IR 05000259/1990036

Insp Repts 50-259/90-36,50-260/90-36 & 50-296/90-36 on 901105-09.No Violations or Deviations Noted.Major Areas Inspected:Corrective Action Program & Procurement Practices

ML18033B581
Person / Time
Site:	Browns Ferry
Issue date:	11/26/1990
From:	Jape F, Moore R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML18033B580	List: IR 05000259/1990036 ML18033B579
References
50-259-90-36, 50-260-90-36, 50-296-90-36, NUDOCS 9012170088
Download: ML18033B581 (16)

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IlA0 UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION II

101 MARIETTASTREET, N.IN.

ATLANTA,GEORGIA 30323 Report Nos.:

50-259/90-36, 50-260/90-36, and 50-296/90-36 Licensee:

Tennessee Valley Authority 6N 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

Inspection Conducte November 5-9, 1990

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Inspector:

R.

oore Team Members:

R. Wright C.

Rapp Accompanying Personnel:

F. Jape - November 7-9, 1990 Approved by:

F.

ape,

~e Engineering Assessment Section Engineering Branch Division of Reactor Safety po ate igne at

)gne SUMMARY Scope:

This routine, unannounced inspection was conducted in the areas of corrective action program and procurement practices.

Results:

In the areas inspected, violations or deviations'were not identified.

The corrective action program was found to be adequate and working well.

Concerns identified in previous NRC inspection (50-259, 260, 296/90-20)

were addressed by the licensee and resolved.

Browns Ferry procurement program and implementation was adequate based on a

sample review of current Unit 2 procurement activities.

90i2170088 90ii30 PDR ADDCK 05000259 Q

PDR

REPORT DETAILS Persons Contacted Licensee Employees P. Carier, Site Licensing W. Clothier, PEG Engineer

'M. Coston, Site guality Manager, Materials and Receiving J. Davidson, Nuclear Stores Manager D. Hicks, Materials and Procurement Manager S.

Holm, Mechanical - Civil Supervisor, PEG R. Hyde, PEG Lead Engineer S.

Holm, Mechanical - Civil Supervisor, PEG

• L. Jones, Manager, Special Projects and Support L. Lemon, PEG, Contractor Engineer

• B. McKinney, Manager Technical Support

• D. Miller, Sg Supervisor

• B. Morris, Corrective Action Coordinator

• L. Myers, Plant Manager G. Peterson, PEG Engineer.

• C. Reed, Procurement Manager

• J. Wallace, Site Licensing J.

Watson, Procedure Writer, PEG 0. Zeringue, Site Director Other licensee employees contacted

. during this inspection included engineers, technicians, and administrative personnel.

NRC Resident Inspectors

• E. Christnot

• C. Patterson

• B. Beardon

• K. Ivey

• Attended exit interview 2.

Corrective Action Program (92720)

The corrective action program was reviewed to verify that NRC concerns were resolved prior to Unit 2 restart.

The program was previously reviewed in June 1990, (NRC Inspection Report Number 50-259,260,296/90-20)

and assessed as effective in resolving identified deficiencies.

This inspection reviewed corrective action performance from June 1990 to November 1990.

Aspects of the corrective action process reviewed

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included; corrective action completion and closure, closure of conditions adverse to quality reports (CAQRs) that required little or no action, management involvement, site quality involvement, and licensee actions to address concerns identified in the previous NRC inspection.

Overall the corrective action program continued to be effective in correction of identified deficiencies.

This assessment was based on the corrective action process currently in use at Browns Ferry.

It was noted the licensee anticipates standardizing the program sometime after restart of Unit 2.

This review provides no assumptions or projections regarding corrective action process effectiveness following the anticipated program change.

Site quality overview was assessed via, review of audits and monitoring reports performed since June 1990.

Audit Report BFA 90021, Correction of Deficiencies reviewed plant performance related to the CAQR and CAQ/ACP processing of identified deficiencies.

The evaluation of plant and management review committee performance was objective and demonstrated SQ commitment to maintaining an effective corrective action process.

