ML20151R654

Insp Repts 50-327/88-07 & 50-328/88-07 on 880125-29. Violation Noted.Major Areas Inspected:Followup to Review Licensee Corrective Actions Relative to Findings Identified in Listed NRC Insp Repts

ML20151R654
Person / Time
Site:	Sequoyah
Issue date:	04/08/1988
From:	Baker E, Hubbard G, Pierson R NRC OFFICE OF SPECIAL PROJECTS
To:
Shared Package
ML20151R600	List: ML20151R597 ML20151R654
References
50-327-88-07, 50-327-88-7, 50-328-88-07, 50-328-88-7, NUDOCS 8804280057
Download: ML20151R654 (15)

See also: IR 05000327/1988007

Text

-0

-

.

.

'

.

.

UNITED STATES NUCLEAR REGULATORY COMMISSION

OFFICE OF SPECIAL PROJECTS

TVA PROJECTS DIVISION

Report Nos.: 50-327/88-07 and 50-328/88-07

Docket Nos.: 50-327 and 50-328

Licensee Nos.: DPR-77 and DPR-79

Licensee: Tennessee Valley Authority

6N 38A Lookout Place

1101 Market Place

Chattanooga, Tennessee 37402-2801

Inspection Conducted: January 25-29, 1988

Inspectors: MP 7'

George T. Hubbard Date

Inspection Team Leader ,

l

O)LQ W ' '

Edward T. Baker Da'te

Senior Reactor Engineer

Approved by: M

Robert C. Pierson, Chifef

h II

D' ate i

Plant Systems Branch  !

l

.

8804280057 800413

. PDR ADOCK 05000327

O PDR

.

.

-- - -_, - ,_, _,. ._ 7, , ~_ y _. - , . -__ _ .. .

_ - - _ _ .

i

'

1

INSFECTION REPORT NO. 50-327,328/88-07 INPUT

INSPECTION SUMMARY I

l

Inspection on January 25-29, 1988 (Inspection Report Nos.: 50-327/88-07 and

50-328/88-07).

Areas Inspected: Announced follow-up inspection to review the licensee's

corrective actions relative to findings identified in NRC Inspection Reports

50-327,328/86-61 and 50-327,328/87-40. The Safety Systems Outage Modification

(Installation) Inspection (SS0MI) findings (identified in NRC Inspection i

Reports 50-327,328/86-68) that remained open following the 87-40 inspection l

were not evaluated during this inspection.

l

Results: The inspection determined that TVA/SQN has implemented a program to .

correct procurement deficiencies identified in Inspection Report 86-61 and )

87-40. While the NRC has observed improvements in TVA's procurement of l

purchased parts due to their corrective actions, this inspection determined I

that SQN was still procuring comercial grade purchased parts without adequate )

dedication of the parts for use in safety-related applications. One apparent I

violation and one inspection fol. low-up item were identified during the l

inspection. . l

l

Items Remaining Open from Previous Inspection Reports: ,

Inspection Report 50-327,328/87-40:

Unresolved Item:

,

1. Adequacy of Seismic Evaluations of Replacement 50-327/87-40-01;

Parts for Seismically Qualified Equipment 50-328/87-40-02

New Items:

Apparent Violation:

1. Failure to Take Adequate Corrective Action 50-327/88-07-01;

and Follow Procedures Relative to Dedication 60-328/88-07-01

of Commercial Grade Items for use in i

Safety-related Applications

Inspection Follow-up Item:

1. Documentation of Receipt Inspection Activities' 50-327/88-07-02;

for Comercial Grade Items 50-328/88-07-02

-

-2-

.

.

-_ _ ,. - . _ . , .

. _ - .

_ _- - _ - - __

l

.

'.

,' .

1.0 PERSONS CONTACTED

1.1 Tennessee Valley Authority (TVA)

• S. Bargerstock, Supervisor, Contract Engineerivig Group (CEG) l

'

• J. Zeigler, Licensing

• G. A. Roberts Supervisor, Power Stores  !

• R. B. Constable, Quality Assurance (QA) Engineer

'

• M. L. Crane, Assistant Material Manager l

• J. M. Fontenot, Supervisor, CEG  !

