ML18039A674

Responds to NRC 981209 Ltr Re Violations Noted in Insp Repts 50-259/98-07,50-260/98-07 & 50-296/98-07,respectively. Corrective Actions:Will Revise Procedure NEPD-8 Re Vendor Nonconformance Documentation Submission to TVA

ML18039A674
Person / Time
Site:	Browns Ferry
Issue date:	01/21/1999
From:	Abney T TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-259-98-07, 50-259-98-7, 50-260-98-07, 50-260-98-7, 50-296-98-07, 50-296-98-7, NUDOCS 9902020320
Download: ML18039A674 (18)

Text

CATEGORY 1 REGULATORY INFORMATION DISTRIBUTION SYSTEM (RZDS)

CCESSION NBR:9902020320 FACZL:5'0-259 Browns DOC.DATE: 99/01/21 NOTARIZED: NO Ferry Nuclear Power Station, Unit 1, Tennessee DOCKET 05000259 I

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50-260 Browns Ferry Nuclear Power Station, Unit 2, Tennessee 05000260 50-296 Browns Ferry Nuclear Power Station, Unit 3, Tennessee 05000296 AUTH. NAME AUTHOR AFFILIATION ABNEY,T.E. Tennessee Valley Authority l RECIP . NAME RECIPIENT AFFILIATION UN

SUBJECT:

Records Management Branch (Document Control Desk)

C Responds to NRC 981209 ltr re violations noted in insp repts 50-259/98-07,50-260/98-07 & 50-296/98-07,respectively.

Corrective actions:will revise procedure NEPD-8 re vendor nonconformance documentation submission to TVA.

DISTRIBUTION CODE: IEOZD COPIES RECEIVED:LTR i ENCL TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response 5 SIZE:

E'OTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-3-PD 1 1 DEAGAZZO,A 1 1 INTERNAL: ACRS 2 AEOD/SPD/RAB 1 1 AEOD TTC 1 1 DEDRO 1 1 E E 1 1 NRR/DRCH/HOHB 1 1 NRR/DRPM/PECB 1 1 NRR/DRPM/PERB 1 1 NUDOCS-ABSTRACT 1 1 OE DIR 1 1 OGC/HDS3 1 1 RGN2 FILE 01 1 1 D

EXTERNAL: LZTCO BRYCE,J H 1 1 NOAC 1 1 NRC PDR 1' NUDOCS FULLTEXT 1 i 1 N

~ I NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE,DOCUMENT CONTROL DESK (DCD) ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED: LTTR 19 ENCL 19

Tennessee Valley Authority, Post Office Box 2000, Decatur, Aiabarna 35609.2000 January 21, 1999 U. S. Nuclear Regulatory Commission 1'0 CFR 2.201 ATTN: Document Control Desk Washington, D.C. 20555 Gentleman:

In the Matter of Docket Nos. 50-259 Tennessee Valley Authority 50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN) NRC INSPECTION REPORT 50 259 r 50 260 r 50 296/98 07 COMMENTS ON VIOLATION 50 260 r 296/98-07-04 This letter provides TVA's comments on the subject NOV transmitted by letter from Mr. H. 0. Christensen, NRC, to Mr. J. A. Scalice, TVA, dated December 9, 1998. In the letter, two violations of NRC requirements50-296/98-07-01). were identified.

TVA agrees with the first violation (VIO This violation does not require a response since the corrective actions are already adequately addressed on the docket in the inspection report.

The second violation (VIO 50-260, 296/98-07-04) in the letter was associated with the procurement and receipt activities for a valve part. This violation does not require a response since the corrective actions are already adequately addressed in the inspection report. While TVA agrees with the violation, the discussion in the inspection report is not correct in all aspects. For clarity, we have provided our.

comments in the Enclosure. These comments do not affect the 9902020320 990i2i PDR ADOCK 05000259 8 PDR

U.S. Nuclear Regulatory Commission Page 2 January 21, 1999 corrective a'ctions addressed on the docket in the inspection report.

