ML18025B551
| ML18025B551 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 04/17/1981 |
| From: | Mills L TENNESSEE VALLEY AUTHORITY |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML18025B550 | List: |
| References | |
| NUDOCS 8106230033 | |
| Download: ML18025B551 (19) | |
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TENNEssEE VALLEYAUT}doRITY CH'A f ANOOGA TENNESSEE 37.10 I 400 Chestnut Street Tower II
~ 'I April 17, 1981 Mr.'ames P. O'Reilly, Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission
~
Region II - Suite 3100 101 Marietta Street Atlanta, Georgia 30303
Dear Mr. O'Reilly:
This is in response to R.
C. Lewis'arch 18, 1981, letter to H.
G. Parris, Report Nos. 50-259/81-02,
-260/81-02, and -296/81-02, concerning activities at the Browns Ferry Nuclear Plant which appeared to violate NRC requirements.
Enclosed is our response to Appendix A
Additionally, this letter expressed concerns regarding the implementation of our quality assurance program.
This program is presently being evaluated to determine what actions are necessary to improve its effectiveness, and a response to this concern will be provided upon completion of this evaluation.
If you have any questions, please call Jim Domer at FTS 857-2014.
To the best of my knowledge, I declare the statements contained herein are complete and true.
Very truly yours, TENNESSEE VALLEY AUTHORITY 4'~~ i Q~n '(i
('.
M. Mills, Manager Nuclear Regulation and Safety Enclosur e I
81 06 20 0 0 3Pi
C 3
t 0'
ENCLOSURE
RESPONSE
TO R.
C. LEWIS'ARCH 18,
- 1981, LETTER TO H. G.
PARRIS BROWNS FERRY NUCLEAR PLANT (50-259/81-02,
-260/81-02,
-296/81-02)
Violation A 10 CFR 50, Appendix B, Criterion XI states that test results shall be documented and evaluated to assure that test requirements have been.
satisfied.
The accepted QA Program, Section 17.2.11 requires results of tests performed on CSSC shall be docume'nted, evaluated, and their acceptability determined by qualified individuals.
Contrary to the above, test results were not evaluated and their acceptability determined in that the evaluation and determination of acceptability of testing on the main steam pilot operated safety relief valves during the 1980 unit No.
3 refueling were not accomplished.
Three valves did not meet the acceptance criteria for reseat pressure as required by MMI 107 and no,documentation of the deficiency or evaluation of acceptability was done by either the contractor who did the testing or by the responsible utility personnel.
Documentation of the test results by the contractor was done for all of the valves but evaluation by the utility was not documented on any of the valves.
This is a Severity Level V Violation (Supplement I.E.) and is applicable to unit 3.
Admission or Denial of the Alle ed Violation TVA admits to the violation in that the required evaluation, although performed, was not'ocumented.
TVA takes exception to the statement
. no documentation of the deficiency.'
." This documentation existed and allowed the NRC insp".ctor to identify the violation of the procedure.
Reasons for the Violation if Admitted The main steam safety relief valves are bench tested for the set pressure determination during refuel outages in compliance with Technical Specification 4.6.D.1 and in accordance wih ASME Power Test Codes.
- However, MMI 107 does require the reseat data to be obtained during the set pressure test and provides the expected reseat parameters.
This data is collected for information only and is not an acceptance criteria by either technical specifications or the Power Test Code. If the reseat pressure parameters fall outside the limits specified in MMI 107, the TVA
'l e
4
4 J
n Outage Management Branch or Nuclear Maintenance Branch approval is required.
MMI 107 did. not provide a specific signoff as a means to document that this approval was obtained, hence approval was provided through verbal communication only, without documentation of this approval.
V Corrective Ste s Which Have Been Taken and Results Achieved After the item was brought to TVA's attention, the reseat pressure deviation previously approved verbally was documented to be acceptable.
Corrective Ste s Which Will Be Taken to Avoid Further Violations The requirement for evaluation of a reseat pressure deviation from the range is being deleted from MMI 107.
The change to MMI 107 will be completed by May 1,
- 1981, Date When Full Com liance Will Be Achieved Full compliance will be achieved by May 1, 1981.
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Violation B 10 CFR 50, Appendix B, Criterion XVI states that measures shall be established to assure that conditions adverse to quality are promptly identified and corrected.
The accepted QA Program, Section 17.2.16 states that adverse conditions shall be corrected in a manner consistent with their safety.
Contrary to the above, adverse conditions have not been corrected as required, in that for audit OPQAA-BF-79SP-03, finding A-1, identified December 14,
- 1979, and audit OPQAA-BF-80-01, finding A-1, identified March 4, 1980, corrective action had not been taken as of this inspection.
This is a Severity Level V Violation (Supplement I.E.).
Admission or Denial of the Alle ed Violation TVA admits to the violation.
