IR 05000327/1986061

Reactive Insp Repts 50-327/86-61 & 50-328/86-61 on 860915-19 & 0929-1003.Potential Enforcement Finding Noted:Failure to Correct Deficiencies Identified in Nuclear Safety Review Staff Repts Re Procurement & Record Storage Practices

ML20214A177
Person / Time
Site:	Sequoyah
Issue date:	11/05/1986
From:	Baker E, Harper J, Merschoff E, Petrosino J, Stein S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:
Shared Package
ML20214A166	List: IR 05000327/1986061 ML20214A163 ML20214A187
References
50-327-86-61, 50-328-86-61, NUDOCS 8611190282
Download: ML20214A177 (14)

Text

o

.

'.

Report No.: 50-327/86-61 and 50-328/86-61 Licensee: Tennessee Valley Authority 6N 38A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Docket No and 50-328 License Nos.: DPR-77 and DPR-79 Facility Name: Sequoyah Nuclear Station Units 1 and 2 Inspection Conducted: September 15-19 and September 29-October 3,1986 Inspectors: d V l'/5/f( )

E. Baker, Tea, der D~atte

\

l

~ l' .\

f. Pet'rosino, Quality Assurance Specialist sh;4 Wat4

'

h!I/f!f4

' 5. R. Stein, Electrical Engineer Date E V- l$(

J. C. Harper, Metallurgical Engineer Daire

/ f ll Approved by: .

n /r/n E. W. Merschoff, , Reactive Inspection Date Section, Vendor gram Branch SUMMARY Scope: This was an announced reactive inspection which was conducted at the Seq oyah Nuclear Station to determine the effectiveness of TVA's corrective action for problems identified in Nuclear Safety Review Staff Reports R-84-17-NPS, I-83-13-NPS, and R-85-07-NPS concerning past procurement and record storage practices. Areas inspected included procurement actions taken for replacement of safety-related electrical and mechanical components of the residual heat removal, control air, and emergency power (diesel generator)

systems; a sample of procurement actions identified by TVA's review of Class 1E replacement devices; a sample of procurement actions taken on equipment selected during a plant walk-through; NDE personnel qualifications; and Power

Stores receiving inspection practice Results: One Potential Enforcement Finding was identifie DR 861114 ADOCK 05000327 PDR i

_-_____-

..

.

..

'

REPORT DETAILS Persons Contacted: l Licensee Employees

• H. L. Abercrombie, Site Director

• E. Andrews, Site Quality Manager

• Blankenship, Information Office Panager L. D. Brewer, Control Shift Operator R. Bruce, Program and Standards Section Supervisor

• R. H. Buchholz, Office of Nuclear Projects (ONP) Site Representative

• S. K. Chapman, Electrical Maintenance General Foreman M. Crane, Site Services Procurement Supervisor

• D. C. Craven, Quality Assurance Manager

• M. R. Harding, Site Licensing Manager R. Jenkins, Division of Nuclear Engineering (DNE) Supervisor -

• Z. M. Kabiri, Site Services Manager

• J. W. Kelly, EA Engineer G. Kirk, TVA Compliance T. Kontovich, Electrical Maintenance Engineering Supervisor

• J. E. Law, Chief Quality Systems Branch

*A. S Lehr, Instrument Maintenance Group Engineer

• M. R. Matthews, Restart Task Force

• B. Patterson, Maintenance Superintendent G. W. Petty, Materials Officer H. L. Pope, QC Supervisor

• A. Purcell, Licensing Engineer

• B. Schofield, Licensing Engineer

• J. R. Staley, Power Stores Supervisor l C. Stutz. 0A Engineer l *P. R. Wallace, Plant Manager

• J. R. Watson, QA Engineer l * J. Wilburn, Site Maintenance

! *L. J. Wheeler, Materials Manager

! *C. R. Wherter, Materials and Procurement Services Staff Chief

The inspectors also contacted or interviewed other licensee personnel from the operations, training, maintenance, and technical staf Other Organizations R. V. Matheison, Westinghouse Site Representative NRC

• E. Harmon, Pesident Inspector

• M. Jenison, Senior Resident Inspector

• P. Loveless, Resident Inspector

• W. Merschoff, Chief, Reactive Inspection Section

• attended exit meeting

-___-_ _

.