There are no commitments in this letter. If you have any questions on these comments, please contact me at (256) 729-3675.

Si cerel Abney Site Licen ng a d Industry Affair Manager Enclosure cc: See page 3

0 U.S. Nuclear Regulatory Commission Page 3 January 21, 1999 Enclosure cc (Enclosure):

Regional Administrator U.S. Nuclear Regulatory Commission Region II 61 Forsyth Street S.W.

Suite 23T85 Atlanta, Georgia 30303 Mr. P. E. Fredrickson U. S. Nuclear Regulatory Commission Region II 61 Forsyth Street S.W.

Suite 23T85 Atlanta, Georgia 30303 NRC Resident Inspector Browns Ferry, Nuclear Plant 10833 Shaw Road Athens, Alabama '5611 Mr. L. Raghavan, Project Manager U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852

0 ENCLOSURE TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)

UNITS 1, 2, AND 3 INSPECTION REPORT NUMBER 50 259 50 260 g 50 296/98 07

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COMMENTS ON NOTICE OF. VIOLATION (NOV)

RESTATEMENT OF VIOLATION (VIO) 50-260, 296/98-07-04 10 CFR 50 Appendix B, Criterion V, requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.

The licensee' Nuclear Quality Assurance Plan, TVA-NQA-PLN89-A, Revision (Rev.) 8, Section 6.1, states that the Quality Assurance Program requires that quality-related activities shall be prescribed by documented instructions appropriate to the circumstances. Activities shall be accomplished in accordance with these procedures and instructions.

TVA nuclear power mechanical design standard DS-M18.2.18, Rev. 10, Note T2054, requires nonconformances to the requirements of the contract to be handled in accordance with the vendor's quality assurance program. Nonconformances with a disposition of "Accept As-Is" or "Repair" shall be submitted to TVA for approval.'VA standard program and process procedure SPP-4.2, Material Receipt 'and Inspection, Rev. 0, implements the requirements of TVA NQA-PLN89-A concerning receipt and inspection requirements for quality-related materials. Section 3.6 of this procedure specifically implements the requirements of DS-M18.2.18 and requires responsible engineering personnel to disposition material nonconforming conditions and document the results of the disposition on a Receiving Unsatisfactory Report (RUR).

Contrary to the above, on October 8, 1997, contract number 121076190ZNU4138 was placed with Fisher Control without imposing the requirements of DS-M18.2.18, Note T2054, for a QA Level 1 purchase order. This failure resulted in an inadequate receipt inspection on November 14, 1997, which was performed for TVA Item Identification Code (TIIC) No. CBW9098C. This procurement action involved-the purchase of three Fisher Pressure Controller Model 4160 flappers, part number 1H2669-41132. The vendor provided nonconformance report (NCR) Nos. 544579-1, -2, and -3 in connection with deviations from the vendor

t specification for the flapper diameter. Fisher design required a diameter of 1.99 to 2.00 inches and the measured, diameter of all three flappers was 1.95 inches. The vendor also provided a recommendation for use as-is. These nonconformances were never dispositioned by Procurement Engineering and the results documented on a RUR, in accordance with the requirements of procedure SPP-4.2.

This is a Severity Level IV Violation (Supplement I).

TVA's COMMENTS ON VIOLATION In the third paragraph of the violation discussion, it is stated that TVA nuclear power mechanical design standard DS-M18.2.18, Rev. 10, Note T2054, requires nonconformances to the requirements of the contract to be handled in accordance with the vendor's assurance program and that nonconformances with a 'uality disposition of "Accept-as-is" or "Repair" be submitted to TVA for approval. It further states that Section 3.6 of TVA SPP-4.2, Materials Receipt and Inspection, specifically implements the requirements of DS-M18.2.18. Actually, as detailed below, DS-M18.2.18 Note T2054 is only applicable if designated on the Procurement Data Sheet (PDS) in accordance with NEDP-8, Technical Evaluation for Procurement of Materials and Services. Thus, SPP-4.2 does not directly implement the subject note.

