IR 05000259/1979030
| ML18024B330 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 11/26/1979 |
| From: | Brownlee V, Ruhlman W, Wessman R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18024B327 | List: |
| References | |
| 50-259-79-30, 50-260-79-30, 50-296-79-30, NUDOCS 8002120455 | |
| Download: ML18024B330 (48) | |
Text
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~ItS AKPIy Pp UNITEDSTATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTAST., N.W., SUITE 3'100 ATLANTA,GEORGIA 30303 Report Nos. 50-259/79-30, 50-260/79-30 and 50-296/79-30 Licensee:
Tennessee Valley Authority 500A Chestnut Street Chattanooga, Tennessee 37401 Facility Name:
Browns Ferry 1, 2 and
Docket Nos. 50-259, 50-260 and 50-296 License Nos.
DPR-33, DPR-52 and DPR-68 Date Signed Inspection at Browns Ferry Site near Decatur, Alabama; Authority Offices in Chattanooga, Tennessee and Knoxville, Tennessee inspectors:
<>. A.
W. A. Ruhlman M. C. Ashenden H.
. Jenkins V. Ls rownlee Approved by: TCAvl3 R. H. Wessman, Acting Section Chief, RONS Branch
/r W/7 Date Signed
&I'19 Date Signed iiz4 2 Da e Signed u
<5'ate Signed SUMMARY Inspection on October 9-12 and October 15-17, 1979 Areas Inspected This announced inspection involved 180 inspector-hours on site in the areas of periodic review of QA Program, QA/QC Administration, Organization/Administration, Design Changes, Procurement, Receipt/Handling/Storage, Records, Audits, Maintenance, and Housekeeping/Cleanliness.
Results Of the ten areas inspected, no items of noncompliance or deviations were iden-tified in six areas; seven items of noncompliance were found in four areas (Infraction - Failure to inspect - Paragraph 12.c; Infraction - Failure to con-t duct test - Paragraph 8.b; Infraction - Failure to audit - Paragraph ll.b; Infraction - Failure to review - Paragraph 8.d; Infraction - Failure to complete unreviewed safety question - Paragraph 8.e; Deficiency - Failure to maintain records - Paragraphs 8.c, 10.c and 12.ep'Deficiency - Failure to follow pqocedurps
- Paragraph 12.d).
8 00818
DETAILS 1.
Persons Contacted Licensee Employees
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Abercrombie, Plant Superintendent Alexander> Supervisor, (}uality Planning Brown', Supervisor, Power Stores Unit Chinn, Mechanical Engineer, Division of Nuclear Power Dewease, Assistant Director, Nuclear Power Duncan, Head t}A Engineer, t}A Group, Division of Engineering Design Green, Assistant Manager, Power Operations Harness, Assistant Plant Superintendent I,aw, equality Coordinator Iee, Audit Supervisor McCloud, Nuclear Engineer, Boiling Water Reactors, Office of Power Parker, t}uality Assurance Staff Supervisor Poling, Assistant equality Assurance Manager Rozear, equality Assurance-Iead Engineer Smith, (}uality Assurance Staff Supervisor Thomas, Manager-Power Operations Wallace, Nuclear Operations Coordinator Weeks, Supervisor, MOD/ECN Warehouse Other licensee employees contacted included t}A/(}C personnel both onsite and at the Authority Offices in Chattanooga, craftsmen, technicians, design engineering personnel, operations personnel, and office staff'ersonnel.
NRC Resident Inspector-R. Sullivan-Attended exit interview The following terms are defined as used through this report:
"Accepted gA Program" means TVA Topical t}A Program TVA-TR-75-lA
"OEM" means the Operations guality Assurance Manual
"DPM" means the Division Procedures Manual
"CSSC" means Critical Structures, Systems and Components, the TVA "A" list
"USt}D" means Unreviewed Safety t}uestion Determination
"BF" means Browns Ferry
"TR" means Trouble Reports
-2"
"DED" means Division of Engineering Design
"DEP" means Division of Environmental Planning
"OEDC" means Office of Engineering Design Control
"OP" means Office of Power
"QAAS" means Office of Power Quality Assurance Audit Staff 2.
Exit Interview, The inspection scope and findings were summarized on October 17, 1979, with those persons indicated in Paragraph 1 above.
As each of the items was discussed, the representative of the appropriate TVA office gave the target completion dates that are documented in the discussion of the items given in Paragraphs 5.b through 5.1, 10.d through 10.g, ll.c, 12.f, 14.c and 14.d.
When the apparent item of noncompliance with respect to the records of certifications of receipt inspectors (Paragraph 10.c)
was discussed, the Assistant Plant Manager made several statements which he felt should have eliminated this example from the apparent items of noncompliance.
The inspectors acknowledged his statements, but no change was made in the finding as documented in Paragraph 10.c.
The remainder of the items were discussed by the inspectors with no additional comments other than verifi-cation of target dates on the part of the licensee.
The agreement on specified actions and target dates was achieved without the necessity of extensive dialogue since the TVA had prepared a list of proposed corrective actions, proposed target dates, and the names/organizations responsible for accomplishing the actions; this list was presented to the inspection team at the exit interview.
3.
Licensee Action on Previous Inspection Findings 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'ew unresolved items identified during this inspection are discussed in Paragraph 8.f and 8.g.
5.
Quality Assurance Program Review a ~
Review Conducted The inspectors reviewed the items listed below and items listed as references in other sections of this report to assure continued con-formance to the licensee's accepted Quality Assurance Program.
Mhere
"3-applicable, personnel responsible for implementing changes to proce-dures were interviewed to determine that they understood and were applying the new provisions.
