IR 05000259/1985018

Insp Repts 50-259/85-18,50-260/85-18 & 50-296/85-18 on 850401-04.Violations Noted:Inadequate Procedures & Insp of Diesel Generator Cooling Water Valves & Incorrect Classification of Emergency Equipment Cooling Water Sys

ML20127B486
Person / Time
Site:	Browns Ferry
Issue date:	05/07/1985
From:	Blake J, Girard E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20127B465	List: IR 05000259/1985018 ML20127B460 ML20127B478
References
50-259-85-18, 50-260-85-18, 50-296-85-18, IEB-83-03, IEB-83-3, NUDOCS 8506210490
Download: ML20127B486 (13)

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Report Nos.: 50-259/85-18, 50-260/85-18, and 50-296/85-18 Licensee: Tennessee Valley Authority 500A Chestnut Street Chattanooga, TN 37401 Docket Nos.: 50-259, 50-260 and 50-296 License Nos.: DPR-33, DPR-52, and DPR-68 Facility Name: Browns Ferry Inspection Conducted: April 1 - 4, 1985 Inspector: '

8 . .r 'Date Signed Approved b /T&ke, Section Chief 8'I J. Date Signed E gi ering Branch

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ivi ion of Reactor Safety SUMMARY Scope: This routine, unannounced inspection entailed 26 inspector-hours on site in the areas of licensee action on previous inspection findings, inservice inspection - review of records, Inspection and Enforcement Bulletin 83-03, and inspector followup item Results: Three violations were identified - (1) Procedures for inspection of diesel generator cooling water valves - paragraph 6.b; (2) portion of emergency equipment cooling water system not classified as Critical Systems, Structures and Components - paragraph 3, and (3) records for valve inspections, paragraph 6.b.

s 8506210490 850513 PDR ADOCK 05000259 0 PDR

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REPORT DETAILS Persons Contacted Licensee Employees

• T. Jones, Plant Marecer

• B. C. Morris, Compliance Supervisor

• J. Whitaker, Inservice Inspection Engineer

• D. C. Mims, Engineering Group Supervisor J. E. Swindell, Superintendent - Operations / Engineering B. R. McPherson, Mechanical Engineering and Test Supervisor C. G. Wages, Mechanical Maintenance Section Supervisor W. C. Thomison, Engineering Section Supervisor H. Hodges, Engineer, Engineering Section NRC Resident Inspectors

• L. Paulk, Senior Resident Inspector

• A. Patterson, Resident Inspector

• Attended exit interview Exit Interview The inspection scope and findings were summarized on April 4,1985, with those persons indicated in paragraph above. The inspector described the areas inspected and discussed in detail the inspection findings listed below. No dissenting comments were received from the license Violation 259, 260, 296/85-18-04 was initially identified to the licensee as part of violation 259, 260, 296/84-18-0 In a telephone conversation on April 18,1985, the Browns Ferry Compliance Supervisor was informed that it would be a separate violatio Violation 259, 260, 296/85-18-01: Procedures and Records for Inspection of Diesel Generator Cooling Water Valves, paragraph Violation 259, 260, 296/85-18-02: Portion of Emergency Equipment Cooling Water System Not Classified as Critical Systems, Structures and Components, paragraph Inspector Followup Item, 259, 260, 296/85-18-03: Qualification Records for Inservice Inspection Personnel, paragraph Violation 259, 260, 296/85-18-04: Records for Valve Inspections, paragraph o

