ML18025B583

Revises Response to NRC 810318 Ltr Re Violations Noted in IE Insp Repts 50-259/81-02,50-260/81-02 & 50-296/81-02.New Date for Issuance of Revised DPM Is 810901.Revision to Std Practice Bf 4.5 Issued 810708

ML18025B583
Person / Time
Site:	Browns Ferry
Issue date:	07/23/1981
From:	Mills L TENNESSEE VALLEY AUTHORITY
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
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ML18025B581	List: ML18025B583
References
NUDOCS 8108110089
Download: ML18025B583 (66)

Text

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TENNEssEE YALLEY.$ 4~9'9I8$ FQV N t i LnN1 :I- ger;;,.

A, CHATTANOOGA, TENNESSEE 37401 400 Chestnut Street Tower II 8I JlJLR7 Pl2: l5 July 23, 1981 Mr. James 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:

By my letter to you dated April 17, 1981 we submitted a response to Inspection 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 are revisions to that response.

This was discussed with Floyd Cantrell of your staff on July 17, 1981. 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 L. M. Mills, M nager Nuclear Regulation and Safety Enclosure

'108110089 81073&1 PDR ADOCK 05000259 I',

6 PDR .I An Equal Opportunity Employer

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ENCLOSURE REVISED RESPONSE TO INSPECTION REPORT NOS.

50-259/81-02, -260/81-02, -296/81-02 BROWNS FERRY NUCLEAR PLANT

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Reference:

Letter, from L. M. Mills to J. P. O'Reilly dated April 17, 1981, response to subject inspection report)

Violation B.

Under Corrective ~ste s tlhich Have Been Taken it was stated that a revision to DPM No. N78A13 would be completed by June 15, 1981. The new date for issuance of the revised DPM is September 1, 1981.

Violation C Under Date When Full Com liance Will Be Achieved it was stated that changes to standard practices (BF 4.5) will be issued by June 15, 1981. The revision to Standard Practice BF 4.5 was issued July 8, 1981.-

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O UNITED STATES NUCLEA'R REGULATORY COMMISSION REGION II 101 MARIETTAST., N.W., SUITE 3100 t

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Tennessee Valley Authority ATTN: H. G. Parris Manager of Power 500A Chestnut Street Tower II.

Chattanooga, TN 37401 Gentlemen:

Subject:

Report Nos. 50-259/81-02, 50-260/81-02 and 50-296/81-02 This refers to the routine safety inspection conducted by G. A. Belisle and others of this office on January 26-30 and February 2-6, 1981, of activities authorized by NRC'Operating License Nos. DPR-33, DPR-52 and DPR-68 for the Browns Ferry facility. Our preliminary findings were discussed with H. L. Abercrombie and J. A. Coffey at, the conclusion of the inspection.

'I This inspection was a comprehensive examination of your management and quality assurance controls related to licensed activities. Inspection was conducted in selected key areas of responsibility at both the plant site and your authority offices. Areas examined during the inspection and our findings are discussed in the enclosed inspection report. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations by the i'nspectors ~

During the inspection, it was found that'ertain activities unde'r your license appear to violate NRC requirements. These items and references to pertinent requirements are listed in the Notice of Violation enclosed herewith as Appen-dix A. Elements to be included in your response are delineated in Appendix A.

During the inspection it was found that certain activities under your license .

appear to deviate from commitments to the Commission in response to two Notices of, Violation and have safety significance. These items are identified in the Notice of Deviation enclosed herewith as Appendix B. Similar problems have been identified during recent inspections of other TVA activities. Our concerns regarding these problems were discussed during an enforcement conference con-ducted in this office on February 11, 1981. As discussed during that meeting, the new NRC enforcement policy requires submitting responses under oath or affirmation and deviations from NRC commitments take on a new dimension. A reply to the deviations identified during this inspection is not requested. We will consider your reply to my letter dated February 19, 1981 on a previous Browns Ferry inspection in our evaluation of this matter.