Audit findings included; inappropriate CAQR closures, trending and timeliness of Incident Investigation Reports, and administrative documentation errors.

Audit findings were appropriately documented and entered into the corrective action process.

The 'audit was issued October 22, 1990; therefore, the elapsed time had not been sufficient for development of corrective action.

Monitoring reports are limited scope reviews of specific programatic aspects of plant activities.

The following monitoring reports related to

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the corrective action process were reviewed.

QBF-M-90-289 QBF-M-90-1473 QBF-M-90-1492 QBF-M-90-1486 QBF-M-90-1500 QBF-M-90-0495 QBF-M-90-0457 QBF-R-90-0506 QBF-R-90-0529 QBF-R-90-0499 QBF-M-90-0579 QBF-M-90-0599 QBF-M-90-0598 Radiological Incident Reports Work Order (maintenance)

Inspection Reports and COTS (QC)

Test Deficiencies Receipt Inspection Reports Closure of CAQR CAQRs Applicable to SPOC Process Closure of CAQR - BFP880746 Security Degradation Determinations Disposition of CAQR 900116 Disposition of CAQR BFP 900320 Receipt Inspection Reports Disposition of CAQR BFP 900136 Monitoring reports reviewed the adequacy of corrective action; determina-tion of CAQR applicability by line organizations, timeliness, and administrative closure.

, This evaluation activity was objective and in combination with audits, provided the iicensee an

~ade uate basis for assessment of the corrective action progra Closure and invalidation activity since June 1990 was generally adequate.

The following CARR closures were reviewed.

BFP890720 BFP890123 BFP890392 BFP890287905P BFA900066 BFP890792 BF890219 BFP880703 BFP880442 BFP890379D02 8 FP900102 BFP871060 BFP870319 BFP880826 BFA900025005 BFP890810 The CA(Rs were appropriately addressed and resolved.

Areas which could be strengthened included operability determinations and initial scoping of the identified problems.

Sg had previously identified these areas for increased attention.

Corrective action was to include the Operations staff in operability determinations, especially for determinations involving operating modes 1,

and 3 and the safety/nonsafety equipment interfaces.

CA(Rs BFP900066, 890123, 880703, and 871060 were revised to include additional examples of an identified problem.

For example, seven cracked angle plates on torus supports were identified at different times and were added to an existing CA(R.

Eventually a broad scope evaluation of torus supports was initiated.

These CA(R,revisions, to include additional examples of previously identified deficiencies, indicate that.

the initial generic reviews for CAgRs could be improved.

Closure of CAgRs by invalidation and transfer to CA(/ACPs was generally adequate.

Administrative deficiencies were identified; however, the identified problems were adequately resolved.

A total of 87 CA(Rs were.

'rocessed in this manner, 36 transferred to ACPs and 46 invalidated.

BFP900333 regarding a bypassed gC hold point for a weld removal area was transferred to an inappropriate ACP.

The ACP was not a designated CA(/ACP as required by the Corrective Action Program procedure SDSP 3. 13, Revision 9.

The actual hardware issue for this CARR was not safety significant.

BFP 9003344 was invalidated based on required actions which were not assigned to an ACP.

The CARR addressed an inadequate site procedure which resulted in a missed NDE examination on a support.

The invalidation stated

"the condition can be corrected by reworking the support and performing'he required NDE."

The practice of specifying corrective actions on the invalidation form is questionable because there is no feedback mechanism following CARR invalidation to verify actions were completed.

In this example the'ork was completed due to the associated work plan remaining open.

Overall the invalidation and transfers were adequate.

The examples discussed were of minor safety significance individually.

Review of Sg monitoring activity and discussions with Sg staff indicated this program aspect was adequately monitored..

A specific example of inappropriate CARR closure was identified related to CA(Rs BFP890147 and BF(900116.

The CAgRs addressed replacement of safety related circuit breakers and a field change to CAD system solenoid valve The Site guality Manager authorized closure of these CAgRs prior to completion of the designated corrective actions.