• G. C. Wilkerson, Sequoyah (SQN) Purchasing Representative

• J. E. Maddox, Engineering Assurance (EA) Lead Engineer

• D. Scheide, Licensing Engineer  !

• J. H. Sullivan, Supervisor, Plant Operations Review Staff (PORS) l

• R. A. Witthauer, EA Senior Lead Auditor

• C. McWherter, Materials Manager

• T. E. Spink, Replacement Items Project (RIP), Project Manager l

• J. R. Watson, Supervisor, QA Materials .

• L. E. Martin, Site Quality Manager l

• J. L. Hamilton, Quality Er.gineering Manager l

• S. A. Abu-Yousif Technical Support

'*P. R. Wallace, Site Director's Office

• G. B. Kirk, Complianc'e Licqnsing Manager

D. L. Paul, Project Manager, Project Managers Staff

J. Wheeler, Assistant Manager, Nuclear Maintenance Division

'

I

D. Mack, Engineer, RIP -l '

T. Chiles, Materials Manager

F. Campbell, Licensing

B. Peavyhouse

M. Bishop, EA Engineer

1.2 Consultant

J. Ferguson, Senior Engineer, Impell

'

2.0 BACKGROUND

In September 1986, an inspection of Sequoyah's (SQN) procurement activi-

ties was performed and documented in Inspection Report 50-327,328/86-61

(86-61). In response to this inspection, TVA developed the Replacement

Items Program, created the Materials Management organization, reinserted

engineering into the procurement cycle, established a corporate level

Maintenance Manager, and initiated major revisions to the procedures

governing procurement, receipt inspection, and engineering evaluation of

replacement items. In July 1987, the NRC reviewed TVA's activities to

correct the problems identified in 86-61 and documented the results in

Inspection Report 50-327,328/87-40(87-40).

'

-

-3-

.

.

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

- __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

.

.

.

3.0 SCOPE

This inspection was a follow-up to the 87-40 inspection and focused on

procurement related findings remaining open following that inspection.

One

Roomfinding of the 87-40

was reviewed. SSOMIinspection

inspectionconcerning(the

findings ReportFifth Vital Battery)

50-327,118/86-68

that were still open following the 87-40 report were not reviewed during

this inspection.

4.0 FOLLOW-UP OF INSPECTION REPORT 50-327,328/86-61 OPEN ITEMS

4.1 Potential Enforcement Findings

50-327/86-61-01 and 50-328/86-61-01 (Closed). Failure to take

adequate corrective action in procurement of safety-related equipment

and storage and retrieval of QA records.

In the 87-40 Inspec't ion Report, this finding remained open pending a

decision regarding enforcement. Based on NRC review of this 86-61

finding and its similarity to the apparent violation identified

during this inspection and discussed in paragraph 5.2.2.1 of this

report, this finding i,s closed.

4.2 Procurement Implementation items

Paragraph 6.b.3 of report (Closed). Normal f.eed breaker to reactor

-

vent board 28-8 (2-BDC-201-JQ-P). ,

l

Paragraph 6.b.4 of report (Closed). Auxiliary relay in 6.9KV I

shutdown logic relay cabinet 2A-A (2-PNLB-202-SC-A).

Paragraph 6.b.6 of report (closed). Diesel generator air start

motors.

Paragraph 6.b.7 of report (Closed). Shutdown board 2A-A logic relay

panel (2-BDA-202-CO-A).

The concerns documented in inspection report 86-61 relative to the l

four items above dealt with TVA's documentati6n to support the

seismic qualification of these replacement parts used in l

safety-related applications. During 6nd following the 87-40 l

inspection TVA provided the NRC information to support qualification

of these items based on information from an earthquake experience

data base; however, SQN equipment is requirtM to be seismically

qualified to the requirements of IEEE-344/19.5 which is more

stringent. Since the earthquake data base method is not equivalent

to the IEEE-344/1976 qualification, the use of the earthquake

experience data base is not considered acceptable for the long term.