TVA nuclear power mechanical design standard DS-M18.2.18, Rev. 10, provides procurement personnel with a list of approximately 180 Standardized Procurement Notes which may be used as an aid to procurement activities. When used, these Standardized Procurement Notes communicate applicable engineering requirements and other provisions to procuring organizations, and may be applied to procurement materials or services documents.

The Standardized Procurement Notes are, however, not stand-alone requirements and apply to specific procurements only if prescribed on the contract. For typical contracts the notes that are pertinent to the procurement activity are specific'd by TVA on the purchase contract.

TVA procedure NEDP-8 establishes the procedural requirements to perform technical evaluations and to determine quality requirements for the specification and procurement of materials.

NEDP-8 is used for procuring safety related and non-safety material, as well as equipment of various quality class designations. Section 3.3.6 of NEDP-8 requires the preparation of a PDS which, in turn, establishes the necessary technical and quality requirements for procuring items. Typical attributes listed on the PDS include such items as technical requirements and specifications, receipt inspection requirements, requirements E-2

for 10 CFR Part 21 applicability, handling of nonconformances, arid so forth. These types of standard requirements are incorporated into the procurement contract by the Procurement Engineering Group (PEG) by including the applicable Standardized Procurement Notes from DS-M18.2.18 on the PDS as appropriate for the safety and quality class of the material being procured.

Custom technical or TVA specified design requirements may also be included on the PDS.

The PDS for contract 121076190ZNU4138 did not prescribe any specific TVA technical requirements since the part was a standard vendor supplied replacement part. The PDS did include several Standardized Procurement- Notes from DS-M18.2.18 as enumerated below.

1. Note T1061 requires the parts and materials be supplied under a Quality Assurance (QA) program evaluated and accepted by TVA, and which is in accordance with the applicable provisions of ANSI N45.2.

2. Note T2050 requires that the vendor review the contents of the bid and communicate any exceptions or changes, including part number changes, to TVA prior to executing the order, and provide an analysis of the effects of .any such changes on form, fit, function, or material.

3. Note T2055 specifies that the parts supplied on the order were subject to the provisions of 10 CFR Part 21 regarding the reporting of defects and noncompliances and requires that TVA be informed of each such defect or noncompliance. (Inclusion of Note T2055 is standard on all QA level 1 device requisitions.)

4. Note T2056 requires the vendor to provide access to their facilities for quality inspection or audit, if requested.

5. Note T4157 requires a Certificate of Conformance (COC) be provided which certifies that the items are in conformance to the product specifications for the part/catalog numbers referenced on the contract.

6. Note T5050 requires the item be marked with the TVA purchase order and traceable to the COC.

7. Note T6056 specifies ANSI N45.2.2 Level C packing, shipping, handling, and storage requirements.

NEDP-8 step 3.3.6.B.5 requires that arrangements between the supplier and TVA for the identification, and control and disposition of items that do not meet procurement requirements be E-3

established on the PDS. This procedure currently includes a provision that TVA approval is required on procured items which h v a supplier recommended disposition of "Accept-as-is" or "Repair" if procurement requirements are not met by the supp lier.

When invoked, this provision is incorporated by including mechanical design standard DS-M18.2.18 Note T2054 on the PDS which requires nonconformances to the requirements of the contract to be handled in accordance with the vendor's QA program, and that recommended dispositions of "Accept-as-is" or "Repair" be submitted to TVA for approval. If this note is not emp loye d disposition of nonconformances is delegated to the vendor. For the subject contract, Note T2054 was inadverten tly omitted, which is considered by TVA to be a procedure violation of NEDP-8 since current practice is to impose Note T2054 on those contracts where Note T2055 (Part 21) is specified. This omission b quently resulted in not processing the flappers as nonconforming during receipt inspection as explained be low.

