IR 05000259/1985038
| ML18029A814 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry, Sequoyah, 05000000 |
| Issue date: | 08/12/1985 |
| From: | Belisle G, Julian C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18029A813 | List: |
| References | |
| 50-259-85-38, 50-260-85-38, 50-296-85-38, 50-327-85-28, 50-328-85-27, NUDOCS 8508290306 | |
| Download: ML18029A814 (18) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323 Report Nos.:
50-259/85-38, 50-260/85-38, 50-296/85-38, 50-327/85-28 and 50-328/85-27 Licensee:
Tennessee Valley Authority 500A Chestnut Street Chattanooga, TN 37401 Docket Nos.:
50-259, 50-260, 50-296, License Nos.:
DPR-33, DPR-52, DPR-68 50-327 and 50-328 DPR-77 and DPR-79 Facilities Name:
Browns Ferry and Seequo$ ah Inspection Conducted:
July 15-19, 1985 roepeotor:
<~ ( /
y'.
A. Belisl'e
'd Da'te igned Accompanying Personnel:
L.
R. Moore, Region II J.
H. Moorman, III, Region II
/
Approved by:
C. A. Julian, ting Chief Operations Branch Division of Reactor Safety ate igned SUMMARY Scope:
This routine, unannounced inspection involved 102 inspector-hours on site in the areas of licensee action on previous enforcement matters, QA/QC administration, audit program, and licensee action on previously identified inspection findings.
Results:
No violations or deviations were identified.
8~P8P90306 8508001S25 PDR ADOCK 0500
REPORT DETAILS Persons Contacted Licensee Employees
"H. Abercrombie, Site Director, Sequoyah Nuclear Plant C. Bosley, QA Evaluator R. Bruce, Supervisor, Planning, Scheduling and Support
"C. Chmielewski, Nuclear Support Staff
- W. Cottle, Assistant Manager, Power and Engineering (Nuclear)
"J. Darling, Assistant Manager, Power and Engineering (Nuclear)
"J. Hufham, Manager, Licensing and Risk Protection R. Jarvis, QA Evaluator
"G. Killian, Chief, Quality Audit Branch
"D. Lambert, Licensing Branch
"J.
Law, Chief, Quality Systems Branch L. McCloud, Plant Evaluator Group Head, Watts Bar
"R. Mullin, Director, Division of Quality Assurance (DQA)
R.
Newby, QA Evaluator L. Northard, QA Specialist
"R. Parker, Assistant Director, Divisi'on of Quality Assurance
"H. Parris, Manager, Power and Engineering (Nuclear)
"W. Poling, Nuclear Central Office (NCO)
"F. Szczepanski, Nuclear Safety Staff C. White, QA Specialist
"K. Whitt, Nuclear Safety Review Staff C. Whittemore, QA Evaluator
~Attended exit interview Exit Interview The inspection scope and findings were summarized on July 19, 1985, with those persons indicated in paragraph 1 above.
The inspector desc'ribed the areas inspected and discussed in detail the inspection findings.
The licensee did not identify as proprietary any of the materials provided to or reviewed-by the inspector during this inspection.
Licensee Action on Previous Enforcement Matters (Open)
Severity Level IV Violation (259, 260, 296/85-03-01; 327, 328/85-04-01):
Failure to Promptly Correct Conditions Adverse to Quality.
The licensee response, dated May 21, 1985, was considered acceptable by Region II.
The inspector reviewed the following documents:
il
ESCALATION MEETING -
DEVIATIONS JA-8100-06-A05, CH-8200-12-A05, BF-83TS" 09-A01, BF-82SP-03-A13, BF-83TS-10-03, CH-8200-12-A06, JA-8100-06-A04, and JA-8100-06-AOl dated January 31, 1985 SCHEDULED CORRECTIVE ACTION MEETING - AUDIT DEVIATIONS JA-8100-06-A05, CH-8200" 12-A05, BF-83TS-09-A01, BF-82SP-03-A13, BF-83TS-10-03, CH-8200" 12-A06, BF-8300-01-A01, BF-83TS-07-A04, BF-8300-03-A01, BF-8300"01-A04, JA-8100-06-A04, BF-8400-03-01, BF-8400-04-01 - BFN CARs 78-43,82-001, 82-012,82-147, 81"105, 82"042,82-199, 81-400,81-035, 83-129 dated Apri 1 12, 1985, L17 850412 800 Memo from R. Mullin to those listed dated March 14, 1985, L17850314 801, SUBJECT:
QUALITY BULLETIN 85-02 Memo from H. Abercrombie to R.. Mullin dated April 30, 1985, S53 850424 864, SUBJECT:
SEQUOYAH NUCLEAR PLANT (SQN) - QUALITY BULLETIN 85-01, REVISION 0, COMMITMENT VERIFICATION AND QUALITY BULLETIN 85-02 Memo from J.