However, as discussed in paragraph 5.1 below, the earthquake data

base method is acceptable for establishing the qualification of

replacement items for use in seismically sensitive equipment for the

.

4

.

.

_

.

e

.

~

.

.

near term and for restart of SQN. For these re'asons, these four

items are considered resolved for restart of SQN.

For the long term, these items are considered specific examples of

the overall seismic qualification problem discussed below in

paragraph 5.1.. Resolution of the overall seismic qualitication

problem for the long term will resolve these specific items. Since

the NRC is working with TVA to resolve the long term qualification

problem, these specific items are closed.

For the long term program, TVA should be aware that the NRC has

identified concarns with the seismic qualification of electrical

relays and is working to resolve the concerns under Generic Issue

114. Once the issue is resolved, TVA will be expected to incorporate

any required license action into their long term program as

' appropriate.

5.0 FOLLOW-UP OF INSPECTION REPORT 50-327,328/87-40 CPEN ITEMS

5.1 Unresolved Items

-

50-327/87-40-01 and 50-328/87-40-02 (0 pen). Adequacy of seismic

evaluations of replace' ment p, arts for seismically qualified equipment.

The 87-40 report discussed this item relative to two concerns: (1)

the appropriateness of usirg the earthquake experience data base for -

demonstrating that TVA piece part replacement activities have re-

degraded the seismic qualification of the equipment; and (2) it tar

data base is acceptable, whether TVA is adequately justifying and/or

documenting their conclusions.

5.1.1. Relative to the first issue, TVA submitted a letter to the

NRC, dated August 14, 1987, subject "SEQUOYAH NUCLEAR PLANT

(SON) - REPLACEMENT ITEMS PROGRAM (RIP) SEISMIC SCREENING

METHODOLOGY," stating their position regarding the use of the

experience data base. In response to this letter, the NRC sent

a letter from J. G. Keppler to S. A. White, dated October 29,

1987, stating the NRC position on this subject.

The NRC stated, "The staff is unable to accept TVA's position

that the historic data base review conducted at Sequoyah as part

of the replacement parts programs is sufficient for the lo y

term to ensure that initial equipment qualification to

IEEE-344/75 has not been compromised by using unqualified

seismically sensitive replacement parts." The letter further

stated that based on technical considerations and the historical

reasons TVA used this approach, the staff was prepared to eccept

the technical basis of the TVA screening methodology "as an

interim justification for establishing the qualification of

replacement items for use in seismically sensitive equipment."

-

-5-

.

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

.

. _. . .

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

.-. ___

..

.

.

l

-

l

.  :

.

-

. .

,

Certain provisions were attached t'o'this' fnterim acceptance and

were described in the letter.

The first provision was that TVA should submit a detailed I

program plan describing how SQN would ensure full compliance

with the applicable portions of IEEE-344/75 prior to the end of

the cycle 4 refueling outage. The second provision was that the

"seismic sensitivity screening" reviews be upgraded prior to SQN

restart (Mode 2) to support the short term "interim justifica-

tion" for qualification of replacement items. -This second

'

provision is discussed in paragraph 5.1.2.

With regard to the first provision, TVA comitted to submitting

a program plan to describe how SON will ensure compliance with

the applicable portions of IEEE-344/75 prior to the end of the

cycle 4 refueling outage. This comitment was made in a letter

. to the NRC from R. Gridley, dated December 8, 1987, subject,

"SEQUOYAH NUCLEAR PLANT (SQN) - REPLACEMENT ITEMS PROGRAM (RIP)

SEISMIC ADEQUACY VERIFICATION." At the time of the inspection,

TVA had not submitted the plan. Pending NRC review ano approval I

of the plan and review of the TVA's implementation of the plan,

this item romaint open.

5.1.2 Relative to the adequac'y of justifications and/or documentation

of TVA's conclusions regarding seismic screening review packages

based on the earthquake experience data base, the NRC inspectors -

reviewed a sample of packages which had been upgraded since the

87-40 inspection in July 1987. Of the 15 packa

four pertained to maintenance requisition (MR) ges reviewed,

numbers '

A-299-409, 20690, and A-5-29910 and trouble report (TR) 01563

which were discussed in 87-40. Three of these four packages

, were not comoleted and approved at the time of the inspection;

c however, they were re. viewed since they had been the subject of

i discussion during the 87-40 inspection.

