IR 05000259/1987004

Insp Repts 50-259/87-04,50-260/87-04 & 50-296/87-04 on 870126-30.No Violations or Deviations Noted.Major Areas Inspected:Recirculation Sys Piping Replacement,Program for Inservice Testing of Pumps & Valves & Followup Items

ML20214K436
Person / Time
Site:	Browns Ferry
Issue date:	02/23/1987
From:	Blake J, Coley J, Girard E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20214K406	List: IR 05000259/1987004 ML20214K403
References
50-259-87-04, 50-259-87-4, 50-260-87-04, 50-260-87-4, 50-296-87-04, 50-296-87-4, NUDOCS 8705280440
Download: ML20214K436 (11)

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ga afoug UNITED STATES g

jo NUCLEAR REGULATORY COMMISSION

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REGION 11 p

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101 MARIETTA STREET. N.W.

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t ATL ANTA. GEORGI A 30323

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Report Nos.: 50-259/87-04, 50-260/87-04, and 50-296/87-04

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Licensee: Tennessee Valley Authority 6N 38A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Docket Nos.: 50-259, 50-260 and 50-296 License Nos.: DPR-33, DPR-52, and DPR-68 Facility Name: Browns Ferry l', 2, and 3'

Inspection e:

n ary 26-30, 1987

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J/. L' ioley Date Signed Approved b :_.-

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'. y'.'Blake,SectionChief Date Signed a3erial and Processes Section Division of Reactor Safety

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SUMMARY Scope:

This routine, anr.ounced inspection was conducted in the areas of

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previously identified enforcement matters, recirculation system piping replace-ment, program for inservice testing of pumps and valves, licensee event reports and inspector followup items.

Results: No violations or deviations were idsntified.

B705280440 870512 PDR ADOCK 05000259 PDR G

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REPORT DETAILS

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Persons Contacted

l Licensee Employees

• J. G. Walker, Deputy Site Director

• R. E. McKenna, Information Coordinator

• F. E. Hartwig, Project Manager

• S. P. Stagnolia, Section Manager, Nozzle Replacement Group

• M. May, Manager, Site Licensing and Safety

• J. A. Savage, Compliance Engineer

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• B. Blair, Compliance Engineer

• R. L. Lewis, Plant Manager

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• R. Bentley, Level III Radiographic Examiner

T. Everitt, Welding Engineer, Nozzle Replacement Group H. E. Hodges, Engineer, Technical Support Mechanical. Test Section

I. Holt, Manager, Materials and Procurement Services

• R. A. Latimer, Supervisor, Inservice Inspection (ISI)

• M. D. Holland, Vendor Manual Project Coordinator

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NRC Resident Inspectors

• G. L. Paulk, Senior Resident Inspector

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• C. A. Patterson, Resident Inspector

• C, Brooks, Resident Inspector j

• Attended exit interview 2.

Exit Interview The inspection scope and findings were summarized on January 30, 1987, with those persons indicated in paragraph 1 above.

The inspectors described the areas inspected and discussed in detail the inspection findings.

The

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inspectors specifically noted concerns that there had been excessive delays in the licensee resolution of matters addressed in Unresolved Item 259, 260, 296/85-07-01 (paragraph 3.a), Unresolved Item 259, 260, 296/87-04-01,

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(paragraph 3.b) and Inspector Followup Item 259, 260, 296/86-04-03 (para-t graph 8.d).

No dissenting comments were received from the licensee. -The

following new item was identified during this inspection.

Unresolved Item 259, 260, 296/87-04-01: Corrective Actions for Improperly.

Stored Items, paragraph 3.b.

The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspection.

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3.

Licensee Action on Previous Enforcement Matters a.

(0 pen) Unresolved Item (259, 260, 296/85-07-01): Adequacy of Actions Taken with Regard to Allegations Concerning Category 1 Supports.

This item was opened to express concern that the licensee failed to sufficiently investigate the alleged violation of procedures by a general foreman and a project engineer.

During NRC Inspection 85-07, the Browns Ferry plant manager committed to a further investigation.