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The licensee did not identify as proprietary any of the material provided to or reviewed by the inspector during this inspectio . Licensee Action on Previous Enforcement Matters (Closed) Unresolved Item (259, 260, 296/84-47-02): Why Are Diesel Generator Cooling Water check Valves Not Classified as Critical Systems, Structures and Components (CSSC). This item identified an inspector's concern that components required to mitigate the consequences of a postulated accident, which could cause undue risk to public health and safety, had been specifically omitted from TVA's Quality Assurance (QA) program in that they were not included (in the licensee's listing of CSSC) in the program. The components which the inspector found omitted are those contained in the portion of the emergency equipment cooling water system (EECWS) that provides cooling water to the diesel generators. The item was identified originally in NRC Inspection 259, 260, 296/84-47, which was conducted November 13 - 16, 198 Based on discussions held with the TVA Compliance Supervisor during the current inspection, the inspector understands that TVA agrees that the subject components should be in the program but that they have not, as yet, been able to get the CSSC listing revised to correct the omission - over four months after the concern was originally identified by the NRC inspecto A general listing of CSSC is given in the Final Safety Analysis Report (FSAR) and a more detailed listing is provided in the TVA Operational Quality Assurance Manual (0QAM) and in Brown Ferry Standard Practice BF 1.11 (3/21/84). The FSAR listing is referenced in TVA's NRC approved QA program document (Topical Report TVA-TR75-1A, Rev. 8). The FSAR references the detailed listing of the 0QAM. BF 1.11 indicates its listing is taken from the 0QA The instructions provided in TVA Standard Practices often reference CSSC for applicability of requirement For example BF (10/23/84), Performance of Maintenance; BF 3.12(3/21/84), Quality Assurance Organization and Responsibilities; BF 3.2 (10/23/84), QC Inspection Program; and BF7.6 (10/2/84), Maintenance Request and Tracking; all contain specific reference to CSSC when indicating the applicability of their requirement The error of omission identified by the inspector in the TVA CSSC list and TVA's failure to obtain prompt correction of the error are considered a violation of 10 CFR 50, Appendix B: CFR 50, Appendix B, Introduction and Criterion II, together require that the licensee identify the components to which their QA program applies and that the components identified must include those which mitigate the consequences of postulated accidents that could cause undue risk to the health and safety of the public. The QA program did not meet these requirements in that it omitted components required to mitigate the consequences of postulated accidents that could cause undue risk to the public health and safety - specifically, it omitted

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the components in the portion of the EECWS that provide cooling water to the diesel generators. The TVA procedures that implement their QA program, in turn, omit the subject components from their requirements by reference, for applicability, to the CSSC list identified by the QA progra CFR 50, Appendix B, Criterion XVI requires prompt correction of deficiencies. TVA's correction of the deficiency in their QA program referred to above was not prompt, in that, over four months after it was identified to them by the NRC inspector, it had not been correcte The noncompliance with 10 CFR 50, Appendix B described above was identified to the licensee as Violation 259, 260, 296/85-18-02, Portion of Emergency Equipment Cooling Water System Not Classified as Critical Systems, Structures, and Component With the opening of the violation the unresolved item is considered close . Unresolved Items Unresolved items were not identified during the inspectio . InserviceInspection-ReviewofRecords(73755B)-Units 1,2,and3 The code applicable to the licensee's inservice inspection (ISI) is ASME Section XI (74S75). The inspector questioned licensee ISI personnel as to whether they had ISI personnel qualification records and associated eye test records available on site to show that they met the requirements of ASME Section XI. Licensee personnel stated that they did not, but that they could provide a computer printout indicating current personnel qualification and eye test data. They stated that the actual records were maintained and were available for review at their training center outside Chattanooga, Tennessee. The inspector further questioned ISI personnel as to whether there was every any surveillance or auditing to independently verify that requirements such as qualification and eye test requirements were being complied with and, if so, how this could be accomplished with no records available at the site. Licensee personnel responded that their was no independent surveillance, but that there was auditing and the auditors, who work out of a Chattanooga Office, have access to the qualification and eye test records at the training center if they determine they need to check the They stated that the detailed records of the audits were only available in Chattanooga, though the audit reports were available at Browns Ferry. The inspector reviewed a copy of the licensee's computer printout of ISI personnel qualifications and eye tests. The inspector identified the question of whether ISI personnel qualification records should be available at the site as Inspector Followup Item 259,260,296/85-18-03, Qualification Records for Inservice Inspection Personne Within the area examined no violations or deviations were identifie . .