'.'

2. Exit Interview The inspection scope and findings were summarized and discussed with those individuals identified in paragraph 1, above. The team members described the areas inspected and discussed the inspection findings i

listed below. The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspectio . Licensee Action on Previous Enforcement Matters This subject was not addressed in this inspectio . Unresolved Issues No unresolved issues were identified during the inspectio . Background TVA's Nuclear Safety Review Staff (NSRS) performed in-depth audits of TVA's procurement system and records retention system. The results of these audits are documented in reports I-83-13-NPS dated June 17, 1983, R-84-17-NPS dated March 8, 1985 and R-85-07-NPS dated July 5, 1985. These reports high-lighted programmatic deficiencies without providing specific examples of the problems found. One of the more significant findings related to the use of components purchased " commercial grade" and used in safety-related systems without any additional determination by TVA of the components' qualifications for use in safety-related applications. Another significant finding dealt with the difficulty or inability to retrieve quality assurance records in a timely manner. TVA took corrective action in response to these findings to improve their procurenent and record storage programs to prevent similar problems from recurring. However, these corrective actions did not appear to address the effect past procurement practices may have had on the quality of installed equipmen This inspection was conducted to determine how procurement practices for original and replacement components and parts affected the original quali-fication or design requirements of safety-related equipment installed in the plant or if record storage practices prevent determining whether or not the qualification of equipment has been adversely affected. The inspection i

utilized three separate methods for selecting equipment for detailed review; A sample of electrical, mechanical, and instrumentation components was selected during a plant walk-through for a review of the related procurement document Equipment was selected based on problems identified during previous inspections of licensees and vendor Problems noted in paragraph 6.b.7 were identified for an item from this sample.

l

-_ _ . _ . - . _ . - _

.___ -_-

._ - . - _ - _ _ _ _ _ _ _ _ - -

.

". A computer listing of maintenance requests (MRs) initiated during the time period 1980 to 1984 was obtained for selected systems and MRs were selected from these lists for follow-up based on whether or not a safety-related component was replaced. Problems noted in paragraphs 6.b.1, 6.b.6, 6.b.9, 7.a. and 7.b were identified for items drawn from this sampl TVA began an effort in July 1986 to evaluate the seismic qualifica-tions for a sample of Class 1E devices that had been replaced. From a total of approximately 125,000 MRs, they identified 238 MRs under which Class 1E devices had been replaced. At the time of this inspec-tion TVA was in the process of determining the status of seismic qualification for a sample of 50 MRs which represented Class IE replacement devices supplied directly from stock. This inspection reviewed several MRs from the 238 that were not part of TVA's sample of 50. Problems noted in partgraphs 6.b.2, 6.b.3, 6.b.4, and 6. were identified for items drawn from this sampl . Review of Procurement Program Review The team reviewed Part III, Section 2.1, " Procurement," of the Operating Quality Assurance Manual; SQA-45, " Quality Control of Materials, Parts, and Services," Sequoyah's site specific require-ments for procurement; and Sequoyah's Administrative Instruction AI-11, " Receipt Inspection, Handling, and Storage of QA Materials, Substitutions and QA Level / Descriptions Changes."

A review of the definitions section of SQA-45 shows that TVA accu-rately reflected the NRC's intent for the terms " basic component,"

" Class 1E," and " commercial grade item," terms commonly used when discussing procurernent. Three other definitions of interest to the team were, " Level I Quality Assurance Material," and " Level II Quality Assurance Material," commonly referred to as QA Level I and QA Level II, and " Critical Structures, Systems, and Components (CSSC)." A significant part of the problems discovered during this inspection stem from the definitions given for QA Level I and QA Level II and their use. TVA's definitions for these terms are as follows:

Level I Quality Assurance Material--(1) Those CSSC materials, components, and spare parts which are a part of and whose failure would violate the reactor coolant pressure boundary; (2) those other CSSC items that cannot be bought by industrial standards and reference part number; (3) certain items that must be specifically bought as Level I as required by Attachment 21 (reference DP N76A10) of this standard practice, and (4) electrical equipment defined as Class I .