Changes made to the following documents after October 1,
1979 were reviewed:
Standard Practices BF 3.2 dated February 9, 1979, 3.3 dated May 31, 1979, 3.5 dated January 23, 1979, 3.6 dated September 18, 1979, 3.7 dated January 5, 1979, 3.8 dated December 14, 1978, 3.10 dated December 14, 1978; Operations equality, Assurance Manual (OEM) Part II Sections 5.1 dated February 1979, 5.2 dated March 1979, 5.3 dated February 1979, 6.1 dated April 1979, 6.4 dated October 1978; and OEM Part III Sections 2.1 dated February 1979, 2.1A dated November 1978, 2.2 dated April 1979, 2.3 dated October 1978, 3.1 dated April 1979, 3.1 dated April 1979, 4.1 dated June 1979, 5.1 dated June 1979, 5.2 dated June 1979, 6.1 dated January 1979, 7.1 dated August 1979, 8.1 dated January 22, 1979.
No items of noncompliance or deviations were identified during the review.
However, eleven items which will require additional action were identified as set forth in Details 5.b through 5.1 below.
OEM/DPM Procedures Do Not Completely Implement the TVA Topical gA Report During the review of both the 0(}AM and the Division Procedure Manual (DPM) procedures, the inspectors noted cases where these documents had not yet completely implemented the commitments made in the accepted TVA Topical gA Report.
This inadequacy had been previously identified by the licensee and by the NRC in RII Reports for another TVA Facility (Sequoyah reports 50-327/78-39 and 79-41 dated January 19 and August 2, 1979).
In accordance with the commitment for upgrading the OEM and DPM to meet the current revision (Revision 3) of the TVA Topical QA Program associated with item 327/78-39-01 and the previously stated scheduled completion date of August 31, 1980; this item (259/79-30-01; 260/79-30-01; 296/79"30-01) will also be scheduled for completion by August 31, 1980
'A Program for Outage Group During the review of various aspects of Outage functions, cases of parallel but not equivalent procedures were noted (Details 9.c, 10.e, 10.f, 10.g and 12.f).
In some cases, plant procedures were more closely following and implementing the accepted QA Program; in the case of control of rigging, the Outage procedure was more closely following and implementing the accepted QA Program.
TVA Management personnel both at the Brown's Ferry site and at the Power Production offices indicated that that Outage function was to be under the indi-vidual plants'A Program where the Outage activities were being conducted.
TVA management stated that the OEM will be revised to clarify this matter by January 1,
1980.
Until the proposed revision
'f the OEM has been completed, this will be designated item 259/79-30-02, 260/79-30-02 and 296/79-30-0 g
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-4-Tracking System for Plant Quality Assurance Staff Identified Items Standard Practice BF 10.1 describes several'ethods for tracking quality problems.
However, the current
"red folder" and computer
"System 6" method used/under development by and for the Plant Quality Assurance Staff (PQAS) items is not described in writing.
TVA Management stated that plant procedures will be revised as necessary to completely describe this system including the assignment of responsibilities for completion of the items, assignment of target completion dates, descrip-tion of proposed corrective actions, and definition of the methods/criteria for escalating items to higher management when defined actions and/or schedules are not met.
Such revisions are targeted for completion by January 1, 1980.
Until these revisions have been completed and reviewed, this will be designated item 259/79-30-03, 260/79-30-03, and 296/79-30-03.
Definition of Implementation Time for New DPM/OQAM Procedures As discussed in items below and elsewhere in this report, cases were found where the Office of Power had issued new or revised DPM/OQAM procedures which covered requirements in the accepted QA Program and where these requirements had not yet been translated into implementing instructions at the plant level.
The Nuclear Power QA Staff acknowledged that the implementation schedule was not specifically defined in writing.
The licensee stated that the criteria for determining the schedule for plant implementation of new or revised DPM/OQAM procedures and the method for promulgating such schedules would be delineated in writing; the target
~ date for completion of this action was given as December 16, 1979.
Until these actions have been completed and reviewed, this will be designated item 259/79-30-04, 260/79-30-04 and 296/79-30-04.
Standard Practice to Control Chemicals and Reagents Used to Verify ICO Values DPM N79E2 was issued on July 16, 1979.
This procedure described the types of controls which were to be applied to chemicals and reagents used to verify compliance with LCO conditions; the plant had not yet completed the implementing instruction to apply this procedure to plant activities.
Plant management stated that the required Standard Practice was in the process of being written and gave a target date for issuance/implementation of the instruction of November 15, 1979.
Until these controls have been implemented, this will be designated item 259/79-30-05, 260/79-30-05 and 296/79-30-05.
Issuance of Sections III and VI of DPM N79E2 As noted in RII report 50-327/79-41 for another TVA facility,Section III of DPM N79E2 (Laboratory Quality Control Program} and Section VI (Quality Assurance Audits)
were not issued with the July 16, 1979 version.
Since these sections are required to provide a
complete
QA program in this area, the issuance of these sections is being tracked at the Sequoyah unit under item 327/79-41-01.
The licensee stated that these two additional sections would be written and issued and gave a target date of March 15, 1980.
Until these sections have been issued and implemented, this willbe designated item 259/79-30-06, 260/79-30-06 and 296/79-30-06.
Clarification of PQAS Duties with Respect to Review of TRs In Standard Practice BF 7.1, the Plant Quality Assurance Staff (PQAS)
is assigned the responsibility to "review" Trouble Reports.
These reports are used to perform and request maintenance.
While the oral description of the review provided was satisfactory, the current description in BF 7.1 is not adequate since it does not include or specify that a review is conducted both before the work is started (to assure that appropriate QA/QC controls are included)
and after the work is completed (to assure that the required controls were imple-mented).
The licensee stated that the current practices as described to the inspector would be included in the instruction and gave a
target date of January 1,
1980.
Until the required revisions to BF 7.1 have been completed and issued, this will be designated item 259/79-30-07, 260/79-30-07 and 296/79-30-07.
Definitions of "Nonconformance" and "Noncompliance" Procedure BF 1.2 defines the term "nonconformance".
Procedure BF 10.3 uses the term "noncompliance" and, while that term is not defined, examples of "noncompliance" are given in the procedure.