The inspectors' review of the fifteen packages identified only

one completed package where they had questions. The one

question concerned the addition of weights and balances to the

EGTS Backdraft Damper (MR 075110). TVA was able to resolve the

question by demonstrating that the MR only added weights of 2.5

pounds and the dampers were qualified with weights up to 6

pounds.

While the inspectors' review of the upgraded pacirages jetermined

'

them to be an improvement over the packages reviewed in July

1987, the inspectors stressed the importance of adequate

documentation of TVA's justifications relative to the seismic

, qualification of installed equipment. The inspectors stressed

~

this to be especially true for those packages which r not

justified by the experience data base and require ah.itional

evaluations.

.

-

- 6-

'

1

.

. . . - - , . - - - - . . . , . - _ , . - _ . . .. ,,_ _ --.._ ~ c ,,..-_ _v ,.,__,m,me -

m, ,y ,-, ,%,ye .m,.r.m,

_ _ _ - - _ _ _ _ - - - - - - - - _ - - - _ - - - - - - _

_

,

l

.  !

• .

Based on the inspectors' review an'd'the in'terim justification

criteria for seismic qualification discussed 'in paragraph 4.1.1-

above, the NRC determined that TVA's program for installed  ;

seismically cua11fied equipment, including upgraded justifica-

tion packages and seismic evaluations as needed, would be

adequate to support restart of SQN Unit 2 when the program is ,

completed. Based on the inspection results, this part of the l

unresolved item is closed.

5.2 Inspection Follow-up Items (IFIs)

1

5.2.1 50-328/87-40-01 Verification of seismic tasks completion.

(Closed)

In the 87-40 report two issues were addressed under this IFI.

The first issue pertained to verification that a pipe hanger

installed in the waste disposal system (WDS) under MR 48452

(87-40 mis-identified MR as 48482), dated April 17, 1979, was

part of the original installation. In respon.se to the

inspectors' questions on the hanger, TVA responded that the WDS

was part of the design reconciliation effort which would resolve

this issue prior,to restart.

During this inspection,' the NRC inspectors determined through a

review of documentation that the WDS was a part of the design

reconciliation effort and that the activities are not restart

'

j

items. Based on a October 2,1987 letter from R. Gridley to the

NRC, the scheduled completion date is April 1,1988. Since the

hanger issue will be resolved by the design reconciliation

effort, this item is closed.

The other issue pertained to MR A-112165, dated October 27,

1983, upper head injection (VHI) room and the inspectors'

observation that finger clamps were missing from the conduit.

The inspectors discussed-this item with TVA and determined that

the inspection report had incorrectly identified the issue as

being on Unit 2 when it was actually a Unit 1 observation.

Since thic issue had no affect on the Unit 2 restart and the

intpectors verified that a work request had been written to

'orrect the problem, this issue is closed.

.

5.2.2 50-327/87-40-02 and 50-328/87-40-03 (Closed). Dedication

package preparaticn, inspection instructions for receip1;

inspectors, and missing MRs.

5.2.2.1 Dedication Package Preparation: In reviewing TVA's program

for the control of their preparation of dedication packages

(DPs), the inspectors reviewed the following procedures /

instructions:

l

-

-7-

.

e __ _ _ _ _ - - _ _ -_-

'

.

.

.

,

-

.

SQA45, "Procurement of Materi'a lt, 'Com'ponents, Spare Parts,

and Services," Revision 29, dated Octobe'r 19, 1987.

SQA170, "Issuance of Materials, Components, and Spire

Parts," Revision 0, dated October 16, 1987.

TI-105, "Dedicating Commercial Grade Items for Use as Basic

Components," Revision 1, dated August 18, 1987, plus

changes includea in an instruction change form dated

October 30, 1987.

TI-110. "Procurement of Repiacement Items for Use in

Permanent Equipment, Systems and Structures," Revision 0,

dated October 19, 1987.