This further investigation was completed by licensee Concerns program personnel in October 1986 and it confirmed that the subject general foreman had knowingly and repeatedly violated procedural requirements for work on safety-related items.

The NRC inspectors reviewed the investigation performed by Concerns Program personnel during NRC Inspection 86-42. In that inspection the inspector questioned licensee personnel as to whether any personnel action was anticipated in response to the investigation findings. The inspectors were informed that the need for personnel action would be determined by management in their review of the matter.

During the current inspection the inspectors discussed the status of licensee actions on this item with the TVA Concerns Program Coordinator and were informed that, although a report of the Concerns Program investigation had been released, there had been no decision as to personnel action. The inspectors expressed their concerns regarding the delay in resolution of this item with responsible licensee personnel, including the Deputy Site Director.

This iteca remains open pending the licensee's determination and implementation of corrective action and review of the corrective action by NRC Region II.

b.

(Closed) Violation (259, 260, 296/86-04-01):

Snubber Storage This violation involved snubbers which were improperly stored and tagged.

TVA's letter of response to the violation, dated April 10, 1986, was reviewed and determined acceptable by Region II.

During NRC Inspection 87-01 the inspectors discussed this item with responsible licensee personnel and inspected the TVA Power Stores storage area.

The inspectors found that TVA had implemented the corrective action stated in their response.

However, the response addressed only the specific examples of snubbers, identified in the violation and the

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inspectors observed that additional examples of snubbers appeared improperly stored and that they exhibited rust. There were no " Hold"

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tags on these snubbers to indicate that the apparently unsatisfactory storage had been identified by licensee personnel. One of the NRC inspectors questioned a TVA QA surveillance inspector as to the

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acceptability of the conditions observed.

The TVA surveillance inspector stated that widespread improper storage conditions had been identified previously and that corrective action had been taken to assure the acceptability of improperly stored items prior to release.

During the current inspection the NRC inspectors reviewed this matter further with responsible Power Stores and QA personnel. The inspectors also reviewed a memorandum from the Site Director to management personnel dated September 3, 1986, which acknowledged the deficient storage conditions and established a plan to resolve the deficiencies.

The inspectors found that the plan required:

No safety items are released from storage without QC authoriza-

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tion.

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Before they authorize release, QC inspectors obtain engineering evaluations of the acceptability of all items whose conditions they feel are unacceptable or indeterminate.

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If the capability of an item to adequately function or operate cannot be readily determined, but it meets all other inspection criteria, the item should be accepted for issue.

Normal plant procedures require a functional test of safety related items at the time of installation.

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After warehouse storage level capabilities are determined materials subsequently received will be stored in accordance with the preventive maintenance program level requirements designated by the TVA Contract Engineering Group (CEG).

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A preventive maintenance program was to be provided by September 10, 1986.

The inspectors expressed their concern that the licensee's plan allowed materials received prior to determination of storage level requirements to continue to be improperly stored with no evaluation of their condition to be performed until they are requisitioned. The inspectors informed licensee management that this lack of timely evaluation, disposition and assurance that all items were properly stored did not appear to represent a sati sfactory resolution of their storage deficiencies.

The inspectors indicated that the significance of TVA delays in implementing fully acceptable storage requirements and dispositioning improperly stored materials would be identified as Unresolved Item 259, 260, 296/87-04-01, Corrective Actions for Improperly Stored Items.

This Unresolved Item addresses the concerns that remain relative to Violation 259, 260, 296/86-04-01.

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(0 pen) Violation (260/86-03-01):

Failure to Follow Procedure for

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Housekeeping in Radiation and Contaminated Areas.

Browns Ferry Procedure 14.2L " Safety Inspections and Audits," was revised due to NRC s

inspect 4T > findings that identified inadequate housekeeping practices.

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In addi(ton, the licensee committed to perform periodic surveillances

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of housekeeping activities to insure that the provisions of the revised

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procedure ' (BF-14.?.) were met.