6. StatusofInspectionandEnforcementBulletins(IEBs)(92703)

=(Closed) IEB 83-03: Check Valve Failure in Raw Cooling Water Systems of Diesel Generators (Units 1, 2 and 3)

References:

NRC Bulletin

- Inspection and Enforcement Bulletin No. 83-03 (IEB-83-03): Check Valve Failure in Raw Water Cooling Systems of Diesel Generators, dated March 10, 1983 TVA Browns Ferry Responses to IEB-83-03

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June 15, 1983 letter response from L. M. Mills (TVA) to J. P. O'Reilly (NRC Region II)

- November 7, 1983 letter response from L. M. Mills (TVA) to J. P. O'Reilly (NRC Region II)

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January 25, 1984 letter response from L. M. Mills (TVA) to J. P. O'Reilly (NRC Region II)

- January 24, 1985 letter response from J. A. Domer (TVA) to J. P. O'Reilly (NRC Region II)

NRC Inspection Reports in which IEB 83-03 was Addressed

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Report 259, 260, 296/83-32 dated September 12, 1983

- Report 256,260,296/83-41 dated December 2, 1983

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Report 259,260,296/84-11 dated April 27, 1984

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Report 259,260,296/84-22 dated July 12, 1984

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Report 256, 260, 296/84-47 dated December 12, 1984 TVA Instructions

- Mechanical Maintenance Instruction MMI-6 (10/24/84), Diesel Generator Units Scheduled Maintenance Program, Units 1 and 2, or 3 TVA Maintenance Requests (MRs) for Inspection of Diesel Generator CoolingWater[EmergencyEquipmentCoolingWater(EECW)]CheckValves

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A-271179 [ Scheduled Maintenance (SM) Item F1196] for Cooler 3C (Unit 3), completed June 15, 1984

- A-271180 (SM Item 1197) for Cooler 3D (Unit 3), completed June 15,

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- A-309385 for Cooler 3B (Unit 3), com leted August 1,1984

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A-309386 for Cooler A Units 1 and 2 , completed August 1, 1984 i

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A-309387 for Cooler B Units 1 and 2 , completed August 1, 1984

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A-309388 for Cooler C Units 1 and 2), completed August 1, 1984 l

l Note: The NRC inspector had asked to review the MRs for the valve inspections. He was informed by the cognizant Engineering Section

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engineer that some had been lost and could not be located. These were the MRs for Coolers D and 3A, reportedly MRs A-261126 and-26035 Work Plans for TVA Replacement for Subject Check Valves With New Stainless Steel Valves

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Work Plan (WP) 10453 (Units 1 and 2)

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WP 13169 (Unit 3)

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Records (Preventive Maintenance Work Item - Form 111) Indicating Deletion of Subject Check Valves From the Scheduled (Preventive)

Maintenance Program

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Foms 111 for Preventive Maintenance (PM) Item Nos. F1190 through 1197 (all dated August 31,1984)

Browns Ferry Standard Practices (BFs)

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BF7.6(10/02/84), Maihtenance Request and Tracking

- BF 6.1 (10/23/84), Performance of Maintenance a. Introduction The inspector reviewed TVA's actions in response to this Bulletin to evaluate their responsiveness to the concerns expressed and actions requested and to determine whether regulatory requirements were me The inspector found that many aspects of TVA's actions in response to the Bulletin were deficient. and that there was apparent noncompliance with regulatory requirements. A summary description of the Bulletin and a chronology of TVA and NRC actions taken in regard to the Bulletin (for Browns Ferry) are provided in Attachments 1 and 2 to this inspec-tion report, respectivel A description of the review conducted by the NRC inspector during this inspection and of his findings from the review are provided in 6.b belo b. Review and Findings The inspector reviewed TVA (Browns Ferry) and the related NRC actions in response to this Bulletin through discussions with cognizant TVA Compliance, Engineering Section and Mechanical Maintenance personnel; through examination of related TVA instructions and records (as identified by the cognizant TVA personnel); and through review of the results of previous NRC inspections of this Bulletin at Browns Ferr TVA instructions and records and NRC reports reviewed by the inspector relative to this item are identified under " References" at the heading for this paragrap The inspector identified the following apparent deficiencies in the licensee's actions:

