCLOSURE (CONTINUED)~

r BROWNS FERRY NUCLEAR PLANT ,

j CLOSURE OF REGULATORY PERFORMANCE: IMPROVEMENT PROGRAM 1

b

.'Long Terni FU)lP )(ction Iterns:  !

Item II-1.1, Vendor Manual Upgrade Program Actions Review and resolve an audit finding on the vendor manual-control program.

Closure TVA's revised Vendor Manual Control Program was discussed in NPP  !

Sections II.2.4 and II.5.1. The Vendor Manual control Program at i Browns Ferry was reviewed and found acceptable as documented in -1 Inspection Report 89-56, dated March 26, 1990. Since that time, >

the Staff issued Generic Letter 90-03, dated March 20, 1990, which j relaxed the guidance previously provided in Generic' Letter 83-28, Item 2.2, Part 2, Vendor Interface for Safety-Related components. ,

~

TVA11etter dated August 24, 1990 certified that TVA's corporate standard met the requirements of Generic-Letter 90-04. This ,!

standard is scheduled for implementation on September 28, 1990.

?

. Item 11-1.2, Close out of QA Audit Findings *

~

Actions- Close out QA findings for which corrective action is complete.

Closure: This RPIP item was closed in Inspection Report 88-31, dated October :24,'1988. The Inspection Report stated that there were two remaining QA audit findings which required ~ closure. The first a was for TVA to implement a technical training program for the-Modification and Plant Engineering sections in preparation of work plans. The second was the improvement.of inadequate corporate < M pcocedures.

The technical training program audit finding was resolved in 1987.

Training was performed on work plans for the modifications group and similar training was-provided to the. plant engineering staff'.

The audit-finding regarding the improvement of corporate procedures was closed since TVA had committed in the Corporate Nuclear Performance Plan-(CNPP), which'was originally submitted to NRC on November 1, 1985, to correct identified weaknesses in.

programs and procedures. The NRC reviewed the CNPP and concluded in the July 28, 1987 Safety Evaluation Report that TVA's effort to upgrade procedures and to establish uniform controls and.

centralized direction.was an acceptable program for procedure development.

2

- -~-. - - - - - ,

s Page 4 of 11 :

ENCLOSURE-(CONTINUED)- '

BROWNS FERRY NUCLEAR PLANT CLOSURE OF REGULATORY PERFORMANCE IMPROVEMENT PROGRAM  ;

Long Term RPIP Action items (Continued):  ;

item II-2.1,-Close-out of ECN D'cumentation  :

Action: Assign management priority to the BFN As-Constructed Drawing Task ,

Force for resolution of open/ incomplete ECNs, workplans, as-constructed drawings, and resolve the disapproved but implemented FCR backlog issue.

Closure: This was a broad based effort to establish a design baseline consistent with the as-built condition and to maintain control of future plant configuration changes. Actions to implement the effort were described in Section III.2 of the NPP. Major progress has been.made in the updating of drawings cnd the resolution of outstanding design and work documents.

Item II-3.1, Corporate Procedure Upgrade

?

Action: Rework and upgrade upper-tier procedures. '

Closuro: As discussed in Item II-1.2 above, TVA committed in the Corporate Nuclear Performance Plan (CNPP) to correct identified weaknesses mi i-in programs and procedures. ' Procedures are being upgraded-through-short- and long-term programs. The NRC reviewed the CNPP and concluded in the July 28,.1987 Safety Evaluation Report that.TVA's

., . effort to upgrade procedures and to establish uniform controls'and

' centralized direction was an-acceptable' program for procedure development.

Item II-3.2, Management Observation and Craftsman or Operator Involvement in

~

Procedures Action: Verify procedures during management observation in the field.

Assign senior craftsmen in each section to work with section q,; engineering personnel to ensure that. procedure revisions resulting from-field observations are written for the man performing the-work and not the reviewer.

Closure This RPIP item was closed in Inspection Report 88-31, dated October 24, 1988. The inspector noted that a majority of maintenance procedures were upgraded in the electrical, I&C, and Mechanical areas.

l.