In addition to the need for corrective action regarding these specific viola-tions, we are concerned about the implementation of your quality assurance program that permitted their occurrence. Consequently, in your reply, you should describe in particular those actions taken or planned to improve the effective-ness of your quality assurance program.

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'MA'R I8 1981 Tennessee Valley Authority P

We have examined actions you have taken with regard to previously identified enforcement matters and unresolved items. The status of these items is discussed in the enclosed report.

In accordance with Section 2.790 of the NRC "Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosed inspec-tion report will be placed in the NRC Public Document Room. If this report contains any information that you believe to be proprietary, it is necessary that you make a written application within 20 days to this office to withhold,such information from public. disclosure. Any such application must include the basis for claiming that the. information is proprietary and the proprietary information should be contained in a separate part of the document. If we do not hear from you in. this regard within the specified period, the report will be placed in the Public Document Room; Should you have any qu'estions concerning this letter, we will be glad to discuss them with you.

Sincerely EC R. C. Lewis, Acting Director Division of Resident and Reactor. Project Inspection

Enclosures:

1. Appendix A, Notice of Violation

2. Appendix B, Notice of Deviation

3. Inspection Report Nos. 50-259/81-02, 50-260/81-02 and 50-296/81-02 cc w/encl:

H. L. Abercrombie, Plant Superintendent R. E. Rogers, Project Engineer H. N. Culver, Chief, Nuclear Safety Review Staff H. J. Green, Division Director

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APPENDIX A NOTICE OF VIOLATION Tennessee Val 1 ey Authority Docket Nos. 50-259, 50-260 & 50-296 Browns Ferry 1, 2, and 3 License Nos. DPR-33, DPR-52 & DPR-68 As a result of the inspection conducted on January 26-30 and February 2-6, 1981, and in accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7, 1980), the following violations were identified.

A. 10 CFR 50, Appendix B, Criterion XI states that test results shall. be docu-.

mented and evaluated to assure that test r'equirements have been satisfied.

The accepted QA Program, Section 17.2. 11, requires results of tests per-formed on CSSC shall be documented, evaluated and. their acceptability bilityy determined by qualified individuals.

Contrary to the=above, test results were, not evaluated and their accepta-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 MMI107 and no documentation of the deficiency or evaluation of acceptability was done by either the- contractor, who did. the testing, or by 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 for any of the valves..

This is a. Severity Level V Violation (Supplement I.E.) and is applicable to Unit 3.

B. 10 CFR 50, Appendix B, Criterion XVI states that measures shall be estab-lished 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.).

C. 10 CFR 50, Appendix B, Criterion V and Section 17.2.5 of the accepted QA program require 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.

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Tennessee Val 1 ey Authority License Nos. 50-259, 50-260 Browns Ferry 1, 2, and 3 'and 50-296

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 main-tained on all personnel. Certain temporary per'sonnel 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.).

D. 10 CFR. 50.59 requi res that the licensee submit to the NRC annually or at such shorter intervals as may be specified in the license, a report con-taining 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.).

E.. 10 CFR 50, Appendix B, Criterion VI and Section 17.2.6 of the accepted QA Program require that measures shall be established to control instruc-tions, 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 areas and one, sent to maintenance in multiple copy form, had only one locatable copy in maintenance. Also, four manuals with- .,

out 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 accepted QA Program and the N-OQAM were in use at Browns Ferry with outdated revisions.

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Tennessee Valley Authority License Nos. 50-259, 50-260 Browns Ferry 1, 2, and 3 and 50-296

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 Orawing Control Section were not managed to prevent improper use of outdated revisions.

This. is a Severity Level V Violation (Supplement: I.E.).

pursuant to the provisions of 10 CFR 2.201, you are hereby required to submit to this office within twenty-five days of. the date of this Notice, a written state-ment or explanation in reply, including: (1) admission or denial of. the alleged violations; (2) the reasons for the violations if admitted; (3) the corrective steps which have been taken and the results achieved', (4) corrective steps which will be taken to avoid further violations; and '(5) the date when full compliance will be achieved'.. Under the authority of Section 182 of the Atomic Energy Act of 1954, as amended, this response shall be submitted under oath. or affirmation.

