ML20151E751
| ML20151E751 | |
| Person / Time | |
|---|---|
| Site: | Hartsville  |
| Issue date: | 07/14/1988 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8807260191 | |
| Download: ML20151E751 (18) | |
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TENNESSEE VALLEY AUTHORITY i
1 CHATTANOOGA. TENNESSEE 374o1 SN 157B Lookout Place i
JUL 141988
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I U..S., Nuclear Regulatory Commission
?.TTW i Document Control Desk Washington, D.C.
20555 Centlemen:
HARTSVILLE PROJECT - NRC REGION II INSPECTION REPORT NO. 50-518/87-01 This is in response to Kenneth P. Barr's letter dated March 1, 1988, to S. A. White that transmitted NRC Inspection Report No. 50-518/87-01 for the 11artovillo Project. _This report cited TVA with one violation, 50-518,
-520/87-01-01, Severity Level IV.
Also iCentified in this inspection report iwere two unresolved items, 50-518, -520/87-01-02 and 50-518, -520/87-01-03; and one open allegation, OSP-87-A-0075.
Out responso to.the violation and our submittal of information concerning both unresolved items and the allegation are all included as enclosure 1.
An extension request, revising TVA's submittal date for the violation responso from March 31, 1988 to May 31, 1988, and from May 31, 1988 to July 15, 1988, was discussed with Stevo Elrod, NRC Reglon II, on March 30, and on May 27, 1988,~ respectively.
Enclosuro 2 provides a list of commitments made by TVA in this responso. If there are any questions concerning this responso, please telephone 1
W. T. Watters at (615) 751-2723.
Very truly yours, TENNES".E
..Ef AUTHORITY R.
ridley, D ector Nuclear Licensing and Regulatory Affairs Enclosure ec: See page 2 6
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PDR ADOCK 05000510 G
,1 An Equal Opportunity f.mployer l.
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U.S. Nuclear Regulatory Commission
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Ms. S. C. Black, Assistant Director for Projects TVA Projects Division U.S. Nuclear Regu?,ata 7 'ommission 11555 Rockvillo r..,
Rockville, Maryla.,? 20852 I
I Hr. F. McCoy, Assistant Director for Inspection Programs TVA Projects Division Office of Special Projects U.S. Nuclear Regulatory Commission Region 11 101 Marietta Street, NW, Suite 2900 Atlanta, coorgia 30323 Bellefonte Resident Inspector Bellefonte Nuclear Plant EP.O. Box 2000 Hollywood, Alabama 35752 U. S. Nuclear Regulatory Commission Watts Bar Resident Inspector P.O. Box 700 Spring City, Tennessee 37381 l
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- ENCLOSURE 1 HARTSVILLE PROJECT RESPONSE TO NRC REGION 11 INSPECTION REPORT NO. 50-518/87-01 KENNETH P. BARR'S LETTER TO S. A. WHITE DATED MARCH 1, 1988 Violation 50-518, 5?O/87-01-01. "Failure to Follow Procedure For Equipment in Warehouse Storage" 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," indicates activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriato to the circumstances and shall be accomplished in accotdance with these instructions, procedures, or drawings.
TVA's Quality Assurance (QA) Topical Report, TVA-TR75-1A, Rev. 9 in Tables 17E-1 (for design and construction) and 17E-2 (for operations) indicates that the Nuclear Quality Assurance Manual (NQAM) delineates responsibilities, requirements, and commitmeats for the quality assurance program.
The NQAM, Part I, Section 3.6, Rev. 1, "Packaging, Shipping, Receiving, Storage, and Handling," indicates packaging, shipping, receiving, storage, and handling shall be in accordance with ANSI N45.2.2-1972, "Packaging, Shipping, Receiving, Storage, and Handling of Items f.or Nuclear Power Plants."
ANSI N45.2.2-1972 in paragraph 6.4.2 (8) indicates maintenance requirements specified by manufacturer's instructions for the item shall be performed.