.

"

.

Level II Quality Assurance--CSSC materials, components, and spare parts that can be purchased by positive identifica-tion, provided that these items are not QA Level I. QA Level II permits in-kind replacement of items when the specified industry code or standard provides positive identificatio Positive identification is established for an item by using one of the following methods: Documentation supplied with the original equipment and/or from nameplate / tag information attached to the equipmen The item's description as specified by the engineering drawing bill of material, provided no special process is performed due to drawing notes, etc.

> The item's description as specified in the procurement technical specification.

l The item's noun name and part number when supplied by the original supplier, manufacturer, or vendo These definitions are atypical of what is normal industry practice in that they describe what equipment falls into each category rather than describing the quality assurance requirements applicable to each category. Appendices to Attachment 20, " Specification of QA Program Requirements for Nuclear Power Requisitions," of SQA-45 contain the actual quality assurance requirements. These appendices are written for particular categories of equipment, e.g., Appendix 1, "ASME Section III Materials;" Appendix 2, "ASME Section III Valves;"

Appendix 5, " Class 1E Materials and Equipment;" Appendix 8, "Non-ASME Code, Items Which Have Unique Nuclear Requirements."

A note which is pertinent to the findings of this inspection appears j under the title of Appendix 8 as listed on page 250 of the 7/12/82 version of SQA-45. The note reads as follows:

>

... Used

"

for procurement of QA Levels I and II [10 CFR 21 Applicable] basic components which have unique nuclear requirements, including Seismic Category I A and equipment used in Class 1E application [pplication device as a whole which requires qualification by supplier or manufacturer] which are not ASME Section III Code."

A cursory reading of this note by someone not familiar with TVA's interpretation of the phrases "10 CFR 21 Applicable," " Seismic Category I Application," and " Class IE application," would lead one to believe that electrical and non-ASME mechanical equipment that was reouired to operate during and after a seismic event would be subject to the require.nents of Appendix 8. However, as the next two paragraphs show, this is not the cas . . - - - - - - _____ - _ __ . _ _ _ . - _ - . - - - . _ . -- -__ .

..

When TVA procedures discuss requirements for Seismic Category I application and Class 1E application, they are not necessarily referring to the specific pieces of equipment which must function during or af ter a seismic event. The statement, " device as a whole which requires qualification by the supplier or manufacturer,"

appears in the note quoted above. As explained by TVA personnel during the inspection and as can be seen from the examples cited in paragraph 6.b. below, TVA personnel interpreted this to mean that seismic and IE qualification was only applicable to the assembly qualified and supplied by the manufacturer. Therefore, if a

"whole device" (e.g., motor control center, diesel generator set)

was replaced, seismic qualification of the replacement was require However, if a subcomponent of the whole device was replaced (e.g.,

relay, circuit breaker, air starter motor) seismic oualification was not required for the replacement, regardless of whether or not the replacement had to function during or after a seismic event. The reason given for this practice was that TVA was ordering replacements by part number and was receiving an "in-kind" or "like-for-like" par This practice was not adequate to assure a qualified part, however, because the procurements were made OA Level II, no documentation required, which amounted to commercial grade and provided no assurance that the replacements were in fact "like-for-like."