MAR 1 8 198l

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APPENDIX B NOTICE OF DEVIATION Tennessee Valley Authority License Nos. DPR-33, DPR-52 &

DPR"68 Based. on the results of the NRC inspection conducted on January 26-31, and February 2-6, 1981, certain of your activities appear to deviate from your commitments to the Commission as indicated below:

A. As stated in TVA correspondence dated January 25, 1980, in response to IE Reports 50-259, 50-260, and 50-296/79-30, Appendix A, Item E, TVA stated "As a result of TVA' own review of its procedures, we, will review each USED, including any revisions, to ensure that each USED accurately addresses the change before notification to NUCLEAR POWER that ENDES work is completed on the change. This will provide further assurance that the change is accu-rately evaluated in the USED. This procedural change was implemented on December 3, 1979."

Contrary to the above, a procedure change was=. implemented to EN DES-EP 2.03

~, on January 8, 1981, exceeding the commitment date by 13 months.

As stated in Reports TVA 50-259, correspondence dated Janaury 25, 1980, in response to IE 50-260, and 50;296/79-30, Appendix A Item A, TVA stated "Additionally, existing section instructions will be surveyed by the plant quality assurance staff by January 31, 1980. The results of these surveys will be documented.and reported to the plant superintendent."

Contrary to the above, no survey had been conducted by the established date, January 31, 1980. As of this inspection; the survey had not been conducted.

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UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II t

0 101 MARIETTAST., N.W., SUITE 3100 ATLANTA,GEORGIA 30303

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Report Nos. 50-259/81-02, 50-260/81-02 and 50-296/81-02 Licensee: Tennessee Valley Authority 500A Chestnut Street Chattanooga, TN 37401 Facility, Name: Browns Ferry Docket Nos. 50-259, 50-260 and 50-296 License Nos. DPR-33, DPR-52 and DPR-68 Inspection at Browns Ferry site near Decatur, Alabama. and the Authority Offices in Chattanooga and Knoxville, Tennes ee Inspectors: s a/

G. A sl Date S gned P. E. Fredric son Date Signed 3

T. A. eebl s D te . igned S/6 g/

P. H. Skinner Date Signed I

Approved by:

C. . Upright, > f, Ma ement Programs Section, te igned Engineering In p tion nch, Division of Engineering and Technical Inspection

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; QA 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.

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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. 8.a, 8.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 10 CFR 50.59, 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).

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DETAILS Persons Contacted Licensee Employees Abercrombie, Plant; Manager Andrews, Nuclear Power QA Staff Bynum, Assistant Plant Manager, Operations Cambell, Nuclear Power, Chief OMB Chinn; Compliance Staff Supervisor-J. Coffey, Nuclear Power Assistant Director J. Crowell, Modification Director J. Ferguson, Assistant Outage Nuclear Safety Staff Director'albreth, AJ Glover, Shift Engineer Training R**J Harness, Assistant Plant Manager, Maintenance M. Jackson, Assistant Electrical Maintenance Supervisor Lee, QAA Staff R. Metke, Results. Supervisor S. Mindel, QA Engineer C. Myers, Head Nuclear Engineer, NEB 4'4 G Odell, Nuclear Power Management Service Staff Support AAR Parker,'Assistant to Director, Nuclear Power.

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Pittman., Instrument Maintenance Supervisor 8 8'g Poling,. QA&A Staff AAR Sessons, Nuclear Power Staff

• R*R Smith, QA Staff Supervisor AJ Swindell, Outage Director AB Weeks, Power Stores Other licensee employees contacted included operators, mechanics, security force members, and office personnel.

NRC R'esident Inspector "R. Sullivan "G., Paulk "Attended exit interview at site on February 4, 1981.