X %r ,

, i . . _ .

a Page 5 of 11 ENCLOSURE (CONTINUED) a -BROWNS FERRY NUCLEAR PLANT CLOSURE OF REGULATORY PERFORMANCE IMPROVEMENT PROGRAM Long Term RPIP Action items (Continued):

Item 11-3.4, Intent /Non-Intent Revisions to Procedure

(

Action: Define clearly the method and limitation imposed to revise  !

. procedures on the spot and also ensure proper review-of the change. j Closure: TLis RPIP iten was closed in Inspection Report 88-31, dated i October 24, 1988. The Inspection Report stated that a Site Director Standard Practice described how to make .mmediate l Temporary changes which are.also known as non-intent changes.

They are normally used for completing a procedure in progress.  !

requiring an immediate revision in which the change does not alter  ;

the intent of the original procedure.

I Item II-3.5, Hodification Control Process '

Actions. Revise modification control procedures to ensure completion of work,. post-modification testing, configuration control, and .,1 training documents before'a modification is placed in service. i Closure This item covered a broad scope of activities and improvement for-the modification control process which were discussed in det... in Sections III.2.3 and III.2.4 of_the NPP. The performance of the 3 plant in the area of. modifications control was documented-in'the' 1 latest Systematic Assessment =of Licensee Performance, Inspection.

Report 90-07, dated June 14, 1990. There was increased management '

involvetrent and control of the modification control process. The Browns Ferry onsite engineering and modification groups were ~j reorganized. Improvements were made in accountability, responsiveness and effectiveness of these groups.

.L

-l l

.9' l

/

+ '

Page 6 of 11~ \

ENCLOSURE (CONTINUED)

L

" BROWNS FERRY NUCLEAR PLANT-L LCLOSURE OF REGULATORY PERFORMANCE IMPROVEMENT PROGRAM

~ Long Term RPIP Action items (Continued):

Item 11-3.6, Programmatic Improvements Action: Implement programmatic improvement plans in the areas of l radiological control, security, quality assurance, chemistry, and i fire protection.

l-closures Programmatic improvements have been made in the areas of g radiological control, security, quality assurance, chemistry, and l fire protection as documented be2ow j Programmatic improvements is the area of radiological control were j described in Section II.6.1 of the NPP. Reductions were achieved l in collective annual'aite dose, personnel contamination evento and )'

in the size of the area of the plant considered contaminated.

l- Training for Health Physics technicians was increased. The=NRC Staff evaluated improvements to radiological control in Section 4.10 of NUREG-1232, Volume 3, dated April 14, 1989.. The.

NRC Staff concluded in that document that-the: improvements were acceptable to support restart of BFN Unit 2.. The performance'of.

the plant-in the area of Radiological controls was documented in the latest Systematic Assessment of Licensee Performance, Inspection Report 90-07, dated June 14, 1990. ,.

Programmatic improvements is the area of security were_ described-in Section II.7 of the NPP. The NRC Staff evaluated plant security in Section 4.8-of NUREG-1232, Volume 3, dated ,

U April.14, 1989. The Staff concluded that the physical security program was acceptable with the implementation of the following  ;

i. security related actions -

1) Test security emergency power,

2) Reduce the size of the protected area,

3) Improve alarm assessment capabilities, and ,

4) Reduce the number of compensatory measures.

1 li

Page 7 of 11 ENCLOSURE-(CONTINUED)

BROWNS FERRY NUCLEAR PLANT CLOSURE OF REGULATORY PERFORMANCE IMPROVEMENT PROGRAM Long Term RPIP Action Items (Continued):

Item II-3.6, Programmatic Improvements (Continued) l i

closure: The security emergency power system was successfully tested (cont.). and the remaining security related actions are being finalized at the time of this submittal. The performance of the plant in the area of security was documented in the latest Systematic Assessment of Licensee Performance, Inspection Report 90-07, dated  ;

June 14, 1990.

Programmatic improvements is the area of quality assurance.were discussed in Sections II.1.2.9 and II.2.2.6 of the NPP. The NRC Staff evaluated the conditions Adverse to Quality (CAQ) program and the quality assurance program in Sections 4.3.1.and 4.3.2 of d NUREG-1232, Volume 3, dated April. 14, 1989. The Safety Evaluation concluded that no issues involving the CAQ program needed to be resolved before restart of Unit 2 and the quality assurance . l~

program for the Browns Ferry Nuclear Plant was acceptable. The '

Crder'(EA 85-49)'regarding the CAQ-program was lifted by NRC  !