The procurement of safety-related equipment requiring seismic and environmental qualification as OA Level II occurred because of two problems. The second statement in the definition QA Level I and the definition of QA Level II allow items which can be identified by a unique manufacturer's part number and are produced to industry standards to be procured as OA Level Il regardless of the safety function of the item or the industry standard invoked. The other problem is that rather than basing quality reouirements solely on the importance of the item being procured. TVA based quality requirements on whether or not 10 CFR 21 was judged applicable to the item. This problem was compounded by the fact that the form for

!

determining Part 21 applicability, Attachment 11 to SQA-45, was biased towards not imposing Part 21 on anything less than a whole devic Therefore, a piece of equipment which was originally supplied by the manufacturer as seismically qualified could be replaced by a commercial grade item without appropriate engineering analysis because TVA's procedures allowed the equipment to be classified as OA Level II, Part 21 Not Applicabl Paragraph 10.3 of ANSI N45.2.13 states that equipment may be accepted by source verification, receiving inspection, supplier certificate of conformance, post installation testing, or a combination thereo As the examples in paragraph 6.b. show, TVA chose to accept equipment based or receiving inspection and post installation testing. The receiving inspection performed by TVA during the time period 1980-1984 consisted only of a check for shipping damage and cleanliness, and a comparison of the part number on the item to the ordered part

number. Functional testing is performed af te.r installation and assures that the piece of equipment will function during normal operatio However, receipt inspection and functional testing in-situ cannot

.

..

validate the ability of a piece of equipment to function during or af ter a seismic event or exposure to a harsh environment. The other methods of acceptance available to TVA were source verification and supplier certificate of conformance. The " source verification required" block and the " documentation required" block were marked N/A for all QA Level II procurements reviewed, although some manu-facturers submitted certificates of conformance (C of Cs) anywa However, in order to take credit for C of Cs, paragraph 10.2 of ANSI N45.2.13 requires that the purchaser have a means of verifying the validity of the C of C. The means permitted by paragraph 10.2 are audits of the supplier or independent inspections or tests. While TVA performed independent inspections and tests, these tests could not be used to validate a C of C for seismic or environmental quali-fication since they only involved functional testing during normal operating conditions. TVA also performed audits of the suppliers of most of the equipment for which documentation packages were reviewe However, a review of those audits indicates that the programs reviewed were the nuclear quality assvance programs and not the commercial grade programs. Based on pruious NRC vendor inspection experience, if the nuclear quality assuraece program is not invoked in the procurement document, the items being procured are usually not manufactured under the nuclear quality assurance program. Therefore, a C of C received based on a contract which invoked the commercial grade quality program can only be considered valid if the comercial grade program has been audited and found acceptable, Procurement Implementation The following describes the results of the review of MRs, procurement documents, receipt inspection records, and other associated document-ation for selected equipmen ) Steam Generator Level Solenuld Valve (2-LSV-003-174):

MR A-593379 was issued on 12/2/85 to replace the coils in this ASCO solenoid valve (model 206-381-2RVU) which provides a control function for the Main Steam Isolation Valves. The valve being worked on, S/N 49243J-90, was an environmentally and seismically qualified valve, purchased under contract 80KJ3-00827551, which had imposed 10 CFR Part 21 and an Appendix B quality assurance program on the manufacture The valve location is the West Valve Room, a harsh environ-ment. Because of this, the maintenance was being controlled under the Qualified Maintenance Data System (QMDS) and the MR was marked "QMOS" and "10 CFR 50.49 Device."

As stated above, the original scope of work was to replace the coils in this valve. However, because the craftsman could not remove the coil subassembly with the tools supplied for the job, the whole valve was replaced with another fully qualified valve, S/N 84146N- .

.

..

If the craftsman had not encountered difficulty installing the replacement coils, the qualification of the original valve would have been indeterminate since the coils were procured as pieceparts, QA t.evel II, no documentation required, and no review of the effect of the commercial grade coils on the seismic and environmental qualification of the original valve was mad ) Reactor Trip Bypass Breaker B (2-BKRC-099-KH/319-G):