This, action directly conflicted with the licensee corrective action program requirements as indicated by SDSP 3. 13.

This authorization was granted despite a closure rejection previously issued by the Sg staff.

In discussion with the Sg manager regarding this inappropriate closure authorization he indicated he was knowledgeable of the CARR issues and status at the time and decided closure was acceptable.

It was notable that the authorization occurred on a weekend, the time period was near the end of the fiscal year, and the licensee had previously established goals regarding open CAgRs.

The significance of this issue was limited due to licensee identification of the issues and recognition that this was'

unique occurrence.

The Sg staff initiated a

PRD which is a lower tier CAg process to identify this deficiency.

This action will assure the identified CAgRs are adequately tracked and closed.

No similar inappropriate closure authorizations were identified, therefore this occurrence appeared unique.

A trend of deliberate program circumvention would have negatively impacted the quality of the corrective action program; however, this single example did not demonstrate a programatic or process weakness.

Overall, the corrective action process has continued to be effective in resolving identified problems at Browns Ferry.

Contributors to program

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effectiveness were the cross organizational NRC and the close monitoring by Sg.

A review of NRC minutes from June to October 1990 indicated that the amount of management involvement has decreased due to the fact that fewer CAgs are required to be reviewed by the NRC.

The process continued to function adequately with less high level management involvement.

The cross organizational review was an important program aspect.

Sg monitoring activity was evident in all aspects of the corrective action program and demonstrated an uncompromising investigative function.

'I The corrective action program presently in use will remain through Unit 2 restart.

Changes to the process, Revisions 8,

9, and 10 of SDSP 3.13, since June 1990 have been minor.

Procurement (38701, 38703)

The purpose of this inspection was to ascertain that BF is implementing a

gA program which ensures procurement activities for safety related items/services and currently procured CG components/piece parts is in accordance with regulatory requirements, licensee commitments, and industry guides and standards.

The inspector met in conference 'with the various managers and supervisors involved in the procurement cycle which included, Nuclear Stores, PEG, Procurement, Purchasing, and gA.

At this meeting the BF procurement process was described in detail to the inspector and any questions he had regarding the procurement scenario were satisfactorily answered.

These discussions and review of procedures SDSP-16.9, Rev. 4, Technical Evaluation for Procurement of Materials and Services; and SDSP-16.2,

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Rev. 2, Procurement of Material, Components, Spare Parts, and Services (under revision)

disclosed that BF's procurement program is generally patterned after Sequoyah Nuclear Plant's program which was previously inspected by Region II (Report No. 50-327,328/90-02)

and found acceptable.

The inspector selected the following sampling of recent Appendix B, Eg, licensee upgrades, and CG item procurement and dedication packages to review and assess their adequacy for specifying proper technical and gA requirements, testing, vendor documentation, dedication attributes, and acceptance criteria for the procured items.

QA Level Contract No. /Re ort No.

Descri tion IS IS IIIIII 90NJC-82218C 90NLF-448628/RD-139969 Yi9004575B 89NLC-44914B/RD-137300 89NLG-75294A 91NJG-82408C 91NJL-82465C SWE8908355 Technical Report 90-5694 M9100760 Carbon Steel, 45'lbows Electrical Insulation Sleeving Rosemont Transmitters (10 CFR 50.49)

Rebuild GE Circuit Breakers Repair/Refurbish Temperature Switches Pressure Controller Parts Cartridge Fuses Pump Parts, Upgraded to gA Level II by Dedication Copper Elbows and Tubing, Upgrade Terminal Lugs and Splices One discrepancy involving Contract 91 NJG-82408C was identified concerning an inadequate TVA source inspection of the parts manufacturer.

Contrary to contract requirements the source inspection conducted by TVA on October 24, 1990 did not verify the manufacturer's conformance to process and materials of construction.

The current proposed licensing basis for-restart of Unit 2 may allow deferral of evaluation of safety-related replacement items installed in safety-related application for other than

CFR 50.49 systems until after the restart 'of Unit 2.

