IR 05000259/1985056
| ML18030A949 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 12/03/1985 |
| From: | Belisle G, Casey Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18030A948 | List: |
| References | |
| 50-259-85-56, 50-260-85-56, 50-296-85-56, NUDOCS 8512230430 | |
| Download: ML18030A949 (18) | |
Text
~P,g AtgI Wp0 Cy A
/p 0~*~4 UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323 Report Nos.:
50-259/85-56, 50-260/85-56, and 50-296/85-56 Licensee:
Tennessee Valley Authority 6N11 B Missionary Ridge Place 1101 Market Street Chattanooga, TN 37402-2801 Docket, Nos.:
50-259, 50-260 and 50-296 License Nos.:
,and DPR-68 Facility Name:
Browns Ferry 1, 2, and
Inspection Conducted:
October 10 - November 1,
1985 Inspector:
j C.
Approved by:
.
~i'i'.
Belisle, ct>ng Section Chief Division of Reactor Safety Date Signed
/2-y D
e Signed SUMMARY Scope:
This routine, unannounced inspection involved 35 inspector-hours on site in the areas of document control, records, and licensee actions on previously identified inspection findings.
Results:
No violations or deviations were identified.
PD51223 430 851210
REPORT DETAILS Persons Contacted Licensee Employees
"B. Blair, Browns Ferry Nuclear Plant (BFNP) Procedures
"J. Carlson, BFNP-Quality Assurance (QA)
"L. Clardy, Quality Surveillance Supervisor
"R. Guthrie, BFNP-Design Services D. Harlow, Management Analysis Company (MAC) Consultant
"W. Hayes, Reactor Engineer (Technicll Specialist)
"M. Holland, Project Manager-Design Services
"M. Johnson, Supervisor, Document Processing and Control (DP&C)
A. Kelly, Yendor Manual Coordinator
- R. Lewis, BFNP-Acting Plant Manager
- S. Machr, BFNP-Planning and Scheduling
- B. McClanahan, Record Officer, OPEC M. McGuire, QA Analyst, Division Quality Assurance (DQA)
- B. Morris, Compliance Supervisor
- W. Pattison, BFNP-Draw.'ng Control R. Rigdon, QA Corrective Action Repor't/Discrepancy Report (CAR/DR)
Coordinator
- R. Smith, BFNP-Regulatory Performance Improvement Program (RPIP)
- J. Swindell, BFNP-Superintendent (Operations and Engineering)
NRC Resident Inspectors C. Patterson, Resident Inspector C. Brooks, Resident Inspector
- Attended exit interview Exit Interview The inspection scope and findings were summarized on November 1,
1985, with those persons indicated in paragraph 1 above.
The inspector described the areas inspected and discussed in detail the inspection findings.
No dissenting comments were received from the licensee.
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 This subject was not addressed in the inspectio.
Document Control (39702)
References:-
(a)
CFR
Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants (b)
CFR 50.54(a)(1),
Conditions of Licenses (c)
TVA-TR75-1A, TVA Topical Report, Revision
(d)
Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation)
(e)
ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants (g)
Technical Specifications, Section
The inspector reviewed the 'icensee document control program required by references (a) through (f) to determine if 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:
Administrative controls had been established for issuance, updating, and recall of outdated drawings.
Master indices were maintained for drawings, manuals, and procedures.
Administrative controls had been established for distributing, updating, and recall of outdated documents.
Administrative controls had been established for distribution of as-built drawings and P&IDs in a timely manner.
Administrative controls had been established to control discrepancies between as-found conditions and as-built drawings.
The documents listed below were reviewed to determine if these criteria had been incorporated into the document control program:
TVA Topical Report, TVA-TR75-1A, Revision 8,
Section 17.2.5, Instructions, Procedures, and Drawings; Section 17.2.6, Document Control NQAM, Part III, Section 1. 1, Document'ontrol, dated March 21, 1985 PMP 1707.034.01, Controlled Documents, dated December 6,
1984 SDSP-2.2, Controlled Documents, dated August 12, 1985 BF-2.5, Drawing Control, dated October 9, 1985
NQAM, Part III, Section 1. 1 QN, Document Control-Mechanism for Requesting Correction of Drawing Discrepancies, dated May 2, 1985 PMP 1707.03.04, Vendor Manual Program, dated December 21, 1984 BF-2. 16, Vendor Manual Program, dated April 19, 1985 SDSP-2.4, Source Document Implementation, dated August 20, 1985 BF-2. 18, Procedures Upgrade Administration, dated September 17, 1985 Interviews were conducted with onsite QA staff members to ascertain their involvement with activities within the functional document control area.