The undervoltage trip attachment (UVTA) on this Westinghouse DB-50 breaker was replaced under MR A-101112 on June 24, 198 The UVTA withdrawn from stock was one of 22 UVTAs purchased under contract 84P64-343921 in November 1983. The contract identified the UVTAs as QA level II, and did not impose QA, 10CFR21, seismic or documentation requirements on the supplie However, the supplier (Westinghouse) modified the original bid and self-imposeo QA and 10CFR21 requirements. The microfilmed contract file at Sequoyah includes a Certificate of Qualification from Westinghouse for ten UVTAs, but only four of the ten listed correspond to the UVTAs delivered under contract 84P64-343921 and the UVTA installed on this breaker is not one of them. As there is no documentation to support qualification of the UVTA, the cualification of the breaker assembly is indeterminat ) Normal Feed Breaker to Reactor Vent Board 28-B (2-BDC-201-JQ-B):

The Reactor Vent Board 2B-B was originally purchased with the 480V motor control centers under contract 71C2-54752, dated May 5, 1971. The contract required a cuality assurance program and seismic testing and qualification for the safety-related motor control centers listed on the contract. The seismic test report, dated March 1972, also documented successful separate testing of internal components, including a circuit interrupter of the type specified for the motor control center feed breaker On December 26, 1978, Purchase Requisition 272924 was issued to procure a replacement for the Reactor Vent Board 2B-B normal feed breaker and two additional overload trip units. The purchase requisition and contract classified the items as QA level II, did not impose QA requirements on the supplier, did not require any quality documentation from the supplier, and determined that 10CFR21 was not applicable to this procurement. The receiving inspection consisted of a comparison of nameplate data to the purchase document One d the two overload trip units was withdrawn from stock on September 8,1979, and installed on the normal feed breaker for the Reactor Vent Board 2B-B under MR 00226. As there is no documented evidence of qualification for the trip unit, it renders the qualification of the feed breaker and the safety-related motor control center it services indeterminat _

i

.

..

'

4) Auxiliary Relay in 6.9kV Shutdown Logic Relay Cabinet 2A-A (2-PNLB-202-SC-A):

This safety-related logic cabinet was originally purchased in June 1972 under contract 72002-83403, which required a full OA program and seismic qualification. Contract 78P15-24576, dated September 29, 1979, purchased as OA level II, 15 relays of various styles without imposing QA,10CFR21, seismic, or quality documentation requirements on the supplie One of the replacement relays was withdrawn from stock and installed in the 6.9kV Shutdown Logic Relay Cabinet 2A-A under NR A-019533 on May 28, 1982. As there is no documented evidence of qualification for the relay, it renders the ouali-fication of the safety-related relay cabinet indeterminat During research of the contract files for this panel, the origi-nal seismic report and additional correspondence was found to indicate problems with the seismic testing of two types of relays, including the type of relay replaced under MR A-019533. Although a letter from TVA indicates acceptance of additional seismic testing of the relays, the report documenting the additional testing could not be located in the document control system during the three week period over which the inspection was conducted but was later obtained from an engineer who had retained a personal cop ) Boric Acid Transfer Pump Motor (2-MTRB-62-230-A):

The original pump and motor assembly was supplied under the NSSS l contract with Westinghouse. The applicable Westinghouse speci-fication (677123 Rev.0) imposed seismic requirements for the assembly and required the supplier to provide documented proof of compliance to those requirements. Westinghouse provided Quality Release 11358-1, dated January 9,1974, as documentation i that the boric acid transfer pump and motor assembly met the requirements of Specification 677123, Re A replacement pump motor was purchased on January 13, 1982 under contract 82P64-323717. Although TVA classifies the motor as Class 1E, the contract identified the purchase as OA level II and did not impose QA, seismic,10CFR21, or documentation requirements on the vendor. A motor different than ordered was supplied. A TVA substitution evaluation form (SONP AI-11 Attachment 10, Appendix A Rev. 18) was completed on August 9,

! 1982, but the engineering concurrence for Class IE substitutions j

was marked as not applicable. On January 13, 1983, the replace-l mer,t motor was installed. As there is no documentation to

support qualification of the pump motor, the qualification of

' the pump motor assembly is indeterminate.

1

!

l i

l L

_ _

.'

.

..

>

.