TVA Drawing 89-3GA-0200-00-0A and Nucleat Power Standard TS 01.00.15.14.03, Rev. O, "Equip;nent and Material Storago Requirements for Nuclear Power Stores," specify the storage maintenanco at the Hartsvillo facility.
TS 01.00.15.14.03 specified that Reactor Water Cleanup Pump and Residual Heat Remaval Pump Motor Proventive Maintenanco include vendors' specifi'ed maintenance.
TVA Power Stores Quality Assurance Manual Section 7.0 and sub-tier procedure PS-QAP 7.3, "Storage of Items," required for warehouse storage that end caps, blank flanges, and other protectivo covers be in place to prevent damage or the accurulation of dirt, dust, and moisturo.
Manufacturer's storage maintenanco requirements for the following equipment is in the manuals indicated:
Fire Protection Pump Motors (Contract 821689)
US Electric Motors Instruction 509-1, November 1979 Reactor Water Cleanup Pump (General Electric (GE) Mastor Parts List (MPL) G33-6001)
Unlon Pump Company Manual for Order N753764 A & B
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Residual lleat Removal Pump Motors (GE MPL E12-6002)
GE Inst.ruction Manual CEK 70205 a.
Contrary to the above, manufacturer's storago maintenance requirements were not always incorporated in drawing 89-3GA0200-00-0A or in TS j 01.00.15.14.03.
Consequently, the following required maintenanec.,was not being performed for fire protection motors:
Preventive coating checks Oil changes Oil level maintenanco Space heater application and monitoring of winding temperatures Shaft rotation periodicity i
b.
Contrary to the above, the requirement in Nuclear Power Standard TS 01.00.15.14.03 to perform vendor specified maintenance was not implemented in the sito PM program as follows:
Reactor Water Cleanup Pumps Semi-annually, bearing housings were not being drained and refilled No protective coatings on pumps' (serial Nos. 5463752 and
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N753764A201) shafts Rusty bolts on pumps (serial Nos. 5463752 and N753764A20)
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Rusty scaling surfaces on the suction flange for pump serial No. 5463752 Residual Heat kamoval Pump Motors
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Oil level was not being maintained. Motors overfilled with
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oil are LilJ-1103027, JMJ-908021, LHJ-1103028. Motors underfilled with oil are ENJ-525002, FNJ-601022, CNJ-309001, FNJ-601021.
Quarterly inspections were not being performed for physD:al damage, cleanliness, oil loaks, oil level, signs of condensation, discoloration of paint, sign of vermin activity, integrity of protectivo coatings, and integrity of all closures, c.
Contrary to the above, eight items in warehouse storage failed to moet the requirements of procedure PS-QAP 7.3 in that caps, covers, and seals were missing on stored QA material.
Items were also stored with foreign material (mud) on the component.
Surfaco rust existed on some surfaces, bolts, and wold preparation surfaces.
This is a Severity Level IV Violation (supplement II).
(NOTE! TVA will discuss each element of the violation, parts a., b., and c.
individually.)
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1 Part a. Incorporation of Manufacturer's Require.ments 1.
Admission or Denial of the Alleged Violation TVA admits the violation occurred as stated.
2.
Reason for the Violation
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Upon the deferral of Hartsville,fPhipps Bend, and Yellow Creek Nuclear Plants, the Division of Nuclear Engineering (DNE) issued long-term storage and preventivo maintenance instructions by Drawings 89-3GA0200-00-0A.
These drawings were an effort to streamline and consolidate the storage and preventive maintenance instructions received from the various vendors, and in,some casos, are not in strict accordance with a particular vendor's instructions.
At the time of the issuance of the DNE drawings, DN8's interpretation of ANSI 45.2.2, "rackaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants (During the Construction Phaso),"
was that vendor instructions, unless explicitly stated by the vendor as requirements, were recommendations which could be modified for I
particular situations. However, this interpretation of ANSI N45.2.2 was not documented.