In addition to the above procedures / instructions review, the NRC

inspectors reviewed 19 out of a total of approximately 260 DPs

which had been prepared by the contract engineering group (CEG)

at SQN, Four of the DPs reviewed were identified as having the

same problems which resulted in the Potential Enforcement

Finding of NRC Inspection Report 86-61. The inspectors provided

comments and/or r,ecommendations for four other DPs. The

remaining eleven ops wqre considered acceptable.

Dedication package 5098 for an adapter bushing established

critical characteristics for dedication as material and -

dimensions. Dimensions were chocked by TVA QC inspectors;

however, the material was accepted based on a Certification of

Complianca (C0C) from the supplier. This supplier was listed on

the TVA Approved Supplier List (ASL) as qualified to provide

material under their ASME Certificate of Authorization and their

ANSI N45.2 QA Program. However, the bushing was ordered QA

Level II (commercial grade) and the suppliers controls on

commercial grade products had not been reviewed and approved by

TVA. Therefore, there was no basis for establishing the

validity.of the COC.

Dedication package 5137 for a temperature switch stated that the

replacement was a "like-for-like replacement" and that purchas-

ing and dedication by part number alone was acceptable. This is

contrary to paragraph 11 of Attachment 4 to Temporary

Instruction TI-105. Paragraph 11 states, "A check that the part

number is the same does not indicate that an item is a direct

replacement. Critical characteristics must be checked." The

part was transferred from the Watts Bar plant as QA Level II and

receipt inspection and acceptance was based solely on part

number.

Dedication package 5243 for a safety relief valve identified

adequate critical characteristics for dedication; however,

receipt inspection was based on part number verification and a

'

.

-8-

.

. . --

--

,,, ,- . , , , -- -

. _ -

.

.

'

.

.' .

!

-

COC from the supplier. As in OP 5098 above, the vendor was on i

the ASL for his ASME programs; however, the part was ordered QA i'

Level II (commercial grade) and the suppliers controls on

commercial grade products had not been reviewed and approved by

TVA. Therefore, there was no basis for establishing the

validity of the C0C,

Dedication package 5252 for a valve positioner identified

critical characteristics for dedication as being the model and

part number and receipt inspection was based on verification of

the model and part number. In this particular case the vendor

had no applicable QA program, was not on the TVA ASL, and the

bases for using the vendor was that he was the original

equipment manufacturer. Based on this, TVA had no valid basis

to dedicate the positioner solely on model and part number.

The inspectors asked questions on DPs 5008, 5025, and 5191 l

relative to post-installation testing adequacy for dedication. '

In DP 5008 post-installation test was initially required for

dedication then it was cancelled without any documentation of

the reason. The inspectors were able to determine that

post-installation testing was actually performed and it was

adequate to demonstrate its function for its in-plant

application. Questions' on DPs 5025 and 5191 relative to

post-installation testing were resolved when it was determined

that one DP was not needed and would be cancelled and the -

solenoid valves of the other DP were not needed due to a system

modification and the valves were subsequently surplused. The

inspectors stressed to TVA the importance of ensuring that

post-installation testing requirements in DPs are clearly

defined.

The inspectors' review of DP 5175 for a linear amplifier

determined that it was classified as QA Level II (commercial

grade) procurement; however, TVA imposed ANSI N45.2 on the

vendor. The vendor was on TVA's ASL for ANSI N45.2. The review

further determined that 10 CFR Part 21 was not imposed for the

procurement. In discussion with TVA as to why the procurement j

was not classified as QA Level I since the procurement invoked a

nuclear specific specification, TVA explained that even though

the vendor would accept a procurement under ANSI N45.2 they

would not accept 10 CFR Part 21.

The inspectors discussed with TVA the NRC position that when a

nuclear specific specification (in this example ANSI N45.2) is

imposed in procurement documents, that the procured item cannot

be classified as commercial grade. The NRC position is that the

item would not meet the definition of commercial grade item

defined in 10 CFR Part 22. In this example the amplifier should

nct have been classified commercial grade and 10 CFR Part 21

should have been imposed.

.

