ML20076F531

Responds to NRC 830414 Ltr Re Violations Noted in IE Insp Repts 50-438/83-07 & 50-439/83-07.Corrective Actions: Equipment Named in Violation Tagged or Returned to Instrument Test Lab for Repair or Calibr

ML20076F531
Person / Time
Site:	Bellefonte
Issue date:	05/16/1983
From:	Mills L TENNESSEE VALLEY AUTHORITY
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20076F512	List: ML20076F531
References
NUDOCS 8306140150
Download: ML20076F531 (7)

Text

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TENNESSEE VALLEY AUTHORITY .

CHA's "ANOOGA. TENNESSEE 37401 . g., QQpG[A 400 Chestnut Street Tower II May 16, 198 3 MAY 17 A 8 : 4 5 U.S. Nuclear Regulatory Comission Region II l Attn: Mr. James P. O'Reilly, Regional Administrator 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30303

Dear Mr. O'Reilly:

BELLEFONTE NUCLEAR PLANT UNITS 1 AND 2 - RESPONSE TO VIOLATIONS 50-438/83-07-01, 50-439/83-07-01, FAILURE TO CONTROL AND CALIBRATE MEASURING AND TEST EQUIPMENT 43d/83-07-02, 50-439/83-07-02, FATLURE TO ,

AUDIT SEVERAL SITE CONSTRUCTION ACTIVITIES ON AN ANNUAL FREQUENCY - '

50-438/83-07-03, 50-439/83-07-03, FAILURE TO REAUDIT ITT ORINNEL DESIGN ACTIVITIES ON A THREE-YEAR CYCLE This is in response to D. M. Verrelli's letter dated April 14, 1983, report numbers 50-438/83-07, 50-439/83-07 concerning activities at the Bellefonte Nuclear Plant which appeared to have been in violation of NRC regulations.

Enclosed is our response to the citations.

If you have any questions concerning this matter, please get in touch with R. H. Shell at FTS 858-2688.

To the best of my knowledge, I declare the statements contained herein are complete and true.

Very truly yours, TENNESSEE VALLEY AUTHORITY

, i L. M. Mills,i Manager Nuclear Licensing Enclosure cc: Mr. Richard C. DeYoung, Director (Enclosure)

Office of Inspection and Enforcement U.S. Nuclear Regulatory Comission Washington, D.C. 20555 r306140150 830526 6 PDR ADOCK 05000438 An Equal Opportunity Employer G PDR b _

, s ENCLOSURE BELLEFONTE NUCLEAR PLANT UNITS 1 AND 2 RESPONSE TO SEVERITY LEVEL V VIOLATION 50-438/83-07-01, 50-439/83-07-01 FAILURE TO CONTROL AND CALIBRATE MEASURING AND TEST EQUIPMENT Description of Deficiency 10 CFR 50, Appendix B, Criterion XII and Quality Control Procedure 10.11, Rev. 9, require that measures be established to assure that tools, gages, instruments, and other measuring and testing devices used in activities affecting quality are properly controlled, calibrated, and adjusted at specific periods to maintain accuracy within necessary limits.

Contrary to the above, damaged and out-of-calibration pressure gages found on shelves D and E in the instrument calibration laboratory and damaged torque urenches found in the hanger engineering unit storage locker were neither segregated nor properly tagged to pr'efent their misuso. Additionally, in the same storage locker, a Wild NaK 1 surveJor's level (identification No. TVA 360673) was found out of calibration and not suitably tagged to indicate this condition.

Admission or Denial of the Alleged Violation TVA admits the violation occurred as stated.

Reason for Violation The damaged and/or out-of-calibration equipment although not tagged in the mannner prescribed by QCP-10.11, Revision 9, was thought by the involved personnel to be adequately controlled to prevent inadvertent use. Latitude was taken outside the wording of the QCP by the personnel involved.

Corrective Steps Taken and Results Achieved The specific equipment named in the violation was tagged or returned to the instrument test laboratory for repair or calibration.

In addition, procedure BLN-QCP-10.11, "Out of Tolerance Sheets," was generated to alert the inspection units of the affected equipment.

Other areas where equipment is stored were examined and out-of-calibration tags were placed on equipment as required.

Corrective Steps Which Have Been Taken to Avoid Further Violation Formal tags stating "Eold, do not use until calibrated," are being used by the instrument test laboratory to identify out-of-calibration equipment. ,

QCP-10.11 is being revised to alsrt potential users of test equipment to ;

chtok for current calibration sticksrs prior to uss.

Instructions have been givea to all affected groups to return any damaged or out-of-calibration equipment to the test laboratory. Instrument test laboratory personnel have been instructed to bring any unsuccessful equipment calibration or damage concern to management's attention.

Date When Full Comeliance Will Be Achieved Full compliance will be achieved on July 15, 1983 1

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i BELLEFONTE NUCLEAR PLANT UNITS 1 AND 2 RESPONSE TO SEVERITY LEVEL.V VIOLATION 50-438/83-07-02, 50-439/83-07-02 FAILURE TO AUDIT SEVERAL SITE CONSTRUCTION ACTIVITIES ON AN ANNUAL FREQUENCY Description of Deficiency 10 CFR 50, Appendix B, Criterion XVIII nnd Quality Assurance Staff Procedure 7.1, Revision 11, require that a comprehensive system of planned and periodic audits be carried out ror construction site activities at least annually or at least once within the life of the activity whichever is shorter.

Contrary to the above, between March 16, 1981, to March 15, 1982, audits were not performed in the areas of field fabrication orders, weld repair, equipment installation - electrical, audit preparation and review of field procurement documents, transfer of items, and stop work authority / allegations. These audits were conducted from one to three months beyond the annual frequency.