"*Attended exit interview at authority offices in Chattanooga, Tennessee on February 6, 1981

• • "Attended both exit interviews

2. Exit Interview 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

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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 TVA-TR75-1A, Revision 4 ECN Engineering Change Notice EMO El ectr i ca 1 Ma i nte nance Of fi ce EMS Electrical Maintenance Shop EN DES Engineering Design LER Licensee Event Report MMO Mechanical Maintenance Office MMS Mechanical Maintenance. Shop N-OQAM'SRB Nuclear-Operational Quality Assurance Manual Nuclear Safety Review Board QA Quality Assurance SIL Section Instruction Letter STEAR Special Test, Experiment or Activity Report STI Special Test Instruction TR Trouble Report USQD 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.

'a ~ (Closed) Infraction (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.

b. (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 ECN L 1911. 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.

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'I (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) I'nfraction (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 USQOs for ECNs P0081, L2051, P3000 and.P0267. The inspector also requested the following procedures: TDP-EP 41.02, TDP-EP-41.03, TDP-EP-41. 04, TDP" EP-4105, TDP-EP" 41. 06, TOP" 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,

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2.4,, 2..5,. EN OES-EP 3.03, and TOP-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 ECNs 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 USQOs 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 insti-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

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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 Matts 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.

(Cl osed) In fracti on (259, 260, 296/79-30-25): Appendi x A; i tern C, failure to conduct. audit. The inspector reviewed the results of conducted January 21-25, 1980. This was a special audit'PQAA-BF-80-SP-01 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 SIL 5 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,

'979, as part of the corrective action to avoid further noncompliance, the licensee stated, "Existing section instructions will be surveyed by-

0 the plant quality assurance staff by January 31, 1980. 'he 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) Oeficiency (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 Oecember 18, 1979. =The inspector reviewed ten trouble reports from the Mechanical Maintenance Section and,found them satisfactory.

4. Unresolved 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 10 CFR 50, 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 QA 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.

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7. Design, Design Changes and Modifications (37700, 37702)

References:

(a) BF 8. 1, Modification Status, dated 1/79 (b) BF 8.2, Temporary Alterations, dated 1/80 (c) BF-8.3, Plant Modification Work Plans, dated 12/80 (d) BF 8.4,. 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 QA Program and ANSI. N45 2.11-1974's 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'he 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 design changes were-reviewed to verify the implementation of the previously mentioned require-ments:

P-3000 Replace existing GEMAC Transmitters with Foxboro Transmitters for PT-'4-50, 51 and PT-64-67 P-0350 Reverse polarity on diode IN4499, in. panel 9-29, TBI-5, TB2-1 and TB2-9, points D,and E P"0267 Provide chain driven operators for valves HCV-74-49, 55, 69 and HCY-69"500 P-0338 Replace existing rupture disk, Fike Metal Products Model 8-PLHOV with Fike Model 8-C;PVC P-0277 Replace existing transmitter mounting studs at each MSRV tailpipe with vendor supplied equipment

0 P-,0353 Reroute CRD scram header vent to 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 12/80 (b) BF 2.7, Changes to Vendor Manua'ls, 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'pecifications, FSARs 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:

Instructions Manuals ~Drawin s EMI-6'I-15 45N644 15N500 MMI"22 47W200 MMI-99 55N670 OI-77 77W210 SI-4.2..A;6 122D9378 S I-4.8.B.4. 4 47W600 Techni cal Specifications, Uni-t 1 45N2677 N-OQAM Topical Report-TVA-TR75-1A Several Vendor Technical Manuals 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 The licensee utilizes two types of drawings, controlled and uncon-trolled. 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

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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 failure 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).'he 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. 10 CFR 50, 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 located 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 (25) 85895 Transmitter; Series Ptessure (37) 821125 Valves, Component "

(48) 69C30"91133-2 Monitor, Area (22) 1.3.5-5.E Also, contrary to 'the above, the EMO and the EMS had two instruction manuals without files identification; and the MMO and MMS 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; y'et, 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) ~

Q

C. Failure to Control TVA Generated Documents 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 Dece'mber 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 index for both total copies sent and copy numbers. 10 'CFR 50, 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 riot 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) .

d. 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 open (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 Instruc-tions, Revised 1/80 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.'hat 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'nd three STIs for review:

STEAR 80-06 STI 165-STEAR 80-19 STI'86 STEAR 80"26 STI 187's

a. result of this. review, one violation and one open item were identified and are. discussed in paragraphs 9.a and,9.b.