6) Diesel Generators:

The diesel generators were procured under contract 71061-92652 from Bruce-GM which required manufacturing under a 10 CFR 50, Appendix B quality assurance program and seismic qualification of all equipment. Under RD-579489, dated 6/6/77, to contract 73Z23-65906, TVA procured replacement air starter motors from Ingersoll Rand as QA Level II, no documentation required. TVA has replaced these air starter motors numerous times either with motors procured from Ingersoll Rand or rebuilt by Sequoyah plant personnel. As there is no documentation to support qualification a

of the replacement or rebuilt air starter motors, the qualifi-cation of the air starter motors and the diesel generators in which they are installed is indeterminat ) Shutdown Board 2A-A Logic Relay Panel (2-BDA-202-CO-A):

Items selected by the inspection team during the plant walkdown included two Agastat time delay relays from this safety-related Class 1E panel. These were Agastat model number 7012PD relays, serial numbers (S/Ns) 81031110 and 80362242, and are in the control logic circuits for the essential raw cooling water and the component cooling water systems. The markings on these two i relays indicate that they were not manufactured as qualified Class 1E components since the model number is not proceeded by an "E." This was subsequently confirmed with the relay manu-facturer, Amerace Corp. When contacted after completion of the inspection, Amerace Corp. indicated that the relays, S/Ns 80362242 and 81031110, were manufactured commercial grade during the thirty-sixth week of 1980 and the third week of 1981, respectivel Although requested during the first week of the inspection, TVA

' was unable to identify or produce the procurement documents for these relays. However, since these relays are not uniquely identified by TVA as Class 1E devices, the inspection team assumes that they were procured as piece parts, QA Level 11, without the imposition of QA or documentation requirements on the supplie As there is no documentation to support qualification of the relays and the vendor's records indicate that they were not supplied as qualified devices, the qualification of the relays and shutdown board in which they are installed is indeterminat ) Containment Isolation. Valve (2-FCV-32-103):

!

This air operated globe valve is required to close on a Class B isolation signal and is listed in Table 9.3.1-2 of the FSAR as a seismic category I valve. This valve was chosen during the walk-through by the team to trace the procurement chain from an installed condition back to the documentation, and was also

included in the sample of items for which the maintenance history

,

_ - . . _ _ _ - . _ . - . _ _ , _ _ _ _ - - _ _ _ _ _ - - . _ . _ _ _ _ _ - - _ . _ _ -

- - - _ - _ _ - - _

.

..

,

was reviewed. The valve was ordered as an ASME Class 2 valve, seismically qualified, under contract 73C34-83577, dated 3/15/73, from Masonellan International Inc. The serial number of the installed valve, N00137-21-4, traces back to a valve data package for valve PCV-32-103. However, a valve data ordering sheet could not be located for either PCV-32-103 or FCV-32-103 under contract 73C34-8357 A review of the maintenance history for this valve indicates that the valve failed its local leak rate test end was repaired under MR A-081518, dated 8/1/83. The MR indicates that the soft rubber seat had been c'amaged in service and was replaced. The seat was procured QA Level II, no documentation required, under contract 79P14-278023 along with two other items. Because the seat was classified as QA Level II, the receipt inspection did not include characteristics such as material type, cure date, durometer standard, estimated shelf life and storage conditions, all of which should be verified for this type of materia ) ControlValve(2-FSV-32-1031):

This ASCO solenoid valve, model 206-380-2RVU, serves a control function for air operated containment isolation valve 2-FCV-32-103 and is listed in Table 9.3.1-2 of the FSAR as a seismic category I valve. This valve was chosen during the walk-through by the team to try to trace from the installed condition back through the procurement chain to the documentation. The valve (serial number 68337K), was purchased under contract 82PK1-330545, dated 4/8/82, from Mills & Lupton Supply Co. as CA Level II, no docu-mentation required. Also purchased as QA Level II under this contract were replacement coils and repair kits for this model valve. Although no documentation was requested and the receipt inspection report for the valve had the " Certifying Document No."