(1) Although they did not clearly so state, TVA's initial response (June 15,1983) to the Bulletin indicated they would not perform the tests or examinations requested by the Bulletin and agreement to comply with the Bulletin was obtained only through discussions between TVA and NRC Region II management (August 26,1983).

(2) TVA's initial response (June 15, 1983) to the Bulletin was submitted one week late. Their revised response (November 7, 1983) was submitted 43 days later than agreed to in a telephone conversation held on August 26, 198 ,

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(3) The Bulletin requested that a report of the results of the examinations be submitted within 90 days of completion of the examination The last examination had been completed by August 1, 1984. The report was not submitted until January 24, 1985, 65 days later than requested by the Bulleti (4) The licensee's response of January 25, 1984, indicated that the check valves would be inspected per a plant-approved Mechanical Maintenance Instruction (MI). The inspector found that the initial inspections.were documented on Maintenance Requests (MRs)

prepared by a maintenance engineer, and licensee personnel indicated they could find no approved MMI that included instruc-tions for inspecting the valve The MRs are not " plant-approved." MI-6 did require that the cognizant engineer initiate an MR for inspection of EECW check valve The MMI did not indicate how, by whom, or for what the valves were to be inspecte (5) In response to a request from the NRC inspector (during NRC inspection of April 1 - 4, 1985) Engineering Section personnel were unable to locate records for inspections of check valves to the Diesel Generator (DG) 3A and D coolers. They were reportedly on MRs A-261126 and A-260352, which could not be foun (6) Two of the MRs were incorrectly identified for the equipment they dealt with, in that the equipment identifiers referenced system 82, whereas the valves were in system 67. The MRs with incorrect identifiers were MR A-271179 and 271180. Entry of correct identifiers is specified by TVA Standard Practice BF- Proper identifiers are needed to assure retrieval of maintenance (history) record (7) The instructions for performing the initial inspections were described in the MRs under the heading " Work Instruction". In some instances the only inspection instruction was to inspect the valves and record the condition (e.g., on MR 309386); in other instances the instruction stated " inspect check valves for damage or rust buildup." In no instance did an instruction require inspection for or even reference the concern of the Bulletin which was excessive wear that might result in the valve disk coming loose and moving to a position that would block flo Further, none of the instructions stated or referenced the failure mode encountered in the initial licensee inspections perfomed per the Bulletin - specifically excessive crud buildup causing valves to be frozen open and to not operate through their full design rang __

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I (8) In their final Bulletin response (January 24,1985), TVA indicated they would continue to reinspect the valves annually in accordance with a plant-approved MMI. In response to the inspector's request to see the inspection instruction licensee personnel stated that the only instruction was the following note contained in data -

shret 6-2 for MMI Note: Cognizant engineer initiated an MR to inspect EECW check valves during annual inspectio /

Cognizant Engineer Date This provides no criteria for inspection and therefore is inadequat The deficiencies indicated in (4), (6), (7), and (8) represent noncompliance with 10 CFR 50, Appendix 8. Criterion V requirements to prescribe and accomplish activities affecting quality through

- procedures and instructions which include criteria to determine that important activities are satisfactorily accomplishe These deficiencies are identified as Violation 259, 260, 296/85-18-01, Procedures for Inspection of Diesel Generator Cooling Water Valve ,