3.
Corrective Steps Which Have Boon Taken and Results Achieved DNE has reviewed the vendors storage and preventivo maintenanco instructions against those specified in Drawings 89-3GA0200-00-0A and Procedure TS 01.00.15.14.03, "Equipment and Hatorial Storage Requirements for Nuclear Power Stores," and concludes that TVA requirements are adequato for those motors sinco the motors are not nuclear safety rotated.
4.
Corrective Steps Which Will Be Taken To Avoid Further Violations TVA will reviso Topical Report TVA-TR75-1A to clarify the commitment to ANSI N45.2.2 to allow deviations from vendor storago and proventive
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maintenance instructions based upon an engineering evaluation. DNE will establish and issue an approved procedure which definos the method of specifying preventive maintenance requirements.
Included in l
this procedure will be directions on the consideration of vendor's recommendations and instructions.
S.
Dato When Full Complianco Will be Achieved I
The Topical Report will be revised to clarify the commitment to ANSI 4
N45.2.2 by December 1, 1989.
DNE will issue an approved proceduro on
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proscribing proventivo maintenance requirements by December 1, 1988, i
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Part b. Implementation of Vendors Maintenance Requirements 1.
Admission or Denial of the Alleged Violation TVA admits the violation occurred as stated.
2.
Reason for the Violation TVA's warehouse personnel did not implement the prescribed preventive maintenance requirements due to a misunderstanding of the requirements, j
3.
Corrective Steps Which Have Been Taken and Results Achieved TVA's Power Stores has identified and tagged all material associated with this portion of the violation.
The tags require that the item identified will undergo an evaluation by DNE before its use in a safety-related application at one of TVA's nuclear plants.
4.
Corrective Steps Which Will Be Taken to Avoid Further Violations DNE will provide training to warehouse personnel on the uso of the preventive maintenance and storage Drawings 89-3GA0200-00-0A. TVA's Power Stores will train responsible personnel in the subject of preventive maintenance in accordance with the Office of Power training
- program, j
5.
Date When Full Compliance Will Be Achieved j
Power Stores completed tagging of all items on June 1, 1988. DNE will complete the training of warehouse personnel by October 1, 1988.
-S-Part c. Items in Storano Failed to Meet Requirements (Item c, will be discussed as subparts c.1 and c.2.)
col MissinR Caps and Covers 1.
Admission or Denial of the Alleged Violation TVA admits the violation occurred as stated.
2.
Reason for the Violation Warehouse personnel did not fully implement the requirements of an internal procedure.
3.
Corrective Steps Which Have Been Taken and Results Achieved TVA's Power Stores has identified all items with missing caps and covers. These caps and covers have been replaced on all identified items.
4.
Correct.ive Steps Which Will Be Taken to Avold Further Violations TVA's Power Stores personne'.have been and will continuo to bo trained on preventivo maintenance requirements in accordanco with the Offico of Power training program.
5.
Date inutn Full Compliance Will Be Achieved Caps and Covers replacement was completed on June 1, 1988. Training on the controlling proceduro (PS-QAP 7.3, "Storage of Items") was completed on July 8, 1988.
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c.2 Items Not in Compliance With Procedure 1.
Admission or Denial of the Alleged Violation TVA admits the violation occurred as stated.
2.
Reason for the Violation Warehouse personnel did not fully implement the requirements of an internal procedure.
3.
Corrective Steps Which Havo Been Taken and Results Achieved TVA has identified and removed items from nuclear reserve status which had small portions of their exterior covered with mud. TVA's preventive maintenance drawing prescribes refurbishment requitements prior to issuance for use.
The surface rust will be removed in accordance with this refurbishment practice prior to issuance for use, per PS QAP 4.3.
4.
Corrective Steps Which Will Be Taken to Avold Further Violations n.
