ML18033B051
| ML18033B051 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 11/20/1989 |
| From: | MEDFORD M O TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8911270107 | |
| Download: ML18033B051 (12) | |
See also: IR 05000259/1989047
Text
ACCELERATED
DISTRIBUTION
DEMONSTPA.TION
SYSTEM REGULATORY
INFORMATION
DISTRIBUTION
SYSTEM (RIDS)ESSION NBR:8911270107
DOC.DATE: 89/11/20 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
RECIPIENT AFFILIATION
Document Control Branch (Document'ontrol
Desk)'OCKET
g 05000259 05000260 05000296 SUBJECT: Responds to NRC 891021 ltr re violations
noted in Insp Repts 50 259/89 47150 260/89 47&50 296/89 47'ISTRIBUTION
CODE: IEOlD COPIES RECEIVED:LTR
~ENCL i SIZE: TITLE: General (50 Dkt)-Insp Rept/Notice
of Violation Response NOTES:1 R.1 R.1 R.Copy each to: B.Wilson,D.M.Crutchfield,B.D.Liaw,S.Black
Pierson, Copy each to: S.Black,D.M.Crutchfield,B.D.Liaw, Pierson,B.Wilson
Copy each to: S.Black,D.M.Crutchfield,B.D.Liaw, Pierson,B.Wilson
05000259 05000260 05000296 RECIPIENT I D CODE/NAME PD I ERNAL: ACRS AEOD/DE I I B DEDRO NRR/DEST DIR NRR/DOEA DIR 11 NRR/DREP/RPB
10 NRR/PMAS/I
LRB12'E L N,J RE FILE 01 EXTERNAL: LPDR NSIC NOTES'OPIES
LTTR ENCL 1 1 2 2 1 1 1 1 1 1 1 1 2, 2 1.1 1 1 1 1 1 1 1 1 1 1 5 5 RECIPIENT ID CODE/NAME GEARS,G AEOD AEOD/TPAD NRR SHANKMAN,S
NRR/DLPQ/PEB
NRR/DREP/EPB
10 NRR/DRIS/DIR
NUDOCS-ABSTRACT
OGC/HDS2 RES MORI SSEAU i D 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 NOTE TO ALL"RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE!CONTACT THE DOCUMENT CONTROL DESK ROOM Pl-37 (EXT.20079)TO ELIMINATE YOUR NAME FROM DISTRIBUTION
LISTS FOR DOCUMENTS YOU DON'T NEED!TAL NUMBER OF COPIES REQUIRED: LTTR 31 ENCL 31
0'
'0 TENNESSEE VALLEY AUTHORlTY CHATTANOOGA.
TENNESSEE 37401 6N 38A Lookout Place NOV 20 888 U.S.Nuclear Regulatory
Commission
ATTN: Document Control Desk Washington, D.C.20555 Gentlemen:
In the Hatter of Tennessee Valley Authority Docket Nos.50-259 50-260 50-296 O.BROWNS FERRY NUCLEAR PLANT (BFN)UNITS 1, 2, AND 3-NRC INSPECTION
REPORT NOS.50-259/89-47, 50-260/89-47, AND 50-296/89-47
-RESPONSE TO NOTICE OF VIOLATION This letter is to provide TVA's response to your letter from Bruce Wilson to Oliver D.Kingsley, Jr.dated October 21, 1989, which transmitted
the subject'nspection
report.This report cited TVA with one Severity Level V Violation (Supplement
I)in accordance
with 10 CFR Part 2, Appen~ix C.Enclosure 1 provides background
information
and TVA's response to the violation cited in the subject report.A list of commitments
is provided in Enclosure 2.If you have any questions, please telephone Patrick P.Carier, BFN, at (205)729-3570.Very truly yours, TENNESSEE VALLEY AUTHORITY Enclosures
cc: See page 2 Mark O.Medford, Vice esident, Nuclear Technology
and Licensing 85'11270 g 07 goal g.-.0~E1OCr,<~.",iaoc>-
~-a i3 F'DC An Equal Opportunity
Frnployer
U.S.Nuclear Regulatory
Commission
cc (Enclosures):
Ms.S.C.Black, Assistant Director for Projects TVA Projects Division U.S.Nuclear Regulatory
Commission
One Hhite Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Mr.B.A.Nilson, Assistant Director for Inspection
Programs TVA Projects Division U.S.Nuclear Regulatory
Commission
Region II 101 Marietta Street, NH, Suite 2900 Atlanta, Georgia 30323 NRC Resident Inspector Browns Ferry Nuclear Plant Route-12, Box 637 Athens, Alabama 35609-2000
ENCLOSURE 1 RESPONSE NRC INSPECTION
REPORT NOS.50-259/89-47, 50-260/89-47, AND 50-296/89-47
LETTER FROM B.A.HILSON TO O.D.KINGSLEY, JR.DATED OCTOBER 21, 1989 Statement of Violation 10 CFR 50 Appendix B Criterion VI, Document Control, requires that measures shall be established
to control the issuance of documents including changes thereto, which prescribe all activities
affecting quality.These measures shall assure that documents, including changes, are reviewed for adequacy and are distributed
to the location where the prescribed
activity is performed.