9

.

f - -. . __ _ , , _ - - - . m p .- - .- --

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

'

O

.

'.

.. .

.

.

The inspectors acknowledged the problenis f' acing a licensee when

a vendor will not accept 10 CFR Part 21. The' inspectors

suggested that TVA include 10 CFR Part 21 in all procurement

documents as appropriate and negotiate with the vendor

concerning its inclusion if he will not accept 10 CFR Part 21.

When the inspectors determined that the reviews identified some

of the same problems which the NRC had identified in earlier NRC

procurement inspections, the' inspectors met with TVA corporate

and Sequoyah site management to apprise them of the review

results. Based on discussion with TVA management, TVA took

insnediate action to establish the scope of the problem, to

prevent potentially improperly dedicated items from being issued

from power stores and installed in the plant until proper

dedication could be verified, and to implement corrective action I

to prevent the problem from occurring in the future. In l

conjunction with these activities TVA wrote condition adverse to l

quality report (CAOR) number SQN880088, dated Janucry 27, 1988  ;

to address the NRC concerns.

l

1 In defining the scope of the problem, TVA reviewed all of the i

approximately 260,DPs generated by CEG to identify which DPs had I

the same problems identified during this inspection. From this L

review TVA identified 19 DPs (in addition to the DPs identified

by the NRC) which had similar problems as identified by tw NRC -l

inspectors. Including the DPs identified by the inspectors TVA i

identified 10 packages which covered equipment issued to the

plant. Prior to the end of the inspection TVA was able to

satisfactorily demonstrate that all equipment covered by these

10 DPs were acceptable for perfonning their respective

safety-related functions. This demonstration for equipment

installed in the plant alleviated NRC concerns relative to

restart of Unit 2.

. Suninary: With consideration of the fact that the NRC inspectors

identified some of the same problems identified in previous

inspections and the fact that the TVA Replacement Items Program

was created to prevent these problems from occurring, these

inspection findings are considered an apparent violation of NRC

requirements for failure to take adequate corrective action and

failure to follow procedures. This apparent violation is

identified as inspection item 50-327,328/88-07-01. In vie,w of

this apparent violation, the DP portion of IFIs 50-327/87-40-02

and 50-328/87-40-03 are closed.

5.2.2.2 Inspection Instructions for Receipt Inspectors: As part of

the inspection of receipt inspection, the inspector reviewed the

!

following procedures / instructions which apply to receipt

inspection activities: .

1

-

- 10

.

--,--..-,.m m, , _ . , . . _ . _ - _ - - . . ,,,.._,._,r.,, ,,,_.,_.,,,,,_.,_,m.,,.._,,,.,,,m ,.,,,_.r.,,,,w._, ,m.,,_,m.,,..

- ._- -

_ - -

.

.

.

.

.

AI-11, "Receipt Inspection, Noncoriforining Items, QA

'

Level / Description Changes and Substitutions," Revision 44, 1

dated October 27, 1987. l

QMI 710.2, "Inspection Plans," Revision 0, dated July 16, j

1987;

QMI 710.3, "Inspection Reports," Revision 0, dated July 16, l

1987. l

Inspection Plan (I.P.) No. U01-0001, "Receipt Inspection,"

Revision 1 dated November 12, 1987.

I.P. U01-0002, "Receipt Inspection," Revision 2, dated

November 12, 1987.

In addition to reviewing the above instructions / procedures, the  !

inspectors reviewed eight receiving inspection reports (IR)

associated with seven DPs. Two of the eight were determined to

be acceptable and problems / comments were discussed with TVA on

the remaining six.

The inspectors identified problems with the dimensional

inspections documented by irs R-87-0019 and -0020, which

received items under DP 5138. No tools were listed on the irs ,

'

that could have been used to verify thread type or threads per

inch. The inspectors were told by the supervisor for the

inspection area that uncontrolled thread gages were used to make

these measurements. Additionally, there was insufficient

objective evidence that the dimensional inspection had been

performed. The objective evidence consisted of an item number

marked next to the general inspection attributes "Dimensions"

and "Special Inspection," but there were no records of the i

actual measurements taken or even a listing of the dimensions j

that were to be verified and an inspector sign-off that each

dimension required to be verified for dedication had been

measured.