For the subject requisition, though not contractually obligated to do so (since Note T2054 was not specified), Fisher provided TVA with an NCR with the each of the 3 delivered flappers. The NCRs described a minor deviation from the manufacturers design specifications in which the flapper diameter dimension was 1.95 inches in lieu of 2.00-1.99 inches. Fisher also provided their luation to "Accept-as-is" indicating that the dimension deviation did not affect the form, fit, or function o f the part, and that all code requirements were met. The vendor also provided a COC as required by contract Note T4157, which warranted that parts were manufactured and shipped in conformance with contract specifications, were satisfactorily tested and t d that the items were free from defects in material/workmanship, and were interchangeable in form, function and material with those originally supplied.

m fit and The, material was subsequently received on site Novembe r 14 1997 and found to be conforming during receipt inspection in accordance with Section 3.4 of SPP-4.2, Material Receipt and Inspection. Section 3.4 states, "items are acceptable if the results of receipt inspections indicate that the items conform with PEG procurement package requirements." Section 3.6 o SPP-4.2 stipulates requirements for resolving unacceptable d't' Acquisition and Material personnel or the PEG, Since, however, Note T2054 had not been specified on t hee PDS SSP-4.2 receipt inspection instruct'ions would not regard the d 'd d "Accept-as-is" dispositions as conditions needing further review by TVA. Thus, the receipt inspection accep e parts for issue and use. Had Note'2054 been included on the PDS, the material would have been determined to be non-conforming during receipt inspection and dispositioned in accordance with SPP-4.2, Section 3.6.

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0 The absence of Note T2054 on a particular contract would allow the vendor to disposition nonconformances in accordance with their own ANSI N45.2 approved QA program and without direct TVA involve'ment. For manufactured parts, the vendor is typically the designer and maintains the engineering drawings and design specifications. Hence, it follows that the vendor is in the best position to provide an engineering disposition regarding the acceptability for use of nonconformances. For procurements where TVA provides specific technical requirements and design specifications, Note T2054 would be applicable and TVA would prime responsibility for the approval of nonconformances. 'ssume Contract 121076190ZNU4138 fits into the former category since TVA requested a replacement part by part number and did not stipulate detailed technical requirements. Since the nonconformance regarding the flapper diameter was a variance from the vendor internal design specifications, Fisher was the most appropriate party to disposition the NCRs. The TVA review, when specified by Note T2054 for this kind of procurement, can best be characterized a's a general oversight review of the vendor disposition rather than an independent engineering review since TVA typically does not have access to the vendor's design specifications. Therefore, the safety significance of the omission of Note T2054 for this procurement is considered low based on the following:

1..The NCRs were written against Fisher's design.

2. Fisher dispositioned their NCRs in accordance with their audited ANSI N45.2 program.

3. Fisher provided a COC stating: "Fisher Controls certifies that items herein were designed, manufactured, and shipped in.

conformance to contract specifications. All required tests and inspections were performed and the results found to be satisfactory. We further certi'fy that all items shipped herein are free 'from defects in material and/or workmanship.

Parts are certified to be interchangeable in form, fit, function and material with those originally supplied."

Fisher Controls is on TVA's approved vendor list with an ANSI N45.2 QA program. These vendors are periodically audited to verify conformance with their,QA program. Fisher Controls was last audited in June 1997 by the Nuclear Procurement Issues Committee (NUPIC). TVA is a NUPIC participant.

CONCLUSION The characterization in the violation that SPP-4.2, Section 3.6 directly implements standard DS-M18.2.18, Rev. 10, Note T2054 is out of context. As outlined above, DS-M18.2.18 Note T2054 is only applicable if designated on the PDS in accordance with NEDP-8. SPP-4.2, Section 3.6, only applies when material does not conform with PEG package (PDS) requirements.

For a replacement part procurement such as that described in this NOV, TVA considers the inclusion of DS-M18.2.18 Note T2054 as a conservative measure not specifically required by TVA' QA,Plan or by ANSI N45.2.13, Quality Assurance Requirements for Control of Items and Services for Nuclear Power Plants. Accordingly, as discussed in the inspection report, the developed corrective action for recurrence control of this item involves revising procedure NEDP-8 to more clearly describe when vendor nonconformance documentation is to be submitted to TVA and approved by TVA engineering. These corrective actions are unaffected by the preceding comments on this violation.

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