ML18025B555
| ML18025B555 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 03/16/1981 |
| From: | Belisle G, Fredrickson P, Peebles T, Skinner P, Upright C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18025B550 | List: |
| References | |
| 50-259-81-02, 50-259-81-2, 50-260-81-02, 50-260-81-2, 50-296-81-02, 50-296-81-2, NUDOCS 8106230050 | |
| Download: ML18025B555 (49) | |
See also: IR 05000259/1981002
Text
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UNITEO STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTAST., N.W., SUITE 3100
ATLANTA,GEORGIA 30303
Report Nos. 50-259/81-02,
50-260/81-02
and 50-296/81-02
Licensee:
Yalley Authority
500A Chestnut Street
Chattanooga,
TN
37401'acility
Name:
Browns Ferry
Docket Nos. 50-259,
50-260 and 50-296
License Nos. DPR-33,
Inspection at Browns, Ferry site near Decatur,
and the Authority Offices
in Chattanooga
and Knoxville, Tennes
ee,
Inspectors:
G. A.
sl
Date
S gned
0
C
P.
E. Fredric
son
T. A.
eebl
s
P.
H. Skinner
Approved by:
C.
- Upright,
1 f, Ma
ement Programs Section,
Engineering In
p
tion
nch, Division of
Engineering
and Technical Inspection
Date Signed
3
D te
igned
S /0 g/
Date Signed
g
te
igned
SUMMARY
Inspection
on January
26-30 and February 2-6,
1981
.
Areas Inspected
This routine,
announced
inspection
involved 200 inspector-hours
on site
and at
the
TVA headquarters.
The inspection
was
conducted
in the areas
of licensee
action
on
previous
inspection
findings;
gA program review; qualifications of
personnel;
design
changes
and modifications;
test
and
experiments;
document
.
control; off-site review committee;
audits; off-site, support staff; training;
requalification training; surveillance testing
and calibration; maintenance;
and
licensee action on previously identified open items.
oI,oosso Qgg
g ~
~
~
0
Results
Of the
14 areas
inspected,
no violations or deviations
were identified in nine
areas;
five violations were. found in five areas
(Failure to review and evaluate
results
of test,
paragraph
15; Failure to control drawings,
vendor manuals
and
TVA issued. documents-,
paragraphs
S.a, S.b and S.c.;
Failure. to maintain retraining
and training, paragraph
13; Failure to take prompt corrective actions
on audits,
paragraph ll.c; and Failure to annually report to
NRC special
tests
performed
under
paragraph
9.a).
Two deviations
were
found in one
area
(Failure to perform
a
gA survey
on
maintenance.
Trouble
Report
instructions,
paragraph
3.h and Failure to implement procedure
change,
paragraph 3.d).
DETAILS
Persons
Contacted
Licensee
Employees
0
'"H.
AJ
- 8'T
J.
J.
J.
AJ
M.
R.
S.
C.
- G
RJ
A8W
PAAR
- J
Abercrombie', Plant Manager
Andrews, Nuclear Power QA Staff
Bynum, Assistant Plant Manager, Operations
Cambell, Nuclear Power, Chief OMB
Chinn, Compliance. Staff Supervisor
Coffey, Nuclear Power Assistant Director
Crowell, Modification Director
Ferguson, Assistant Outage
Director'albreth,
Nuclear Safety Staff
Glover, Shift Engineer
Training
Harness, Assistant Plant Manager,
Maintenance,
Jackson, Assistant Electrical Maintenance Supervisor
Lee,
QAA Staff
Metke,, Results Supervisor
Mindel, QA Engineer
Myers, Head Nuclear Engineer,
NEB
Odell, Nuclear Power Management Service Staff Support
Parker, Assistant. to Director, Nuclear Power
Pittman, Instrument Maintenance Supervisor
Poling,
QA&A Staff
Sessons,
Nuclear Powei Staff
Smith,
QA: Staff Supervisor
Swindell,. Outage Director
Weeks,
Power Stores
Other licensee
employees
contacted
included operators,
mechanics,
security
force members,
and office personnel.
NRC Resident Inspector
~R. Sullivan
- G. Paulk
"Attended exit interview at site on February 4, 1981.
"*Attended exit interview at authority offices in Chattanooga,
on
February
6,
1981
~"*Attended both exit interviews
2.. Exit Interview
0
The inspection
scope
and findings were
summarized
on February
4 and
6 1981,
with those persons indicated in paragraph
1 above.
At the February
4,
1981,
meeting site personnel
were briefed on the inspection activities conducted
through February 4,
1981.
The February 6,
1981 meeting included
a summari-
zation of both weeks activities and was held at the Chattanooga
offices of
the
licensee.
The
licensee
was
informed of the
inspection
results
as
discussed
in the index of findings, paragraph
19.
List. of Abbreviations
The following terms are defined and used throughout this report:
Accepted
QA Program
EMO
EMS
EN DES
LER
MMO
N"OQAM
STEAR
USQD
TVA-TR75-1A, Revision
4
Engineering
Change Notice
Electrical Maintenance Office
Electrical Maintenance
Shop
Engineering Design
Licensee
Event Report
Mechanical
Maintenance. Office
Mechanical Maintenance
Shop
Nuclear-Operational
Quality Assurance
Manual
Nuclear Safety Review Board
Quality Assurance
Section Instruction Letter
Special Test, Experiment or Activity Report
Special Test'nstruction
Troubl e- Report;
Unreviewed Safety Question Determination
3.,
Licensee Action on Previous Inspection Findings (92702)
Items of noncompliance
and. unresolved. items from Inspection
Reports
50-259,
260,
296/79-30
were
reviewed with respect
to the licensee's
letter dated
December
19, 1979.
0
a ~
b.
(Closed)
I'nfraction
(259,
260,
296/79-30-13):
Appendix A,
item B,
failure
to
conduct.
required
testing.
The
inspector
reviewed
MMI
15.5.4-D data
sheets
and determined that testing
had been
performed
as
required
by the
USQD.
The inspector
also verified by direct ques-
tioning of the engineer
in charge that testing
had
been
performed
as
required, and this information was
recorded
on page
7 of MMI 15.5.4-D
dated November 7, 1980.
(Closed)
Deficiency
(259,
260,
296/79-30-14):
Appendix A,
item F,
incomplete test records,
receiving inspector training
and qualifica-
tions certificates, and.failure to maintain records.
(1)
Incomplete test
records.
The
inspector
verified that
voltage
readings
were
recorded
on
Work Plan
9346 for
The
inspector also reviewed
a
memo sent
from the
outage director to
the
assistant
plant
superintendent
dated
December
14,
1979,
emphasizing
the duties of the cognizant
engineer
and
those
per-
sonnel responsible for reviewing modification documentation.
~ ~
3
(2)
Receiving, inspector training and qualifications ce'rtificates.
The
inspector reviewed the recertification of receiving inspectors
and
determined
that. the classes
conducted
were satisfactory.
Also,
BF 16'.4,
revised
November 28,
1979,
was
reviewed
and
found to
contain certification controls and training requirements.