The inspector determined that a
sgecial survey of the document control program was conducted from December 6,
1984, through January 11, 1985.
The findings are documented in Report Number OC-21-QAS-85-38 which identified deficiencies under the following headings:
An integrated plan for maintaining and upgrading site/plant procedures had not been established.
An integrated plan for establishing and maintaining configuration control had not been developed.
The program for maintenance and implementation of Technical Specifications had inadequacies.,
Detailed planning for the implementation of the comprehensive procedure upgrade effort had not been completed-.
However, the planning is in progress.
Browns Ferry Operations had not evaluated or taken action on General Electric (GE)
recommendations.
However, the Engineering Section has evaluated some of the recommendations but lack of manpower is slowing the evaluations.
QA audits and surveys of plant document control activities had been superficial and had not previously identified most of the problems in this report.
There were problems with the micro-filming system (Nuclear Plant Document Control System (NPDCS)
impacting retrievability of some records).
The controls and implementation of source document roll-downs were inadequate.
The control and protection of controlled documents and QA records were inadequat Attachment B to the survey report provided 16 recommendations for corrective actions to address these deficiencies.
Responsibility for implementing each corrective action was subsequently assigned to a
cognizant site organization.
The inspector reviewed the corrective actions for selected recommendations delineated in the following documents:
Memorandum from T.
F. Ziegler, Site Services Manager, to J.
0. Carlson, Quality Assurance Supervisor, Browns Ferry Nuclear Plant, Subject:
Browns Ferry Nuclear Plant (BFN) - BF-CAR-85-001, dated April 1, 1985.
Memorandum from T.
F. Ziegler, Site Services Manager, to J.
0. Carlson, Supervisor, Quality Assurance, BFN, Subject:
Browns Ferry Nuclear Plant (BFN) BF-CAR-85-001, dated April 25, 1985.
A recommendation for establishing instructions that define the as-configured drawing program was contained in the special survey report.
Additional recommendations were made to address the verification of as-configured drawings and the development of a
program for scheduling completion or closing out of partially completed Engineering Change Notices (ECNs).
The inspector conducted interviews with licensee management concerning the status of the Configuration Drawing Control Program and the integration of th',s program into corrective actions for other groups, e.g.,
the procedure upgrade team.
The inspector was informed that schedules and plans had been'eveloped and implemented to support and expedite the Backlog Work Team in connection with verification of.as-configured drawings and completion or closing out of ECNs.
The inspector perceived an absence of integrated project management controls for controlling work functions, i.e.,
identifying activities, scheduling activi.ties, and coordinating the interfaces of the various implementing groups involved in numerous corrective actions relative to document control.
The inspector subsequently determined that a
Configuration Management Program was presently being developed by the licensee.
This program is intended to establish an integrated configuration management program to ensure that the plant configuration is in accordance with TVA policies, regulatory requirements, and applicable code and standards.
By using this management process, the licensee will be able to identify and control plant component configurations along with controlled documents which define plant equipment, physical and functional characteristics, and supporting computer software.
Activities in the document control area required to support the operational readiness review program were discussed with licensee management.
At the exit interview, the inspector stated that additional management attention needs to be directed to the plant/procedural interfaces to ensure that upgraded procedures reflect actual plant configuration and accurate vendor manual technical data.
This will require better scheduling and
. control of the work functions of the procedures upgrade team, the Backlog Work team, and plant sections performing reviews and search of vendor's manual The inspector reviewed program documents which delineate requirements for drawing control.
Standard Practice BF-2.5 implements the requirements of the source document NIZAM, Part III, Section 1. 1, and delineates the administrative controls for as-constructed drawings.
A guality Notice has also been prepared for this section which describes the method for correcting discrepancies between as-constructed drawings and the actual plant configuration.
Based on interviews with licensee management and a
review of program documents, administrative controls applicable to as-constructed drawings appear adequate with the following exception.
Paragraph 5.4 of Standard Practice BF-2.5 addresses the requirements for drawing control in support of system operability/unit startup.
The requirements for ensuring accurate plant/procedural interface information are not addressed.
The activities of the procedures upgrade team (RPIP Long Term Item 3.7)
and the incorporation of actual plant configuration into upgraded procedures need to be addressed in connection with system/unit operational readiness.
Additional inspection of the drawing control implementation program will be required in order to verify conformance with regulatory and code requirements.
The licensee has developed and implemented a Vendor's Manual Program which ensures that the following manuals will have a'Revision Level." controlled status:
Vendor manuals referenced in plant instructions, Vendor manuals to be used for troubleshooting on Critical Structure System and Componen.is (CSSC) equipment, and Manuals to be used for troubleshooting on non-CSSC equipment of management designates.
