IR 05000259/1987024
| ML20236B529 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 07/14/1987 |
| From: | Belisle A, Moore R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20236B499 | List: |
| References | |
| 50-259-87-24, 50-260-87-24, 50-296-87-24, NUDOCS 8707290138 | |
| Download: ML20236B529 (9) | |
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49 REou UfdlTED STATES
- o NUCLEAR REGULATORY COMMISSION
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REGION 11 J 'i,
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101 M ARIETTA STREET,N.W.
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ATLANTA, GEORGI A 30323 s...../
Report Nos.:
50-259/87-24, 50-260/87-24, and 50-296/87-24 Licensee: Tennessee Valley Authority GN 38A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Docket Nos.:
50-259, 50-260 and 50-296 License Nos.:
DPR-33, DPR-52, and DPR-68 Facility Name:
Browns Ferry 1, 2, and 3 l
Inspection Conducted: June 15-19, 1987 Inspectors:
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/d7 A. Bel >ifle Ud -
04te'51gned i
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R. Moore La/
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Ddte'51gned-Accompanying Personne :,K. Jury Approyed by:
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~///9'/[7 A. BeTi sie, ~CM6f Ddte ' 51gried Quality Assurance Programs Section Division of Reactor Safety
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SUMMARY Scope:
This routine, announced inspection was conducted in the areas of licensee actions on previous enforcement matters, corrective actions, quality assurance personnel qualifications, resolution of previous items, and licensee actions on previously identified inspection findings.
Results:
No violations or deviations were identified.
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8707290138 870721 PDR ADDCK 05000259 G
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l REPORT DETAILS l
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Persons Contacted j
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Licensee Employees
- L. Clardy, Quality Surveillance Supervisor R. Cole, Trend Analysis Coordinator
- D. Evans, Conditions Adverse to Quality (CAQ) Coordinator G. Hall, Project Manager, Employee Concerns Program
- L. Jones, Quality Assurance (QA) Supervisor J. Krieg, Engineering Associate, Division of Nuclear Engineering (DNE)
J. Law, Chief, Quality Systems Branch (QSB)
L. Lemon, Electrical Engineer, DNE
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- N. McFall, Compliance Licensing D. Miller, Quality Surveillance Supervisor l
R. Parsons, Lead Engineer, DNE
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- H. Pomrehn, Browns Ferry (BFN) Site Director i
V. Smith, Electrical Engineer, DNE
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- P. Speidel, Project Engineer, DNE M. Thatcher, Quality Assurance Evaluator
- G. Turner, Site Qu'ality Manager J. Walker, Quality Engineering Supervisor M. Whited, Electrical Engineer, DNE F. Wiederecht, Quality Assurance Analyst K. Wright, Materials Receipt and Issue Supervisor I
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l Other licensee employees ' contacted included engineers, and office l
personnel.
NRC Resident Inspectors
- C. Brooks, Resident Inspector i
- G. Paulk, Senior Resident Inspector
- Attended exit interview l
2.
Exit Interview The inspection scope and findings were summarized on June 19, 1987, with i
those persons indicated in paragraph 1 above. The inspector described the areas inspected. No dissenting comments were received from the licensee.
2 The licensee did not identify as proprietary any of the materials.provided to or reviewed by the inspectors during this inspection.
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Licensee Action on Previous Enforcement Matters j
(Closed) Severity Level V violation 259,260,296/86-08-01:
Failure to Protect Items in Storage in Accordance with ANSI Standards and Licensee a
Procedures.
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The licensee's response dated May 12, 1986, was considered acceptable by
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Region II. The inspector reviewed an Interim Material Storage Maintenance i
program dated April 30, 1986.
This program specified controls for the
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Warehouse 12 complex and main storeroom during consolidation and relocation. This program became effective on the date specified and' was in use until a permanent preventive maintenance program was developed.
The inspector reviewed Site Director Standard Practice (SDSP) 16.3, Preventive Maintenance of Stored Items dated April 17, 1987.
This procedure establishes methods and assigns responsibilities to effectively perform preventive maintenance on materials, components, and spare parts while in storage at the Power Stores facilities.
The inspector also reviewed licensee inspection results that verified temperature, humidity, and storage requirements.
This inspection was conducted April 23, 1987.
The inspector toured various Kelly Buildings, the Environmental Qualification warehouses, the laydown area and warehouses 3, 3A, 4, 4A, 5, 5A, 6, 6A, 7, 8, 9,10, and 10A. No deficiencies were identified during this tour.
The inspector concluded that the licensee had determined the full extent of the violation, taken action to correct current conditions, and developed corrective actions needed to preclude recurrence of similar problems.
Corrective actions stated in the licensee's response have been implemented.