The ' deficiency indicated in (5) represents noncompliance with 10 CFR 50, Appendix B, Criterion XVII that records be retrievabl This deficiency is identified as Violation 259,260,296/85-18-04, Records for Valve Inspection Licensee personnel made no effort to provide the inspector with any explanation of' their actions regarding the apparent deficiencies that resulted in identification of the above violations. The inspector's concern with regard to the records had been identified in NRC Report 84-47. Based on his previously indicated concern, the inspector would have expected the ' licensee to have reviewed their records and other material related to this matter and to have taken actions to correct any deficiencies. The inspector was provided with no information that would indicate this had been don The inspector questioned Engineering personnel to determine whether the ,

above deficiencies might have been due to the improper classification (see paragraph 3 above) of the valves involved as non-CSSC. The inspector was informed that this was not the case, that licensee personnel had recognized the importance of the equipment and treated it as CSS Bulletin 83-03 is considered closed. Remaining concerns with regard to -

the licensee's actions on this matter are addressed through the above ,

identified violatio Within the areas examined two violations were identified, es described  !

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i 8 InspectorFollowupItems(IFIs)(927018)

(Closed) IFI (259, 260, 296/84-47-01): Review of Documentation for Inspection and Replacement of Diesel Generator Cooling Water Valve The inspector's interest in the documentation covered by this item was addressed in inspection of IEB-83-03, as described in paragraph 6 l above. The inspector's further interest in the matter is adequately identified in the violation described in (Closed) IFI (259, 260, 296/84-22-01): Corrections to Pump Test Procedures. The inspector reviewed the test procedures covered by this item and determined that the licensee had adequately addressed the l questions that had resulted in identification of this followup ite This matter is close Attachments

, Summary Description of IEB-83-03

' Chronology of TVA and NRC Actions l Taken in Regard to IEB-83-03 for Browns Ferry l

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ATTACHMENT 1 SUMMARY DESCRIPTION OF IEB-83-03 This Bulletin was issued to address concerns regarding the numerous incidents of check valve failures that had been found in systems important to safety and to particularly address generic check valve failures discovered in diesel generator raw cooling water systems. The IEB specifically cited examples of multiple check valve failures in the raw cooling water systems for diesel generators at two nuclear plants. The failures cited involved abrasive and corrosive wear that had resulted in the valve discs becoming detached. At one plant the discs had moved to locations that impeded cooling water flow and disabled two diesel generator Because of the generic implications of the failures that had occurred, the Bulletin indicated that holders cf nuclear plant licenses (who used raw water for cooling diesel generators) were required to take the following actions:

(1) Review the ASME Section XI Inservice Test (IST) program to ensure inclusion of diesel generator (DG) cooling water check valve (2) Examine and modify IST program to include procedures that verify the integrity cf DG cooling water check valve internals on a reasonable schedul Forward and backflow tests or valve disassembly were suggested as methods for verificatio (3) Perform initial evaluation of valve internals integrity by the end of the next refueling outage commencing after April 1,198 (4) Submit a report to NRC within 90 days of the IEB date listing the above valves and describing the valve integrity verification procedure. Include a history of known previous failure (5) Submit a report to the NRC within 90 days of completion of the initial valve integrity verification stating the results and describing any disassembly or partial disassembly of internals found.

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ATTACHMENT 2 CHRON0 LOGY OF TVA AND NRC ACTIONS TAKEN IN REGARD TO IEB-83-03 FOR BROWNS FERRY c. Chronology Date Event 03/10/83 NRC issues IEB-83-03 04/16/83 Browns Ferry Unit I refueling outage commences 06/15/83 TVA submits initial report requested in Bulletin [see 6.b.(4)