Inspection report R-87-0383 was generated to document the

results of an inspection of ASTM A-307 bolts being dedicated

under DP 5116. The DP required that 3 of 10 bolts be

dimensionally inspected and tested for hardness. The DP

!

required the bolts to be inspected using "G0/N0-G0" thread gages

or an equivalent mernnd. The only piece of inspection equipment

listed on the IR was a dial caliper (E09528). When asked how l

threads per inch, thread type, and hardness had been verified,

the inspectors were informed that uncontrolled equipment had

been used to verify threads per inch and thread type and that a

'

, Certified Material Test Report (CMTR) supplied by the vendor had

,

been the basis for acceptance for hardness. The QC inspection

'

I

-

- 11 - I

i

.

-- - -- , --.-.w. .---_,.._,.-,--.,--.l. ,-.t,, , , . - .

.

.

.

.

.

l

^

.

group had not received documented pehnissfon from CEG to waive

the hardness testing upon receipt.

Inspection report R-87-0237 was generated to document the

results of an inspection of terminal lugs under DP 5065. The DP

required part number, size, and Underwriters Laboratory (UL)

label or marking be verified as required by the purchase

requisition (PR). The PR included minimum hole size as a

requirement. In reviewing the inspection report, the inspectors

noted that no measuring or test equipment was listed as being

used and the block next to the general attribute "Dimensions" ,

was marked "NA" (not applicable). l

l

.

Inspection report R-88-01342 was generated to document inspec- l

tien of wire mesh being dedicated under DP 5313. The critical '

chtracteristics listed in the DP were wire diameter, mesh hole

size, and material. The inspection report indicated that the

dimensional inspection had been accomplished using a dial

caliper and the material was accepted based on a CMTR received

from the vendor. The vendor's commercial quality program had  !

been reviewed and approved by TVA. However, the CMTR was from a

third party (the , manufacturer of the wire) who had not been

reviewed and approved by TVA. As such, a separate tese of t:,e

material should have been performed upon receipt of the

material.

Inspection report R-87-0336 documented the performance of a

reinspection of carbon steel, ASTM A-307, Grade A bolts to the

requirements of TI-105 Attachment 5 for DP 5016. This report

listed a dial caliper as the only piece of measuring and test

equipment (M&TE) used for the inspection. Thread type and

threads per inch were verified by uncontrolled thread gages.

The NRC comments provided earlier for irs R-87-0019 and -0020

are equally applicable for this IR.

During the review of IR 87-0336 and its associated DP, the

inspectors identified that the DP called for the procurement to

be classified QA Level II (comercial grade) and invoked ANSI

N45.2 for a QA Program; however, 10 CFR Part 21 was not invoked.

This situation is identical to the situation discussed for DP

517E in paragraph 5.2.2.1; therefore, the coments provided

there are also applicable for this case.

After reviewing the irs, the inspectors discussed with TVA the

NRC position that when critical characteristics are identified

for inspection in DPs, the characteristics should be inspected

with controlled and calibrated M&TE and inspection documentation

should demonstrate that identified inspection requirements have

been met. This documentation should include, but not be limited

to, number of items inspected, inspection criteria (i.e.

dimensions with tolerances), actual measurcrents obtSt.u d,.".'.TE

.

- 12 -

,

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

.

,

,

• .

.

used, inspectors name, and whether oi n'ot'the. items are

acceptable. This NRC position is based on the fact that the

process of dedication provides licensees the means to use a

comercial grade item in a safety-related application in a

nuclear plant; therefore, the licensee should have objective

evidence available which demonstrates that critical

characteristics, necessary to ensure the item's suitability to

perfom its safety-related function in the plant, have been met.

Summary: While the NRC review of the receipt inspection process

determined that improvements have been made since the 87-40

inspection, additional improvements are in process. Among

improvements observed by the NRC inspectors was the segregation

of material which had been received but not receipt inspected,

establishment of a receipt inspection area with some inspection

equipinent, segregated areas for nonconforming materials, and

improved receipt inspection documentation.

