IR 05000259/1982010
| ML20054K238 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 04/26/1982 |
| From: | Fredrickson P, Upright C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20054K225 | List: |
| References | |
| 50-259-82-10, 50-260-82-10, 50-296-82-10, NUDOCS 8207010324 | |
| Download: ML20054K238 (8) | |
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UNITED STATES
NUCLEAR REGULATORY COMMISSION o
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REGION 11 101 MARIETTA ST., N.W., SulTE 3100 s
ATLANTA, GEORGIA 30303 s
Report Nos. 50-259/82-10, 50-260/82-10, 50-296/82-10 Licensee: Tennessee Valley Authority 500A Chestnut Street Tower II Chattanooga, Tennessee 37401 Facility Name: Browns Ferry Docket Nos. 50-259, 50-260, 50-296 License Nos. OPR-33, DPR-52, OPR-68 Inspection at Browns Ferry site near Decatur, Alabama and the Authority Offices in Chattanoo a, n
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Inspector: \\.
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P. E. Fredrick3on j
Date Signed Approved by:
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C. M. Upright /fec~tijyfi hisf
' Uate 61gned Engineering fr(specgon Branch Division of Engineering ani Technical Programs SUMMARY Inspection on March 22-26 and 29-31,1982 Areas Inspected This routine, unannounced inspection involved 46 inspector-hours on site and at TVA headquarters in the areas of licensee action on previous enforcement matters, QA Program annual review, audits, maintenance, records, procurement, and licensee action on previously identified inspection items.
Results Of the seven areas inspected, no violations or deviations were identified in three areas; four violations were found in four areas (Failure to establish corrective action measures, paragraph 9; Failure to follow an audit procedure, paragraph 6; Failure to implement the QA Program, paragraph 5; Failure to follow Technical Specifications for PORC meeting minutes distribution, paragraph 10.k).
8207010324 820623 PDR ADOCK 05000259
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REPORT DETAILS
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1.
Persons Contacted i
I Licensee Employees
- W. Andrews, Nuclear Power QA
- E. Balch, Document Control i
- R. Boyer, Information Officer
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- T. Chinn, Compliance Staff
- R. Cole, Office of Power QA and Audit Staff
- R. Cook, Power Stores-Modifications A. Crevasse, QA Manager
- G. Jones, Plant Superintendent
- D. McCloud, Nu. lear Power QA
- R. Nixon, Doctment Control
- C. Rozear, Crmpliance Staff
- B. Weeks, Pcwer Stores Other licensee employees contacted included technicians and office personnel.
NRC Resident Inspector
- J. Chase i
- Attended exit interview i
2.
Exit Interview The inspection scope and findings were summarized on March 31, 1982, with
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those persons indicated in paragraph 1 above. The licensee acknowledged the inspection findings.
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3.
Licensee Action on Previous Enforcement Matters (92702)
a.
(Closed) Deviation (259/78-09-01):
Failure To Meet Records Handling
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Requirements. This item was reviewed with respect to the licensee's
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correspondence dated May 24, 1978. The inspector reviewed the records program to verify that records handling now meets the accepted QA i
Program.
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b.
(Closed) Violation (259, 260, 296/81-02-04): Failure to Obtain Prompt Corrective Action.
This item was reviewed with respect to the
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licensee's correspondence dated April 17, 1981. DPM No. N78A13 has l
been revised to comply with the N-00AM.
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c.
(0 pen). Violation (259/81-18-03, 260/81-18-05, 296/81-18-04): Failure To Follow Corrective Action Procedure.
This violation was reviewed with respect to the licensee's correspondence dated September 14, 1981.
This violation contained three subparts with section E-3 being the area dealing with the corrective action procedure. The review of this area is primarily discussed in paragraph 9.
Although a revised corrective action system has been developed as addressed in the response, the corrective action reports (CAR) written prior to the revised system are still not being adequately controlled.
As the "old" CAR's were not specifically addressed in the licensee's response, credit is being given for developing a new system closing section E-3 of this violation and a new violation is identified as discussed in paragraph 9.
4.
Unresolved Items Unresolved items were not identified during this inspection.
5.
QA Program Annual Review (35701)
References:
(a) TVA Topical Report, TVA-TR75-1A, Revision 4 (b) Nuclear Operations Quality Assurance Manual The licensee is now functioning under the acceoted QA Program as described in reference (a). A proposed revision 5 to the program is now under review with the NRC. The inspector reviewed the procedures referenced throughout the report to verify their conformance to the accepted QA Program.
Based on this review, one violation was identified.
Section 17.2.10 of reference (a) requires that personnel who perform material receiving inspections shall be assigned to the Supervisor, Plant Quality Assurance Staff.
Part III, Section 2.2 of reference (b) addresses this QA Program requirement.