Nuclear Quality Assurance Manual Part I, Section 2.6, Document Control, Paragraph 5.1.1, requires that programs and procedures
shall be established
for the control of documents for activities
that affect safety-related
functions.
Site Directors Standard Practice 2.12, Controlling
Documents, establishes
the requirements
for the processing
of controlled
documents to ensure that the latest applicable
controlled
documents are available and distributed
to identified
recipients
and to minimize the inadvertent
use of voided or superseded
documents.
Contrary to the above, these requirements
were not met in that adequate document control was not maintained
for a TS amendment and controlled
copies of TS for the following three examples: l.Adequate document control was not maintained
for TS Amendment 135, 131, 106, dated August 20, 1987, which revised TS definition
1.0.C.2 to.clarify its applicability
during Cold Shutdown or Refueling.
On September 26, 1989, the inspector identified
that page 1.0-2 located in controlled
copies of the TS did not reflect the approved and issued change.The correct wording had been incorporated
into controlled
copies of the TS but not into the plant licensing's
staff master copy.In February 1989, TS Amendment 158, 157, 129 revised different information
contained on the same page in TS definition
1.0.C.2.2.Unit 2 TS controlled
copy 52 was not properly maintained
with the latest amendment to TS.On September 27, 1989, the inspector identified
that existing pages 1.1/2.1-2 through 1.1/2.1-4 of copy 52 reflected the original amendment dated March 19, 1987, instead of amendment 143 dated March 3, 1989.3.Unit 2 TS Control Room copy 40 was not properly maintained.
On September 27, 1989, the inspector identified
that two copies of page 3.7/4.7-16
existed but only one of which was annotated with information
pertaining
to compensatory
measures 88-64-2-007, in effect at the time.The above instances are examples of a Severity Level V Violation (Supplement
I)and is applicable
to all three units.
T VA Response l.Admission or Denial of the Alleged Violation Page 2 of 4 TVA admits the violation occurred as stated.Due to the difference
in the three examples, TVA will discuss the reasons for the violation, corrective
steps which have been taken and results achieved, corrective
steps which will be taken to avoid further violations, and date of full compliance
separately
for each example.2.Reasons for the Violation A.TVA BFN uses a computer master TS file to store NRC approved TS's.This file is updated by the BFN Licensing Speciali.st
when the NRC approved TS change is received.The master file can only be accessed through a security code which is controlled
by the Licensing Specialist.
In investigating
this specific example, it is apparent that the computer master file was not updated after the issuance of TS Amendment 135, 131, 106 dated August 20, 1987.As a result, when this specific page was revised (TS Amendment 158, 157, and 129), the original TS words were inadvertently
incorporated.
Therefore, when TS Amendment 158, 157, and 129 was issued, the previously
approved changes in TS Amendment 135, 131, and 106 were not contained.
This resulted in inadvertent
use of the outdated wording in TS definition
1~0.C.2, however, use of the outdated wording did not decrease any margin of safety.The outdated words were minor in nature and were changed to only provide additional
clarification.
B., BFN Document Control uses two methods of updating controlled
documents.
The first method utilizes Document Control staff to physically
insert the revised pages in the controlled
document.In the second method, the revised pages are submitted to the document holder with instructions
of how to update their controlled
documents.