These surveys were performed from

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May 20, 1986 to December 12, 1986.

In the course of these surveys, numerous deficiencies were found. Information obtained as a result of the surveys indicated that the corrective actions committed to have not resulted in the desired improvements.

As a result of the survey findings.the licensee issued Corrective Action Report (CAR) 86-0246 i

against the plant for inaffective corrective action.

The licensee's

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'jl, resolution of this matter will be reviewed in a subsequent inspection.

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(0pbn) Violation (259/84-11-01):

Reactor Vessel Support Skirt o

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Examination. This item dealt with an inadequate examination of the required inspection volume on the reactor vessel support skirt. This

item was initially written on all units and TVA re-examined the welds on Units 2 and 3 (see Inspection Report 86-03).

However, Unit I was never re-examined.

The inspector discussed this with the cognizant a

inservice inspection supervisor and found that the inspection has not been performed on Unit 1 because tne plant has stopped all inservice work on Unit 1 until Unit 2 is operational. This item will remain open until the licensee corrective action is complete on Unit 1.

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Unresolved Items i,

Unresolved item are matters about which more information is required to determine whether they are acceptable or may involve violations or devia-tions. An unresolved item identified during this inspection is discussed in

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paragraph 3.b.

5.

Inservice Testing Program For Pumps and Valves In a letter dated December 23, 1986, the licensee submitted a new inservice testing program to the NRC. This program contains a number of requests for relief from the requirements of the applicable code for the testing, which is ASME Section XI.

Such requests are evaluated by the NRC in accordance with 10 CFR 50.55a(g)(4) and responsibility for performance of the evalua-tion has been assigned to NRC Region II.

During the current inspection, the NRC inspectors' activities relative to the program submittal consisted of (1) obtaining the licensee drawings needed to aid in understanding the locations and functioning of the pumps and valves and (2) identifying licensee technical personnel who would be directly ' responsible for providing any additional information required.

As understood by the inspectors the individual with primary technical responsibility is the Technical Support Mechanical Test Section engineer listed in paragraph 1.

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5 Within the area examined, no violations or deviations were identified.

6.

Recirculation Piping Replacement (Unit 2)

The inspectors found that piping replacement work activities had. essentially ceased while the licensee investigated and evaluated apparent lack of fusion indications observed in their safe-end to reactor vessel nozzle replacement welds. Only three (of ten) such welds had been attempted in the field and all three exhibited similar questionable indications on the radiographs.

The inspectors discussed the matter with responsible licensee personnel, observed safe-end mock-up welds and reviewed radiographic film associated with the safe-end welds to verify that the licensee's actions represented good engineering practice and compliance with NRC regulations and TVA commitments.

The -inspectors had previously inspected this area during NRC Inspection 87-01.

Significant concerns with regard to the licensee's practices for recirculation piping replacement welding and nondestructive examination (NDE) work were described in the report for that inspection (reference Unresolved Item 259, 260, 296/87-01-03).

Four of those concerns were examined further in the course of. the current inspection.

The original concerns and the inspector's findings from the current inspection are as follows:

(1) Original Concern: The Level II radiographer failed to identify lack of fusion that was apparent on a safe-end mock-up weld.

Finding: The inspectors were informed that the reason the examiner failed to identify the lack of fusion was that the radiographs were forgotten and not reviewed. The inspectors expressed concern to TVA management that no one had been responsible enough to assure that the radiographs were considered prior to performance of production safe-end welds.

(2) Original Concern:

There was no Level III radiographic examiner overview of the mock-up weld radiography.

Finding:

The inspectors. found that the licensee was now assuring an overview of related weld radiography by a Level III examiner.

(3) Original Concern:

The root _ pass installation weld for nozzle

"G" safe-end was accepted by a Level II radiographic examiner. This joint was-subsequently rejected by the same radiographic examiner after several additional weld layers had been added to the joint.

The discrepancy that caused rejection of the weld was also on~ the film when root pass radiography was performed but was not recognized by the radiographe.