At the site implementing level; however, BF 16.4, Material, Components, and Spare Parts Receipt, Handling, Storage, Issuing, Return to Storeroom and Transfer, revised 2/82, eliminates the requirement for QA personnel to perform the item receipt inspection and requires QA only to verify the adequacy of receipt procurement documentation. Stores personnel perform the item receipt inspection.
The inspector did not identify any discrepancies in the receipt inspections conducted by the Stores personnel.
Failure to provide an implementing procedure to carry out this portion of the QA Program is a violation (259, 260, 296/82-10-03).
6.
Audits (40704)
References:
(a) OP-QAP-18.1, Audits, Revision 3 (b) OP-QAP-16.1, Corrective Action, Revision 0 (c) N-0QAM, Part 3, Section 5.1, Auditing of the Quality Assurance Program for TVA Nuclear Plants, revised 10/80 (d) QAAS-QAP-3.1, Quality Audit Program, Revision 8 (e) OP-QAP-2.3, Request for Management Resolution, Revision 0
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Six audits were reviewed to verify that they were conducted by trained personnel not having direct responsibility in the area being audited, that the frequency of audits was in conformance with the Technical Specifications and the QA Program,that appropriate followup actions had been taken and that the audited organization responded to the audit findings. The following is a list of audits selected for review:
AUDIT REPORT DATE OPQAA-BF-81TS-02 4/27/81 OPQAA-BF-81TS-05 7/24/81 OPQAA-BF-8100-04 1/18/82 OPQAA-CH-81TS-02 8/04/81 OPQAA-CH-8100-03 9/02/81 OPQAA-CH-8100-05 12/23/81 Based' on this review,- one violation was identified.
Reference (d),
implementing the accepted QA Program, requires that the audited organization respond to audit findings with the date by which the findings will be corrected. Of the six audits reviewed, three responses did not provide the corrective action completion date for several audit findings. The following audit findings were missing the completion dates:
AUDIT FINDINGS OPQAA-BF-81TS-02 A1, A2, A6 OPQAA-BF-81TS-05
'A2 OPQAA-CH-8100-05 A15, A16 The failure to follow procedure QAAS-QAP-3.1 is a violation (259, 260, 296/82-10-02). Although audit findings were being corrected in sufficient time, the potential exists for audit findings to " drop through the crack" when the anticipated correction date is not provided, thus giving the audit reviewer no completion date at which time escalated corrective action may be necessary.
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7.
Maintenance (62700)
References:
(a) N-0QAM, Plant Maintenance, Part II, Section 2.1, revised 3/82 (b) BF6.1, Performance of Maintenance, revised 2/82 The inspector determined that the NRC resident inspectors periodically observe implementation of the corrective maintenance program. The preven-tive maintenance program was reviewed to verify that schedules were being maintained and that the maintenance activities were being properly conducted.
Based on this review, no violations or deviations were identified.
8.
Records (39701)
References:
(a) N-0QAM, Part III, Section 4.1, Quality Assurance Records, revised 10/81 (b) BF2.10, Plant Records, Management, revised 2/82 (c) Browns Ferry Management Information Manual, revised 2/82 The 1'nspector reviewed the above references to verify that provisions had been made to maintain various types of quality records, in both permanent and temporary storage, and that responsibilities had been assigned to carry out records storage requirements.
Records storage procedures were also reviewed to ensure that they described the storage facilities, the filing systems used, and methods of receipt, handling and disposal of the records.
In order to verify implementation of these procedures, the inspector selected several records to verify indexing, retrievability and storage.
Based on this review, one inspector followup item was identified.
During the review of the records vault, the inspector noted that, although the records were being physically stored properly, an index of records identi fying their location within the vault was not adequate for ready retrievability of the records. This problem exists due to filing records in the vault by receipt date and not by an identifiable number sequence.
Document control personnel are in process of compiling a location index for vault records to be input into the records location computer system. The licensee gave a target date of May 15, 1982, for implementing this computer assisted retrieval system for the vault records.
Implementation of this vault record index and retrieval system is identified as an inspector followup item (259, 260, 296/82-10-05) and will be reviewed during a subsequent inspectio.
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9.
Procurement (38701)
References:
(a) N-00AM, Part III, Section 2.1, Procurement of Material, Components and Spare Parts, revised 3/82 (b) N-0QAM, Part III, Section 2.2, Receipt Inspection, Handling, and Storage of Materials, Components and Spare Parts, revised 3/81 (c) BF16.4, Material, Components and Spare Parts Receipt, Handling, Storage, Issuing, Return to Storeroom and Transfer, revised 2/82 The inspector reviewed the above references to verify that procurement, documents were being satisfactorily generated and reviewed and that material and documents received were in conformance with the TVA procurement documents.
Based on this review, one violation was identified. During the review of the purchase request / requisition QA review process and the material receipt inspection review, the inspector noted that several CARS had been written against both functional areas.