Upon completion
of either process, documentation
of completion
is returned to Document Control.The subject controlled
document, TS copy 52, is updated by the BFN Document Control staff.For the specific example cited in the subject inspection
report, the pages were either inadvertently
replaced with the original pages 1.1/2.1-2 through 1.1/2.1-4 or those revised pages were not inserted when the controlled
document was being updated.Controlled
copy 52 is the Site Residents copy of the BFN TS.This copy is not used to perform any safety analysis or operation of the plant, therefore, this specific issue did not decrease any margin of safety.C.The Unit 2 Control Room TS copy 40 is updated by the Document Control staff.When this copy was updated, the existing, page 3.7/4.7-16
was to be replaced.When the revised page was placed in the document, the existing page was not removed.This resulted in two page 3.7/4.7-16's
left in the document.The only difference
in the two pages was the revised page had an annotation
pertaining
to a compensatory
measured'his
is an additional
requirement
implemented
by BFN.The Limiting Condition of Operation (LCO)and the Surveillance
Requirement (SR)were the same on both pages therefor e, there was no decrease in the margin of safety.
3.Corrective
Steps Which Have Been Taken and Results Achieved Page 3 of 4 TVA reviewed these three examples to determine the reason for error.Based on this review it was determined
that these were isolated issues and there is not a programmatic
problem.In all three cases personnel error was identified
to be the reason for the error.When TS Amendment 158, 157, and 129 was issued (February 1989), BFN typically reviewed only those parts of the LCOs or SRs that were being revised.In early spring 1989, BFN started to review not only those sections being revised but the entire page.This provided additional
checks and balances to ensure that the entire page reflects not only those sections being revised but ensures the rest of the page reflects what has been approved by NRC in previous changes.Since'his practice was implemented, BFN has minimized such errors.As a result of the subject inspection
report, BFN Document Control Records Management (DCRM)conducted a 100%assessment
(51 copies)of the controlled
sets of TS's on site and 2 additional
sets in Chattanooga.
The scope of this assessment
was to see if any other controlled
copies of the BFN TS's contained the same page errors identified
in controlled
copy 52.The results of the assessment
demonstrated
that the page errors were unique to controlled
copy 52.This is considered
an isolated case which resulted from personnel error.In early 1989, DCRM implemented
a self-assessment
program, improved transmittal
receipt acknowledgment
tracking system, and a reduction in the number of controlled
manuals in an effort to enhance the overall document control process at BFN.DCRM instruction
DCRMI 302.2 was also updated to require that an audit of selected controlled
documents (including
the Technical Specifications)
be performed on an annual basis.These steps, in addition to the actions discussed above, have enhanced the overall control process of these documents.
After NRC identified
that two copies of the same page existed in Unit 2 TS Control Room copy 40, one of the pages was deleted to correct the problem.Upon correcting
this problem, DCRM instructed
their personnel of the importance
of correctly updating controlled
manuals.In addition, DCRM performed a 100%audit of controlled
copies of the TSs on site to ensure that the same problem did not exist (two copies of the same page 3.7/4.7-16).
This audit did not identify any other copies with the same problem, therefore, this is con'sidered
an isolated case which resulted from personnel error.
Page 4 of 4 4.Corrective
Steps Hhich Hill Be Taken to Avoid Further Violations
A.To correct the specific problem, BFN will resubmit the correct page 1.0-2 in a subsequent
TS submittal to NRC.This has been discussed and approved by the NRC/TVA Project Manager.B.The continued implementation
of the corrective
steps discussed in section 3.B above are considered
adequate to avoid further violations.
No other steps are being considered
at this time.C.As stated above, DCRM procedure DCRM 302.2 was revised to require an annual audit be performed on specified controlled
documents to minimize such errors.In addition, continued emphasis to the DCRM employees on the importance
of correctly updating these documents is expected to avoid further violations
of this nature.5.Date Hhen Full Compliance
Hill Be Achieved A.The correct page 1.0-2 wi 11 be submitted to NRC by January 5, 1990.B.BFN is in full compliance
with the steps stated abov'e.C.BFN is in full compliance
with the steps stated above.
'
ENCLOSURE 2 LIST OF COMMITMENTS
1.TVA will submit the correct page 1.0.2 to NRC by January 5, 1990.