(3)
Failure
to
maintain
records.
The
inspector verified that
a
drywell entry was made, that the sensing line repair was inspected.
by.
QC personnel
and that the inspection
was
documented
to the
plant. superintendent.
(Closed)
Infraction (259,
260,
296/79-30-15):
Appendix A,
item D,
unretrievable
design inputs.
The inspector
requested
information from
the KnoxvilTe offices of TVA.
This information was mailed
by
TVA on
February
12,
1981,
and
was received
by .the inspector
on February
18,
1981..
The: information
requested
included
documentation
of design
inputs, calculations,
verifications,
evidence
of supervisory
reviews
and
USQDs for
ECNs P0081,
L2051,
P3000
and P0267.
The inspector
also
requested.
the
following procedures:
41.02,
TDP-EP-41.03,
TDP"EP-41. 04,
TDP-EP-4105,
TDP-EP" 41
~ 06,
TDP"EP"41. 09,
TDP"EP-41. 12,
EN DES-EP 2.03,
2.04,
3. 10, 3.02, 3.04, 3.09,
3. 16, 4.03,
4. 18, 6.03,
4.01, 4.02, 4.04, 4.25, 4.21, 5.20,
DED-EP 7.01,
ID-QAP 1.2, 2.2, 2.3,
2.4, 2.5,
EN DES-EP 3.03,
and TDP-EP 41.15.
The procedures
delineate
how design
changes
are handled
by
EN
DES and .TOP.
By. a comprehensive
review of the
procedures
and
the
previously
mentioned
the
inspector
determined that applicable design
inputs were being applied
to modifications.
The inspector
also determined. that design interfaces
were. procedurally controlled and
USQDs were adequately
addressed.
(Closed)
Infraction (259,
260,
296/79-30-16):
Appendix A,
item E,
incomplete
unreviewed
safety
question
determination.
The inspector
reviewed six recently completed
ECNs as discussed
in paragraph
7.
The
USQDs
were
carefully
reviewed
for- adequacy.
The
inspector
also
reviewed and discussed with cognizant personnel
in Knoxville, Tennessee
the method used to determine
how USQDs are made.
In the licensee's
response
to Appendix A, item E, dated
December
19,
1979,. as part of the corrective action to avoid further noncompliance
the licensee
stated,
"As
a. result; of TVA's own review of its proce-
dures,
we will review each
USQD, including any revisions,
to ensure
that
each
USQD accurately
addresses
the change
before notification to
nuclear
power- that
EN
DES work is complete
on the
change.
This will
provide further assurance
that
th'e
change
is accurately
evaluated
in
the
USQD'.
This procedural
change
was implemented
on December
3,
1979".
The inspector
requested
to
see
the procedural
change that was'nsti-
tuted to meet this commitment.
The licensee
presented
to the inspector
a copy of
EN DES-EP 2.03,
Unreviewed Safety Question Determination-
Handling
and Preparation,
Revision
3 dated
January
1981.
The last
revision to this procedure,
Revision
2 was dated
May 1979 prior to the
date of the previous
inspection
in October
1979.
The licensee
also
presented
a copy of a memo written by the Chief Nuclear Engineer to the
thermal
design
project- manager
and the Sequoyah
and Watts Bar design
project
manager
dated
December
13,
1979,
SUBJECT:
ALL OPERATING
PLANTS UNREVIEWED.SAFETY QUESTION DETERMINATIONS (USQD).
The licen-
see's
QA staff. performed
an audit of the Nuclear Engineering
Branch
(NEB) December
1-3,
1979 (Audit JA8000-13)
and identified a nonsigni-
ficant finding against
NEB relative to
EN DES-EP 4.03,
Field Change
Request.
Neither the
memo,
audit or change
to procedure,
adequately
fulfills the licensee's
commitment
as
stated
in their correspondence
dated
December
13,
.1979.
This failure to
meet
the
commitment
in
correspondence.
dated
December= 13,
1979 is
a deviation
(259,
260,
296/81-02-06).
For tracking
purposes
item 259,
260,
296/79-30-16 is
closed with the identification of this deviation.
(Closed)
Unresolved
(259,. 260,
296/79-30-17):
Ill-defined internal/
external
design .interfaces.
The=inspector reviewed applicable sections
of the Interdivisional Quality Assurance
Procedures
Manual, the Browns
Ferry
Standard
Practices
and
EN DES-EP
Procedures
relative
to the
initiation, handling
and processing
of design
changes
(ECNs,
FCRs
and
DCRs)
and
was
able. to determine
that internal/external
design inter-
faces are adequately defined.
(Closed) Unresolved
(259,
260,
296/79-30-18):
Inadequate
Implementa-
tion Control.
The inspector
reviewed the Browns Ferry Standard
Prac-
tices relative to design
modifications
and
conducted
interviews
in
Knoxville, Tennessee
with personnel
in the Engineering
Design Section
and Nuclear Engineering
Branch. It was concluded that although design
modifications
are
sometimes
worked
piecemeal,
all required
design
inputs are satisfied prior to implementation.
The inspector
reviewed
six ECNs as discussed
in paragraph
7 and verified their implementation.
(Closed)
Infraction
(259,
260,, 296/79-30-25):
Appendix A,
item C,
failure to conduct audit.
The inspector
reviewed the results of audit
OPQAA-BF-80-SP-01
conducted
January
21-25,
1980.
This
was
a special
audit conducted to assess
the adequacy of the quality assurance
program
as applied to refueling activities during
a Unit 1 outage.
Current
audit
schedules
now contain provisions to conduct
audits- of outage
activities as required.
(Closed)
Infraction (259/79-30-27):
Appendix A,
item A, failure to
inspect maintenance.
The licensee's
response
to this item stated that
by December
31,
1979, the Mechanical Maintenance Section would have the
necessary
instructions for preparing
trouble reports.
The inspector
verified
the
issuance
of
Mechanical
Maintenance
dated
December- 18, 1979.
The inspector reviewed ten trouble reports
from the
Mechanical Maintenance Section
and found them to be satisfactory.
In the licensee's
response
to Appendix A, item A, dated
December
19,
1979,
as part of the corrective action to avoid further noncompliance,
the licensee stated,
"Existing section instructions will be surveyed by
~ a
0
the plant qual'ity assurance
staff by January
31,
1980.
The results. of
these
surveys will be documented
and reported to the plant superinten-
dent."
The inspector
questioned
the cognizant plant personnel
about
the survey and the report
and
was
informed that this
survey
had not
been
done.
The failure to
meet the
commitment is identified as
a
deviation (259,260,296/81-02-07).
(Closed)
Deficiency
(259,
260,
296/79-30-28):
Appendix A,
item G,
failure to follow procedures.
The inspector verified the issuance
of
Mechanical
Maintenance
SIL 5 dated
December
18,
1979.
The inspector
reviewed
ten trouble reports
from the Mechanical
Maintenance
Section
and found them satisfactory.
4.
Unresol ved items
Unresolved items were. not identified during this inspection.
5.