block marked "N/A," a Certificate of Compliance for the valve certifying its compliance to IEEE-323 and IEEE-344 was in the contract fil c. Conclusions Orawn from Inspection Findings 10 CFR 50, Appendix B, Criterion XVI requires that conditions adverse to quality be promptly identified and corrected. However, although NSRS Report R-84-17-NPS, dated March 12, 1985, pointed out that TVA was using commercial grade items as basic components without deter-mining the effect on the safety function of the component or system in which it was installed, TVA has not initiated an effort to identify

- equipment which may be in nonconformance with seismic or environmental qualification requirements as a result of this practic Sequoyah personnel have started a review of Class 1E replacement devices for seismic qualification. However, the effect of using commercial grade piece parts on seismically and environmentally qualified devices had not been considered at the time of the inspectio ,

!

i

.

.

The method used by TVA to identify their sample of 50 devices resulted in the majority of the sample being instrumentation items'such as level, pressure, or temperature switches. TVA's selection process started with equipment identification numbers that were categorized as Class IE, 10 CFR 50.49, or had a safety train designation. However, TVA's program only identifies "those devices qualified as a whole" as Class 1E and does not consider components or parts within a device as being Class IE or affecting the qualification of the device. As a result, many safety-related electrical items such as circuit breakers, relays, and solenoid coils are not classified as 1E and therefore were not included in TVA's original sampl TVA management stated that they intended to look at the 238 MRs iden-tified as involving Class 1E device replacements rather than only the sample of 50 as originally intended. This would still not account for the piece part replacements for safety-related electrical or mechanical ,

equipment which comprise the majority of the replacements performe The concerns identified above constitute examples which support Potential Enforc.ement Finding 50-327,328/86-61-01, Inadequate Corrective Action to Previously Identified NSRS Procurement Finding . Record Retrievability At the start of the inspection approximately 30 components were identified by the inspectors during a plant walk-through to determine if the installed hardware was traceable back to the required procurement documents. This was in addition to the equipment documentation requested as a result of the review of MR In addition to examples 7.a and 7.b below, which involve record retrieva-bility, paragraphs 6.b.2), 6.b.4), 6.b.7), and 6.b.8) above provide examples of record retrievability in addition to procurement problems, a) Residual Heat Removal Isolation Valve (2-FCV-74-1):

MR A-10737, for the fabrication and installation of sixteen 1-3/4" x 8" bonnet studs, was issued 8/20/83. Although no procurement deficiencies were noted, a record retrieval or accuracy problem was identified. The MR required a visual examination of the studs. Inspection report R-0686, dated 8/20/83, referenced visual inspection procedure N-VT-1, Revision 4. During the course of the inspection this revision of the procedure was requested, but TVA was unable to produce i b) ResidualHeatRemoval(RHR)PumpMotor(2-FMP-74-10):

MR A-C80564, dated 3/15/83, requested that the 2A-A RHR pump motor shaf t material be verified. The method chosen to identify the shaft material was the application of a copper sulfate solution, which in combination with visual observation, can be used in making a quali-tative decision as to whether the material is carbon steel or stainless steel. Sequoyah Nuclear Power personnel performed the test and deter-mined that the material was stainless stee . - _ - - _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ - .

>

.

..

,

When the inspector requested the procedure for performing the test, TVA could not produce it. As a minimum, there should have been written instructions concerning the strength of the copper sulfate solution, the length of time between application and evaluation, temperature of the material prior to application, method of appli-cation, and evaluation criteri Several completed Power Stores material receipt inspection packages that were ready to be micro-fisched were reviewed. The review revealed that some packages for safety-related components did not contain the required objective evidence of acceptability, i.e., manufacturer's Certificate of Conformances and the component functional test data sheets. Discussions with Division of Nuclear Engineering (DNE)