While improvements in receipt inspection as related to DPs were

observed, the above identified problems with the reviewed

inspection reports indicates that work is still needed to ensure

that critical characteristics identified in OP inspection

requirements are verified for compliance during receipt

inspection or by other appropriate means and that documentation

supports the conclusions. ,

Since discussions with TVA indicated some disagreement with the

NRC position regarding the documentation details necessary for

ensuring DP critical characteristics were being met, TVA is

requested to respond in writing to the above NRC stated position

by describing how they plan to ensure, through inspections and

inspection documentation, that comercial grade items are

adequately dedicated for use in safety-related systems.

Since TVA is still making improvements in their receipt inspec-

tion area and based on NRC findings during this inspection TVA

is requested to respond to the NRC position concerning

documentation requirements for demonstrating DP inspection

requir.ements have been met. A new inspection follow-up item

(50-327,328/88-07-02) is identified relative to these items. In

view of the new IFl. the related portion of IFIs 50-327/87-40-02

and 50-326/8740-03 are closed.

While'an IFI was identified above, the inspectors considered

TVA's receipt inspection process to be satisfactory to support

restart of SQN Unit 2.

5.2.2.3 Missing MRs: The NRC inspectors reviewed TVA's actions rela-

tive to approximately 3000 maintenance requests (MRs) which were

identified to the NRC as being missing during the 87-40

inspection. Since the 87-40 inspection, TVA reduced the number j

i - 13 - i

1

.

. . _ .

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

,-.y -

.,

.

? .

.

'

to approximately 2250 MRs. Since TVA has been unable to find  !'

any of the remaining missing MRs, they performed an analysis of

the relative impact that these MRs would have o~n the

qualification of installed 10 CFR 50.49 equipment.

The inspectors reviewed the TVA analysis that concluded that

since only five items of equipment were replaced in 10 CFR 50.49

qualified equipment as a result of the RIP evaluation of over l

192,000 MRs, the probability of one of the missing MRs

introducing unqualified material into the plant was extremely

small. TVA also felt that if unqualified material had been

introduced into the plant by the missing MRs, it would have been l

discovered by equipment functional testing. Based on the

'

inspectors' review of the analysis and discussions with TVA, the

inspectors found the TVA conclusion to be acceptable.

Therefore, the missing MR portion of IFIs 50-327/87-40-02 and l

50-328/87-40-03 are closed. l

5.2.3 50-327/87-40-03 and 50-328/87-40-04 (Closed). Walkdown

inspection observations in fifth vital battery room.

The NRC inspector,s verified that TVA issued "Clearance Order," l

number 1606, dated Sept; ember 1,1987, concerning the fifth vital

battery room. This order identified that no credit could be

taken for the fifth vital battery room during plant operations

until deficiencies with the room, identified during NRC -

inspections, are corrected. Since NRC-inspection report i

50-327,328/87-76 has identified unresolved items I

(50-327,328/87-76-03) to follow TVA's resolution of NRC l

identified deficiencies (including these IFIs) with tiie fifth l

vital battery room, these IFIs are closed.  !

l

.

.

- 14 -

.

.

.

'

,

. Mr. S. A. White

Tennessee Valley Authority Sequoyah Nuclear Plant

SUBJECT: FOLLOW-UP INSPECTION FOR PIECE PARTS PROCUREMENT (50-327/88-07

'

AND 50-328/88-07

DISTRIBUTION (w/ enc 1):

~

(DC5-(Docktt: Fo. 50-327/328)

PDR

LPDR

OSP R/F

TVA R/F

TVA TP R/F

JPartlow, NRR

BGrimes, NRR

FMiraglia, NRR

SEbneter

JAxelrad

SRichardson

GZech

BDLiaw  !

i

KBarr

RHermann

RPierson ,

EMarinos

GHubbard

EBaker, NRR j

JDonohew, OSP

FMcCoy, RII.

BHayes, 01

SConnelly, OIA

EJordan, AEOD

JRutberg, OGC i

TVA-Rockville l

Resident Inspector )

ACRS (10)

. ,

k

'