The governing document, the Operational Quality Assurance Manual (OQAM) only defines
"nonconformance" (Part II, Section 5.3, Item 6.0).
As defined in the OQAM, nonconformances which are corrected immediately do not have to be documented and reviewed.
In discussing this matter with both plant and corporate office personnel, understanding of the use and inter-changeability of these two terms was not uniform.
The licensee stated that the term "noncompliance" would be defined and that the condition under which and the criteria for not requiring documentation of non-conformances would be expanded and clarified.
The PQAS group was also working on an expanded program for control of nonconformances and indicated that the current use of noncompliances might be deleted if the required controls were incorporated under the new program.
The licensee gave a target date of November 15, 1979, for clarification and or definition of these two items.
Until this clarification and/or definition process is completed, this will be designated item 259/
79-30-08, 260/79-30-08 and 292/79-30-0 S
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Definition of "Second Party" and "Independent" Verification As with the previous item above, there was not a uniform understanding of the use and interchangeability of these two terms.
As before, only
"independent" verification is defined in the controlling document, the OQAM.
The licensee stated that the criteria for the use of these two types of controls and the required definitions of these terms would be documented; a target date of November 15, 1979, was given.
Until the usage and definitions are defined and reviewed, this will be designated item 259/79-30-09, 260/79-30-09 and 296/79-30-09.
k.
Implementation of ANSI N45.2.4 (IEEE 336-1971)
The licensee's accepted QA Program contains a commitment to follow the requirements of ANSI N45.2.4.
As of this inspection, the requirements of the standard had not been included in the DPM and OQAM nor imple-mented at the plant.
However, this item was detected by the licensee during the conduct of an internal QA audit and is in the process of being corrected.
An assignment memorandum has been written to direct that division procedures be revised to ensure that the requirements of this standard are addressed.
The target date given for completion of this action is February 15, 1980.
Until the requirements of the standard have been addressed, this will be designated item 259/79-30-10, 260/79-30-10 and 296/79-30-10.
l.
Implementation of ANSI N45.2.8
~As in item 5.k above, the licensee's accepted QA Program contains a
commitment to follow the requirements of ANSI N45.2.8.
As of this inspection, the requirements of this standard had not been included in the DPM and OQAM nor implemented at the plant.
Again, this item had been detected by the licensee during the conduct of an internal QA audit and is in the process of being corrected.
An assignment memo-randum has been written to direct that division procedures be revised to ensure that the requirements of this standard are addressed.
The target date given for completion of this action is February 15, 1980.
Until the requirements of the standard have been addressed, this will be designated item 259/79-30-11, 260/79-30-11 and 296/79-30-11.
6.
QA/QC Administration Program The licensee's procedures and instructions were reviewed to verify that:
structures, systems and components to which the program applies (CSSC List)
have been identified; provisions have been made to modify this listing; controls have been established for QA/QC documents to assure that they are reviewed and approved prior to implementation, that changes and modifica-tions are controlled, and that distribution and recall controls exist.
The establishment of responsibilities and methods for overall review of the effectiveness of the QA Program and for providing increased emphasis in areas which are evaluated as
"problem areas" was not. re-reviewed during
I
"7-this inspection.
These aspects of the corporate organization were reviewed and documented in RII Report 50-327/78-39 and 50-327/79-41.
No items of noncompliance or deviations were identified.
7.
Organization and Administration The review of the changes in the licensee's onsite organization were reviewed.
for continued conformance with Technical Specification and other requirements by the Resident Inspector on a continuing basis as documented in his periodic reports; this aspect was not reviewed during this inspection.
In reviewing the activities at the Chattanooga offices, the inspector identified apparent inconsistencies between the current'ractices of the Quality Assurance Manager and the TVA Topical QA Program, and between the accepted Topical QA Program and the Standard Review Plan.
Section 17.2.1.1.2 of the Accepted TVA Topical QA Program states that the Office of Power Quality Assurance Manager reports to the Assistant Manager of Power or his designated alternate; currently, the QA Manager reports to the Manager of Nuclear Safety and Regulation who in turn reports to the Assistant Manager of Power.
The Standard Review Plan (SRP)
Section 17.2.1 lists certain attributes of the position of Quality Assurance Manager, one of which is that he is to be at the same or higher organization level as the highest line manager directly responsible for performing activities affecting quality.
Another is that he is to have responsibility for approval of QA manuals.
The currently accepted TVA Topical QA Program has the Office of Power QA Manager reporting to lower management levels than the Division of Purchasing and the Division of Environ-mental Planning, both of which he audits.
In addition, Table 17.2-1, Item 3 notes that the QA Manager (by means of his staff) has review responsibilities for the procedures within the Operational Quality Assurance Manual; as stated and as practiced he does not have approval authority.
No action is required of the licensee in these matters.
These three issues will be forwarded for the review and disposition of the NRC management.
Until these matters have been reviewed and a determination issued as to their acceptability, this will be designated inspector followup item (259/
79-30-12, 260/79-30-12 and 296/79-30-12).
8.
Design Changes/Modifications References:
a)
BFA 28 dated January 1979 b)
OQAM, Part II, Section 3.2, revised April 12, 1979 c)
EN DES-EP 4.25, Revision 2, dated August 1979 d)
EN DES-EP 4.04, Revision 4, dated November 1978 e)
EN DES-AI 115, Revision 3 (Draft)
f)
EN DES-EP 4.02, Revision 9, dated September 1979
Inspection Items The inspector reviewed the licensee's design changes/modifications program with respect to his implementing procedures and guidance referenced above.
Sixteen (16) design change documents were reviewed which covered the period from July 1977 to March 1979.