TVA's Power Stores personnel have been and will continue to receivo training on preventive maintenance requirements, including applicable refurbishment practices.
5.
Date When Full Compliance Will Be Achieved Items identified as having small portions of snud on their exterior surface were removed from nucicar rescevo status on Juno 1, 1988.
Training of Power Stores personnel on preventivo maintenanco requirements including applicable refurbishment practicos was completed on July 8, 1988.
Unresolved item 50-518, 520/87-01-02. "Adequacy of Preventive Maintenance Program" The inspector reviewed the implementation of Preventivo Maintenance (PM) on items in storage. The requirements for PMs at the Hartsville facility are specified in Division of Nuclear Engineering (DNE) Drawing 89-3GA0200-00-0A (note: no title given) and Nuclear Power Standard, TS 01.00.15.14.03, Rev. O, "Equipment and Material Storage Requirements For Nuclear Power Stores."
Except as noted below, it was determined these requirements woro proporly implemented for the sample inspected and were being tracked by a computerized system.
The accomplishment was documented on a computerized card. Numerous cards were examined and found to be neatly and properly filled out before the cards were stored in the QA records vault.
The inspector reviewed, the QA records, for a sample of equipment in the PM program to ensure that required PM's had been performed. The following deficiencies were identified:
Inspection Racords From/
or Date Equipment PMll Task Equipment Rocolved on Site PM00034 Rotate Shaft ESW motor 4/11/80 - Notes 1, 2, 4 PM00082 Rotato Shaft Fire Protection 9/22/82 - Notes 1, 4 Pump Motor PM00178 Heat Check Recirculation 6/10/80 - 8/21/79 -
Pump Motor Hotes 3, 5 Pit 00288 Heat Check Crano-Main 5/26/81 - 4/7/79 -
Holst control Note 5 Panol PM01262 llumidity Off Gas Dryer 4/24/79 - Notes 1, 4 Check PM01525 Storage Area Building CWF 5/14/82 - N/A Inspection Note 1:
Receipt Inspection documents could not be located for this equipment.
Note 2:
No record of annual shaft rotation (PM0034) for the ESW motor between 9/18/81 to 3/24/83.
Note 3:
No record of monthly heat check (PM00178) for Recirculation Pump Motor in the following months:
7/80, 9/80, 10/80, 12/80, 6/84, 7/86, 8/86, 9/86, and 10/86.
Note 4:
No receipt inspection reports could be found for equipment in PM00034, PM00082, and P.t01262.
Note 5:
No record of PM's be'.ng performed between datos indicated for equipment in PM0017) and PM00288.
The oil used in the below listed equipment was not verified by TVA as equivalent to the manufacturer's requirements:
011 Manufacturer's
' Equipment Used Required Oil Fire Protection Pump Motor Shell Rimula Texaco N.3364 or Regal 10 weight Marine VSI TL-10104 Reactor Water Cleanup Pump Shell VSI 32 Shell VSI 27 Residual Heat Removal Shell Rinula Shell Ensis 10w or Gulf Pump Motor 10 weight No-Rust Engine oll, Grade No. 1 TVA Discussion TVA has performed an extensive review of each item identified in this section. TVA has concluded that procedures PS-QAP 4.3 "Transfer of Items from Hartsville, Phipps Send, and Yellow Creek to nuclear power plants", and PS-QAP 4.5, "Reallocation of Items," provide satisfactory i..ternal controls in this area. PS-QAP 4.3 requires a transfer inspection process prior to shipping QA material from Hartsville (or Yellow Creek) to any of TVA's nuclear sites. This process identifies any documentation or record deficiencies, including preventive maintenance records, prior to shipment.
In addition, the process will identify any degradation which is evident. PS-QAP 4.5 requires a DNE inspection if there is evidence that deficiencies exist, such as improper storage conditions prior to transfer.
Also TVA's Nuclear Quality Assuthnce Manual Part III, Section 2.2, requires a receipt inspection at the TVA nuclear site.