Safety Evaluation, dated October 3, 1989. Involvement in the corrective action program was reviewed and documented in Inspect.on Report 90-20, dated August 13, 1990. _The Inspection- .i Report concluded that the CAQR program was. effective in the

~

identification and resolution of problems in the previous one year! l period. j q

-Programmatic improvements is the area of. chemistry were discussed in Section II.6.2 of the NPP. The NRC Staff evaluated improvements to chemistry in Section 4.10 of NUREG-1232, Volume 3, dated April 14,1989. The NRC Staff concluded that the improvement measures were acceptable to support restart of BFN Unit 2. The performance of the plant in the area of chemistry was documented

( in.the latest Systematic Assessment of Licensee Performance, .

Inspection. Report-90-07, dated June 14, 1990.

w l

l

!: >.c.

I

,. ' . . , - J

..' I Page 8 of 11 ENCLOSURE'(CONTINUED).

BROWNS: FERRY NUCLEAR ~ PLANT Cl.0SURE OF REGULATORY PERFORMANCE IMPROVEMENT PROGRAM i

l Long. Term RPIP Action items (Continued):

F Item II-3.6, Programmatic Improvements (Continued)-

• closure: Programmatic improvements is the area of fire protection were <

-(Cont.)- discussed in Section III.5 of the NPP. It was-concluded in Inspection Report 90-06, dated April 3, 1990, that Browns Ferry met the NRC's fire protection requirements.

P Programmatic improvements were made in the areas of radiological control, security, quality assurance, chemistry, and fire protection. . Justification for the closure of th3 RPIP action for each individual program has been provided.

Item,II-3.7, Plant Procedures Upgrade Action: Rework and~ upgrade plant procedures.= '

, closure The procedures upgrade activities were discussed in Section II.2.4 of the NPP. The NRC Scaff reviewed TVA's-programmatic approach

-and concluded in SECY-90-148, dated April 23, 1990, that the procedures upgrade program resulted in overall significant .

improvement'in procedures.

Item II-6.2, Streamline the Procurement Process Action Create a joint task force to study and recommend corrective I actions for the procurement process. ,

' Closures. A broad scope of activities have been taken to improve the procurement _ process. This RPIP action item was tracked by Inspector Follow-up Item 86-04-02, Implementation of. Corrective "

Actions to Resolve Procurement Problems. Corrective actions were reviewed, found to be satisfactory, and the item was closed in i Inspection Report 87-04, May 12, 1987. In addition, TVA har j undertaken an extensive program to review and evaluate pa ad present procurements of replacement items. The NRC Staff viewed TVA's programmatic approach and concluded in SECY-90-148, dated L- April 23, 1990, that the approach was acceptable.

I 1

5 1 l~

f.

l'? .

i

D

.1 ,

Page 9 of 11 -

ENCLOSURE-(CONTINUED) .

BROWNS FERRY NUCLEAR: PLANT  :

CLOSUllE OF REGULATORY PERFORMANCE IMPROVEMENT PROGRAM j Long Term RPIP Action items (Continued):

• Item.II-9.1, Review of Control Room Activities Actions. Assign a trained individual to conduct daily reviews of control room and other.operationcl activities.

- Closure This RPIP item was closed in Inspection Report 88-31, dated E October 24, 1988. The Inspection Report stated that metsures to i monitor and improve control room activities (including logging practices) were implemented and performed on a routine basis.

l

^

Item II-9.2, Valve. Status Alignment

~

Action: Develop routine verification of the physical status of abnormal

-valves.

Closures This-PPIP ltem was closed in. Inspection Report 88-31, dated October 24, 1988. The Inspection Report stated that the commitment for issuance and implementation of a revised procedure' ,

dealing with valve alignment controls and valve position H verification was reviewed.

i l

Item II-9.3,LSecond Party-Verification Program -I I

Action: Develop procedures consistent with.INPO and NRC positions on- l second-party verification. I i Closure: This RPIP item was closed in Inspection Report 88-31, dated October 24, 1988.- The Inspection Report stated that the procedure .I on second party (or independent) verification incorporated the l INPO and NRC positions.