This program is being implemented in two phases.
Phase one, which is a
licensee commitment, has been completed.
It involved establishing controlled status for 44 General Electric manuals.
The inspector reviewed the Master Vendor Manual List and verified that vendor manuals are being controlled in accordance with Standard Practice BF-2. 16 requirements.
The inspector was informed that phase two of the Vendor Manual Program is now being implemented..
Standard Practice BF-2. 16 states that additional vendor manuals will be incorporated into the program by 1988 based on a
higher priori+ being assigned to General Electric CSSC Vendor manuals.
Other vendor manuals which address CSSC and are referenced in plant procedures,will be incorporated last.
The inspector discussed the search and review of vendor manuals by cognizant plant sections.
These sections are required to establish vendor manual controlled status.
Plant procedure upgrade team interfaces with these reviewing groups were also discussed.
Standard Practice BF-2. 16, paragraph 8. 1, describes the cognizant plant section responsibilities for review of vendor manuals in order to establish controlled status.
This paragraph also defines responsibilities of plant sections for revising plant instructions to ensure compatibility with vendor manuals.
Interfaces of these groups with the plant procedures upgrade team
are not addressed.
Standard Practice BF-2. 18 does not specifically define the interface requirements to ensure that accurate and current vendors technical information are incorporated in upgraded procedures.
This apparent deficiency in not defining plant/procedural interface requirements between the procedure upgrade section and the responsible plant sections is attributable to the lack of an integrated management control for both work functions.
In response to the deficiencies identified in the special survey report, the licensee formulated corrective actions, some of which were made part of the RPIP.
One of these is RPIP Long Term Action Item 3.7.
This item concerns upgrading existing procedures.
The inspector discussed the status of this corrective action with licensee management.
The inspector determined that a
group has been organized onsite and assigned responsibility for this program.
Standard Practice BF-2. 18 has been prepared to provide administrative guidance for implementing the Procedure Upgrade Program (PUP).
Additional procedures, i.e., writers guides, have been developed for use by PUP staff members.
Based on discussions with licensee management, the inspector determined that PUP activities are still in the formative stage.
The inspector reviewed Standard Practice BF-2. 18 and the following document to assess the adequacy of the administrative control of work for systems presently included in the Procedure Upgrade Program.
Memorandum from Robert L.
Lew'is, Acting Plant Manager, BFN, to J.
A. Coffey, Site Director, BFN, Title:
Browns Ferry Nuclear Plant-System Sequence for Upgrade, dated August 13, 1985 The inspector discussed the personnel/procedural interface requirements in connection with the procedure upgrade effort.
The inspector determined that plant operating personnel will review and provide comments on draft procedures.
Additional requirements delineated in Standard Practice BF-2. 18 pertaining to personnel/procedural interface such as procedure trials and personnel training, appears to be adequate..
The special survey also contained the following recommendation:
Upgrade site controls to establish a
systematic approach to ensure upper tier source documents/requirements are tracked, evaluated, and appropriately implemented.
Define scope of upper tier source/documents/requirements.
Part B of the licensee response stated that the end product of the corrective action will be the establishment of a
computer based system in 1988 to ensure implementation of upper tier requirements.
Pursuant to discussions which identified problems in the implementation of this corrective action, the inspector informed licensee management that the regulations do not specify the methodology used to ensure compliance with licensee commitments and regulatory requirements.
However, if such a system is'sed, the data base should accurately reflect licensee commitments to upper tier documents such as NUREGs, Generic Letters, IE Bulletins, and LERs, in addition to conditions of the license and regulatory requirement The inspector stated that the integrity of the data base, of necessity, must be verified to ensure compliance with the accepted gA program.
Three inspector followup items were identified to licensee management in this area.
One involved a revision to BF-2. 16 to more adequately address administrative controls applicable to shop drawings contained in vendor's manual.
The others.involved revisions to BF-2.5 for update of the Appendices listing drawing types, and revision to SDSP-2. 11 for changes in administrative controls applicable to procedure revisions.
In subsequent discussions with regional management, the decision was made to delete these items subject to a reinspection of the document control area.
Within this area, no violations or deviations were identified.
5.