These procedures prevent the transfer and installation of unacceptable materials at nuclear sites.
The following investigation section details the specific results of TVA's review.
INVESTIGATION PM Task Equipment Data PM00034 Rotate Shaft ESW Motor 4/11/80 Notes 1, 2, and 4 Noto 1:
Receipt inspection documents could not be located for this equipment.
Response
The Receipt Inspection Report could not be located. NCI N' 88-3011 was written to require a reinspection of this motor.
A new receiving report was initiated.
Internal TVA aueds have not identified missing Receipt Inspection Reports as a genuric problem.
Note 1:
No rocord of annual shaft rotation'botween September 18, 1981, and March 24, 1983.
Respc..se:
From September 1981 to March 1982, the task was not performed.
Since March 1982, shaf t rotations have been required annually and tracked by task cards (initially generated in March 1983 for this equipment). In accordance with Procedure PS-QAP 8.1, "Preventive Maintenance of Items," task cards are now-generated for overdue tasks and should prevent recurrence of this type of deficiency in the future.
The reporting frequency is once nonthly. Subsequent shaft rotations exhibited freedom of movement with no detectable problems.
Note 4:
No receipt inspection reports could be found for equipment.
Response
See the response to Note 1.
PM Task Equipment Date PM00082 Rotato Shaft Fire Protection 9/22/82 Pur Motor Notes 1 & 4 Notes 1 & 4: Receipt inspection' documents could not be located for this equipment.
Response
The origina) procurement document identifies this item as non-QA.
The existing TVA QA Program at the time of the original receipt inspection did not require documentation of receipt inspections of non-QA items.
PM Task Equipment Date PM00178 Heat Check Recirculation 6/10/80 - 9/21/79 Pump Motor Notes 3 & S Note 3:
No racord of monthly heat checks in the following months:
July 1980, September 1980, October 1980, December 1980, June 1984, July 1986, August 1986, September 1986, and October 1986.
Respoase:
The item was received in September 1978. The requirement was for a heat check every three months:
December 1978, April 1979, August 1979, November 1979, February 1980, August 1980, November 1980, and February 1981.
The above heat checks were documented on the Motor Inspection Checklist.
Af ter February 1981, the requirement was changed to monthly which was accomplished through May 1984.
On July 19, 1984, QC Investigation Report No. 35577 was written to document that the QC material inspector did not witness or document the pH task.
In June 1986 the motor was moved from "C" Level storage to "B" Level utorage an action which would normally eliminate the environment for energizing the heater strip.
The PM task was inadvertently deleted from July 1986 to October 1986, at which time, it was discovered that this motor' required the heater strip to be energized regardless of storage level. The item was then energized and has been maintained as required, since.
Subsequent megger tests have revealed no equipment degradation-due to the heater strips not being energized for the timeframe identified. TVA believes the current program, which requires the generation of task cards, should prevent recurrence of this deficiency.
Note 5:
No record of PM being performed between dates indicated for equipment.
Response
See the response to Note 3.
PM Task Eguipment Date PM00288 Heat Check Crane-Main S/26/81 - 4/7/79 Holst Control Note S Panel Note 5:
No record of PM being performed between dates indicated for equipment.
i Responso:
The PM heat check was not put into the preventative maintenance program until May 1981. Since May 1981 the PM has been
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accomplished as required.
A visual inspection reveals no 1
apparent damage.
PM Task Equipment Date PM01262 Hun".dity Off Gas Dryer 4/24/79 Check Notes 1 & 4 Notes 1 & 4: Receipt inspection documents could not be located for this item.
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Response
The Receipt Inspection Report could not be located. NCI No.
88-S010 was written requiring a reinspection of this item.
The QA vendor documentatien was found and a Receipt Inspection q
Report was initiated and completed on March 10, 1988. TVA believes that this is an isolated incident, as prior internal audits have not found generic problems with missing records at Hartcvllle.