personnel determined that separate organizational files of these documents were kept by DNE. Therefore, several areas would have to be researched before the required objective evidence of acceptability for an item was availabl As an example, package #839407, for eight nuclear grade Agastat tire delay relays (Models E7012/E7022) procured by DNE, contained a closed OC inspection report that accepted the relays based on a handwritten note from Ol1E stating that DNE intended to accept the manufacturer's C of Cs. The required manufacturer's functional test data sheets were not in this package, but TVA personnel stated that the test data sheets were in a DNE file. When asked how the equipment was controlled or tracked until DNE approved the C of Cs, Sequoyah personnel stated that no additional controls were placed on the equipment and no tracking system existed. If DNE eventually decided that the C of Cs were not acceptable, the equipment may have already been installed. Similar examples were found in package 838674 for four nuclear grade Foxboro differentiai pressure transmitters, and package 836394 for Atwood and Morrill ASME Section III diesel generator plug valve The lack of objective evidence of acceptability in the closed procure-ment and receipt inspection packages appears to have been caused by the following items. (Items a) and b) were addressed in the NSRS reports.)

a) Failure to establish a procedure, including acceptance criteria, for closed package review to ensure that the necessary documents are included in each package, b) La:k of adequate TVA organizational coordination, communication and/or procedures to provide one central focal point for review and storage of quality related documents, c) Frilure to establish a tracking system to assure receipt inspec-t ton packages eventually contain all necessary documentation or a reference to where the documentation is located, d) Failure to adequately review and approve the completed QC inspection reports by the OC inspectors immediate managemen *

.

10 CFR 50, Appendix B, Criterion XVII requires that records be identi-fiable and retrievable. ANSI N45.2.9, paragraph 6.2, requires that records be retrievable without undue delay. However, records for installed equipment which do not have a unique plant identification number (i.e., piece parts) could not be identified or retrieved during the three week period between the time the inspection started and the exit interview. Additionally, certain records could not be located through the record retrieval. system and were located only by contacting an engineer in the Division of Nuclear Engineering who had a personal cop This problem was previously identified in NSRS Reports I-83-13-PS and R-85-07-NPS and provides an additional example of TVA's failure to take adequate corrective action to NSRS findings. The concerns identified above contributed to Potential Enforcement Finding 50-327, 328/86-61-01, Inadequate Corrective Action to Previously Identified NSRS Procurement Finding . Receipt Inspection Receipt inspection packages for both past and present procurements and the associated versions of Administrative Instruction AI-11, " Receipt Inspection, Handling, and Storage of OA Materials, Substitutions, and QA Level / Description Changes," were reviewed. AI-11, Attachment 1,

" Materials Receipt Inspection Report," is a listing of types of inspec-tions such as shipping damage, markings, cleanliness, dimensional, electrical insulation, etc., with three check-off columns, "Yes," "No,"

and "N/A." Paragraph 2.4 of AI-11 states that the inspector is respon-sible for determining which of the twenty inspection requirements appl Paragraph 2.4.1 of AI-11 states that if any inspections in addition to the twenty listed are needed, the originator of the purchase request is responsible for preparing appropriate inspection instructions. However, Al-11 does not contain or reference any detailed inspection or test procedures which would tell receipt inspectors what dimensions or any other characteristic to check, what tools or equipment should be used, or what the acceptance criteria are. The inspection report does not provide any space for recording the results of any inspections other than "Yes,"

"No," and "N/A."

10 CFR 50, Appendix B, Criterion V, requires that activities affecting quality be prescribed by documented instructions or procedures and include appropriate quantitative or qualitative acceptance criteria for determining that activities have been satisfactorily accomplishe Contrary to the above, Sequoyah has not established detailed receipt inspection procedures which provide appropriate guidance to the receipt inspectors. This lack of instructions contributed to the problem discussed in Section 7 of this report concerning closing of incomplete receipt inspection folders without a tracking system to assure that C of Cs are eventually approve This problem was previously identified in NSRS Report R-84-1-17-NPS and provides an additional example of TVA's failure to take adequate corrective action to NSRS findings. The concerns identified above contributed to Potential Enforcement Finding 50-327,328/86-61-01, Inadequate Corrective Action to Previously Identified NSRS Finding