ML20215F346

Final Part 21 & Deficiency Rept Re Failure to Adequately Disposition Reportable Nonconformances in Divs of Nuclear Engineering & Nuclear Const.Initially Reported on 860224. Changes to Corrective Action Program Listed

ML20215F346
Person / Time
Site:	Bellefonte
Issue date:	10/06/1986
From:	Gridley R TENNESSEE VALLEY AUTHORITY
To:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
REF-PT21-86-361-000 PT21-86-361, PT21-86-361-000, NUDOCS 8610160161
Download: ML20215F346 (5)

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pMb TENNESSEE VALLEY AUTHORITY CHATTANOOGA. TENNESSEE 37401 SN 157B Lookout Place 66 0CT 9 A8*'4 1 BLRD-50-438/86-06 T 0 6 886 BLRD-50-439/86-05 U.S. Nuclear Regulatory Conunission Region II Attention: Dr. J. Nelson Grace, Regional Administrator 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323

Dear Dr. Grace:

BELLEFONTE NUCLEAR PLANT UNITS 1 AND 2 - FAILURE TO ADEQUATELY DISPOSITION REPORTABLE NONCONFORMANCES IN THE DIVISIONS OF NUCLEAR ENGINEERING AND NUCLEAR CONSTRUCTION - BLRD-50-438/86-06 AND BLRD-50-439/86 FINAL REPORT l The subject deficiency was initially reported to NRC-0IE Inspector Art Johnson on February 24 and Fobruary 28, 1986 in accordance with 10 CFR 50.55(e) as SCRs BLE 4703 and BLN CEB 8604, 8605, 8606, respectively. This was followed by our first interim report dated April 3,1986. Related SCR GEN NEB 8603 was also determined to be reportable under 10 CFR 50.55(e). Enclosed is our final report. We consider 10 CFR 21 to be applicable to SCR BLN CEB 8604.

If there are any questions, please get in touch with D. L. Terrill at (615) 751-7558.

Very truly yours, TENNES E VALLEY AUTHORITY R. L Gridley, ! Director Nuclear Safety, and Licensing Enclosure cc (Enclosure):

Mr. James Taylor, Director Mr. G. G. Zech Office of Inspection and Enforcement Director, TVA Projects U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Region II 101 Marietta Street, NW, Suite 2900 Records Center Atlanta, Georgia 30323 Institute of Nuclear Power Operations 1100 Circle 75 Parkway, Suite 1500 Atlanta, Georgia 30339 etho'nha!8t!8lb S

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An Equal Opportunity Employer I

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ENCLOSURE BELLEFONTE NUCLEAR PLANT UNITS 1 AND 2 FAILURE TO ADEQUATELY DISPOSITION REPORTABLE NONCONFORMANCES IN THE DIVISIONS OF NUCLEAR ENGINEERING AND KUCLEAR CONSTRUCTION BLRD-50-438/86-06 AND BLRD-50-439/86-05 10 CFR 50.55(e)

SCR GEN NEB 8603, SCR BLN 4703 AND SCR BLN CEB 8604, 8605, AND 8606 FINAL REPORT Description of Deficiency In performing independent (" peer") reviews of 10 CFR 50.55(e) reportable nonconformance reports /significant condition reports (NCRs/SCRs), which were believed to be completed and ready for NRC closure, approximately 50 percent .

(18 of 34) of the items were found to be incomplete for a variety of reasons, including inadequate implementation of corrective actions; incomplete, inadequate, or nonexistent review for generic implications; and inadequate specification of corrective action and action required to prevent recurrence.

Major concerns (although all not safety related) were found for 12 of the incomplete items as listed in table 1.

The cause of this deficiency is believed to result from (1) failure of TVA engineers to take a broad scope view of problems and potential problem areas in problem identification, investigation, and resolution; (2) deficiencies in the method of control and tracking of generic implications reviews within TVA (i.e., failure of the system to ensure the reviews are completed and documented and to document reasoning when "no generic review is required");

and (3) isolated failures of TVA engineers to ensure completion of all activities required to complete an item and/or maintain acceptable configuration control over completed items.

This condition was evaluated for the Watts Bar Nuclear Plant (WBN) and it was determined that corrective' action specific to WBN was not required. The reasoning behind this determination is given in the letter from R. L. Gridley to J. Nelson Grace dated June 27, 1986.

1 Specific corrective actions on the Browns Ferry and Sequoyah Nuclear Plants ,

are not required as a result of this deficiency. These two plants now have I' major efforts underway to correct deficiencies wherein the final configuration does not match the design. Whether their problems were caused by inadequate implementation of corrective actions or other reasons, they will be adequately handled under their specific design baseline / configuration control programs.

Corrective actions for other generic / programmatic concerns in areas such as corrective actions, generic reviews, training, etc., are given below.

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Safety Implications Failure to fully complete corrective actions, identify proper corrective actions and actions required to prevent recurrence, or perform adequate review for generic implications may result in a degraded or nonconservative condition remaining uncorrected. As a result, the safe operations of the plant might be jeopardized.