The modifica-tions reviewed were:
ECN cwork Plan Name I, 1443 P 0081 9218 7697/7698 Unit 2 Drywell Cooling Fans Alternate power supply for 4-KV unit boards P 0124 L 2020 L 1862 6339 9348 9326 Setpoint Change RPT Modification Replace neutron monitoring L 1823 I, 1967 9323 9349 bypass switches Replace pressure switches with electronic transmitters Recirculate flow transmitters L 1911 L 2051 P 0205 9328/9346 9247 6352 to Rosemont-type Change resistors in HPIC/RCIC turbine speed controllers Modify MSSRV's RPT logic for turbine stop valves I, 1946 9361 Install <" lines on CAO purge header
ECN Work Plan Name L 1496/
I 2064 L 2073 P 0058 9317 7721 6561 Change flow control valve discs Service Water tunnel Replace relays in Core Spray L 1741/
L 1375 L 1990 6558 9315 Replace temporary PCV Remove CRO Hydraulic Return For the items selected, the inspector verified that documentary evidence was available onsite or in the Knoxville corporate offices to support their conformance to design change requirements.
Design inputs, encom-passing codes, standards, regulatory requirements and design bases were verified. Additionally, as-built drawings affected by the selected design changes were reviewed to verify their up-to-date revision status.
As a result of the review, the inspector identified four (4) items of noncompliance and two (2) unresolved items as discussed in Paragraphs 8.b through 8.g, respectively.
b.
Failure to Conduct Required Testing During the review of design changes, the inspector identified that a
preoperational test specified in the Unreviewed Safety Question Deter-mination (USQD) for Engineering Change Notice (ECN)
L 1496 was not accomplished.
Upon replacement of the discs in Flow Control Valves (FCV) 3-23-52, 3-23-34, 2-126 and 3-23-40, the USQD specified as part of the justification that the chattering FCV's "willbe operated over the entire operating range and observed by qualified personnel...".
Contrary to the above, the FCV's for the RHR Service Water system were modified, but there was no evidence that the valves were operated over the entire operating range as required prior to their being placed back in service.
This failure to conduct required testing is an item of noncompliance (259/79-30-13, 260/79-30-13 and 296/79-30-13).
-10-Incomplete Test Records While reviewing the completed work plan for ECW L 1911, the inspector identified that the voltage value necessary to verify proper installation was not annotated on the test documents.
CFR 50, Appendix B, Criterion XVII and the TVA Topic'al Report (TVA-TR75-02, Section 17.2.17) requires that records be maintained to include test records which have the inspector or data recorder, the type of observation, the results and the acceptabi'lity of the test.
ECN L 1911 required the cognizant engineer to test the voltage on terminals'
and 2 of the resistor box, to verify the voltage to be
VDC + 2.5 VDC, to log the actual reading and sign that the accep-tance was conducted.
The cognizant engineer did sign on October 20, 1978, that the test was conducted; but, contrary to the above, the actual voltage reading required to verify acceptable limits was not properly annotated.
The failure to maintain adequate records has been combined with addi-tional failures described in Paragraph 12.e and 10.c to collectively constitute an item of noncompliance (259/79-30-14, 260/79-30-14 and 296/79-30-14).
Unretrievable Design Inputs The inspector reviewed sixteen (16)
design changes for status and adequacy.
He requested both onsite and in the Knoxville corporate office that the design inputs and verifications for the ECN's listed in Paragraph 8.a be provided for review.
These was no evidence produced to indicate that a design analysis had been accomplished.
ANSI N45.2.11-1974, as committed to by the QA Program, requires that appli-cable design inputs, such as design bases, regulatory requirements, codes and standards, shall be identified, documented and their selection reviewed and approved, and that these design analyses shall be suitable for reproduction, filing and retrieving.
Contrary to the above, 16 of 16 safety-related design changes reviewed did not have retrievable design inputs.
This failure to produce evidence that design analyses were performed, reviewed and approved is an item of noncompliance (259/79-30-15, 260/79-30-15 and 296/79-30-15).
Incomplete Unreviewed Safety Question Determination The inspector identified four ECN's (P-0124, P-0081, L 1073 and L 1967)
which were implemented with incomplete determinations as to'hether an unreviewed safety question was involved.
CFR 50.59 and EN DES EP-4.02 require that an Unreviewed Safety Question Determination be
made for all changes to the facility as described in the safety analysis report.
The determination shall be addressed to three specific items which provide the bases for the determination that the change does not involve an Unreviewed Safety Question.
Contrary to the above, Engineering Change Notices P-0124, P-0081, L 2073 and L 1967 were implemented with Unreviewed Safety Question
Determinations which did not completely address all three items necessary to establish that the design change did not involve an Unreviewed Safety Question.
The design bases considered were not based upon actual design analysis and verification, but on concepts which did not provide the bases for the making the required deter-mination.
This failure to complete unreviewed safety question determinations is an item of noncompliance (259/79-30-16, 260/79-30-16 and 296/79-30-16).
Ill-Defined Internal/External Design Interfaces During his inspection of the design change process, the inspector interviewed several individuals responsible for developing the design change information.
The interviewees ranged from supervisors in the onsite
"Outage" group to project section supervisors in the Thermal Plant Engineering Department.
There was no one person familiar with a systematic, documented method in existence to control interfaces within the TVA engineering design organization, or with external organizations.
As required by ANSI N45.2.11-1974, as committed to by the accepted QA Program, internal and external interfaces within the design organi-zations shall be provided using a systematic method to establish lines of communications for transmission of design information.
Responsi-bilities for each organizational unit shall be defined and documented in sufficient detail to cover the preparation, review, approval, distribution and revision of documents involving design interfaces.
Procedures shall be established to control the flow of design information between organization units.
Contrary to the above, a systematic program does not exist to provide lines of communication (1) for squad checks, describing specific duties and responsibilities of the unit design organizations, (2) for amplifying and revising design information affecting USQD's, and (3) to assign other organizations in the "Further Review Request".
Since the inspector did not identify any instances in which proper review or approval were missed due to undefined design interfaces, this item (259/79-30"17, 260/79-30-17 and 296/79-30-17) is unresolved until such time as a systematic method is established and documented to control design interface g.
