IR 05000259/1979009
| ML18024A917 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 03/26/1979 |
| From: | Dance H, Price D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18024A915 | List: |
| References | |
| 50-259-79-09, 50-259-79-9, 50-260-79-09, 50-260-79-9, 50-296-79-09, 50-296-79-9, NUDOCS 7907310165 | |
| Download: ML18024A917 (9) | |
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UNITEDSTATES NUCLEAR REGULATORYCOMMISSION
REGION II
101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30303 Report Nos.
50-259/79-09, 50-260/79-09, and 50-296/79-09 Licensee:
Tennessee Valley Authority 500A Chestnut Street, Tower II Chattanooga, Tennessee 37401
, Facility Name:
Browns Ferry Nuclear Plant Docket Nos.
50-259, 50-260, and 50-296 License No DPR-33, DPR-52, DPR-68 Inspection at Browns Ferry Site near Athens, Alabama Inspector:
Approved by:
H. C. Dance, Section Chief, RPS
2C l'toe Date Signed
Date Signed SUMMARY Inspection on March 12-15, 1979 Areas Ins ected This routine unannounced inspection involved 30 inspector-hours onsite in the areas of corporate audit program, annual operating report, and secondary containment leak rate testing.
Results Of the three areas inspected, no apparent items of noncompliance or deviations were identified in two areas; one apparent item of noncompliance was found in one area (Infraction - Failure to follow quality assurance (QA) procedures.
and ANSI N45.2.12).
DETAILS 1.
Persons Contacted Licensee Em lo ees
- H. L. Abercrombie, Assistant Plant Superintendent
- R. Cole, QA Site Representative, Office of Power 0.
W. Kilgore, QA Auditor, Office of Power C. R. McWherter, QA Auditor, Office of Power C, Rozear, QA Engineer
- J. L. Harness,QA Supervisor
- R. G. Metke, Results Section Supervisor NRC Resident Ins ector
- R. F. Sullivan
~Attended exit interview 2.
Exit Interview The inspection scope and findings were summarized on March 15, 1979 with those persons indicated in Paragraph 1 above.
The licensee acknowledged the noncompliance discussed in Paragraph 5.
3.
Licensee Action on Previous Ins ection Findin s Not inspected.
4.
Unresolved Items Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve noncompliance or deviations.
New unresolved items identified during this inspection are discussed in paragraph 7.
5.
Cor rate Audit Pro ram The inspector reviewed documentation and made direct observations of an audit to determine whether the licensee had developed and implemented a
QA Program relating to audits of activities that was in conformance with facility Technical Specification 6.2.C, 10 CFR Part 50, Appendix B, Criterion XVIII, and Licensee Quality Assurance Program Description (Topical Report-TVA-TR75-lA) section 17.1.18 and table 17.2 - The inspection included a review of nineteen Office of Power Quality Program Audits from the period January, 1978 through January, 1979; a review of Quality Assurance Procedures OP-QAP-18.1, Revision 0, Audits, QAAS-QAP-3.1, Revision 3, Quality Program Audits, QAAS-QAP-3.2, Revision 2, Quality Program Audit Planning, and QAAS-QAP-4.1, Revision 0, Quality Assurance Training Program; and observation of a portion of Office of Power Quality Program Audit OPQAA-KX-79-01, Meterological Monitoring Program.
CFR Part 50, Appendix B, Criterion XVIII, states, in part, that a comprehensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the QA program.
The facility Quality Assurance Program Description, in implementing this requirement, states in table 17.2-1, that Quality Assurance and Audit Staff (QAAS) Procedures are the governing documents for the internal activities of the QAAS with respect to the QA responsibilities that it has been assigned.
Procedure QAAS-QAP-3.1, section 6.2.1, states, in part, that the lead auditor shall prepare an audit notification.
Contrary to this, the following audit notifications were prepared by persons other than the lead auditor:
OPQAA-78-2 through 78-9, 78-11, 78-12, 79-1, 78-SP-3, 78-SP-7, and 78-SP-12.
Procedure QAAS-QAP-3.1, section 6.4.1, states, in part, that the audit report shall be initialed by members of the audit team.
Contrary to this, the following audit reports were not initialed by all members of the audit team:
OPQAA-78-8 through 78-12, 79-01, 78-SP-3, 78-SP-9, 78-SP-10, and 78-SP-12.
The facility Quality Assurance Program Description in table 17.2-3, states that the Office of Power procedure which implements
CFR 50, Appendix B, Criterion VIIIis OP-QAP-18.1.