Discussions with the resident inspectors revealed that a violation (259/81-18-03, 260/81-18-05, 296/81-18-04) had been ' identified concerning a failure to follow a corrective action procedure (BF 10.1) and thus inadequately handle seven CARS. The inspector used the response to this violation to review the handling of the procurement identified CARS and to review the corrective action for the violation. A general CAR review identified that, of the seven CARS originally identified, two of them (78-43-0T and 79-41-0T) had not been resolved. This review also identified several additional CARS that had not been satisfactorily resolved. The CARS identified and the respective problem areas are as follows:
CAR PROBLEM 78-43-0T No Followup 79-41-0T No Corrective Action 81-35-0T No Followup 81-66-0T No Corrective Action 81-74-0T No Corrective Action 81-83-0T No Followup The above examples are representative and are not intended to be all inclusive.
A revised corrective action system is described in BF10.3, Corrective Action Program, revised 1/82, which addresses handling new CARS L
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(as described in the response to the initial violation). However, the inspector's review identified negligible effort to organize and expedi-tiously resolve CARS identified pricr to the revised program. This failure to establish measures to ensure prompt.orrective action on the referenced CARS is a violation (259, 260, 296/82-10-01). The revised system has been in place only two months. The implementation of this new system will be reviewed during subsequent inspections.
The inspector was also notified that the Nuclear Power QA staff is working on a generic TVA operating plant corrective action system.
10.
Licensee Action On Previously Identified Inspection Items (92701)
a.
(Closed) Inspector Followup Item (259, 260, 296/79-30-01): Implemen-tation of TVA Topical QA Report. The inspector noted that Revision 4 to the QA Topical Report has been implemented in the N-0QAM and the DPM.
b.
(Closed) Inspector Followup Item (259, 260, 296/79-30-04): Definition of Implementation Time for New DPM/0QAM Procedures. Part III, Section 8.1 of the N-0QAM was revised on August,1981, to identify the required implementation timeframe for these procedures.
c.
(Closed) Inspector Followup Item (259, 260, 296/79-30-06): Issuance of Sections III and IV of DPM N79E2. The inspector verified that the quality assurance requirements have been incorporated into the DPM.
d.
(Closed) Inspector Followup Item (259, 260, 296/79-30-07): Clarifica-tion of PQAS Duties With Respect to Review of TRs. BF7.6, Trouble Report Review Prior to Work, dated December 1981, and N-0QAM, Part II, Section 2.1, Plant Maintenance, revised August 1981, both adequately cover the duties of the QA staff with respect to TR reviews.
e.
(Closed) Inspector Followup Item (259, 260, 296/79-30-10): Implemen-tation of ANSI N45.2.4(IEEE 336-1971) 1972.
The licensee has incorporated requirements of this standard into applicable sections of the QA Program.
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(Closed) Inspector Followup Item (259, 260, 296/79-30-11): Implemen-tation of ANSI N45.2.8. The licensee has incorporated requirements of this standard into applicable sections of the QA Program.
g.
(Closed) Inspector Followup Item (259, 260, 296/79-30-12): Organiza-tion and Administration.
The accepted QA Program commitments as addressed in this item have been implemented.
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(Closed) Inspector Followup Item (259, 260, 296/79-30-26): Conflict in Audit Procedures. Revision 4 to the accepted QA Program permits either a written summary or an audit conference to be conducted at the conclusion to a licensee audit.
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(Closed) Open Item (259, 260, 296/81-02-08): QA Records Storage. The inspector verified that the three-month record storage program has been incorporated into the N-0QAM and has been implemented at the site.
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(Closed) Open Item (259, 260, 296/81-02-11): Procedure Incorporation of Inspector Certification Program.
The centralized QA inspector certification program is well under way with new inspector certifica-tions and recertifications being conducted under the new program.
k.
(Closed) Inspector Followup Item (259, 260, 296/81-21-02):
PORC Meeting Minutes Distribution. The PORC charter as described in the N-0QAM, Part I, Section 6.2 revised 3/80 still disagreed with the Technical Specifications as of March 23, 1982, in that the charter did not require distribution to the Director of Nuclear Power.
The distribution of the PORC minutes has continued to follow the charter with no change to either the charter to agree with the Technical Specifications or to the Technical Specifications to agree with the charter.
This continued failure to distribute the PORC minutes in accordance with the Technical Specifications is a violation (259, 260, 296/82-10-04). Prior to departing the site, the inspector noted that the PORC charter had been revised on March 25, 1982, and that minutes were being sent to the Director of Nuclear Power.
The Division of Nuclear Power is establishing a computerized tracking system for both NRC and Office of Power audit findings.
Successful establishment of such a program would control those items that could be inadvertently forgotten and not implemented solely due to communication problems and not lack of effort.
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