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Finding: The inspectors reviewed the root pass radiography and

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found that although the discrepancy was-apparent it did not appear

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rejectable at that point in the welding. ' The Level II radiographer was not at fault and the inspectors condiser this concern to be

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resolved.

-(4) Original Concern: Mock-ups used to train welders for-the nozzle to -

safe-end welding did not have exactly the same joint preparation as the production weld. The production welds had a 12 degree taper on the bottom surface of the nozzle weld prep that was not-on the mock-up. This taper could result -in accenting a root edge condition

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on film and could result in incorrect interpretation of the production radiographs.

In addition, this condition is almost

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i impossible to verify on the inside surface of the production weld.

I Finding: The inspectors reviewed additional mock-up work that has been performed by the licensee and found that the 12 taper did not appear to have resulted in the accenting of a' root edge condition.

The inspectors _ questioned licensee personnel as to the details of their

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investigation and evaluation of the apparent lack of fusion in the safe-end welds.

In response to their questions, the inspectors were informed that the actions that had been or were being undertaken were extensive, and included radiographic enhancement, development of improved a

welding parameters, development of special ultrasonic examination

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standards, automated ultrasonic examination of field welds, review of i

radiographs by various experts, review of ASME code cases to determine a

possible basis for acceptance of the observed indications, possible

boroscopic examination of the root of the field welds '(which are

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currently inaccessible for visual examination), etc.

The inspectors found that the licensee had no documented plan for the investigation and

evaluation of the indications, even though it had been underway for over

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three weeks. Licensee personnel stated that there was no requirement' for such a written plan.

In response, the inspectors noted that their lack of formal planning and controls in thier original preparation for the welding had resulted in their failure to recognize rejectable indications in their original mock-up welds.

Prior to the conclusion of the inspection, Region II requested the licensee to prepare and implement a

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written plan to cover the investigation and evaluation work and possible repairs of the safe-end welds.

Licensee management agreed to-the request.

Within the area examined, no violations or deviations were identified.

7.

Licensee Event Reports (LERs) (92700)

a.

(Closed) LER 50-259/83-23, Intergranular Stress Corrosion Cracking in Recirculation System Pipe Welds. During the '1983 refueling outage of Unit 1, the licensee notified Region II that ultrasonic inspection required by IE Bulletin 83-02 had detected crack-like inications on

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recirculation system weld KR-1-37.

Subsequent ultrasonic examinations conducted in accordance with IE Bulletin 83-02 revealed crack-like indications in 33 of the 91 welds examined.

In addition to the inspection of welds on the recirculation system piping, 32 welds on

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the residual heat removal (RHR) system-piping were ultrasonically examined. Crack indications were detected on 14 of the 32 welds. IE Bulletin 83-02 activities at the Browns Ferry facility were examined in d2 tail by NRC Region II personnel at the time.

A listing of-corrective measures taken were also submitted to Region II by TVA in a 90 day report (Reference Memorandum from L. M. Mills to J. P. O'Reilly, dated May 22,1984). This submittal was reviewed in detail by Region II.

All subsequent actions taken by the licensee for the inspection, repair and mitigation of intergranular stress corrosion cracking on Unit 1 will be inaccordance with the recommendations of NRC Generic Letter 84-11.

b.

.(Closed) LER 50-296/84-06, Jet Pump Instrument Nozzle. Cracking.

This reported condition dealt with intergranular stress corrosion cracking (IGSCC) that was detected in two jet pump instrument nozzle safe-ends on Unit 3 and the subsequent detection of 'IGSCC on two additional nozzel safe-ends on Unit 2.

A contributing factor may have been that Units 2 and 3 were procured from Ishikawajima-Har_ima Heavy Industry Company, Ltd., a Japanese vendor, while Unit I was bought from Coulter Steel and Forging Company.

The certified material test reports from the Units 2 and 3 vessel ' penetrations show a higher carbon content than those for Unit 1 increasing the

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potential sensitization areas.

This event was, therefore, deemed Part 21 reportable.

The inspectors observed in process repair and replacement work on i

these items at the time of its performance.