This procedure, revision 0, defines, in section 4.2 a category B audit finding as a noncompliance which is corrected during the audit and for which no followup action will be taken.
Contrary to this, noncompliances which had not been corrected during the audit were designated category B findings in the following reports:
OPQAA-78-10 through 13, and OPQAA-79-1.
It was noted that a recent revision to this procedure, dated March 13, 1979, appears to correct this discrepancy by changing the procedure to reflect the way in which audit findings are being reporte The facility Quality Assurance Program Description, in table 17.1-7.0, requires compliance with ANSI N45.2.12 {Draft 3, Revision 4 - February 1974),
Requirements for Auditing of Quality Assurance Programs for Nuclear Power Plants.
This standard requires, in section 4.5.1, the management of the audited organization or activity to review and investigate any adverse audit findings, including actions to prevent recurrence and to report in writing within thirty days the results of the review and investigation.
Contrary to this, Quality Assurance Procedure QAAS-QAP-3.1, section 6.5.2, requires the audited organization to respond to category A findings only (continuing noncompliances).
Adverse findings not labeled as category A were contained in the following audit reports and not responded to:
OPQAA-78-3, 78-5, 78-6, 78-8 through 12, 79-1, and 78-SP-10.
ANSI N45.2.12 states, in section 4.4, that the audit report shall be written and signed by the audit team leader.
Contrary to this, the following audit reports were not signed by the audit team leader or, in the case of multiple leaders, by the team leader designated for the Browns Ferry site:
OPQAA-78-2, 78-3, 78-5, 78-6, 78-8 through 12, 78-SP-7, 78-SP-10, 78-SP-12 and 78-SP-13.
ANSI N45.2.12, states, in section 4.2.2, that one of the members of the audit team shall be appointed as the leader.
Contrary to this the following audits had two team members appointed as team leaders:
OPQAA-78-6, and 78-8 through 12.
The standard also states, in section 4.3.3, that at the conclusion of the audit, a post-audit conference shall be held with management of the audited organization.
Contrary to this, Quality Assurance Procedure OP-QAP-18.1, section 6.3.1, stated that supervision of the audited organization may be briefed by either an exit interview or written summary.
One audit, OPQAA-78-1, was not followed by a post-audit conference but by a written memorandum from the audit team leader to the plant management.
ANSI N45.2.12 states, in section 4.5.1, that the written response from the audited organization, to the auditor shall include, for corrective action that cannot be completed in thirty days, a
scheduled date for corrective actions and then a followup report stating the corrective action taken and the date corrective action was completed.
Contrary to this, the above information was not included in responses to the following audits:
OPQAA-78-1, 78-6, 78-11, and 78-SP-ANSI N45.2.12, section 4.4.6, states that the audit report shall be issued within thirty days after the audit.
Contrary to this, the following reports exceeded this time period when measured from the date of the exit conference or memorandum at Browns Ferry to the date that the audit was approved:
OPQAA-78-1 (39 days),
78-10 (35 days),
78-11 (36 days),
78-12 (34 days')
and 78-SP-10 (32 days).
This finding of a series of examples of failure to follow QA procedures and ANSI N45.2.12 as committed to by the licensee Quality Assurance Program Description, represents noncompliance with 10 CFR Part 50, Appendix B, Criterion XVIII. (259/79-09-01).
6.
Review of Annual Report A review was made of the annual report, January 1,
1978 to December 31, 1978 Browns Ferry Nuclear Plants Units 1, 2, and 3 to verify that the information reported appeared to be technically adequate and satisfied the reporting requirements of facility Technical Specification 6.7.1,b.
The inspector had no further questions.
7.
Secondary Containment Leak Rate Test As documented in IE Inspection Report No. 50-259/79-5, data on inside temperatures had not been included in the Browns Ferry Nuclear Plant Unit 1 - Secondary Containment Leak Rate Test - 90 Day Report of February 9, 1979.
This data was requested of licensee management but the inspector was conformed that this information had not been recorded and so was unavailable.
The inspector stated that the data omission could be construed as a deficiency but due to the apparent administrative oversight is not deleting the reporting requirement from the administrative section of the Technical Specification and the licensee's commitment to submit a change to the Technical Specifications correcting this situation, this matter will be considered an unresolved item pending submittal and approval of the Technical Specification amendment (259/79-09-02).
The licensee was informed that until a Technical Specification change was approved the data would be required in all Secondary Containment Leak Rate 90 Day Reports,