Reasons for the Violation if Admitted 1.
Audit OPQAA-BF-80-01, finding A-1.
This audit finding requir ed major revisions to Standard Practice BF 16.5 and involved review by several plant sections in making the revision.
Hence, revision to this standard practice was time consuming.
2.
Audit OPQAA-BF-79SP-03, finding A-1.
Operator training program requirements since TMI have changed significantly by NRC.
These requirements have been implemented and lesson plans developed;
- however, the documentation (in various procedures) reflecting these changes have not been completed.
~ Corrective Ste s Which Have Been Taken and Results Achieved 2 ~
Revision to Standard Practice BF 16.5 has been issued.
N-OQAM, Part III, Section 6.1 was revised on January 15, 1981.
A revision to DPM No.
N78A13 will be completed by June 15, 1981, to comply with N-OQAM, Par t III, Section 6.1.
Corrective Ste s Which Will Be Taken to Avoid Further Violations TVA has established a compliance staff at Browns Ferry.
One of the duties of this staff is to ensure that commitments to offsite groups, including the Office of Power Quality Assurance and Audit Staff, are met in a timely manner.
Date When Full Com liance Will Be Achieved 1.
Full compliance was achieved on February 27,
- 1981, when the revised Standard Practice BF 16.5 was issued.
2.
Full compliance will be achieved by June 15,
- 1981, when a revision to DPM No.
N78A13 is issued.
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Violation C 10 CFR 50, Appendix "B, Criterion V and Section 17.2.5 of the accepted QA Program requires that activities affecting quality shall be prescribed in procedures and accomplished in accordance with those procedures.
The training program is described in Standard Practice BF 4.5, Plant General Employee Training Program revised 5/28/80.
1.
BF 4.5 requires that master training records be maintained on all personnel and updated after all required personnel have attended the course.
Contrary to the above, master training records were not being maintained on all personnel.
Certain temporary personnel in both the operating and outage groups have no master training record.
2.
BF 4.5 Appendix A requires that Measuring and Test Equipment Training be provided to craft personnel every two years.
Contrary to the above, an assistant mechanical maintenance supervisor and a boilermaker had not been retrained during the past
'two years.
3.
BF 4.5 Appendix A defines general employee training courses required for various plant personnel.
Contrary to the above, randomly selected training records indicated that all training courses specified for these personnel had not been accomplished.
This is a Severity Level V Violation (Supplement I.E.).
Admission or Denial of the Alle ed Violation TVA admits to the violation.
Reasons for the Violation if Admitted 1.
The individual in the operations section responsible for training was maintaining adequate records in a manner agreed to by plant management but never documented in standard practices.
Some records for outage trades and labor hourly personnel were maintained with the administrative department rathei than the training coordinator.
However, the training records should have been consolidated and documented on the appropriate standard practice forms.
2.
Training courses were scheduled;
- however, the two individuals probably missed the course due to vacation or illness.'.
The reasons for the missing of the classes is unknown.
Again, it is possible that vacation or illness caused the missing of a training
- class, or an individual had offsite training or could have changed gobs which would change his training requirements after a specific course had been taught in the normal two-year rotation period.
A
Corrective Ste s Which Ha've Been Taken and Results Achieved 1 ~
New master training records have been established for operations personnel and adequate documentation transferred to these records.
Regarding the outage organization, ANSI/ANS-3.1-1978, Section.5.4, states that "Temporary maintenance and service personnel shall also be trained in the above areas to the extent necessary to assure safe execution of their duties." It was not the intent of standard practice BF 4.5 for temporary employees to attend all general employee training courses or for their training to be transferred to a master training record (BF-54).
Changes to BF 4.5 and other procedures will be made as necessary to clarify the training requirements for temporary employees and the documentation to be maintained.
An outage instruction letter will be generated to cover the procedures necessary to implement these changes.
2.
The two individuals involved have completed the required retraining.
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Individuals are scheduled for required retraining when a particular course is taught again.
Positive assurance that required retraining courses are attended is described below.
Corrective Ste s Which Will Be Taken to Avoid Further Violations 1.
Appropriate standard practices will be changed to reflect the acceptability of the previous method for maintaining operations training records.
The corrective steps for the outage organization are noted above.
2.
Any individual not completing required retraining will have his unescorted privileges removed until required retraining is accomplished.
3.
Same as No; 2 above.
Date When Full Com liance Will Be Achieved 1 ~
Date of full compliance for both operations and the outage organization will be June 15,
- 1981, when changes to standard practices will be issued.
2.
Full compliance was achieved on April 16, 1981.
3.
Full compliance has been achieved in that a positive means for recurrence control has been established, and all individuals will attend future required retraining.