QA Program Annual Review (35701)
References:
(a)
TVA-TR75-1A
(b)
N-OQAM, Operations Quality Assurance
Manual
(c)
Office of Power Quality Assurance
Manual
(d)
Letter, L. Mills to W. Haass,
dated April 1, 1980
(e)
Letter,
W. Haass to L. Mills, dated August 18,
1980
The licensee
has
made
one
change
to the
accepted
QA Program
since
the
previous
(October
1979) inspection in this area.
This change
was reviewed
to assure
'that, the
requirements
of
Appendix
B were being
met.
The inspector
reviewed the impact of this revision with cognizant plant and
authority personnel.
As a result. of this review no violations or deviations were identified.
6.
Qualification of Personnel
(36701)
Reference:
Technical Specifications, Section 6.1.E
The inspection
consisted. of ascertaining
whether
the
licensee
has
a
program relating- to qualification of personnel
that is in .conformance with
regulatory
requirements.
and licensee
commitments.
The inspector verified
that qualifications.had
been established
for personnel
in the onsite organ-
ization.
The inspector reviewed the qualification of the plant manager,
the
assistant
plant
manager,
the
maintenance,
operations
and results
super-
visors,
the
QA staff supervision,
three reactor
operators,
three electri-
cians,
two mechanics
and
two inspectors.
As
a result of this review
no
violations or deviations were identified.
~ ~
7.
Design, Design Changes
and Modifications (37700,
37702)
References:
(a)
BF 8. 1, Modification Status,
dated 1/79
(b)
BF 8', Temporary Alterations, dated 1/80
(c)
BF 8.3, Plant Modification Work Plans,
dated 12/80
(d)
BF'.4,. Authorization
and
Work Performance
of Plant
Modifications, dated 8/80
(e)
N-OQAM,
Part II,
Section
3.2,
Plant
Modifications:
After Licensing, revised 7/80
(f)
N-OQAM, Part II, Section
3.2A,
Core
Component
Design
Change After Licensing, revised 10/80
(g)
EN
DES-EP 2.03,
Unreviewed Safety Question
Determina-.-
tion - Handling and Preparation,
Revision
3 dated 1/81
(h)
Interdivisional
Quality Assurance
Procedures
Manual,
dated 9/79
The
referenced
documents
were
reviewed with respect
to the
accepted
'rogram
and
as
committed
to
by that
Program.
The
licensee's
design
change
program
was reviewed to verify that procedures
have
been
established
for control
of design
and modification
requests;
that
administrative
controls for design
document control
have
been established;
that controls
and responsibilities
have
been
established
to
assure
that
design
changes
are incorporated into plant procedures,
operator training and
affected drawings; that controls have been developed for interfacing between
different design
organizations;
that administrative controls require docu-
mentation
and, records
be collected
and, stored; that controls. require imple-
mentation
of design
changes
to be performed. in accordance
with appr'oved
procedures;
that. controls require post modification testing to be performed
and the results
evaluated;
that responsibility
has
been
assigned for iden-
tifying post modification testing requirements
and. acceptance
criteria;
and
that responsibility
and methods for reporting design
changes
to the
NRC are
delineated
in accordance
with 10 CFR 50.59.
Similar requirements
were also
verified for the
use of temporary alterations.
Six desijn
changes
were-
reviewed to verify the implementation of the- previously mentioned
require-
ments:
P"3000
Replace existing
GEMAC Transmitters with Foxboro Transmitters for
PT-64-50,
51 and PT-64-67
P-0350
P"0267
Reverse polarity on diode
IN4499. in panel 9-29, TBI-5, TB2-1 and
TB2-9, points D.and
E
Provide
chain driven operators
for valves
HCV-74-49, 55,
69 and
HCV"69-500
P-0338
Replace existing rupture disk, Fike Metal
Products
Model
8-PLHOV
with Fike Model 8-C-PVC
0
P-0277
Replace existing transmitter mounting studs at each
MSRV tailpipe
with vendor supplied equipment
P-0353
Reroute
DRW floor drains
As a result of this review no violations or deviations were identified.
8.
Document Control (39702)
References:
(a)
BF 2. 10, Plant Records
Management., dated'2/80
(b)
BF 2.7, Changes to Vendor Manuals, dated 12/80
(c)
BF 2.5, Drawing Control, dated 10/79
(d)
N-OQAM, Part III, Section
4. 1, Plant
QA Records,
dated 12/80
(e)
N-OQAM, .Part III, Section
1. 1,
Document Control,
dated 2/79
The inspector
reviewed
the
referenced
procedures
to verify that
proper
controls
have
been.- established
for drawings,
vendor
technical
manuals,
technical
specifications,
and
procedures
affecting
quality.
In
particular the inspector
selected
several
documents
to verify the proper
handling per the applicable procedures,
to verify the accuracy. of the master.
index for the various
documents
and to verify the
proper
updating
of
controlled drawings
and other documents.
The selected
documents
reviewed
were the following:
Instructi'ons
Manuals
EMI-6
TI'-15'MI "22
MMI-99
OI-77
SI-4.2.A.6
S I.-4.8.B. 4 ~
4'echnicalSpecifications, Unit 1
N"OQAM
Topical Report-TYA-TR75-1A
Several
Vendor Technical
Manuals
~Drawin
s
45N644
15N500
47W200
55N670
77W210
122D9378
47W600
45N2677
As a result of this review,
two violations and one open item were identified
and are discussed
in paragraphs
8.a-d.
'a ~
Failure to Control Drawings
0
The licensee utilizes
two types of drawings,
controlled
and
uncon-
'rolled.
The controlled drawings are not removed from their assigned
location; whereas the uncontrolled drawings are
used
by the technicians
during
work performance.
Drawing Control
personnel
hand-carry
new
drawing revisions
to both
the controlled
and uncontrolled
drawing
locations.
Uncontrolled
drawings
are
maintained
in the electrical
maintenance
shop and are issued from Drawing Control across-the-counter
i
to individuals; but no method exists to preclude
these
drawings
from
being
used after
a
new revision
has
been
issued.
10 CFR 50, .Appen-
dix B, Criterion VI states
that
measures
shall
be
established
to
control
drawings
which
prescribe
activities
affecting
quality.
Contrary to the
above,
drawings
were not controlled in that the
un-
controlled
drawings
used
by
the electrical
maintenance
shop
and
drawings
issued across-the-counter
did not have sufficient controls to
prevent
improper
use of outdated
revisions.
This fai lure to control
drawings
has
been
combined with other
examples.
as discussed
in para-
graphs
8.b
and 8.c to collectively constitute,a violation (259,
260,
296/81-02-02).
The inspector did not identify any drawings
used with
outdated revisions.
Failure to Control Vendor Technical Manuals
The inspector
selected
several
manuals
from the vendor
manuals distri-
bution index in plant files.
These
manuals. were then traced to several
of their
designated
locations.
In addition,
several
maintenance
instructions
were
reviewed
to
determine
whether
procedural
steps
referenced
instruction
manuals.
Appendix B, Criterion VI
states that measures
shall
be established
to control instructions which
prescribe activities affecting quality.