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Unresolved Items Unresolved items were not identified during this inspection.
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Corrective Action (92720)
The following procedures were reviewed and evalcated during this inspection:
Nuclear Quality Assurance Manual (NQAM), Part I, Section 2.16,
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Corrective Action, Revision 3
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Site Director Standard Practice (SDSP)-3.7, Corrective Action, f
Revision 1
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Nuclear Engineering Procedure (NEP)-9.1, Corrective Action,
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Revision 1 s
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The inspectors reviewed the licensee's ' corrective action program established in procedures (a) through (c) to assess implementation and effectiveness of the licensee's CAQ program.
The CAQ program was implemented at Browns Ferry (BFN) on March 30, 1987. As of. June 15, 1987, 348 Condition Adverse to Quality Reports (CAQRs) have been initiated.and 114 have been closed.
The procedures reviewed appeared to be adequately detailed to permit the CAQ program to achieve its objective of-identifying, tracki ng, and resolving conditions adverse to. quality.
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Responsibilities for specified activities and reporting form completion-were clearly delineated.
General site training to the CAQ program primarily addressed site implementing procedures and reporting form utilization.
All individuals interviewed had received this one hour training and appeared to be knowledgeable of general procedural requirements; more extensive training was provided to CAQR management reviewers.
This management training established standard guidelines far determining if an initiator had identified a valid CAQ.
The management reviewer or review team apparently functions as a filter to the CAQ program therefore reducing the number. of ' non problems being addressed l
through the CAQ reporting process.
The inspectors reviewed CAQ program implementation with respect to volume, time frames, and completion trends. The rate at which CAQRs were entered into the system exceeded the resolution rate.
This is partially due to the plant being in a problem identification mode as well as program implementation deficiencies which have resulted in processing delays.
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Time extensions were granted on completion due dates, and only after QA concurs with the proposed justification.
No extensior,s are granted for the processing deadlines delineated in the procedures.
On June 8-12, 1987, QA site personnel performed a surveillance (QBF-S-87-0205) on closed CAQRs to provide an indication of CAQ program.implementat<on effectiveness. This surveillance identified problems involving inadequate or incomplete disposition, root cause and/or recurrence control
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l inadequacies, prompt initiation and review time limit inadequacies, generic review inadequacies, review for significance and/or deportability
inadequacies, and various administrative inadequacies.
The inspector
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interviewed personnel who performed the surveillance and was informed that this surveillance constituted review of all CAQRs (88) that were closed as of the surveillance's initiation.
Based on the surveillance findings, CAQRs BFP 0357 to 0385 were being generated to address the inadequacies.
The inspector reviewed randomly selected CAQRs and identified that the corrective action completion dates for CAQRs-12, 13, 14, 53, 67, 68, 74, 198, and 222 were event oriented (i.e., prior to unit startup) as opposed to date oriented, A potential problem exists in this arcat in that individuals responsible for corrective action are not necessarily responsible for urit startup.
Consequently, thq event dates may slip,
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resulting in a percentage of CAQRs not being closed in a timely manner.
The inspectors discussed this potential problem with cognizant plant management personne _ _ _ _ _ _ _ _ _ ____ __
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4 Management attention to the CAQ program was evident via the close monitoring of this system by QA (including a periodic update to management of system performance), management statements of the high priority placed on CAQRs, performance of the quality surveillance described earlier, and the emphasis that was placed on training to the new program.
The inspector met with the Chief, QSB and was given copies of CAQ program implementation reviews performed by QSB personnel at Sequoyah and BFN.
The report for BFN acknowledged that CAQ program implementation problems existed, but overall there was a positive attitude toward corrective action and a spirit of teamwork was noted.
The inspectors reviewed significant CAQRs (CAQRs with an elevated priority associated with higher relationship to plant safety) issued by QA for inadequate performance by some plant departments in processing CAQRs in a timely manner.
The QA Department appeared to be maintaining a close surveillance on CAQ activities in an effort to direct the program toward greater efficiency. The QA Department also provided a monthly report to management which provides the gross number of CAQRs, the number opened and closed, average age, and the number deliquent.
This report includes a breakdown of CAQR by responsible organization which provides management a quick method of identifying group performance for the month.
The trend analysis program, e.ithough in its infancy 3 has already been the catalyst for actions taken by several departments.
The trending program appeared to be a useful management tool that was being utilized.
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emphasis on the CAQ program at BFN was also reflected in a memorandum from the Plant Manager to plant organization managers dated June 15, 1987, which stated that managers were to give resolution of CAQs a priority equal or greater than normal production work. This memorandum reiterated a similar statement by the Manager of Nuclear Porer to TVA plant sites dated April 15, 1987.