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g Task Equipment Date PM01525 Storage Area Building CWF 5/14/82 Inspection No note
Response
The equipnent inspection requirements for individual warehouses became effective in 1982.
Construction Engineering Procedure (CEP) 13.02, Revision S, "Storage and Preventive Maintenance",
dated June 8, 1982, stated these requirements. Revision 4 had no auch requirements. Since the approval of CEP 13.02, Revision S, storage area inspections have been accomplished as required.
(Note - CEP 13.02 is currently at Revision 11.
This procedure was used by the Hartsville Warehouso Personnel until it was superseded by PS QAP 8.1 in February 1987.)
The oli used in the equipment listed below was not verified by TVA as equivalent to the manufacturer's requirements.
Equiprent Oil Used Manufacturer's Required Oil Fire Protection Shell Rimula TeXPJo N. 3364 or Regal Pump Motor 10 weight Marine VSI TL-10104
Response
Although the U.S. motor manufacturer did not identify the approved equivalent, GE, the NSSS vendor did identify substitutes for vortical motors. GE Storage Instruction No. 34 A180535 approves Shell Rimula 10 weight.
Equipment Oil Used Manufacturer's Required Oil Reactor Water Shell VSI 32 Shell VSI 27 Cleanup Pump
Response
Purchase Contract No. 78K82-535696 indicates that this substitute was approved by the responsible Project Mechanical Engineer.
Equipment Oll Used Manufacturer's Required Oil Residual Heat Shell Rinula Shell Ensis 10w or Gulf Removal Pump Motor 10 weight No. Rust Engino 011, Grado No. 1
Response
GE Storage Instruction No. 34 A180535 approves Shell Rimula 10 weight.
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Unresolved Item 50-518 520/87-01-03. "Tracking and Implementing Modifications. Bulletins, and Information Notices for Equipment in Power Stores Storage" Information was requested as to how equipcent modifications that were being implerented at nuclear power plants (examples:
Engineering Change Notices (ECN), responses to NRC Compliance Bulletins, etc.) would be incorporated in equipnent shipped from the Hartsville facility to nuclear power plants.
The Power.9 tores management posillon was that they could only ship equipment as requested.
The tracking of necessary modifications at a specific site was not their responsibility. Specifically, the licensee was requested to supply informatica regarding their plan to comply with NRC Compliance Bulletin 8/-02, "Fastences," for the Martsville and Yellow Creek facilities.
This Bulletin asked the licensee to test samples of studs, bolts, car screws, and nuts in stores at their facilities to ensure they meet required mechanical and chemical specifications. The inspector identified in storage A-193 grade B7 bar stock which is covered by this Bulletin.
Some examples of this material are in contracts 33039A, 370172, and 254379.
The management at Hartsville knew nothing about the requirement to respond to this NRC Compliance Bulletin.
TVA Discussion TVA's Power Stores organization is a part of TVA's Office of Power and not a part of TVA's Office of Nuclear Power (ONP).
The Power Stores Unit works at the direction of ONP's Manager of Materials through an interoffice agrooment between ONP and the Office of Power.
ONP's Manager of Materials reports to the Director, Division of Nuclear Business Operations. No ONP personnel were present at or aware of the NRC inspection when it took place during December 1987. Power Stores provided the correct response to the NRC Inspectors when it was stated that the tracking of modifications was not the responsibility of Power Stores. This specific responsibility rests within ONP.
ONP's Nuclear Materials Branch has since been recognized as a Division focal point for TVA's Nuclear Experience Review Program to be supplied appropriate materials related matters in accordance with ONP procedure PHP 0501.01, "Uuclear Experience Review." Information on nuclear experience review items (i.e-Sulletins, Ceneric Letters, Notices, vendor-information, etc.) related to material, equipment, spare parts, etc., is now disseminated to the nuclear site materials managers and to the Office of Power facilities (e.g.,
Hartsville and Yellow Creek) by the Nuclear Materials Branch as part of those Nuclear Experience Review activities. This activity will ensure that responsible individuals performing materials management functions for TVA's nuclear program are apprised of partlnent information.