Contrary to the above, of four
selected
vendor manuals,
one was not in the 'file room,
two could not be
1'ocated
in the maintenance
supervisors'reas
and one,"sent to mainte-
nance in multiple. copy form,
had only one locatable
copy in mainte-
nance.
The four manuals are', respectively,
the following:
Manual
To ic
Index No.
Contract
No.
Crane,
Crawler-
Transmitter, Series Pressure
Valves,
Component
Monitor, Area.
(25)
85895
(37)
821125
(.48)
(22)
1.3.5-5.E
A
Also, contrary to the
above,
the
EMO and the
EMS had two instruction
manuals
without files, identification;
and the.
MMO and
had
one
manual
each
without
the files
information.
Several
uncontrolled
technical
manuals
were also located
in the Drawing Control area.
The
plant manager
stated that the intention of Browns Ferry is, to use all
vendor manuals for information only and not as procedural
references;
yet, of 20 maintenance- instructions reviewed, five had procedural
step
references
to
vendor
manuals
(MMI-13, EMI-26,
MMI-28,
MMI-4,
and
MMI;77). Also, by direct questioning of plant personnel,
the inspector
ascertained
that vendor manuals
have not been controlled.
This- failure
to control
vendor
manuals
has
been
combined with other
examples
as
discussed
in paragraphs
8.a
and 8.c to collectively constitute
a
violation (259, 260, 296/81-02-02).
'
c ~
Failure to Control TVA Generated
Documents
d.
During the review of documents
at the site,
the inspector identified
two manuals controlled by TVA from Chattanooga
that did not
have the
current revision:
Copy
103 of the accepted
QA Program
and copy
11 of
the.
N-OQAM, both
located
in the site
QA office.
Plant
generated
procedures
are directly controlled
by
the
site
Document
Control
Section.
TVA generated
documents
are
controlled
by the
Management
Services
Staff at
the authority offices.
The inspector
noted that
receipt acknowledgement
of QA program changes
are not required
and the
change
receipt
acknowledgement
form to
the
N-OQAM sent
out
on
December
24, 1980,
had not been returned for copy
11 nor had
a followup
been
submitted.
This problem is also
compounded
in that the document
distribution index at the site for these
two manuals
does not coincide,
with the authority office'ndex for both total
copies
'sent
and copy
numbers.
Appendix B, Criterion VI states
that
measures
shall
be. established, to control instructions which prescribe activities
affecting quality.
Contrary to the above,
the
N-OQAM and the accepted
QA Program
manual
were not. controlled.
This failure to control manuals
has
been
combined with other examples
as described
in paragraphs
8.a
and 8.b to collectively constitute
a violation (259,
260, 296/81-02-
02) .
Document Receipt Acknowledgement
During a review-of. reference (a), the inspector
noted that although the
receipt. acknowledgement
form (BF 92) contained
a space for "return by"
date, this timeframe
was not described
in reference (a).
The licensee
has
committed to
a target
date of March 31,
1981 to revise reference
(a) to delineate
a maximum time for receipt
acknowledgement
of docu-
ments.
Until this procedure
is reviewed. by the
NRC, this item is opens
(259', 260, 296/81-02"10).
9.
Test and Experiments
Program (37703)
References:
(a)
N-OQAM, Part II, Section
4.6,
Special
Tests,
Experi-
ments, or Activities, dated 3/79
(b)
BF
17. 1,
Special
Tests,
Experiments
or. Special
Activities, Revised 5/79
(c)
BF 13. 13,
Format for Refueling/Special
Test
I'nstruc-
tions-, Revised 1/80
P
The inspector verified the following aspects
of the test
and
experiments
program:
A formal
method. has
been
established
to handle all requests
or pro-
posals for conducting special tests involving safety-related
components
Special tests will be performed in accordance with approved procedures
10
Responsibilities
have
been assigned for reviewing and approving special
.test procedures
A system,
including assignment
of responsibility
has
been
established
to assure that special tests will be reviewed
Responsibilities
have
been
assigned
to assure
a written safety evalua-
tion required, by 10 CFR 50.59 will be developed for any special test to
assure. that it. does
not involve
an
unreviewed
safety evaluation
or
change in Technical Specifications
Responsibility
has
been assigned
to assure
that any special test will
be reported to the
NRC in a.timely manner as required by 10 CFR 50.59.
To verify implementation of the. program, the inspector selected three
STEARS
and three. STIs for-review:
STEAR 80"06
STEAR 80"19
STEAR 80-26
STI 165
STI 186
STI'87
As a result of. this review,
one violation and
one
open item were
identified'nd
are discussed
in paragraphs
9.a and9.b.
a 4
b.
Failure to Submit 10 CFR 50.59 Report
The inspector
noted that'he
1979
Annual
Operating
Report did not
contain
a
summary of
STEARS
conducted
during
1979.
The
gA Staff
Supervisor
stated that
an OP/A audit (No. OPIA-BF-80-SP-03) identified
this omission and that a supplement
to the
1979 report was submitted
by
the plant.
At. the authority offices, the inspector
was notified that
this audit conducted
on Nay 28,
1980 did identify the problem
and that
the
plant. did
submit
a
supplement
to the report
to the Assistant
Oirector of Nuclear
Power (Operations)
on
September
9,
1980.
At the
time of this, inspection,
February
6,
1981, this supplement
had not been
submitted to the NRC.. The inspector.
asked
whether
the
summary
could
'ave
been
submitted
via- another
report
and
was
informed that
the
supplement
was the only means
in effect at present.
The- licensee
had'ecognized
the
need for submission of the. supplement but apparently
was
planning
on
sending
the
suppl'ement
to the
NRC with the
1980 Annual
Operating
Report..
This failure to.submit
a. summary of STEARS, at least
annually, to the
NRC as required
by 10 CFR 50.59 is
a violation (259,
260, 296/81"02-05).
Clarification of STEAR Implementing Procedures
Both references
(a)
and (b) give directions fo'r the handling of STEARS.
The two are not consistent at present
in the areas of document flow and
the responsibilities of review.
At present,
reference (a) is being
~ ~
11
revised.
The licensee
has, committed to
a target
date of April 30,
1981, for completing
the, revision of reference
(a)
and conducting
a
review and revision of reference
(b) to clarify the handling of STEARS
at both the plant and authority office levels.
Until these
revisions
have
been
reviewed
by the
NRC, this item is open (259,
260, 296/81-02-
13).
10.
Offsite Review Committee (40701)
References:
(a)
Technical Specifications,
S'ection 6.2
(b)
TVA, Office of Power,
Nuclear
Safety
Review
Program
Manual, dated 1/81
(c)
TVA, Office of Power,
Nuclear Safety
Review Procedures
Manual, dated 1/81
The review was to verify that
NSRB membership
and qualification
are
as
required
by the Technical Specifications;
that. meetings
convened
during the
previous year
were held at the required
frequency;
that reviews
included
persons
who constituted
a
quorum
and
possessed
expertise
in the
areas
reviewed;
and that the
NSRB reviewed activities
as required
by the Technical
Specifications.
The inspector
reviewed
NSRB minutes. from March
1980 through
Oecember
1980.
t
As a result of this. review,
no violations or deviations were identified.