above] - report is one week late 08/24/83 Completion of NRC Inspection 259, 260, 296/83-32 which examined the licensee's Bulletin response - as stated in the report of the inspection, the licensee's response was determined inadequate as their test determine valve integrity [see 6.b.(2) procedure did notand b.(4) above report also documented a telephone conversation between NRC Region II and the TVA management in which the Plant Superintendent a within 30 days (greed to submit by September 25, a revised 1983) - thisBulletin response was documented in Inspection Report 259, 260, 296/83-32 which was issued September 12, 198 /07/83 Unit 3 refueling outage commences 11/04/83 Completion of f!RC Inspection 259, 260, 296/84-41, in which TVA was asked why the revised Bulletin response had not been provided by the agreed to date of September 25, 1983 11/07/83 TVA submits revised initial Bulletin report indicating that they will add backflow testing of the subject check valves to their ISI program, that the test will be at the quarterly frequency already applicable to forward flow tests performed to meet ASME Section XI requirements, and that the testing will be performed by January 1,1984 - the submittal was later than their commitment by 43 day /02/84 Unit I refueling complete - valve inspection not completed as requested by Bulletin or committed to in the TVA November 7, 1983 letter [seeb.(3)above]

01/25/84 TVA submits a report in response to the Bulletin, which provides further revision to the initial report and some final report information including the following:

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- Valve integrity will be determined by disassembly of the valves annually rather than by test (no reason was offered for this change from their Noven.ber 7,1983 response).

- Valve integrity verification inspections will be conducted in accordance with a plant approved Mechanical Maintenance Instructio The inspection frequency will coincide with the annual DG inspection frequency (rather than quarterly as indicated in the previous response). The inspections will be completed by January 1,1985 - allowing for completion of the annual DG inspection The inspections will not be included in the IST program (as indicated in the previous response).

- The (revised) inspection frequency is to correspond with the frequency of the annual DG inspectio The four check valves in the raw cooling water lines to one of four coolers that serve Units 1 and 2 DGs were inspected and it was found that two were frozen open by crud and two would not operate through the full design range of the flapper swing - three were cleaned and returned to service and one was replace /29/84 Completion of NRC Inspection 259, 260, 296/84-11, in which the inspector questioned a list of valves the licensee's reports had stated would be inspected - licensee personnel noted that the list was in error, that it contained valves that they were not required to and did not intend to inspect in accordance with the Bulletin; they agreed to correct their list in their next submitta /84 Replacement of check valves (and piping) to two (of four)

Unit 3 DG coolers 06/84 Replacement of check valves to one (of four) Units 1 and 2 and the remaining two Unit 3 coolers 06/15/84 TVA's inspection of check valves to two Unit 3 coolers were documented on TVA Maintenance Requests (MRs) A-271179 and-27118 /29/84 Completion of NRC ' Inspection 259, 260, 296/84-22 - as documented in the report for the inspection, the NRC inspector was infomed that the inspections of the check

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valves to the Unit 3 coolers had been performed and that they were awaiting completion of certain checks on the Units 1 and 2 valves before submitting the results to the NR /84 Replacement of remaining check valves to Units 1 and 2 cooler /01/84 TVA inspection of all DG cooling water check valves except those documented as inspected June 15, 1984, inspections were documented on MRs dated August 1,1984; however, it was not clear when the inspections were actually performed; one of the MRs (MR A309385) stated it was to document an earlier inspectio /84 Prior to September 1984 TVA had entered a requirement for an annual check of the subject valves for damage and rust in their scheduled (preventive) maintenance program (SM Items F1190-1197). On September 1984 the valves were deleted from the program on the basis that the checks would be accomplished during performance of the annual surveillance required on the DGs with an associated Mechanical Maintenance Instruction, MMI-6, providing the inspectio /16/84 Completion of NRC Inspection 259, 260, 206/84-47, in which TVA was questioned about the adequacy of the records for the subject valve /24/85 TVA submits final report requested by Bulletin - in the report they:

- corrected the previous list of applicable valves

- stated that the valves would be disassembled and inspected on an annual frequency corresponding to DG inspection frequency

- indicated that the inspection would be per a plant-approved MMI

- indicated they had found no known history of failures or significant problems with the valves except for the problems found in their first disassembly inspection and reported January 25, 1984

- stated that annual disassembly and inspection of the valves would be continued until sufficient operational experience existed for reconsideration 04/14/85 Completion of NRC Inspection 259,260,296/85-18 (

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