The Division of Nuclear Engineering (DNE) was identified via a significant CAQR, BFF-870068, as experiencing the largest number of delinquent CAQRs.
This problem was almost simultaneously identified through the QA trending program (as the number of delinquent CAQRs in DNE was progressively increasing) as well as internally by DNE. The inspectors reviewed DNE's CAQ program and interviewed various DNE line personnel and management to evaluate DNE's recognition and proposed resolution of this negative performance indicator. DNE was initiating a corrective acti n plan, the major thrust of which was to establish a 32 member, cross-discipline group dedicated to CAQR evalution and resolution.
This would potentially
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alleviate the conflicting priorities with production work and provide a
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multidisciplined core group knowledgeable of the CAQ process which sheuld lead to more timely CAQR resolution.
It was expressed by DNE management that the negative trends identified with DNE's CAQ program would begin to reverse in a very short time frame from the origination of this group in June.
Additionally, a revision was in progress for the engineering corrective action procedure, NEP-9.1. The effectiveness of these actions will be verified in future inspections of the CAQ program.
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The inspectors interviewed DNE line personnel to assess their attitude, training, and ability to utilize the CAQ system.
Production line personnel initiate a very high percentage (approximately 90%) of CAQRs, and it is essential to ensure their comprehension of the process's
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function and to concisely define both the potential condition as well as the lowest tier requirement violated.
The following aspects were discussed with these personnel:
Individual job function and impact of CAQR initiation on performing l
normal job function.
l Training relative to the CAQ prucess.
Comparison of CAQ system to previous problem identification methods l
at BFN.
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Does the process di'scourage initiation of CAQRs (i.e., too time
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consuming or tedious)?
Weaknesses that have been identified with the CAQ process.
All personnel had received training relative to the initiation of CAQRs.
Several individuals had experiences the time-consuming proces, of rewriting CAQRs or providing additional information which they falt was unnecessary and detracted from their normal work duties. Despite the time
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consumption problem some initiators experienced, none indicated a
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reluctance to utilize the system when a potential CAQ was identified.
Only two of these individual interviewed had been familiar with the j
previt as problem identification programs; both indicated the new system I
was an improvement.
Two of the individuals interviewed expressed j
concerns that the DNE Management Review Team was proving to be somewhat of a barrier to the initiation of a CAQR.
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The inspectors discussed this concern with the DNE CAQR Coordinator (who also is a member of the Management Review Team) to determine if this DNE specific team's function was being overzealously performed, i.e. providing a barrier rather than 'a filter for incoming CAQRs to keep the number of initiated CAQRs at a lower level. The response entailed that this review team acts as the proceduralized management individual reviewer and that
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this team requests rewrites, additional information, or clarification of the specific problem as needed.
It was indicated by those interviewed
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that this is necessary due to the relationship of problem resolution to problem definition; the more well defined the problem, the more expeditions the resolution. The inspectors reviewed the reject rate of CAQRs to assess the potential of the Management Review Team functioning as
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l a barrier to the CAQR process. This was not a problem based on a 10.4% (8
of 77) rejection rate of DNE initiated CAQRs since program implementation, Of the eight rejected, five were determined to be nonproblems and three were identified on Problem Identification Reports (PIR). The management reviewer indicated that the parameters given in procedure NEP 9.1 coupled with the training provides an entry threshold less restrictive than necessary, which could eventually result in overloading the system with
"non-CAQRs".
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CAQ program implementation is a relatively new process at BFN.
The resulting lack of familiarity with the program by line personnel had contributed to the deficiencies identified with the CAQ process.
Management appeared cognizant of the program's deficiencies as well as the resultant negative trends.
Programmatic and organizational adjustments I
were being perfoi ned as management felt necessary.
Management's I
responsiveness combined with plant training (particularly on CAQRs) and i
increasing plant personnel familiarity with the CAQ process should contribute to the potential future success of the program.
I An inspector concern specific to the DNE CAQ system was the use of the
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lower level adverse condition reporting system, PIRs. This PIR system is i
not the same PIR system that was being used by DNE prior to the CAQ
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program implementation.. This has the' potential to lead to some confusion l
if not properly utilized.
The concern was that this system was not l
adequately programmatically establisheci, provisions were not made for
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trend analysis, and thera was no clear statement of the definition or.use of PIRs.
As the potential exists for a number of apparently insignificant adverse conditions to underly a more serious condition when viewed in whole, this system needs to be more clearly defined and trended.
Two concerns not exclusive to DNE were also identified.
CAQRs that are deemed to be insignificant and are not initiated by QA, receive no I
independent QA analysis / review for significance or operability concerns.