11.
Audi-ts (40702, 40704)
References:
(a)
OP-QAP-18. 1, Audits, Revision
2 dated 12/79
(b)
OP-QAP-16.1, Corrective Action,. Revision
0 dated 1/77
(c)
N-OQAM, Part 3, Section
5. 1, Auditing of the Quality
Assurance
Program for TVA Nuclear Plants, revised 10/80
(d)
QAAS-QAP-3. 1,
Quality Audit Program,
Revision
6 dated
12/80-
(e)
QAAS-QAP-3.2, Quality Program Audit Planning,
Revision
2
dated 1/76
(f)
OP-QAP-2.3,
Request
for Management
Resolution,
Revi-
sion
0 dated 1/81
Program
0
The referenced
documents
were reviewed with respect to the accepted
Program
and ANSI N45.2. 12 (Oraft 3, Revision 4,
1974)
as committed to
by the
Program.
The licensee's
audit
program was reviewed to verify
responsibilities
have
been
assigned
in writing for the overall
manage-
ment of the audit program;
administrative
channels
have
been defined
for taking corrective actions
when deficiencies
are identified during
- audits;
the audited organization is required to respond
in writing to
audit findings; distribution requirements for audit reports
and correc-
tive action reports
have
been defined;
and checklist are required to be
used in the performance of audits.
12
Implementation
Thirteen audits
were
reviewed to verify that they were
conducted
by
trained
personnel
not having direct responsibility in the area being-
audited;
the frequency of audits
was in conformance with the Technical
Specifications
and the
QA Program;
appropriate
followup actions
had
been taken;
and the audited organization
responded
to the audit find-
ings.
The following'is a list of audits selected for review:
Audit.
OPQAA-BF-80 "S P-01.
OPQAA-BF"80TS-01
OPQAA"BF"79SP-03
OPQAA-BF-7900-02
OPQAA-BF-7900-08
OPQAA-BF-7900-09
OPQAA-BF"80TS-03
OPQAA-BF-80TS-2
OPQAA-BF"'8000-01
OPQAA-BF-8000-02
OPQAA-BF-8000-03
OPQAA"BF-8000"04
OPQAA-BF-'8000-05
Audit Report Date
02/21/80
08/26/80
12/14/79.
04/25/79
12/06/79
12/12/79
12/11/80
11/21/80
03/04/80
04/17/80.
07/28/80
10/01/80
01/05/81,
In addition to the previously mentioned audits,
the. inspector
reviewed
approximately 80 plant'urveys
performed by the plant quality assurance.
staff.
This group reports
to the plant manager
and does
not perform
surveys to meet
the Technical
Specification
requirements
for audits.
During the review of the
surveys
several
minor inconsistencies
were
identified in the
These minor inconsistencies
were discussed
with the plant quality assurance
supervisor.
During the audit review the inspector identified an apparent violation
in that the audited organization did not respond to the audit findings
within 30 days
as required. by ANSI N45.2. 12 (Draft 3, Revision 4, 1974)
as committed to by the accepted
QA Program;
This violation was dis-
cussed
at the exit interview and the assistant
plant manager
refuted
the finding.
The inspector stated that if the licensee
could provide
additional
information to the inspector,
this apparent violation would
be carefully reviewed.
On February
9,
1981,
a telephone
conversation
was held. between
A. Belisle,
R. Sullivan, Senior Resident Inspector and
T. Chinn,
Compliance
Staff Supervisor.
Additional
information
was
discussed
that
proved that
the licensee's
audited organization
did
respond to audit findings within the ANSI standard
requirements
except
for audit
OPQAA-BF-79SP-03
finding A-1.
Si'nce this
was
the
only
finding- that was identified as having a late response
and no other
0
4
.
13
examples
could
be identified after this audit
was
peformed
in 1979,
this is considered
an isolated
example
consequently
no violation is
issued.
As. a result of the audit program
and implementation
review,
one viola-
tion,and
one
open item were identified and are discussed
in paragraphs
ll.c and ll.d.
c'.
Failure-to Obtain Prompt Corrective Action
Audit OPQAA-BF-79SP-03 identified
as
a finding (A-1) inconsistencies
between
the
licensed
operator
retraining
requirements
contained
in
BFA-75,
DPM N78A13 and the
N-OQAM.
The audited organization
responded,
March 3,
1980,
stating,
"That within three
months
we will either
correct the inconsistencies
defined in this audit
or consolidate
the
three
documents
into
one
master
document
which will describe
the:
operator retraining
program".
Audit OPQAA-BF-80-01 identified
as
a
finding (A-1) that
some
nonconforming
item activities are
not being
conducted
in accordance
with the
requirements.
of Standard
Practice
BF 16.5.
The audited organization
responded April 23,
1980 stating,
"A
revision
is being
made
to Standard
Practice
BF 16.5,
which,
when
approved, will correct this findi'ng.
This will be
issued
by
May 1,
1980".
d.
Both of these
items are
being- tracked,
however at the date of this
inspection,
February
5,
1981,
neither
item
had
been
closed.
Neither
audited organization
had requested
an extension of time to complete the
corrective
action
as
stated
in their
respective
replies
to
the
findings.
This failure to take prompt corrective action is
a violation
(259, 260,. 296/80-02-04)
.
Conflict Between Audit Procedures
0
OP-QAP-18.1 currently defines audit findings
as
Category
A,
B or
C.
QAAS-QAP-3. 1 does not reflect the categorization
of audit findings.
In
discussions
with- the
licensee, it was
learned
that, OP-QAP-18.1 is
currently undergoing revision.
The target date. given for issuance
of
the. revised
procedure
is March 31,
1981.
Until this revised procedure
OP-QAP-18.1 can be reviewed this item is open (259, 260, 296/80-02-12).
12.
Offsite Support Staff (40703)
Reference:
Nuclear-Operational
Quality Assurance
Manual
The inspector
reviewed the referenced
document to verify that the licensee
has identified positions
and responsibilities
in the authority offices to
perform the offsite function of Quality Assurance,
Maintenance,
Outages,
Engineering,
Procurement
and Controls
and Tests.
The inspector interviewed
individuals in each functional area at the managerial
level.
Ouring the
14
interview, the inspector verified that: each individual was qualified for his
position
and was aware. of his responsibilities
and authority in relation to
the authority organization
and the guality Assurance
Program.
As a result- of this review, no violations or deviations were identified.
13.
Training, (41700)
References:
(a)
Technical Specifications
(b)
Operational guality Assurance
Manual, Part III, Section
6. 1, Paragraph
1.5.4 revised 9/79
(c)
Standard
Practice
BF 4.5,
Plant
General
Employee
Training Program, revised. 5/80
(d)
Final Safety Analysis Report, Section 13.3
(e)
Selection
and Training of Nuclear- Power
Plant Personnel,
dated 3/71,
The inspector
reviewed the training program which provides General
Employee
Training
(GET) for both
licensed
and
non-licensed
personnel.