Records (39701)
References:
(a)
CFR 50, Appendix B, (}uality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants (b)
CFR 50.54(a)(1),
Conditions of Licenses (c)
TVA-TR75-1A, TVA Topical Report, Revision
(d)
Regulatory Guide 1.88, Collection,"
Storage, and'-
Maintenance of Nuclear Power Plant equality Assurance Records (e)
ANSI N45.2.9, Requirements for Collection, Storage, and Maintenance of guality-Assurance Records for Nuclear Power Plants (f)
Regulatory Guide 1.33, (}uality Assurance Program Requirements (Operations)
(g)
ANSI N18.7-1976, Administrative Controls and guality Assurance for the Operational Phase of Nuclear Power Plants (h)
Techqical Specification, Section
The inspector=reviewed the licensee records management program required by references (a) through (h) to determine if 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:
Requirements and provisions were established to maintain essential quality assurance records.
Responsibilities were assigned in writing for overall management of the records progra Records storage controls were established in accordance with FSAR commitments.
Records storage facilities were described in writing.
'rovisions had been made to establish the retention periods for all types of records.
Methods had been specified for the disposal of records no longer required.
The following documents were reviewed to determine if these criteria had been incorporated into the records program:
TVA Topical Report, TVA-TR75-1A, Revision 8,
Section 17.2. 17, Quality Assurance Records NQAM, Part III, Section 4. 1, Quality Assurance Records, dated May 15, 1985 SDSP-2.5, Quality Assurance Records, dated October 1,
1985 Special Survey Report No.
DC-21-QAS-85-38 identified inadequacies in the control and protection of QA records.
Pursuant to licensee identified deficiencies, the following corrective actions were being implemented by the Document Processing and Control Unit (DP&CU).
Preparation of DP&CU section instruction letters addressing the administration, records control, procedures processing and control,'nd word processing A site director's standard practice has been prepared to delineate administrative controls applicable to the records management program.
Based on a
review of the upper tier documents and this quality implementing procedure, administrative controls for site records management appear adequate.
The inspector
'conducted a tour of the Lifetime Record Storage Facility (LRSF)
and identified deficiencies which had earlier been identified by licensee management.
These deficiencies include exposed pipes in the LRSF in addition ts inadequate protection for single storage facility records.
Pursuant to discussions with licensee management, the inspector determined that plans have been made to replace the existing LRSF with a
new storage facility.
The licensee anticipates design and construction of this facility to be completed by 1988.
The inspector was informed that in the interim,
Fire Rated Fire Cabinets have been purchased and are being used to provide adequate protection to the following QA records:
Construction records that will be maintained on site as single storage facility records
Work Plans that are presently being used by the Backlog Work Team in drawing configuration control and Engineering Change Notice (ECNs)
closeout Contractor's documents that are being searched and reviewed for technical data in connection with the Vendor's Manual Program Non-fi lmable records which will ultimately be shipped to the Federal Records Center The inspector identified various licensee corrective actions as inspector followup items at the exit interview.
However, subsequent discussions with regional management identified a
need for reinspection of this functional area; consequently, inspector folio@up items were not warranted.
Within this area, no violations or deviations were identified.
6.
Licensee Action on Previously Identified Inspection Findings (92701)
(Open) Inspector Followup Item 259, 260, and 296/84-50-02, Review of Program for Revising Manuals and Instructions.
The above deficiency specifically addressed the accuracy of ":nformation contained in plant instructions referenced by vendor manuals and vice-versa.
The inspector determined, based on interviews with licensee personnel and a
review of Standard Practices BF-2. 16 and BF-2. 18 that existing management controls are deficient for ensuring adequate plant/procedural interface to eliminate such problems.
The cause is attributable to an absence of
- ntegrated management controls for scheduli~g and controlling work functions of the procedure upgrade team and the search and review of vendors technical manual by cognizant plant sections.
The licensee is in the process of establishing an integrated Configuration Management Plan to better control various ongoing work functions and their associated plant/procedural and personnel/procedural interfaces.
Until this configuration management plan is fully developed, this item remains open.
(Open)
Inspector Followup Item 259, 260, and 296/84-50-03, Update and Control of all Vendor's Equipment Manual.
Standard Practice BF-2. 16, paragraph 7.0, delineates the methodology for establishing Revision Level A ( Intial Plant Revision) for vendor manuals.
The methodology involves a search of plant and/or other files to determine the most current information available.
Inconsistencies are resolved by the responsible plant sections, which also perform a technical review to ensure consistency between plant instructions and vendor manuals.
The inspector identified a generic problem in controls applicable to the plant procedural interface relative to the vendor manuals program.
This problem is attributable to an absence of integrated management controls for scheduling and controlling work functions of the procedures upgrade team and the vendor manuals program.
The technical reviews performed by plant II
A
sections to ensure consistency between plant instructions and vendor manuals requires more adequate management controls.
The licensee is developing an integrated Configuration Management Plan to achieve this.
Until this management plan is fully developed, this item remains open.