ML18033B125
| ML18033B125 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 01/10/1990 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML18033B122 | List: |
| References | |
| NUDOCS 9001180341 | |
| Download: ML18033B125 (5) | |
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UNITED STATES NUCLEAR REGULATORY COIVIMISSION WASHINGTON, D. C. 20555 ENCLOSURE SAFETY EVALUATION BY THE. OFFICE-OF NUCLEAR REACTOR-REGULATION COMPONENT AND PIECE PART UALIFICATION SECTION-III.12.0 OF" THE BROWNS.FERRY NUCLEAR.PERFORIIANCE PLAN TENNESSEE VALLEY AUTHORITY BRQWNS-FERRY NUCLEAR PLANT UNIT 2
1.0 INTRODUCTION
Deficiencies in the Tennessee Valley Authority's (TVA) site wide practices for the procurement and control of safety related replacement items were identified in TVA Nuclear Safety Review Staff reports, R-84-17-NPS, I-83-13-NPS, and R-85-07-NPS.
NRC Inspection Reports 50-327, 50-328/86-61 and 50-327/88-07, 50-328/88-07 cited similar deficiencies at TVA's Sequoyah facility which were classified as potential enforcement findings concerning failure to take corrective action.
Section III.12.0 of Volume 3 of the Nuclear Performance Plan (NPP) provides a program intended to correct deficiencies in component and piece part qualification and. control at the Browns Ferry (BFN) site.
BFN is preparing procedures and guides for implementation of the program.
These documents are in various stages of prepar ation and implementation.
2.0 EVALUATION The BFN Items Evaluation Group (IEG) was established to involve nuclear engineering (NE) in the procurement process.
Their two primary goals are to:
1.
Verify that previously environmentally qualified equipment has not been degraded through the use of spare and replacement parts.
2.
Establish programs and practices that will ensure that previously
-qualified equipment (seismic and environmental) will not be degraded in the future through the use of spare and replacement items.
IEG activities are structured into major elements to implement the program.
This is to be done in two phases.
1.
Prior to restart of Unit 2:
a.
Review plant Iriaintenance history to identify activities that have replaced safety related components or items.
b.
Evaluate replacement items that have been installed in 10 CFR 50.49 systems.
c.
Evaluate 10 CFR 50.49 inventoried commercial grade spare parts to assure that their subsequent.use will not degrade previously quali-fied equipment.
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2.
After restart of Unit 2:
a.
Evaluate safety related replacement items installed in safety related applications other than 10 CFR 50.49 systems., Seismically sensitive components at BFN will be reviewed in accordance with the TVA response to USI A-46 requirements presented in Generic Letter 87-02.
b.
Evaluate remaining inventoried commercial grade spare parts to assure that their subsequent use wi 11 not degrade previously qualified equipment.
c ~
Develop pre-engineered specifications detailing technical and quality requirements, source audit and inspection requirements, receipt inspection requirements, part conditioning requirements, and, if appl.icable, post-maintenance testing requirements.
d.
Establish a conditional'release program which will require justifica-tion and senior management review for installation of any item which is nonconforming or otherwise not documented as meeting criteria for a specific safety related application.
In order to better assess the status and depth of the Component and Piece Part gualification Program, the staff obtained copies of some of the program guidance and implementation documents supporting Section III.12.0 of Volume 3 to the BFN NPP.
The documents are identified and discussed briefly as follows:
I.
822 '89 0227 754,. "Replacement Items Project",
BFN Program Plan, February 1989.
Discussion - The program plan elaborates on the outline provided in Sec-tion III.12.0 of Volume 3 by identifying major tasks developing 10 CFR 50.49 replacement item evaluation requirements and providing definitions and references.
2.
B 01 '89 0620 001 NEP-4. 1, "Procurement",
Revision 2, June 15, 1989.
Discussion - This Nuclear Engineering Procedure establishes the organiza-tions and controls for identifying and establishing the quality and technical requirements necessary to support the procurement of permanent plant equipment, materials, and non-personal services.
It identifies responsibilities within TVA for procurement and requirements related thereto.
3.
SDSP - 16.1 "Evaluation and Dedication of Replacement Parts or Components fot 10 CFR 50.49 Application", Revision 6, December 10, 1987.
Discussion - This Site Director Standard Procedure (SDSP) explicitly delineates the method for verifying that 10 CFR 50.49 replacement
- items, obtained through previous procurement practices, have not or will not degrade the equipment qualification status.
It verifies that procured items have met all technical, quality and regulatory requirements.
3.0 The scope of this procedure is carefully limited, deferring to other pro-cedures as appropriate.
For example, current and future procurements of replacement items will be evaluated by the Contractor Engineering 'Group (CEG) in accordance with SDSP-16.2 and SDSP-16.9.
SDSP
- 16. 16, "Material Issuance and Return", Revision 2, April 25, 1989.
Discussion - This procedure establishes the method and assigns the respon-sibilities for the control of material issuance and return activities from site warehousing facilities at the Browns Fer ry Nuclear Plant.
Controls established by this procedure are applicable to materials, components and spares supplied or procured for use in operations, maintenance, and modi-fication of BFN.
References listed in the procedure include three docu-ments providing requirements and twelve listed as interface documents.
The program for BFN involves the TVA Division of Nuclear Engineering.
Nuclear Engineering has coordinated the programs for the various nuclear plants, taking advantage of lessons learned at Sequoyah in developing the program description and supporting procedures and guidance for Browns Ferry.
CONCLUSION 4.0 In conclusion, the staff believes that the program being developed for BFN to assure component and piece part qualifications is likely to correct the deficiencies identified in Section III.12.0 of the Browns Ferry NPP.
The primary reason for this conclusion is that TVA has had recent similar and successful experience at Sequoyah.
TVA has learned from that experience and is factoring the lessons learned into the implementing documents for BFN.
Staff review of the program plan as described in the NPP and avail-able implementing and supporting documents provided positive support for the BFN program for component and piece part qualification.
The NRC staff will perform additional reviews and inspections as required prior to startup to ensure satisfactory program implementation.
REFERENCES NRC Letters 2.
3.
U.
S. Nuclear Regulatory Commission, November 11, 1986, letter from B. Grimes (NRC) to Tennessee Valley Authority transmitting Inspection Report 50-327/86-61.
- - -, April 13, 1988, letter from S.
Richardson (NRC) to TVA, trans-mitting Inspection Report 50-327/88-07.
- >> -, Nuclear Regulatory Commission, February 19, 1989, letter from H. Denton to TVA, transmitting Generic Letter 87-02.
TVA Letter 1.
Tennessee Valley Authority, October 24, 1'988, letter from S. White to NRC, providing Revision 2 of the Browns Ferry Nuclear Performance Plan.
Princi pal Contributor:
J. Matt Dated:
January 10, 1990