Allegation OSP-87-A-0075. "Safety Related Equipment In Warehouse Storage Is Beinn Removed. Then Later Returned to the Warehouse for Nuclear Appilcations" Alleged Concern The NRC was informed that at the Hartsville Facility, which is presently being used as a Power Stores warehouso for cancelled nuclear plants, nuclear equipment stored in warehouses was being taken out of the warehouse to be junked. When removed from the warehouso, it was placed outside in the rain, wind, and freezing weather, then later on, it was returned to the warehouso for nuclear storage.
The concern regarded how such material could go back in nuclear storage (warehouses) after it has boon ruined.
Yellow transformors marked BBC from Secheron located outsido building TWG were given as an example.
NRC Dlscussion The Martsville facility was officially cancelled by the licensee on August 29, 1984. Subsequently, the licensee directed that the Hartsville facility be controlled by the "Materials, Power Stores Branch" of the "Office of Powoe."
The items in storage were then the responsibility of the Office of Power, which is separate from the "Office of Nuclear Power (ONP)."
The Offics of Power has an approved Quality Assuranco Manual which interfaces with the Nuclear Quality Assurance Manual (NQAM) in the following manner:
The Nuclear Quality Assu anco Manual (NQAM) doc 2ments the overall quality assurance program for TVA's nuclear powar plants.
The Power Stores Quality Assurance Program, contained in the Power Stores Quality Assuranco Manual (PS-QAM), is en element of the overall quality assurance program developed to comply with the policios and requirements contained in NQAM, Part I, Section 3.5, "Procuremont," and Section 3.6, "Packaging, Shipping, Recolving, Storago, and Handling."
The Power Stores Quality Assurance program is applicable to those activities related to:
(a) the procurement of certain materials, parts, and components in support of the ONP and (b) the offsito receiving, storage, packaging, maintenance, handling, and shipping of materials, parts, and components which have been declared surplus from the canceled nuclear plants and reserved by ONP for potential use at other TVA nuclear plants.
The methods of accomplishing these activitics are documented by the Power Stores Quality Assurance procedures and are used by Power Stores Branch personnel wten performing activities covered by the quality assurance program.
The PS-QAM, therefore, cont"ols the storage and preventive maintenance activitics for on-site stori ;o.
It establishes the critoria for QA and non-QA items.
It also controls th transfer of items from Hartsville, Phlpps Bend, Yellev Creek, and the Nucle..* Distribution Contor to Nucicar Power Plants.
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The licensee established a program for dispersion and/or reserving the equipment remaining from the cancelled facilities.
For all equipment at Hartsville, each department of TVA, including the fossil plants, had the option of reserving the equ.ipment for later use at their facility. The reserved items were then stored (if not needed innediately) at Hartsville.
The cost of storing was billod to the organization reserving the equipment.
The reserved items are designated "Category A."
Items not reserved which are available for sale or other use within TVA are designated "Category C."
A tour of the storage areas revealed a sizeable portion of the nuclear equipmeni had been reserved by fossil plants.
It was also identified that some items resetved by the fossil plants were being dropped from the reserved list due to the expense involved.
Therefore, the reserved item would go from Category A to Category C.
In the Category C status, the item is removed from warehouse storage to the yard.
It is then offered to other TVA organizations, including nuclear facilities. If it is reserved by another TVA organization, it is returned to Category A status and returned to warehouse storage.
Otherwise it is moved to the "9355" yard location and offered for sale outside TVA.
If not marketable, it is eventually sold as cerap.
While touring the area in the vicinity of building TWG, the inspector noted two control valves in the yard that were unprotected from the weather.