Inadequate Implementation Control The inspector identified during this review that once the ECN cover-sheet is filled out and corrected drawings are attached, the ECN can be implemented prior to the completion of the design analysis, seismic analysis, or continuation of the USED.
An annotation on one ECN coversheet (I-2051) required a seismic analysis; further investigation revealed that the ECN had been transmitted to the site for implementation prior to TVA's review of the completed seismic analysis.
However, the ECN was not, in fact, implemented due to outage delays until after the analysis received the proper TVA review.
Until a method exists to ensure that DED and OEDC design change packages have been reviewed, approved and transmitted for implementation only after all analyses and approvals are completed, this item (259/79-30-18, 260/79-30-18 and 296/79-30-18) is unresolved.
9.
Procurement References:
a)
DPM N77A14, 14A-Materials, Components, Spare Parts or Services Procurement b)
N-OEM, Part III, Section 2.1-Procurement of Materials, Components and Spare Parts c)
N-OEM, Part III, Section 2.1.A-Procurement of Services d)
Standard Practice-BF16.2-Procurement e)
Modification/Addition Instruction 15 (MAI 15)-Receiving, Inspection, Storage and Withdrawal of ECN Material a
~
Program Review The referenced documents were reviewed with respect to the licensee's accepted equality Assurance Program and ANSI N45.2.13-1976 as committed to by that Program.
The inspection was to verify that procedures for the procurement of safety-related items provide for:
identification of the item or service purchased; identification of test, inspection, acceptance criteria, and any special instructions; requisite technical requirements; access to supplier's plant or records for purposes of audit; documentation necessary to certify the item being purchased; and, requirements for the supplier to provide a gA program consistent with the licensee's accepted Program; and that each applicable procure-ment document specify that provisions of 10 CFR 21 apply.
The licensee's current procedures and practices were reviewed to assure that responsibilities had been assigned and methods had been stipulated for: initiation of procurement documents; review and approval of speci-fications differing from the original design documents; review and approval of documents, including changes thereto; making the designation of quality classification With respect to current suppliers, the licensee's practices and pro-cedures were reviewed to verify that they provided:
methods for
"qualifying" vendors; systems for maintaining an "approved bidders" list; channels of communications for feedback on equipment performance to persons evaluating suppliers; and, methods and schedules for auditing vendors as required.
In any area where in-office review indicated inadequate coverage,. the, area was further investigated during the implementation phase of the inspection.
The final conclusion with respect to acceptability of the area is given in Paragraph 9.b below.
'e Implementation The licensee's program for procurement control was reviewed at Browns Ferry Nuclear Plant with respect to the requirements of the referenced documents.
After verifying that appropriate QA/QC lists and procedures were available to personnel performing the various procurement tasks, the inspector selected fourteen (14) safety-related items that had been received onsite.
The specific items selected were from purchase order numbers 271703, 56-09855, 700139, 584502, 280278, 567858, 639433, 639325 p 272029 p 282079 p 258831 y 27 187 1 p 265 105 GIld 567795 Each item selected was reviewed to verify that procurement documents were prepared in accordance with established controls; they were purchased from "qualified" vendors; that required documents were available onsite to establish conformance to procurement specifica-tions; that receipt inspections and subsequent disposition of items
'was in accordance with established controls; and that item traceability was maintained.
The licensee's approved bidders list was reviewed.
The inspector identified one item within the scope of the inspection criteria described below.
This is documented in paragraph 9.c below.
This matter is further described and combined with material in paragraph 10.g.
Modification/Addition Instruction No.
15 (MAI 15)
During the inspection, the inspectors noted that procurement activities were taking place within two onsite organizational units (Power Stores Unit and the Outage Unit).
The inspectors concluded that Power Stores personnel were working in accordance with Browns Ferry Standard Prac-tices 16.0 series for the control of stores and procurement activities.
Outage Unit personnel were working in accordance with MAI 15.
The inspector concluded that MAI 15 does not clearly delineate what gA program documents control Outage Unit procurement activities, areas of responsibility and the preparation, routing, review and approval of procurement documents.
This matter was also identified in TVA Office of Power gA audit report of Browns Ferry dated July 2, 1979.
TVA management committed to review and clarify this matter by January 1,
198 Until TVA reviews this matter and clarifies what QA Program documents are applicable and assures that those documents incorporate the committed standards'equirements, this is designated item 259/79-30;19, 260/79-30-19 and 296/79-30-19.
10.
Receipt, Storage and Handling of Equipment and Material References:
a)
N-OEM, Part III, Section 212, Receipt Inspection, Handling, and Storage of Materials, Components and Spare Parts b)
Standard Practice-BF16.4-Material, Components and Spare Parts Receipt, Handling, Storage, Issuing, Return to Storeroom and Transfer The referenced documents were reviewed with respect to the licensee's accepted equality Assurance Program and ANSI N45.2.2-1971 as committed to by that Program.
The inspection was to verify that administrative controls had been established for the receipt of safety-related items which required:
shipping damage inspection; receipt inspection; dispositioning; segregation and identification of items; and, the documentation of these activities.
Storage procedures and practices were reviewed to assure that they provided for appropriate storage and appropriate environmental controls, access, identification, covering and preservation of items, periodic inspections of the storage area, maintenance and care of items in storage including controls for items 'with limited shelf life, and assignment of responsibilities for the above activities.
Handling activities were reviewed to determine that programs and procedures had been developed for specification of routine and special handling requirements, controlling hoisting equipment, and inspection of rigging equipment as required by the Program.
In any area where the in-office review indicated inadequate coverage, the area was investigated further during the implementation phase of the inspection.
The final conclusions with respect to the accept-ability of these areas is given in Paragraph 10.b below.
b.,
Implementation The licensee's receipt, storage and handling programs were reviewed at the Browns Ferry Nuclear Plant with respect to the requirements of the referenced documents.
The inspector selected fourteen (14) safety-related items which had been received onsite and verified that receipt inspections, dispositioning, and storage had been accomplished in accordance with the licensee's Program.