~ .

L l

I:

>w, ,

' $g

~

Page 10 of 11 , '

ENCLOSURE (CONTINUED)

+

^

BROWNS FERRY NUCLEAR PLANT 1 CLOSURE OF-REGULATORY-PERFORMANCE-IMPROVEMENT PROGRAM <

1 1

Long Term RPIP Action items (Continued):.

Item II-9.6, Contractor Recommendation on NSSS l

Action: Utilize an outside contractor (General Electric) to evaluate NSSS -l operation. This includes normal operation, surveillance-procedures, and shift activities, t

Closure: The GenerEl Electric (GE) recommendations-were discussed in' )

Appendix B of the NPP. The TVA disposition of the GE recommendations was reviewed by th'e NRC staff as documented in Inspection Report 89-16, dated March 9, 1990. The report states-that in general, the team found that the commitment made in the NPP to disposition the contractor recommendations was satisfied.

Item II-9.7, Contractor Recommendations of Technical Specifications

-Action Utilize an'outside contractor (SAI Corporation) to perform an evaluation of Technical Specifications.

.1 LClosures This RPIP item was-closed in Intpection Report 88-31, dated  !

October 24, 1988. The SAI Corporation recommendations and their disposition were discussed in Appendix B of the NPP. The Inspection Report stated.that. acceptability of TVA's work in this area was_ expected to be' addressed. separately.- Inspection ~ l Report 89-47, dated October 21,'1989 reviewed the. disposition of historical Technical Specifications problems. A final. pre-restart' Technical Specifications inspections is currently scheduled.

. . l

-Item II-9.9, Contractor Recommendations on Administrative Management q Action: Reevaluate the 26 MAC recommendations on administrative' management.

Closure: This RPIP item;was closed in Inspection Report 88-31, dated-October 24, 1988. The MAC recommendations were reevaluated and incorporated into the NPP. The Inspection Report stated that the

-issue of administrative management would continued to be monitored separately as part of the overall monitoring of operation )

readiness for restart.

u

~

>+ -

is i

b .,

.o4

.)

A$, '

I~

Page 11.0111 ENCLOSURE-(CONTINUED)= o 4 .

BROWNS FERRY NUCLEAR PLANT-- e CLOSURE OF REGULATORY PERFORMANCE IMPROVEMENT-PROGRAM e . .

Other RPIP Acdion Itenis:

L In addition to the open items listed in Appendix A of.the NPP, discussions f with the Browns Ferry Resident Inspectors have indicated that two additional I ,

.long-term RPIP Items were being tracked by the NRC. These items and the basis for their closure is provided as follows:

a Item II-4.1, Interaction between Nuclear Engineering and the Plant Action: Provide for close and continuing interaction between EN DES'(now

/ titled Nuclear Engineering) and plant to resolve modification implementation questions and to establish priority and evaluation- '

D on nonconformance' items and failure evaluations.

Closure: .At this time, most Nuclear Engineering. activities are conducted ati >

the Browns Ferry site. The configuration management program '

involved a broad scope of activities and improvements for the l design and modification control process as discussed in. >

' Sections'III.2 of the NPP. The performance of the plant in the area of engineering and technical support is documented in the latest Systematic Assessment of Licensee Performance, Inspection ,

Report 90-07, dated June'14, 1990.- There was an increase in d management. involvement and: control of the onsite-engineering and modification groups. Improvements were made in accountability, responsiveness and' effectiveness of these groups. '

-: i Item II-7.0, Onsite Training Organization -

-t Action: Establish an onsite training organization under the supervision of the Training Branch ~with responsibility for all onsite training activities. Work toward INPO accreditation of BFN training programs.

i closures The onsite training organization was' established at the Browns

Ferry Training and Visitors Center.- Browns Ferry's ten training programs-have been accredited by INPO. In addition, TVA is a memberlof-the National Academy for Nuclear Training.

e n v