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There exists the potential to have significant CAQRs not receive the management attention it may require. The only monitoring scheduled to be performed is through the use of quality.surveillan es. Since QA is not in the review cycle, completion dates are not scrutinized, resulting in event-oriented corrective action completion dates as discussed earlier.
Also, it appeared conditions adverse to quality that were identified under
previous corrective action processes have been de-emphasized.
Newly initiated CAQRs are increasing more rapidly th'.n closures.
These two conditions can result in a large backlog generated in a short perico of time.
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QA Personnel Qualifications The inspector reviewed the qualifications of TVA Quality Engineering, l
Quality Surveillance, and Quality Improvement personnel.
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Quality Engineering (QE) personnel are responsible for reviewing technical detail adequacy; quality control (QC) held points and compliance with QA requirements; preparing QC and QE inspection plans, reviewing data for completed work; and preparing QA program implementing procedures for site QA organizations.
Currently this group has 18 personnel and most have technical degrees. With the exception of newly hired personnel, all have broad QA backgrounds.
Quality Improvement personnel are basically responsible for collecting and trending short term quality performance data; performing and assessing root :auses of significant quality problems and initiating appropriate corrective action; evalut. ting the adequacy and dispositioning of major
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quality issues; interfacing with line management on quality improvement initiatives; and CAQ tracking and followup.
Currently this group has eight personnel and most have technical degrees (with the exception of two administrative staff personnel).
All have broad QA backgrounds in addition to varying technical skills.
i Quality Surveillance personnel are responsible for surveillance of' QA
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programs and work procedure implementation; surveillance of maintenance,
modification inspection, and test activities; and surveillance.of l
contractor work activities.
Currently this group has 18 personnel with broad QA backgrounds.
Some have technical degrees.
Noticeably lacking
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from this group are personnel with strong maintenance, electrical, or technical specification surveillance backgrounds.
The lack of expertise in these areas was discussed with management plant personnel.
I The QA surveillance group was preparing checklists to frequently monitor the CAQ program.
This monitoring can be effective to assure CAQ inadequacies are promptly identified and corrected.
QA surveillance monitoring was discussed with cognizant plant management.
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Resolution of Previous Items
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An ongoing licensee initiative is the identification, classification, and resolution of outstanding items that were previously identified by various mechanisms prior to CAQ Program implementation.
This data is being gathered and entered onto a computer tracking system.
To date, approximately 720 items have been identified. The inspector conducted an interview with the Project Manager, Employee Concerns program.
Currently the computer data base contains Corrective Action Reports, Discrepancy Reports, Problem Identification Reports, Significant Condition Reports, i
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Institute of Nuclear Power Operations findings, audit findings, and NRC
findings.
However, SDSP 3.7, Section 6.1.7, identifies other reporting mechanisms that CAQs could have been reported under.
Apparently, all other potential CAQ reporting systems have not been included in the computer data base. The inspector discussed the adequacy of the data base with cognizant plant management.
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Licensee Actions on Previously Identified Inspection Findings a.
(Cicsed) Inspector Followup Item 259,260,296/84-49-03: Inconsistency of Reactor Vessel Head Spray Isolation Valves Surveillance Requirements.
The inspector reviewed a letter (L44 841203 001) from the NRC to H. G. Parris dated November 26, 1984.
This letter issued Amendment No. 84 for BFN Unit 3 which deleted the technical specification (TS)
surveillance requirements for Reactor Vessel Head Spray Isolation valves 3-FCV-74,77, and 78. A review is being performed to evaluate i
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changing TS Section 3.7 (Table 3.7.a), but this review is not
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scheduled to be completed until June 30, 1987.
The TS is scheduled to be amended prior to Unit 2 startup. This item is administrative in nature, consequently TS revision verification will not be required.
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(Closed) Inspection Followup Item 259,260,296/85-03-02: Division of Quality Assurance Instruction Discontinuities.
The inspector reviewed DQAI-312, Quality Audit Program - NQA & EB, Revision 3.
The inspector also reviewed TVA-TR75-1A, Quality Assurance Program Description for Design, Construction, and Operation of TVA Nuclear Power Plants, Revision 9.
These discontinuities have been resolved.
c.
(Closed) Inspector Followup Item 259,260,296/82-35-02:
Conduct of Annual Supplier Evaluations.
The inspector reviewed DQAI-401, Supplier. Audit Program, Revision 0 and DQAI-404, Preparation and Maintenance of Supplier Performance History, Revision 0.
These procedures delineate. requirements - for performing supplier audits and evaluations.
lne inspector was informed by the Manager, Supplier Evaluation Group, that at the time this item was written these evaluations were performad by two groups.
A reorganization has combined this function into one group and these evaluations are now being performed at the required frequency.
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