Admission or Denial of the Alleged Violation y TVA admits the violation occurred as stated.

The Reasons for the Violation The fact that the Bellefonte unit was not fully staffed, coupled with the workload, required the Quality Assurance Unit Supervisor to utilize his personnel to the best advantage considering the relative importance to safety of on-going construction activities, required reviews and follow-ups, and the audit schedule.

Because of the Quality Assurance Unit involvement in the 100 percent review of safety-related field procurement documents and Transfer Requisitions, monitoring of all nonsafety-related procurement documents, and required involvement in all stopwork orders and allegations, TVA believes that these areas received the proper attention and that the Quality Assurance Program was not compromised.

In the same light, the other areas cited were not totally ignored during the period between audits. Follow-up of deficiencies f?om previous audits in these and related areas provided audit persornel opportunities to be cognizant of construction activities within the 12-month period.

Corrective Steps Taken and Results Achieved Efforts to obtain qualified personnel have been increased since the reorganization of the Quality Assurance Organization, and the Bellefonte Section is now interviewing and preparing to extend offers. It is expected that the section will be at full strength by June 30, 1983 L -- _ ___ _ ____ _________________________________d

j Corractiva Steps Which Have Bean Taken to Avoid Further Violation The Office of Quality Assurance is now utilizing a combination of

. surveillance and audits to provide verification of the development and i implementation of the quality assurance program which will minimize the potential for omissions in future coverage. The overall planning and scheduling for verification of TVA's Constructor Program is centralized, as is the tracking of the status of these activities. This provides management visibility'or potential problems in performing verification activities and provides for initiation of enrrective action. j Date When Full Compliance Will Be Achieved Full implementation of the total verification process (audit and surveillance) will be by October 1, 1983 i

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BELLEFONTE NUCLEAR PLANT UNITS 1 AND 2 RESPONSE TO SEVERITY LEVEL V VIOLATION 50-438/83-07-03, 50-439/83-07-03 FAILURE TO REAUDIT ITT GRINNEL DESIGN ACTIVITIES ON A THREE-YEAR CYCLE Descriotion of Deficiency 10 CFR 50, Appandix B, Criterion XVIII and EN DES Engineering Precedure EP-5.34, Rev. 4, require a comprehensive system of planned and periodic audits be carried out for vendor services once every three years.

Contrary to the above, EN DES audited ITT-Grinnell, Prcridence, RI, design activities on January 17-19, 1978, and did not perform the required reaudit of this activity until September 26-28, 1982 (20 months late).

Admission or Denial of the Alleged Violation TVA admits the violatior occurred as stated.

The Reasons for the Violation From the inception of TVA's nuclear power plant program until November 1982, the vendor audit program was the responsibility of Engineering Design (EN DES), delegated to the EN DES Quality Assurance Group. In July 1980, the Quality Assurance Group was separated from the Quality Engineering Branch and organized as a Quality Assurance Branch reporting directly to the Manager of Engineering Design. This action by TVA management demonstrated its recognition that more emphasis should be placed on quality assurance activities, particularly for suppliers of safety-related equipment and services.

In July 1980, the vendor quality assurance group consisted of eight qualified auditors. This group was responsible for monitoring vendor activities on all TVA nuclear plants; Browns Ferry, Sequoyah, Watts Bar, Bellefonte, Hartsville, Phipps Bend, and Yellow Creek. Their activities, in addition to vendor audits, consisted of reviewing purchase requisitions for adequacy of quality assurance requirements, reviewing quality assurance program descriptions of suppliers of safety-related equipment and services, and performing surveys of low qualified bidders.

The number of vendors for seven nuclear power plant projects and the personnel available to perfor,m vendor evaluations did not permit all vendors to be evaluated in strict compliance with NRC Regulatory Guide 1.144. -

TVA adapted a plan whereby vendor evaluations would not be based solely on quality assurance audits but would include reviewing: inspection reports by TVA source inspectors, technical performance as monitored by contract engineers, nonconformance reports, the vendor's equipment either inprocess or upon receipt by TVA and inspections by independent agencies which may have been conducted on the vendor.

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Tha vtndors evaluated as having quality assurance program problems

• utilizing the above techniquss wara audited on a priority basis; whereas, those with no indicated problems were audited less frequently. The l nature of the problems found during audits and the severity of their impact on equipment services determined the frequency with which the particular vendor was reaudited or the follow-up action taken.

Records of vendor activities, including all of the above sources of

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information, were used to rate the performanca of vendors and thus determine the frequency and need for audits.

From July 1980 until November 1982, on an average, 13 vendors were

! audited each quarter. These included first-time audits and repeat audits of problem suppliers, often audited annually.

Corrective Steos Taken and Results Achieved In November 1982, Quality Assurance responsibilities were transferred from EN DES to the Office of the General Manager. The staff of the procurement quality assurance group was increased by four auditors. In addition, three nuclear power plant projects were deferred or canceled, thus the number of vendors has been reduced.

The system of rating vendor performance based on inputs in addition to audits continues to be used. Four audit teams have been established and the active vendors divided among the teams. Each team is responsible for monitoring the progress of its assigned suppliers and establishing audit schedules that will ensure each vendor is audited in compliance with the requirements of NRC Regulatory Guide 1.144.

TVA management, at least quarterly, reviews the status of the vendor audit program and progress made to achieve compliance with 10 CFR 50, Appendix B, Criteria XVIII, requirements.

All active vendors currently due audits will be audited to bring TVA in compliance with Regulatory Guide 1.144.

Corrective Steps Which Have seen Taker to Avoid Further Violation See Corrective Steps Taken and Results Achieved above.

Date When Full Comoliance Will be Achieved TVA will be in full compliance by October 31, 1983

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