The specific items selected
~ ~ Q'
~
"15-were from purchase order numbers 271703, 56-09855, 700139, 584502, 280278, 267858, 639433, 639325, 272029, 282079, 258831, 271871, 265105 and 267?95.
The inspector then inspected the warehouse and verified that required storage and housekeeping controls were in use.
During the tour the inspector selected fourteen (14) items in storage and verified that tagging/marking allowed traceability of the items to purchase, receipt and procurement documents.
The inspector identified one item of noncompliance and four (4) items within the scope of the inspection criteria described above.
These matters are documented in paragraphs 10.c through 10.g below.
C.
Receiving Inspector Training and qualifications Certificates TVA Topical Report Table 17.2-7, Topic J, Regulatory Guide 1.58, August, 1973 provides TVA's alternative to qualifying inspection per-sonnel using levels of capabilities outlined in Section 3 of N45.2.6.
TVA will qualify inspection personnel to internal TVA levels of capa-bility. Appropriate QA groups willprovide certificates for documenting training and qualification for inspections, examination, testing, and other personnel.
Contrary to Table 17.2-7, Topic J, Comment Commitment, TVA has failed to maintain certificates for training and qualification for receiving inspectors.
This matter was identified when the inspectors selected three receiving inspector personnel names from the authorized list of
.receiving inspectors posted in the plant procurement warehouse area and TVA could not produce the subject certificates.
The inspectors held discussions with responsible procurement/warehouse receiving inspector and QA personnel, reviewed training attendance records, and concluded that this matter is primarily a
records (paperwork) problem and has had little effect on quality of inspection and does not compromise safety of the plant.
The failure to maintain records has been combined with similar failures in Paragraphs 8.c and 12.e to collectively constitute an item of noncompliance (259/79-30-14, 260/79-30-14 and 296/79-30-14).
d.
Receiving Inspector Training and qualification Program Clarification During the inspection the inspectors noted that Standard Practice 16.4 did not clearly define the training and qualification program for receiving inspectors.
TVA acknowledged the finding and committed to addressing the matter in the Revised Standard Practice BF 16.4, which the inspectors reviewed in draft form to be approved and issued by November 15, 197 I
This matter is designated as item 259/79-30-21, 260/79-30-21 and 296/79-30-21 until the procedure is issued and reviewed by NRC personnel.
e.
Maintenance of Items in Storage-Power Plant Stores and Outage Warehouse During the inspection, the inspectors found that safety-related items in power plant stores and outage warehouse storage were not under a ~
Maintenance Program as required by Section 6.4-2 of the Committed Standard ANSI N45.2.2-1972 which requires proper maintenance of items during storage to be documented and that written procedures be estab-lished.
The areas identified by the inspectors are listed and discussed below:
Pipe Caps and Plugs:
The inspectors found that
"CSSC" piping in storage did not have caps or covers.
The licensee stated that Standard Practices Procedure BF 16.4 was being revised to address the pipe cap problem.
Rotating Electrical Equipment:
The inspectors found during the insepction that safety-related electrical motors were not under a
maintenance program which would require the insulation to be tested on a scheduled basis, the shafts to be rotated on a periodic basis, and that the space heaters enclosed in electrical equipment be energized.
The licensee again stated that Standard Practice BF 16.4 was being revised and sche'duled to be issued by November 15, 1979, and would address care of Rotating Electrical Equipment.
'The inspectors reviewed the licensee's audit report dated July 2, 1979, and determined that the above listed areas were licensee identi-fied items and that corrective action was being pursued by revising the Procedure BF 16.4.
The inspectors reviewed BF 16.4 draft revision, and determined it addressed the inspector's concerns.
Until the licensee issues the revision of BF 16.4 and implements the program for care of items in storage as required by the accepted gA Program, this item (259/79-30-22, 260/79-30-22, 296/79-30-22) is open.
The licensee committed to a completion date of November 15, 1979, for this item and that the maintenance of items addressed in Browns Ferry Standard Practice 16.4 would be applied to both power plant stores and outage warehouse.
f.
Inspection of Rigging and LiftingDevices The inspectors identified that the licensee had not established a
program for the inspection of lifting devices and rigging used by Maintenance and Power Stores as required by ANSI 45.2.2-1972, Section 7.4.
The inspector determined that the Outage group had addressed the standard requirements of Section 7.4 by the issuance of procedure MAI 12, dated March 197,
"17" The inspectors determined that the licensee had identified the problem discussed above in an audit conducted July 2, 1979.
The licensee committed to having DPM 78S2 and BF 14.25 revised by December 1979 and a program fully implemented by April 1980.
Until the licensee implements a program for the inspection of lifting devices and rigging and it is reviewed by the NRC, this item is designated 259/79-30-23, 260/79-30-23 and 296/79-30-23.
go Modification/Addition QA Requirements During the inspection the inspectors noted that receiving, storage and issue activities were taking place within two onsite organizational units (Power Plant Stores and the outage unit, MOD/ECN warehouse).
The MOD/ECN Warehouse personnel are working in accordance with MAI 15 procedure.
MAI 15 is a general site procedure document and does not clearly delineate what QA program documents control Outage unit ware-house activities, define areas of responsibility, address clearly many of the requirements of ANSI-N45.2.2 such as personnel qualification, maintenance, nonconformances, inspection of equipment and rigging.
TVA Office of Power QA Audit Report of Browns Ferry dated July 2, 1979, identified this same condition.
TVA management committed to review the MOD/ECN warehouse activities and controlling documents and define what QA programs control the Outage Group and revise existing procedures or bring the Outage Group under plant controlling procedures to assure compliance with committed standards.
Until TVA reviews this matter and clarifies what QA program documents
'are applicable and assures that those documents incorporate the com-mitted standards requirements, this is designated item 259/79-30-24, 260/79-30-24 and 296/79-30-24.
This matter is further described and combined with material in Paragraph 9.c.
ll.