Coffey to those listed dated April 18, 1985, R32 850417 856, SUBJECT:
QUALITY BULLETIN 85-02-CORRECTIVE ACTION QUARTERLY CORRECTIVE ACTION REVIEW -
MEETING MINUTES "
WBN/DQA May 31, 1985 QUARTERLY DQA QUALITY PROBLEM STATUS MEETING MINUTES, June 17, 1985, L17 850627 801 SEQUOYAH QUARTERLY CORRECTIVE ACTION-MEETING MINUTES, June 18, 1985 QUARTERLY CORRECTIVE ACTION MEETING - BLN/DQA, June 19, 1985 QUARTERLY CORRECTIVE ACTION REVIEW MEETING BETWEEN DQA/BFN ON June 26, 1985 QUARTERLY CORRECTIVE ACTION MEETING -
NUC SVSC/DQA - July 3; 1985 Agenda, Quarterly QA and Corrective Action Meeting, NUC PR Management and DQA, July 18, 1985 DQAI-312 Quality Audit Program - Quality Audit Branch, Revision I DQAI-313 Escalation of Responsibility for Deviation Corrective Action, Revision
Corrective action resolution within the Division of Quality Assurance (DQA)
and other organizations has shown improvement.
The documents listed provide evidence that DQA is actively seeking resolution for previously identified audit deficiencies and Corrective Action Requests (CAR) generated by site personnel.
Audited organizations are responding accordingly.
DQAI-313
r~
provides definitive guidance for deviation escalation to the Director DQA and Site Director level; however, it does not provide definitive guidance for 'eviation escalation to the Manager, Nuclear Power level.
DQA management made a presentation at the exit interview on proposed changes to DQAI-313 that would delineate when manager intervention was required for deficiency resolution.
The inspector was informed, however, that two deficiencies (JA 8100-06-A01 and BF8400-04-01)
were to be addressed at the manager level during a
July 18, 1985, meeting.
Responses to audit deficiencies has improved although several examples were identified during the audit program review (discussed in paragraph 5) where responses were late.
These examples appear to be anomalies in that for the month of June late responses were not identified.
Additional inspection in this area will be required to verify effective audit deficiency resolution and prompt audit finding responses.
4.
QA/QC Administration (35751)
Reference:
CFR 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants The inspector reviewed the licensee QA/QC administration program required by the reference to verify that activities were conducted in accordance with regulatory requirements.
The following criteria were used during this review to determine the overall acceptability of the established program:
Licensee QA program documents identified those structures, systems, components, documents, and activities to which the QA program applies.
Procedures and responsibilities had been established for making changes to these documents.
Administrative controls had been established for QA/QC department procedure review, inspection, and auditing.
These controls assured review and approval prior to implementation, provided methods to make changes and revisions, and established methods for distribution and obsolete procedure recall.
Responsibilities had been established to assure QA program review for overall effectiveness.
Administrative controls had been established to modify the QA program based on identified problem areas.
The documents listed below were reviewed to verify that these criteria had been incorporated into the licensee's administrative procedures for QA/QC administrative activitie D A Procedures DQAI-501 Functional/Administrative Supervision Interface at Plant Sites for Quality Assurance, February 5,
1985 NQAM Part 5, Section 2.7 NQAM Part 2, Section 5.4 Q List, December 31, 1984 Quality Assurance Surveys, August 17, 1984 NQAM Part 1, Section 3.1 Preparation, Maintenance, and Imple-mentation of NQAM, June 25, 1985 NQAM Part 1, Section 2.1 Organi zati on for Qual ity Assurance, December 31, 1984 Browns Ferr Procedures Standard Practice 1. 11 Standard Practice 2.3 Standard Practice 3.2 CSSC and non-CSSC Listing, March 21, 1984 Review, Approval, Use, and Change of Instructions, April 10, 1985 QC Inspection Program, October 23, 1984 Se uo ah Procedures Administrative Instruc-tion 39 CSSC List, March 19, 1984 Standard Practice
Control of Materials and Parts and Services, May 7, 1985 Arrival Assessment of TVA Quality Assurance Program for 1984, LOO 840912 640, September 6,
1984 QSB Response to Programmatic Problems Identified in 1984 Arrival Assessment of QA program, L16 841115 909 The inspector= reviewed auditing activities as discussed in paragraph 5.
Corrective action was reviewed as part of auditing activities.
An overall review of QA activities was also conducted as part of auditing activities.
Within this area, no violations or deviations were identified.
5.
Audits (40702, 40704)
References:
(a)
CFR 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants, and Fuel Reprocessing Plants
(b)
Regulatory Guide 1. 144, Auditing of Quality Assurance Programs for Nuclear Power Plants (c)
ANSI N45.2. 12-1977, Requirements for Auditing for Quality Assurance Programs for Nuclear Power Plants (d)
Regulatory Guide 1. 146, Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plant (e)
ANSI N45.2.23-1978, Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plant (f)
Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation)
(g)
ANSI N18.7-1976, Administrative Control and Quality Assurance for the Operational Phase of Nuclear Power Plants (h)
Technical Specifications, Section
The inspector reviewed the licensee audit program required by references (a)
through (h) to verify that the program had been established in accordance with regulatory requirements, industry guides and standards, and Technical Specifications.