Therefore, the subject discrepancy was identified as IFI 50-260/90-36-01, Inadequate Vendor Source Inspection.

(See NUREG 1232 Volume 3, Suppplment 2).

This discrepancy has been identified as PRD BFP900375 by the licensee who has been asked to determine the acceptability of these Pressure Controller Parts for their safety-related application and to review this source inspection deficiency for potential generic implications.

The inspector conducted a walk-through inspection of the newly. constructed MPC complex which is unique in that it houses the entire BF procurement organization under one roof.

The MPC building is well laid out in that it contains the main nuclear stores warehouse and stores personnel, PEG, purchasing, procuremont document control, and (A/gC personnel which enhances aood communication The inspector had discussions and queried several PEG personnel concerning procurement packages they were currently working.on'and questioned them on some of the above listed completed procurement packages, asking them to reverify some aspects of the packages.

The inspector found these engineers to be responsive, and knowledgeable of the procurement process and their responsibilities.

The inspector examined the NPC warehouse and was impressed with its cleanliness, its spacious modern facilities, and the identification and storage of materials stored therein.

The inspector talked to and observed stores personnel receiving and issuing materials and identified no significant problems.

Discussion with and observation of gC receipt inspection personnel revealed they appeared to be adequately staffed and knowledgeable of their duties.

Onsite gA testing capability of critical characteristics is generally limited to material hardness testing and dimensional checks since BF depends primarily on audits and source surveillances of CG suppliers at the present time.

The inspector has concluded from this broad based performance oriented procurement inspection that BF has a continually improving, viable, and workable procurement program currently in place that has been adequately implemented for the recent safety-related Unit 2 procurements examined.

The centralization of all procurement activities under one roof (new.

NPC Complex)

appears to greatly enhance the complex organizational interfaces required and is a definite asset to the program.

4.

Action on Previous Inspection Findings (92701, 92702)

a

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(Closed)

IFI 50-259,260,296/90-20-01, Completion of Action Identified to Safety STD 3.1. 10, Trend Analysis This item involved four Administrative Control Procedures used to process conditions adverse to quality which did not contain adequate trend analysis requirements.

The following ACPs were addressed.

(1)

SDSP 7.6 Naintenance Nanagement System (2)

SDSP 9. 1 Processing Drawing Deficiencies 3)

PNI 17. 1 Conduct of Testing (4)

SDSP 27.6 Engineering Evaluation Request Review of draft revisions for ACPs (1)

and (2) above identified the inclusion of trend analysis requirements.

ACPS (3)

and, (4) were deleted from the designated CAg/ACP list in SDSP 3.13, Corrective Action, Revision 10.

These actions adequately addressed

=this issue.

This IFI is close I

b.

(Closed)

IFI 50-259,260, 296/90-20-02, Site Quality Corrective Action Program Overview SQ overview of the corrective action program did not include overview of the following program aspects.

(1)

CAQR - CAQ/ACP determinations by the plant staff.

(2)

Verification of corrective action activity by plant.

Review of Audit Report BFA 90021 and'Q monitoring reports performed between June and October 1990, demonstrate these program aspects were appropriately monitored by SQ.

This IFI is closed.

5.

Exit Interview The inspection scope and results were summarized on November 9, 1990, with those persons indicated in paragraph 1.

The inspectors described the areas inspected and dis'cussed in detail the inspection results.

Proprietary information is not contained in this report.

Dissenting comments were not received from the licensee.

6.

Acronyms and Initialisms ACP BF CAQ CAQR CAD CG COTS EQ MPC MRC NDE PEG PRD SDSP SQ Administrative Control Procedure Browns Ferry Condition Adverse to Quality Condition Adverse to Quality Report Containment Atmosphere Dilution Commercial Grade Corrected on the Spot Equipment Qualification Materials and Procurement Complex Management Review Committee Non-Destructive Examination Procurement Engineering Group

" Problem Report Document Site Director Standard Procedure Site Quality

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