The
Program
was reviewed to verify that:
the program complies with commitments
(references
(a) through (d) above); that the program covers training in the
areas
of administrative
cont'rois
and procedures,
radiological
health
and
safety, industrial safety,
security procedures,
emergency
plan
and quality
assurance
training; prenatal
radiation
exposure
training for females
and.
. supervisors;
and plant cleanliness
and housekeeping
training.
The inspector
reviewed .approximately
50- training records. of the unit operating
personnel
and.interviewed four personnel
(non-licensed).
As a result of this review, one violation was identified.
Technical Specification Section 6.1.E requires that qualifications of plant
management
and operating staff shall
meet the minimum acceptable
levels
as
described
in reference
(e).
The program
implemented, to accomplish this at
Browns Ferry is described in reference (c).
Contrary to the above,
the program is not being accomplished
as described in
that:
Reference
(c) requires
a master training record
be maintained
on all
personnel
and
updated after all the required personnel
have attended
the. course
Training records are not being maintained
on all personnel
in that.'some
temporary personnel
have no training records.
Reference
(c),
Appendix A requires
Measuring
and
Test
Equipment
Training
(GET-12)
be provided for crafts biennially.
An assistant
mechanical
maintenance
supervisor
and
a boilermaker
have
not
been
retrained
as required.
0
15
Reference
(c), Appendix A defines
the
courses
require'd for various
plant personnel
general
employee training.
Thirty randomly selected
personnel
training history
records
were
reviewed
and
none
of the
records indicated that all the. required training had been received.
The
above
examples
are typical, not all inclusive.
This is
a violation
(259, 260, 296/81-02"03).
14.
Requalification Training (41701)
References:
(a)
Technical Specifications
(b)
Final Safety Analysis Report, Section 13.3
(c)
Appendix A, Requalification
Programs
for
Licensed.
Operators
of
Production
and
Utilization
Facilities
The requalification training program
was reviewed to determine
conformance
to references
(a) through (c) above.
The training records of three licensed
reactor operators
and three senior reactor operators
were reviewed.
b
As a result of this review no violations or deviations were identified.
0
15'.
Survei 1 1 ance Testing (61725)
References:
(a)
Techni cal Speci ficati on.
(b) - Section XI, ASME Boiler and Pressure
Vessel
Code
The inspector reviewed surveillance testing activities to ascertain
that the
licensee
has developed
and implemented
programs for control
and evaluation
of surveillance- testing
as required
by Section
4 of reference (a),
and the
inservice inspection
of'pumps
and valves requirements
as described in 10 CFR 50.55a.(g).
The inspector
reviewed surveillance testing with personnel
from the instru-
mentation- section to verify the following:
a ~
A
master
schedule
for
surveillance
testing/calibration/inservice
inspections
required
by Technical Specifications
or 10
CFR= 50.55a
have
been established. which includes:
b.
(1)
Frequency for each test/calibration/inspection
(2)
Plant
group
responsible
for performing
each test/calibration/
inspection
(3)
Surveillance test status
Responsibility
has
been
assigned
in writing to maintain
the
master
surveillance test/calibration/inspection
schedule up-to-date
0
16
c.
Formal
requirements
have
been established
for conducting surveillance
tests,
calibrations,
and inspections
in accordance
with approved
pro-
cedures which include acceptance criteria.
Surveillance testing of the pilot operated
main
steam safety relief valves
was
reviewed.
As
a result of this review,
the inspector
identified. one
violation.
Three. basic
documents
are normally generated
when
a test
program is con-
ducted
by an offsite contractor:
the actual results of the test procedure;
the
note of deficiency/disposition
which documents
any data
outside .the
acceptance
criteria and also, documents. the
TVA disposition of this tested
material;
and,
the test results evaluation
conducted
by TVA to justify the
disposition of the material if deficiencies
have occurred
and to accept the
test. results
as satisfactory if deficiencies
have not occurred.
MMI-107, TVA Test Procedure
for Pilot Operated
Safety Relief Valves, dated
9/80 has acceptance
criteria for the valve testing.
This testing
was
done
by
a contractor
and the results
documented
and
sent to the site
and to
Chattanooga.
However,
no formal evaluation
of the test results
was
com-
pleted by the responsible
TVA personnel.
16.
, Discussions with personnel
at the site-and-at
Chattanooga initially revealed
that
evaluation
of the test
results
was
done
verbally.
The
inspector
questioned
this evaluation,
as test. deficiencies
existed
on four of the
valves.
Also, the
note of deficiency/disposition
was available
from, the
contractor
on only one valve (3-1-4,
S/N 1019)
and not on valves (3-1-23,
S/N 1023; 3-1-42,
S/N 1020;
and 3-1-5,
S/N 1061).
The test- deficiency
on
these
valves
was that the reseat
pressure
was not within the range specified
in MMI-107. All parties
agreed that neither the note of deficiency/dispo-
sition nor the test results
nor the evaluation
was performed
on the three
valves;
and that any test results evaluation
conducted
was only done ver-
bally and should have been documented.
This failure to evaluate test results
and to document test deficiencies is
identified as
a violation (296/81-02-01)
and applies only to Unit 3.
Maintenance
(62700, 62702)
References:
(a)
Technical Specifications
(b)
Section
XI', ASME Boiler and Pressure
Vessel
Code
The inspector
reviewed maintenance activities
on safety-related
systems
and
components
to ascertain
whether the activities were conducted
in accordance
with approved
procedures,
regulatory
guides,
and
industry
codes
and
in
conformance
with Technical
Specification
requirements.
The
following
criteria. were used during this review:
17
Required administrative approvals were obtained prior to initiating the
work
1
Limiting conditions for operation
were
met while the components
were
removed from service
Approved procedures
were. used where the activity appeared
to be beyond
the normal skills of the craft
Activitywas accomplished
by qualified personnel
The licensee
had evaluated
system failures and reported
them in accord-
ance with the Technical Specifications
Written procedures
were. established for initiating requests
for routine
and emergency maintenance.
Criteria
and responsibilities
for review and approval'of maintenance
requests
were established
Criteria and responsibilities that form the basis for designating. the
activity as safety or'non-safety-related
were established
Criteria.
and
responsibilities
were
designated
for performing
work
inspection of maintenance activities
Provisions
and responsibilities
were established for the identification
of appropriate inspection hold points related to maintenance activities
Methods
and responsibilities
were designated
for performing functional
testing of structures,
systems or components
following maintenance
work
and/or prior to their being returned to service.
Sixteen
procedures
were reviewed to verify the implementation of the previ-
ously stated
requirements.
The procedures
were in the areas of reactivity
control
and reactor fTux distribution, instrumentation,
the reactor coolant
system,
emergency
core cooling systems,
plant and electrical
power
systems
and containment
systems.
The procedures
were performed during the 1980/1981
Unit 3 outage.