Audits References:
a)
OP-QAP-18.1, Audits, Revision 1, dated March 1979 b)
QAAS-QAP-3.1, Quality Audit Program, Revision 4, dated April 1979 a
~
Review Conducted The inspector selected twenty-eight (28)
completed Quality Assurance audits for the period since the last inspection of this area (February 1977 through August 1979) for review.
The audits were reviewed with respect to the requirements of the accepted QA program to assure that they were conducted in accordance with checklists/procedures, by trained personnel not having direct responsibility in the area being audited, with the results documented and reviewed by the managers responsible for the audited area and by those directing the QA program with a frequency as stipulated in the accepted program, and with timely corrective action taken and reporte F
'
-18-
As a result of the review, one (1) item of noncompliance is documented in Paragraph ll.b.
One (1) item which will require additional action was identified as set forth in Paragraph ll.c below.
b.
Failure to Conduct Audit The inspectors identified that the Outage Group had last been audited October 4-6, 1977, and was not scheduled for future audits.
Reference')
requires each element of the Office of Power Quality Program to be audited at, least every two years.
The inspector in discussion with the licensee found that the Outage Group had felt that an audit conducted during a 'plant outage placed a burden upon them and therefore the licensee's management decided not to schedule audits for the Outage Group.
CFR 50, Appendix B, Criterion XVIIIstates in part, "a comprehensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the quality assurance program...".
The accepted Quality Assurance Program, Section 17.2.18 (TVA-TR75-1)
states in part, "Audits shall be conducted in accordance with a formal audit schedule which shall be updated at least every six months.
Each element of the Office of Power Quality Assurance Program, such as design and document control, and each area of plant operations, such as normal operation, inservice inspections, and radiological control, shall be audited at least once every two years...".
This failure to conduct an audit is an item of noncompliance (259/79-30-25, 260/79-30-25 and 296/79"30-25).
c ~
Conflict in Audit Procedures The inspector identified that QAP-18.1 allows the audit team to brief supervision on the results, either by holding an exit interview or by presenting a written summary.
This is in conflict with QAP-3.1 which requires an exit interview to be held on the last day of the audit.
The inspector did not identify any audits that were conducted without an exit interview.
The inspectors informed the licensee that the accepted QA Program's commitment to ANSI N45.2.12 requires a post audit conference (exit) shall be held with management of the audited organization to present audit finding and clarify misunderstandings.
The licensee acknowledged the inspector's comments and committed to a
target date of March 15, 1980, for bringing the procedures into alignment with the accepted QA Program; this item is designated 259/79-30-26, 260/79-30-26, and 296/79-30-26.
12.
Maintenance References:
a)
b)
c)
d)
QQAM - Part II, Section 2.1 BF 14.3, Housekeeping, dated 8/79 BF 12.6, Plant Performance, dated 5/79 BF 14.1, Safety and Hazard Control - Policy, dated 3/79
-19-e)
f)
g)
h)i)
k)
1)
BF 3.1, equality Assurance - Safety-Related Activities Policy, dated 1/79 BF 3.10, Cleaness of Piping Systems,'ated 12/78 BF 13.4, Instructions and Guidelines, dated 7/79 BF 3.2, Independent Verification, dated 2/79 BF 17.5, Control of Measures and Test Equipment, dated 9/78 BF 21.3, Indentification of Corrective Maintenance, dated 9/78 BF 14.25, Clearance Procedure, dated 4/79 BF 6.2, Special Processes and Non-Destructive Testing-Maintenance, dated 11/78 BFA8, Organization and Use of Files and Records, dated 8/78 Program Review The referenced documents were reviewed with respect to the licensee's accepted equality Assurance Program.
The review was concerned with the preventive and corrective maintenance programs, equipment control, cleanliness and housekeeping.
The licensee's practices were reviewed to assure that a preventive maintenance program had been established which included the planned retention of operating equipment and equipment lubrication, and that a
master PM schedule had been developed.
The licensee's corrective maintenance practices were reviewed to verify that:
Written procedures had been established for initiation of routine and emergency maintenance.
Criteria and responsibilities had been established for approval of maintenance requests, for designating activities as safety/
non-safety-related, for designating inspection hold points, for performing required inspections, and for determining required functional testing to be performed following completion of the activities.
Administrative controls required approval of maintenance requests, identification of personnel performing and inspecting the work, identification of the malfunction or failure which necessitated the work, identification of the maintenance performed including any post-maintenance testing, and the materials used had been identified along with any measuring or test instrumentation.
Responsibilities had been assigned for the review of the records generated including an assessment to identify repetitive failures or marginal performance and for transfer of these records as require Work control procedures adequately covered special controls necessary for activities such as welding, cutting or use of ignition sources.
Equipment control practices were reviewed to assure that established controls were in place which specify responsibility and authority for release of equipment or systems for maintenance, checking such releases as necessary to assure compliance with the Technical Specifications, and the indication of equipment status for those systems under repair.
Controls were also reviewed to assure that required testing of redundant components is accomplished prior to return to service, and that indepen-dent verification of both pre-maintenance and post-maintenance lineups is performed.
Cleanliness and housekeeping controls were reviewed to verify that appropriate procedures had been developed and implemented to assure that open systems were not degraded and that cleanliness and house-keeping programs had been implemented.
In any case where the in-office review indicated inadequate coverage, the area was further investigated during the implementation phase of the inspection.
Implementation The licensee's maintenance activities were reviewed at the Browns Ferry Nuclear Station with respect to the requirements of the referenced
~documents.
The inspector selected completed corrective maintenance activities and reviewed these to assure that the required controls had been employed.
The inspector also selected equipment on the preventive maintenance schedule and verified that the required maintenance had been performed as scheduled.
As a result of the above review the inspector identified three (3)
items of noncompliance discussed in Paragraphs 12c, 12d and 12e, and one (1) item, requiring followup as discussed in Paragraph 12f.