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Violation D 10 CFR 50.59 requires that the licensee submits to the NRC annually, or at such shorter intervals as may be specified in the license, a report containing a brief description of such 50.59
- changes, tests, and experiments including a summary of the safety evaluation of each.
Contrary to the above, as of February 6,
- 1981, a report of special tests and experiments conducted during 1979 had not been submitted to the NRC.
This is a Severity Level V Violation (Supplement I.E.).
Admission or Denial of the Alle ed Violation TVA admits to the violation.
Rea'sons for the Violation if Admitted C
The report of,special tests and experiments for 1.979 was inadvertently omitted from the main body of the 1979 annual operating report.
When this was discovered at the p'lant, a supplement to the 1979 report was submitted to the NUC PR central offices.
However, the central office failed to submit the supplement in a timely manner due to administrative oversight.
Corrective Ste s Which Have Been Taken and Results Achieved This incident was a result of an oversight.
The summary of special tests and experiments for 1979 was submitted to NRC February 19, 1981.
Corrective Ste s Which.Will Be Taken to Avoid Further Violations A review of reporting requiremencs will be made to ensure that future reports will contain required information and will be submitted in a timely manner.
Date When Full Com liance Will Be Achieved Full compliance was achieved on February 19,
- 1981, when the summary of special tests and experiments for 1979 was sent.to the NRC.
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Violation E 10 CFR 50, Appendix B, Criterion VI and Section 17.2.6 of the accepted QA Program requires that measures shall be established
.to control instructions, procedures, and drawings, including changes
- thereto, which prescribe activities affecting quality and to assure that these are distributed to and used at the location where the prescribed activity is performed.
1.
Contrary to the above, measures were not established to control vendor technical manuals in that of four manuals selected from the plant files distribution index, two could not be located in the maintenance supervisors'reas and one, sent to maintenance in multiple copy form, had only one locatable copy in maintenance.
Also, four manuals without plant files identification were located in the maintenance areas.
2.
Contrary to the above, measures were not established to control TVA-generated instructions, in that one copy of the acccepted QA Program and the N-OQAM were in use at Browns Ferry with outdated revisions.-
3.
Contrary to the above, measures were not established to control drawings in that drawings used for work performance by the electrical maintenance shop and drawings issued across the counter by the Drawing Control Section were not managed to prevent improper use of outdated revisions.
This is a Severity Level V Violation (Supplement I.E.).
Admission or Denial of the Alle ed Violation TVA admits to the violation.
Reasons for the Violation if Admitted 1.
Browns Ferr y Nuclear Plant has always intended that vendor manuals
.be used for information only, and that maintenance work on safety-related equipment beyond the skills of the craft would be performed in accordance with approved plant instructions.
These instructions may 'have information from the vendor manuals included as a part of the instruction but should not include procedural step references to vendor manuals.
The procedures cited were generated before this control was well established and fully understood by all affected personnel.
v4 0
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'Revisions to the accepted QA Program manual (TVA-TR75-1), were inadvertently filed in an uncontrolled manual rather than the controlled copy No., 103.
The revision for copy No.
11 of the OQAM was transmitted to Browns Ferry on December 24, 1980, but was not filed by clerical personnel until February 2, 1981.
3 ~
No program for preventing improper use of outdated revisions to drawings had been established by the drawing control center.
Administrative control of controlled drawings in the electrical maintenance shop was not adequately implemented.
Corrective Ste s Which Have Been Taken and Results Achieved 1 ~
All plant maintenance sections and the outage organization are reviewing their instructions to ensure that vendor manuals are not referenced in instruction steps.
The specific instructions cited by the inspectors will be revised, as well as any others that are identified.
2 ~
Copy No.
103 of the accepted QA Program will be updated by May 1, 1981.
Copy No.
11 of'he OQAM was revised February 2, 1981.
3 ~
Revisions to plant drawing control procedures have been made whereby a stamp is affixed to all drawings issued across.the counter to indicate that the drawing will only be valid for seven days after issuance.
Corrective Ste s Which Will Be Taken to Avoid Further Violations 1 ~
Appropriate individuals have been reminded to not reference vendor manuals in instructions steps.
2 ~
The Document Control Unit at Browns Ferry Nuclear Plant has instituted a system for tracking transmittal sheets for revisions to all controlled documents to ensure that changes are filed and acknowledgments returned in a timely manner.
3 ~
A checkout system for controlled drawings in the electrical maintenance shop has been established.
This combined with corrective steps taken above shall avoid further violations.
~ Date When Full Com liance Will Be Achieved 1 ~
Full compliance will be achieved by June 15,
- 1981, when review and revision of all necessary instructions will be completed.
2 ~
Full compliance will be achieved by May 1,
- 1981, when revision 4 is filed in the accepted QA Program (TVA-TR75-1).
3 ~
Full compliance. will be achieved by May 15, 1981.