Specifically, the following procedures
were reviewed:
SIMI"3
SI-4.1.8.3
SI-4.1.A.5, conducted 1/6/81
BF-MMI-51, Check Valves 75-26 and'73-603
MMI-77, Valves 3-1-537 and 3-1-501
MMI.-9B, conducted 8/27/80
MMI-9A, conducted 9/29/80
MMI-49, conducted
11/15/80
MMI-23, conducted 6/3/80,
(LER, Unit 1 R0-80-45, 6/2/80)
~ ~
0
18
TR-103655,
conducted 7/29/80
EMI-6, conducted 1/9/81
EMI-12, conducted
12/4/80
BF-MMI-50, conducted 12/29/80
BF-MNI-97
BF-MMI"17
As a
were result of this review one
open
item and
one inspector
followup item
identified and are discussed
in paragraphs
16.a and 16.b.
a.
Outage Procedure for Handling TRs
Several
documentation
problems with the Outage Section
TR handling were
noted.
These
problems did not significantly affect the work accomp-
lished,
but could
have
and were
a result of the
Outage
Section
not
having
a. procedure for the handling of TRs.
The licensee
committed to
a target
date of March 31,
1981, for developing procedures
to handle
Outage Section TRs.
Until the completion of these
procedures
and their
implementation
is reviewed
by the
NRC, this item is
open
(259, 260,
296/81"02", 09).
b.
Reinstall
HPCI Line I'nsulation
0
During the walk-through of'he
work areas
involved,
the
inspector
noticed that insulation
on the
steam
supply line, at the
pene.
tration of the containment drywell, was not in place.
A work plan
(7819) to add
a bypass
valve
(FCV 73-81)
around the outboard contain-
ment i sol ation
val ve of the,HPCI
steam
supply val ve was
accompl i shed
during the Unit. 3 refueling outage.
The work plan was signed off as
completed;
however=, the removal, modification and reinstallation of the
insulation
was not addressed.
An
ECN was issued to properly install
the insulation.
The completion of the
ECN will be
reviewed during
a
later inspection
and is identified as inspector
followup item (296/
81"02-14).
17.
Licensee Action on Previously Identified Items (92706)
/
Items from the inspection reports discussed
in paragraphs
17.a
and 17.b were
reviewed for completion.
Inspection Reports 50-259, 260, 296/79-17
(Closed)
Item (259,
260,
296/79-17-01);
Failure to provide written
corrective
actions
in training records
when unsatisfactory
operator
performance
was
so
noted
on the Operation's
Performance
Evaluation
sheets.
A review of selected
operator training records
reflected
the
actions
taken
when unsatisfactory
operator
performance
was
so indi-
cated.
, ~ ~
0
19
b.
Inspection Reports 50-259,
260, 296/79-30
(Open) Inspector Followup Item (259,
260, 296/79-30-01):
OQAM/DPM
procedures
do not completely
implement the accepted
QA Program.
The
QA staff is in process
of total implementation of Revision
3
and Revision 4.
Approximately
95% of this implementation
has been
completed.
(2)
(3)
(4)
(5)
(6)
(7)
(Closed)
Inspector
Followup Item (259,
260,
296/79-30-02):
program for outage
group.
The
N-OQAM, Part II, Section
3.2,
Paragraph
4. 1.3 revised
1/80
and
N-OQAM, Section
2. 1,
Paragraph
2.0'contains
provisions for any organization that provides main-
tenance
support and assistance
to the plant manager'to
comply with
applicable division technical, administrative
and quality assur-
ance requirements
as
implemented
by plant instructions.
Discus-
sions with the outage
section
revealed
that they adhere
to the
requirements
as specified in the N-OQAM.
(Closed)
Inspector
Fol 1 owup
Item
(259,
260,
296/79-30-03):
Tracking
system
for plant quality assurance, staff identified
items.
The licensee
performed
an evaluation
as
documented
in
a
letter
dated
February 2,
1980,
of methods
used for tracking
quality problems.
Based
on this evaluation,
the
licensee
has
stated
that- existing
programs, for tracking quality problems
are
adequate.
(Open)
Inspector
Followup Item (259,
260,
296/79-30-04):
Defi-
nition of implementation
time for new
DPM/OQAM procedures.
The
inspector
reviewed
N-OQAM, Part III, Section 8.1,
Paragraph
7.4
which
states
the
implementation
time
by organizations
after
revisions are
made to the
N-OQAM.
This procedure is still in the
final review process.
(Closed)
Inspector
Fol 1 owup
Item
(259,
260,
296/79-30-05):
Standard practice to control chemicals
and reagents
used to verify
LCO values.
The
inspector
reviewed
BF 17. 12,
Water
Quality
Program,
dated, ll/79 and BF 17.13, Chemical Additives for Critical
Systems
at
Browns
Ferry
Nuclear
Plant
dated
11/79.
These
standard practices. delineate responsibilities for acceptable
water-
quality and compliance with chemical
composition specifications
respectively.
(Open) Inspector Followup Item (259,
260, 296/79-30-06):
Issuance
of Sections III and
IV of
DPM N79E2.
The inspector
reviewed
a
draft copy of. Sections III and
IV of
DPM N79E2 dated
June
13,
1980.
At the date
of- the inspection,
February 4, 1981, this draft
is in the review process.
(Open) Inspector
Followup Item (259,
260,
296/79-30-07):
Clari-
fication of
PQAS duties with respect
to
review of TRs.
The
inspector reviewed BF 7. 1, Activity Control
Maintenance Associ-
gC
20
4
ated Activities, revised
5/80.
This
procedure
has
not
been
changed
with the exception
of adding
references
since
the last
date of inspection,
October 1979.
(8)
(Closed)
Inspector
Followup
Item
(259,
260,
296/79-30-08):
Definition of "nonconformance"
and "noncompliance".
The inspector
reviewed
BF 1.2,
Definitions,
revised
5/1/80.
This
section
contains definitions for noncompliance.
and nonconformance.
(9)
(Closed)
Inspector
Followup
Item
(259,
260,
296/79-30-09):
Definition of "second party" and "independent" verification.
The
inspector
reviewed
BF 1.2, Definitions, revised 5/1/80.
Clarifi-
cation
has
been
included for
second
person
verification
and
inspection (independent verification).
(10) (Open)
Inspector
Followup. Item (259,
260, 296/79-30-10):
Imple-
mentation of ANSI N45.2..4 (IEEE336-1971)
1972.
The licensee
has
reviewed. the requirements
of. ANSI N45.2.4
and
has
made
program
changes
to meet the
requirements
of this
ANSI Standard.
These,
program. requirements
are in the review process.
(11) (Open)
Inspector
Followup Item (259,
260, 296/79-30-11):
Imple-
mentation of. ANSI N45.2.8.
The licensee
has reviewed the require-
ments of ANSI N45.2.8-1975'nd
has
made
program changes
to meet
the- requirements
of this
ANSI Standard.
These
program require-
ments are in the final review process.
(12) (Open) Inspector
Followup Item (259,
260, 296/79-30-12):
Organi-
zation and administration
References:
(a)
Letter,
W.
P.
Haass
January
16,
1980
(b)
Letter;
L.
M. Mills
January
30,
1980
(c)
Letter,
W.
P.
Haass
February
13,
1980
(d)
Letter,
L. M. Mills
March 3, 1980
(e)
Letter,
L. M. Mills,,
August 15'; 1980.
to
H.