The following criteria were used during this review to determine the overall acceptability of the established program:
The audit program scope was defined consistent with Technical Specifications and QA program requirements.
Responsibilities were assigned in writing for overall management of the audit program.
Methods were defined for taking corrective action on deficiencies identified during audits.
The audited organization was required to respond in writing to audit findings:
Oistribution requirements were defined for audit reports and corrective action responses.
Checklists were required to be used in performing audits.
Measures were established to assure that QA audit personnel met minimum education, experience, and qualification requirements for the audited activity.
The documents listed-below were reviewed to verify that these criteria had been incorporated into the auditing progra '
TVA-TR75-1A DQAI "312 DQAI "313 DQAI-314 DQAI-317 Qual ity Assurance Program De seri pti on for Design, Construction, and Operation of TVA Nuclear Power Plants, Revision
Quality Audit Program Quality Audit Branch Revision 1 (Supersedes DQAI's 301, 306, 307, 308, and 309)
Escalation of Responsibility for Deviation Corrective Action, Revision
Responding to and Correction of Deficiencies, Revision 0 (Supersedes DQAI-311)
Auditor Training and Certification for DQA Personnel, Revision
The inspector reviewed audits conducted at Browns Ferry, Sequoyah, and corporate activities.
The following are the specific audits reviewed:
Browns Ferr Audits Audit BF-8500" 01 Area Fuel Handling and Special Nuclear Material Issue Date January 18, 1985 BF-8500-02 QBF"A-85-0003 Inservice Inspection (Pump and Valve testing and Pressure testing)
January 4,
1985 Correction of Deficiencies January 16, 1985 QBF-A-85-0004 PBF-A-85-0005 QBF-A-85-0006 QBF-A-85%007 QBF-A-85-0008 QBF"A-85"0009 Operating Status Procurement/Storage Activities Test Control Electrical and Instrument Maintenance Inspection, Housekeeping, and Correction of Deficiencies Compliance with Technical Specifications April 5, 1985 March 22, 1985 April 16, 1985 April 11, 1985 April 1, 1985 July 3, 1985
Audit QBF-A-85-0010 QBF-A-85-0011 QBF-A-85-0013 Se uo ah Audits Audit QSQ-A-85-0002 Area Plant Staff Performance, Training, and Qualification Plant Modification and Design, Drawing Control Facility Fire Protection System Area Temporary Alterations at SQN not in accordance with Site Instructions Issue Date May 29, 1985 July 3, 1985 May 29, 1985 Issue Date February 28, 1985 SQ-8500-01 QSQ-A-85"0003 QSQ-A-85-0004 Test Control Plant Staff -Performance, Training and Qualification March 22, 1985 April 5, 1985 Corrections of Deficiencies January 16, 1985 PSQ"A-85-0005 QSQ"A-85-0006 QSQ-A-85-0007 QSQ-A-85-0008 Procurement/Storage Activities Compliance with Plant Technical Specifications Plant Modifications and Design Control Fuel Handling and Operating Instructions April 25, 1985 May 3, 1985 May 15, 1985 June 27, 1985 Cor orate Activities Audit CH-8500-05 Area Issue Date Fuel Procurement Program December 21, 1984 and QA Program Implementation CH"8500-04 Env i ronmenta 1 Quali ficat i on of Safety Related Equipment January 18, 1985 The inspector reviewed these audits for timeliness of issuance after completion of the audit and for timeliness of site responses to audit deviations.
Even though some site.responses to audits conducted during the
()
first five months of 1985 were-late, a general trend of improvement in this area was noted.
Apparent increased management attention in this area has resulted in no late site responses to audit findings during the month of June.
Training records of seven auditors were reviewed to verify compliance with requirements.
All records reviewed indicated that the auditors had the necessary experience and training.
During a
review of DALAI-317, the inspector identified that this instruction did not require an auditor in training to have participated in a nuclear quality assurance audit within the year prior to his qualification in accordance with reference (e).
This was brought to the attention of DgA personnel and corrected immediately.
The qualifications records reviewed indicated that this requirement had not been violated.
Audit schedules for 1983, 1984, 1985, and 1986 were reviewed to verify that audits were scheduled and had been performed according to commitments.
Within this area, no violations or deviations were identified.
6.
Licensee Action,on Previously Identified Inspection Findings (Open)
Inspector Followup Item (259,260,296/85-03-02 and 327,328/85-04-02):
Division of equality Assurance Instruction Discontinuities TVA has completely rewritten DALAI-12.
This review corrected two of the three previously identified discontinuities between it and TVA-TR75-1A.
However, DALAI-12 still requires that a post-audit (exit) conference with the audited organization management be held at the close of every audit.
Table 17.D.3 of TVA-TR75-lA takes exception to holding a post-audit conference at the close of every audit.
Discussions with DgA management identified that TVA desires to conduct a post-audit conference at the close of every audit and that the next revision to TVA-TR75-1A will reflect this.
Until this revision to TVA-TR75-1A is approved, this item will remain ope