A follow-up on these items, identified as TIIC BEK 558F and BEK 559D, found they were originally reserved by Bellefonte and placed in warehouse storage, Category A.
On July 15, 1987, a letter from the Office of Nuclear Power advised Hartsville that ONP agrees to release items BEK 558F and BEK 559D.
The ONP advised that this decision was made af ter re-evaluating the expense of removing the internal parts needed by Bellefonte.
At that point, Hartsville placed the items in Category C status and removed them fro.t the warehouse to the yard.
On August 10, 1987, a second letter was issued by ONP advising Hartsville that, af ter discussions with Bellefonte personnel, they do not want to release the valves controlled by TIC BEK-558F and BEK-559D and to please remove the valves from the 9355 location. Therefore, these valves fit the alleged pattern in that they had been previously removed from warehouse storage and placed in the yard where they are subject to damage by the weather. They are presently located in the 9355 location.
Meanwhile, Bellefonte has reserved them for possible use at the nuclear f acility.
From discussions held with various on-site personnel, it appears that occurrences of removing items from the warehouse (Category A) to the yard (Category C) are quite frequent.
The inspector noted the licensee implemented a procedure on March 13, 1987, titled "PS-QAP 4.5-Reallocation of Items," to establish methods and assign responsibilities for reallocation of items from Hartsville, Phipps Bond, and Yellow Creek non-nuclear reserve, either inside or outside of the warehouse, to the Office of Nuclear Power.
This procedure does not prohlblt the transfer and shelfling of equipment from warehouse to yard and vice-versa.
It does establish a QC inspection for damage before being offered [ shipped) to ONP plants.
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- NRC Conclusion The allegation was partially substantiated in that equipment reserved for use in nuclear applications could be shuffled betwean Category A and Category C storage status.
It was not substantiated that equipment dcmage actually occurred as a result of this practice.
in regards to the referenced yellow transformers from BBC, Secheron, located outside building TWG, the inspector visited building TWG and toured the interior and exterior surrounding areas.
Fi'/e yellow transformers from BBC Secheron were found inside building TWG.
A close inspection of the transformers found no apparent damage. The present storage condition of these transformers was found to be excellent, inuluding a positive pressure of 6 PSI on each transformer.
Attached to the frort transformer was a card titled "Request To Stock New Item" and was dated November 12, 1987. The licensco's representative advised this request was bting made to place the item in a TVA Item Identification Code (TIIC). At the.ime of this inspection, tho items had not yet been placed on a TIIC.
It was determined the items were received on site in 1979. However, cince they had not been placed on a TIIC, it was not possible to track the storage status of the items.
It was also determined the items are for non-nuclear turbines.
Therefore, no further efforts were expanded on them.
TVA Dlecussion TVA investigated the examples provided in this allegation and has determined that the equipment referenced is non-safety related.
The condition of the transformers as stated in the URC report "was foucJ to be excellent." TVA inspected the two control valves and found no degradation of the equipment.
Subsequently, it has been determined that these valves are not required and they have been surplused.
TVA la confident that procedure PS-QAP 4.5 ensures that no degraded equipment will bn reserved for nuclear plant safety-related applications. This procedure requires a QC inspection and subsequent DNE inspections if any detrimental conditions are Identified.
Further, procedure PS-QAP 4.3, Section 5.2, ensures that equipment at Hartsville and at Yellow Creek will be inspected prior to transfer to a nuclear site.
d, r.
ENCLOSURE 2 INSPECTION REPORT NO. 50-518/87-01 RESPONSE LIST OF COMMITMENTS 1.
Revise QA Topical Report to clarify the commitment to ANSI 45.2.2 by December 1, 1989.
2.
Establish and issue approved procedures which define the method of prescribla; preventivo maintenance requirements by December 1,1988.
3.
Train warehouse personnel on the use of preventive maintenance and storage drawings 89-3GA0200-00-0A by October 1, 1988.
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