G. Parris
dated
to
W.
P.
Haass
dated
to
L. M. Mills dated
to
W.
P.
Haass
dated
to
W.
P.
Haass
dated
References
(a)
and, (c) contained
concerns
about
the quality
assurance
program at
TVA.
References
(b)
and (d)
answered
the
concerns
raised
in references
(a)
and (c).
Reference
(e)
was
a
request for additional
time to provide adequate
implementation of
commitments
as stated
in references
(b) and (d).
At the date of
this inspection
January
26-30
and
February 1-6,
1981,
approxi-
mately
95% of the
implementation
of these
commitments
has
been
completed.
21
(13) (Closed)
Item (259,
260,
296/79-30-19):
Modification/Addition
Instruction
No.
15 (MAI 15)
~
MAI 15 deals primarily with receipt,
storage,
handling. and issuing of materials.
BF 16.8 delineates
the
TVA procedures
by which the Outage Unit will conduct procure-
ment activities.
Thus there exists
a clear trail for the routing,
review and approval of Outage Unit procurement documents.
(14) (Closed)
Item (259,
260,
296/79-30-20):
Plant
procedures
that
implement
QA requirements
for record
storage.
The
inspector
reviewed
BF 2. 10, Plant. Records
Management,
dated, 12/30/80,
which
implements the Browns Ferry Nuclear Plant Information
Management
Manual.
This manual
describes
the program for records
management.
designed to meet the commitment to ANSI N45.2.9.
I
(15)
(16)
(17)
(18)
(19)
(20)
(Closed)
Item
(259,
260,
296/79-30-21):
Receiving
inspector
training
and qualification program clarification.
The inspector
reviewed
BF 16.4,
revised
11/28/79
and
noted that
the receipt
inspector training
and certification program
had been clarified.
The review of this item generated
an
open
item concerned with the
implementation. of the
QC inspector certification portion of the
N-OQAM, as discussed
in paragraph
18.b.
(Closed)
Open Item (259, 260,. 296/79-30-22):
Maintenance
of items
in storage;
power plant stores
and outage
warehouse.
The inspec.
tor reviewed both BF 16.4, revised 11/28/79,
and the storage
ware-
houses..
The review verified. that procedures
now contain
programs
for weld
end preparation
protection
and rotation of electrical
equipment
and that these
programs
have been implemented.
(Closed)
Item (259,
260, 296/79-30-23):
Inspection of rigging and
lifting devices.
Based.
on
a review of both
DPM 78S2
and
BF 14.24
the
inspector
concluded
that
a satisfactory
system
has-
been
developed for the inspection of lifting devices
and rigging used
by Maintenance
and Power Stores,
(Closed)
Item (259,
260, 296/79-30-24):
Modification/Addition QA
requirements.
MAI 15, revised 9/9/80,'eferences
both the
N-OQAM
and the
Browns Ferry materials
handling
procedures
and. uses
the
format as described in the N-OQAM;
(Open) Inspector Followup Item (259,
260, 296/79-30-26):
Conflict
in audit, procedures.
The conflict between
OP-QAP-18.1
and
QAAS-
QAP-3. 1 has not been corrected.
(Cl osed)
Inspector
Fol 1 owup
Item
(259,
260,
296/79-30-29):
Inadequate
Cleanliness
Procedure.
The inspector reviewed
BF 3;10,
Cleanliness
of Piping Systems,
revised
6/80 and
DPM 73E5,
Clean-
liness Criteria for Piping Systems
All Nuclear Plants,
revised
22
'8/80
and concluded that adequate
cleanliness
procedures
existed.
In interviews with the plant quality assurance
staff these clean-
liness controls were being satisfactorily implemented.
(21) (Closed)
Item (259,
260, 296/79-30-30):
Designation of retention
of
housekeeping,
inspection
records.
BF 14.3
was
revised
on
9/19/80
and
now identifies housekeeping
inspections
as
a QA record
and has assigned
a retention time for this type record.
(22),(Closed)
Item (259;.260,
296/79-30-31):
Storage. of QA records
in
office files.
The inspector
noted that a records group supervisor
has
been
appointed
and that the location
and relative
volume of
records
in office files has
been identified.
During this review,
the inspector
not'ed that the recently revised
N-OQAM had not been
incorporated into the Browns Ferry records
procedures.
This item
is addressed
in paragraph
18'.
18.
Independent
Inspection Findings/Items
(92706)
a.
QA Records Storage
'uring the closeout
review of item 259,
260, 296/79-30-31,
the inspec-
tor observed that the. licensee
was not in compliance with the accepted
QA Program in that records
were in temporary storage
longer= than three
months
and
no index existed
in the
N-OQAM listing the exceptions
to
this three-month
commitment.
Due. to
the- fact that
the
N-OQAM was
changed
in
12/80
to reflect
the
8/80
QA program
change
and
the
exception listing is in progress,
no violation is issued.
The licensee
has committed to a target date of April 30,
1981; for the incorporation
of the three-month
record exceptions into the
N-OQAM and
a target date
of March 1,
1982, for the
l-'icensee
to
have. the
program
completely
implemented at the site.
Until this area
has
been
reviewed by the
NRC,
this item is open (259, 260, 296/81-02-08).
b.
Procedure Incorporation of Inspector Certification Program
During the closing review of item 259, 260, 296/79-30-21,
the inspector
observed that the licensee
had not incorporated
Part II, Section
5.3A,
N-OQAM, Training
and Certification
Program for the Quality Control
Inspectors,
dated
10/22/80,
into the
BF Standard
Practices
and
the
Modification Addition Instructions.
The. licensee
has
committed to a
target
date of March 31,
1981 for the
completion
of the
necessary
procedure
rev'isions.
Until the
NRC reviews the incorporation, this
item is open (259, 260, 296/81-02-11).
P
P
23
19.
Index of Findings of Inspection Reports 50-259,
260, 296/81-02
Item Numbers
259, 260, 296/81;02-.
01
02
02
02
03
03
03
04
04
04
05
05
05
Fai lure
Failure
Failure
Failure
Failure
Failure
Failure
Item Description
Violations
to Evaluate Results of Test
to Control Drawings
to Control Vendor Technical Manuals
to Control TVA Generated
Documents
to Maintain Retraining and Training
to Take Prompt Corrective Action
to Submit 10 CFR 50.59 Report
Deviations
Report
Location
15
8.a
8.b
8.c
13
11.c
9.a
06
06
06
07
07
07
08
08
08
09
09
09
10
10
10
11
11
11
12
12
12
13
13
13
Failure to Perform Corrective Action-
Procedure
Change
Failure. to Perform Corrective Action
Conduct Survey
Open Items
gA Records Storage
Outage Procedure for Handling TRs
Document Receipt Acknowledgement
Training and Certification Program for gC
Inspectors into Standard Practices
Conflict. Between Audit- Procedures
Clarification of STEAR Implementing Procedures
Inspector Followup Item
Reinstall
HPCI Line Insulation
3.d
3.h
18.a
16.a
8.d
18.b
11.d
9.b
16.b