'a ~ Failure to Submit 10 CFR 50.59 Report The inspector. noted that the 1979 Annual Operating Report did not contain a summary of'TEARS conducted during 1979. The QA Staff Supervisor stated that an OPQA audit (No. OPQAA-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 May 28; 1980 did identify the problem and that the plant did, submit. a supplement to the= report to the Assistant Director 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 have been submitted via another report and was informed that the supplement was the- only means in effect at present. The licensee the need for submission of the supplement but apparently was had'ecognized planning on sending the supplement 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).

b. Clarification of STEAR Implementing Procedures Both references (a) and (b) give directions fo1. 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

revised. The licensee has committed to a target date'f April 30, 1981, for completing the revision of reference (a) and conducting a review. and" revi sion 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 13).

10. Offsite Review Committee (40701)

References:

(a) Technical Specifications, Section 6.2 (b) TVA, Office of Power, Nuclear Safety Review Program Manual, dated TVA, Office of Power, Nuclear Safety Review Procedures 1/81'c)

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'hrough December 1980.

1 11.

As a result of: this- review,. no violations or deviations were identified.

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 a 0 Program-The referenced documents were reviewed with respect to the accepted QA Program and ANSI N45.2. 12 (Draft 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 Imp 1 ementati on 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'echnical 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:

Audi t. Audit Report Date OPQAA-B F-80 "S P "01, 02/21/80 OPQAA-BF-80TS-01 08/26/80 OPQAA-BF-79SP-03 12/14/79 OPQAA-BF-7900"02 04/25/79 OPQAA-BF-7900-08 12/06/79 OPQAA-BF"7900"09 12/12/79 OPQAA"BF-80TS"03 12/11/80 OPQAA-BF-80TS-2 11/21/80 OPQAA-B F-8000-01 03/04/80 OPQAA-BF"8000-02 04/17/80 OPQAA"BF-'000-03 07/28/80 OPQAA-BF-8000-04 10/01/80 OPQAA-BF"8000-05 01/05/81 In addition to the previously mentioned audits, the. inspector reviewed approximately 80 plant surveys 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 QA: SILs. 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

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'he audit program and implementation review, one viola-tion and one open item were identified and are discussed in paragraphs ll.c and 11.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".'udit 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 finding. This will be issued by May 1, 1980".

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).

d. Conflict Between Audit Procedures 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).

1P,. 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.'he inspector interviewed individuals in each functional area at the managerial level. During the

0 S I

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) ANSI N18. 1, Selection and Training of Nuclear Power Plant Personnel, dated 3/71 The inspector reviewed the training program which provides General (GET) for both licensed and non-licensed personnel. The GET Employee'raining 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 controls 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 required 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) 10 CFR'0.55, Appendix A, Requalification Programs for Licensed, Operators of Production

. and. Utilization Fac.i 1 i ti es 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; As a result of this review no violations or deviations were identified.

15. Surveillance Testing (61725) 0

References:

(a)

(b)

Technical Specification 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 survei 1 lance testi ng/ca ibrati on/in servi ce 1

inspections required by Technical Specifications or 10 CFR 50.55a have been established which includes:

(1) Frequency for each test/calibration/inspection (2) Plant group responsible for performing each test/calibration/

inspection (3) Surveillance test status

b. Responsibility has been assigned in writing to maintain the master surveillance test/calibration/inspection schedule up-to-date

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'he 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.

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 cri-teria were used during this r'eview:

0 17 Required administrative approvals were obtained prior to initiating the work 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 Activity was 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 flux 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.B.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)

Lt g 4 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-MMI-97 B F-MMI-17 As a result of this review one open item and one inspector followup item were 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 wor'k 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 Insulation During the walk-through of the work areas involved, the inspector noticed that. insulation on the HPCI steam supply line, at the pene-tration of the containment drywell, was not in- place. A work plan (7819)'o add a bypass valve (FCY 73-81) around the outboard contain-ment isolation valve. of the HPCI steam supply valve was accomplished 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 1'ater 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.