Corrective Action TVA will ensure completion of the specific concerns and/or activities

- identified as incomplete in the Bellefonte peer review noted above. These items will be completed and reverified before being presented to the NRC Resident Inspector for closure.

The Bellefonte Site Director has issu'de a requirement for peer review of 50.55(e) items, violation responses, and other responses to NRC that contain significant corrective actions. This procedure has been submitted to the TVA Engineering Assurance organization in DNE for approval and will be implemented in the Bellefonte Project Manual. It will ensure that final configurations and documentation meet commitments made in those responses and will emphasize consideration of aspects of a deficiency outside of those identified on the item being dispositioned. This increased attention to corrective actions will result in better and more complete reviews and actions on the part of the individuals involved due to increased knowledge of requirements and awareness that their work is being thoroughly reviewed after-the-fact for acceptability.

In addition, TVA has a number of efforts underway to ijmprove the corrective

action process and configuration control. These efforts are being led by the Division of Nuclear Quality Assurance (DNQA) and the DNE Engineering Assurance organization (EA). These activities will also serve to prevent recurrence of i this problem. The following programmatic changes are underway by DNQA and EA

DNQA is developing a centralized and standardized corrective action program which will enhance the overall effectiveness of the current systems. The program will upgrade the areas of generic reviews, interface controls, tracking, trending, and corrective action verification. In particular, the centralized generic reviews should ensure all identified deviations receive a consistent and timely review for generic implications. Additionally, the proposed increased involvement of the quality assurance organizations in corrective action verification should raise the confidence level that required actions have been completely and effectively implemented. Also, DNQA has a major effort underway to improve configuration control at all TVA nuclear plants. Some 21 areas of configuration control have been surveyed (with INPO '

involvement). Detailed actions are being developed into a TVA corporate plan -

on configuration management. .

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4 To strengthen the corrective action program for CAQs in DNE, numerous changes and revisions are being planned and/or implemented by EA within the DNE Procedures Manual. These changes, coupled with enhanced management awareness and attention, are intended to ensure the complete resolution of all steps involving CAQs within the corrective action process. Specifically:

1. Training - NEP-1.2 contains requirements for training of employees and

, management commensurate with levels of responsibilities and task assignment. DNE personnel have received instructions on NEP-9.1,

" corrective Action." Additionally, the Engineering Assurance Training Section will be developing a training course on the CAQ/ corrective action program as part of its course offerings and will provide further i instructions on NEP-9.1 when revisions occur. -

2. Generic Implications - CAQs processed beyond the immediate supervisor level, under NEP-9.1, will be reviewed by a branch / project appointed management review committee, whose primary purpose will be to assess significance and generic implications. Although responsibility for conduct of generic-investigations will remain with the initiating organization, CAQs will be given close scrutiny by the review committee

, and receipt of all responses to any generic evaluation will be a prerequisite to CAQ closure. Long-range planning by EA for the correction action program includes the staffing of the Problem Report Section of the Problem Report and Trending Croup. This section will be responsible for implementing and coordinating the DNE corrective action i progr,am by ensuring that all potentially generic CAQs are evaluated and investigated by projects and branches. This organization will ensure centralization and control of generic investigations within DNE and eliminate the concerns relative to the failure to conduct generic evaluations. v v

3. Corrective /PreventiveAc{lon-Existingpracticesandpoliciesforthe implementation of correciive and preventive actions, to include the j determination and documentation of root causes, are considered adequate.

l NEP-9.1 will, however, require completion of physical plant work as a l condition for CAQ closure. Supplemented by the tracking of CAQs in the Tracking and Reporting of Open Items (TROI) system, more emphasis will be placed on those elements that ensure a closed loop system. Additionally, I the Engineering Assurance internal auditing program will audit projects

and branches for compliance with NEP-9.1.

All of the above procedural changes by DNQA and DNE will be implemented as they are finalized, but no later than March 31, 1987. Necessary training will take place before implepentation and audits performed as deemed necessary ocedures. The above programmatic changes will prevent i

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e TABLE 1 MAJOR CollCERNS FROM BELLEFONTE PEER REVIEW NCR/SCR NO. MISSING ELEMENT BLN 2318 & Clamp tightening procedures and generic review 2917 BLN 2393 Corrective action changed, but report was not changed BLN 2661 Generic review incomplete BLN BLP 8121 Adequate design criteria revision and generic reivew BLN BLP 8224 Corrective action inadequate BLN NEB 8007 B&W to revise specifications BLN QAB 8102 Documentation of required approval of ECN not complete BLN CEB 79-07 Work not done although reported complete BLN 1885 Future problems not considered BLN 2383 & Corrective action not accomplished as committed. Some 2494 reinspection not done BLN BLP 8133 Error in final report and minor documentation mistake on commitment tracking record completion BN-C 04 Program to show acceptability of miscellaneous steel (Def. No. 2) not established as committed 0290c -

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