Failure to Inspect Maintenance
CFR 50, Appendix B, Criterion X, requires an inspection of activi-ties affecting quality be performed by individuals other than those who performed the activity.
The accepted QA Program, TVA-TP-75-1A, Revision 2, Section 17.2.10 requires inspections to be performed during maintenance, modification or repair activities affecting the quality of CSSC items at TVA plants to verify conformance with applicable requirements.
Contrary to the above the inspector found that Unit, 1 HPCI rupture disc (Trouble Report 135958) had been replaced without any inspection requirements imposed on the activity.
The licensee stated that the Trouble Report had not been reviewed at the morning meeting as required by Procedure BF 7.1, because the trouble
"21-had been reported after the morning meeting had adjourned.
The inspector noted other shops ensure that all Trouble Reports are reviewed and QC inspection hold points designated.
The licensee stated that procedures were being revised which would ensure that all Trouble Reports were reviewed by the Quality Assurance Department.
This failure to specify/conduct inspections on CSSC maintenance activi-ties is an item of noncompliance (259/79-30-27)
and applies only to ~
Unit 1.
d.
Failure to Follow Procedures Technical Specification 6.3.A.5 requires detailed written procedures be prepared, approved and adhered to, for preventive or corrective maintenance operations which could have an effect on the safety of the reactor.
Contrary to the above, the inspector found that procedures were not being followed for Trouble Reports 104531, 85353, 135512, 135958 and 134173 as indicated below:
These were not reviewed as required by Standard Practice BF 7.1.
These were not filed as required by Standard Practice BAF8.
These were not designated as CSSC as required by OQAM, Part III, Section 1, Paragraph 4.2.
'These examples of failure to follow procedures, collectively, constituted an item of noncompliance (259/79-30-28, 260/79-30-28 and 296/79-30-28).
e.
Failure to Maintain Records 10 CFR, Appendix B, Criterion XVII requires sufficient records shall be maintained to include test records with a minimum record of the inspector or data recorder, the type of observation, the results, and the acceptability.
The accepted QA Program (TVA-TR75-02) Section 17.2.17 requires the plant superintendent to provide storage, preserva-tion and safekeeping of the required quality assurance records in accordance with TVA-established requirements and regulatory requirements.
Contrary to the above, the inspector identified that maintenance instruction MMI 14.4.1.3A required by Trouble report 106568, which was issued for the repair of a cracked sensing line to instrument transmitter PT 68-82, could not be located by the licensee.
Additionally, the inspection records of the repairs to the above mentioned line could not be located.
The inspector was able to verify that the inspection had been completed by discussion with the license l
"22-This failure to maintain records has been combined with similar failures noted in Paragraphs 8.c and 10.c to collectively constitute an item of noncompliance (259/79-30-14, 260/79-30-14 and 296/79-30-14).
Inadequate Cleanliness Procedure The inspectors identified that BF 3.10 implements DPM N73E5, "Clean-liness Criteria for Fluid Systems."
However there are differences between DPM N73E5 and ANSI N45.2.1-1973 as committed to in the accepted QA program.
Section 2.2 of the Standard requires cleaning procedures, as well as procedures or work instructions for cleanliness control practices and inspections or tests to verify cleanliness of items to be prepared.
There are no cleaning procedures or instructions for fluid systems outside the Reactor Coolant System boundaries.
This problem was identified in audit report dated July 2, 1979, and a
target date of January 1,
1980, was given for completion of this item (50-259/79-30-29, 50-260/79-30-29 and 50-296/79-30-29),
13.
Housekeeping/Cleanliness References:
a)
DPM N78S2 b)
DPM N74A17 c)
Standard Practice-BF 14.3-Housekeeping a
~
Program Review The referenced documents were reviewed with respect to the licensee's
~Accepted QA Program and ANSI N45.2.3-1976 as committed to in that program.
The inspector identified no items of noncompliance or deviations as a
result of this review.
b.
Implementation Housekeeping activities were reviewed during a tour of spaces con-taining safety-related equipment including Unit 1, 2 and 3 reactor buildings, Unit 3 containment, warehousing and Unit 1, 2 and 3 turbine building.
The inspector identified no items of noncompliance or deviations during this review.
14.
Records a.
Inspection Items The inspector reviewed the licensee's program for control, storage, retention and retrieval of records and documents pertaining to safety-related systems to verify that it was in conformance with Technical Specifications and QA program requirement The inspector also reviewed the licensee's operations and maintenance recordkeeping systems to assure that the information documented was sufficient to permit review by licensee personnel.
No items of noncompliance or deviations were identified during the review.
However, three items which will require additional action were identified as set forth in Paragraphs 14.b through 14.d below.
b.
Designation of Retention of Housekeeping Inspection Records The inspector identified that BF 14.3 did not classify the Housekeeping Inspection results as a
equality Assurance document.
The licensee stated the Standard Practice BF 14.3 would be revised by November 15, 1979, and the retention time would be specified.
Until the proposed revision has been completed, this willbe designated item 259/79-30-30, 260/79-30-30 and 296/79-30-30.
c.
Storage of QA Records in Office Files J
The inspector identified that Maintenance Trouble Reports and Mechanical Maintenance Instructions greater than two years old were filed in the Maintenance Offices.
This item was licensee identified in an audit dated July 2, 1979, and has targeted a date of January 1,
1980, for the hiring of a records group supervisor and conducting a survey of record storage area to identify location and,relative volume of records in storage in the office files.
The inspector notified the licensee future inspection in this area would be scheduled.
This item is
'designated 259/79-30-31, 260/79-30-31 and 296/79-30-31.
d.
Plant Procedures that Implement QA Requirement for Record Storage The inspector found that the plant does not have procedures that implement the committed standard ANSI N45.2.9.
The licensee acknow-ledged the inspector's comments and stated that upon implementation of the record management system the problem willbe corrected expeditiously.
The inspector notified the licensee that future inspection in this area would be scheduled.
I This item is designated 259/79-30-20, 260/79-30-20 and 296/79-30-20.