'a ~ 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.

s) ~ ~

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) (Closed) Inspector Followup Item (259, 260, 296/79-30-02): QA 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.

(3) (Closed) Inspector Followup Item (259, 260, 296/79-30-03):

Tracking system for plant quality assurance staff identified items. The licensee performed an evaluati'on 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.

(4) (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,'aragraph 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.

(5) (Closed) Inspector Followup 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 11/79 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.

(6) (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.

(7) (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-

-0 ~

20 ated Activities, revised 5/80. This procedure has not been changed with the exception of'dding references since the last date of inspection, October 1979 (Closed) Inspector Followup Item (259, 260, 296/79-30'-08):

'8)

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 requi rements 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 and 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 to H. G. Parris dated January 16, 1980 (b) Letter, L. M. Mills, to W. P. Haass dated January 30, 1980 (c) Letter, W. P. Haass to L. M. Mills dated February 13, 1980 (d) Letter, L. M. Mills to W. P. Haass dated March 3, 1980 (e) Letter, L. M. Mills to W. P. Haass dated August 15, 1980 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'hese commitments has been completed.

C >0 .0 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'torage. 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.

(15) (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.

(16) (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'll/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.

(17) (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 li.fting devices and rigging used by Maintenance and Power Stores.

(18) (Closed) Item (259, 260, 296/79-30-24): Modification/Addition QA requirements. MAI 15, revised 9/9/80, references both the N-OQAM and the Browns Ferry materials handling procedures and uses the format as. described in the N-OQAM.

(19) (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.

(20) (Closed) Inspector Followup 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 gA record and.has assigned a retention time for this type record.

(22) (Closed) Item (259, 260, 296/79-30-31): Storage of (}A 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 noted that the. recently revised N-OEM had. not been incorporated into the Browns, Ferry records procedures. This item is addressed in paragraph 18.a.

18. Independent Inspection Findings/Items (92706)

a. gA Records Storage During the clos'eout. review of item 259, 260, 296/79-30-31, the inspec-tor observed. that the- licensee was not in compliance with the accepted gA'rogram in that records were in temporary storage longer than three months and no index existed in the N-OEM listing the exceptions to this three-month commitment. Due: to the fact that the N-OEM was changed in 12/80 to reflect the 8/80 gA 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-OEM and a target date, of March 1, 1982 for the 1'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-OEM, Training and Certification Program for the guality 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 revisions. Until the NRC reviews the incorporation, this item is open (259, 260, 296/81-02-11).

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19. Index of Findings of Inspection Reports 50-259, 260, 296/81-02 Report Item Numbers Item Description Location 259, 260, 296/81.-02--

Violations 01 Fai lure to Evaluate Results of Test 15

02. 02. 02 Failure to. Control Drawings, 8.a Failure to Control Vendor Technical Manuals 8.b Fai lure to Control TVA Generated Documents 8.c 03 03 03 Failure to Maintain Ret~aining and Training 13 04 04 04 Failure to Take Prompt. Corrective Action 11. c 05 05 05 Failure to Submit 10 CFR 50.59 Report 9.a Deviations 06 06 06 Failure to Perform Corrective Action- 3.d Procedure Change 07 07 07 Failure to Perform Corrective Action- 3.h Conduct Survey Open Items gA Records Storage 18.a 09 09 09 Outage Procedure for Handling TRs 16.a 10 10 10 Document Receipt Acknowledgement 8.d 11 11 11 Training and Certification Program for gC 18.b Inspectors into Standard Practices 12 12 12 Conflict Between Audit Procedures 11.d 13 13 13 Clarification of STEAR Implementing Procedures 9.b Inspector Followup Item Reinstall HPCI Line Insulation 16.b

~or e 0

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