In addition, the completed records were also reviewed. Actions were taken by TVA to reduce the effect of IGSCC on the remaining jet pump nozzle-safe-ends. Inspections, repairs and other corrective actions have been completed for all three units at Browns Ferry. Therefore, this item is considered closed.

8.

Inspector Followup Items (IFIs)

a.

(0 pen)

IFI (259, 260, 296/84-40-07):

Historical Information on Equipment.

This item identified an inspector's concern that the licensee's maintenance history records might not be complete and that they had not provided a satisfactory response to related concerns expressed in NRC Generic Letter (GL) 83-28, Item 2.2.

The inspectors discussed this a

matter with responsible TVA personnel, directing particular attention to the licensee's actions with regard to assuring that vendor manuals

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and data for important equimpent are obtained, properly controlled and i

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updated. The inspectors found that the licensee had taken action to accomplish their commitments in this area but that actual accomplish-ment was as yet incomplete.

Related documents reviewed by the inspector were as follows:

September 2,1986 letter from R. Cridley (TVA) to J. Grace (NRC,

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Region II), providing an update on the Browns Ferry Vendor Manual Control Program.

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June 1986 Revision (R0001) of Site Director Standard Practice 10.1, Vendor Information Program.

Pending TVA completion of their actions in regard to GL-83-28, Item 2.2, this matter remains open.

b.

(0 pen) IFI (259, 260, 296/85-07-02): Adequacy of Procedures.

This item identified an inspector's intention to assure that TVA procedure MAI-23, BF 8.3, and other procedures used for piping support inspections be reviewed for adequacy. During NRC Inspection 86-27, it was determined that the reported findings of the TVA Welding Project relative to support welds would be taken into consideration in resolving this item.

In the current inspection, the inspectors questioned licensee personnel as to whether the Welding Project work had been completed and reported to the NRC.

The inspectors were informed that the work had been completed and that a report of the findings was to be formally submitted to the NRC in the near future. This item will remain open pending the Region II review of related information provided in that submittal.

c.

(Closed) IFI (259, 260, 296/86-27-02): Does Common Start Date for ISI Program Apply to Pump and Valve Testing This item was opened to identify the need to determine if an NRC approved start date for the licensee's Inservice Inspection (ISI)

interval was applicable to their inservice pump and valve testing.

During the current inspection, the inspectors reviewed related corre-spondence and determined that the apprcved interval die aply to pump and valve testing. The matter is considered resolved.

d.

(0 pen) IFI (259, 260, 296/86-04-03): Adequacy of Work Plan Records Unresolved Item 83-41-05 identified an inspector's concern that QA personnel were being relied on to detect a higher incidence of errors, such as material requisition discrepancies, in completed Work Plans (records). The QA personnel were reviewing all completed Work Plans

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and the frequency of errors that was being detected by them was so high that it was apparent that they were not performing their intended surveillance or audit function, but that they were instead, performing the functions of others who were supposed to have assured the Work Plans were satisfactory before they were submitted to QA..During-NRC Inspection 86-04 (conducted January 13-17,1986) an NRC inspector found that the licensee had taken actions that addressed the concern:

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Responsibilities for assuring the completed Work Plans were satisfactory had been clearly assigned to personnel responsible for the work

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QA was now only to check a sample of Work Plans

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Discrepancies previously identified in Work Plans by QA had been documented on Corrective Action Reports (CARS) and dispositioned for correction by Modification personnel responsible for the work (the NRC inspector examined CARS84-094 and 83-163 as examples).

The inspector was informed, however, - that the most recent QA check of Work Plans indicated continued deficiencies. The inspector indicated his concern that the licensee assure correction and identified IFI 86-04-03 for followup.

In the current inspection the NRC inspectors questioned licensee personnel to determine if the licensee's corrective action had assured proper completion of Work Plans.

The inspectors were. informed that QA surveillances conducted in December 1986 had.found continuing deficiencies.

Cognizant licensee personnel stated that corrective actions are targeted to be completed by March 15, 1987. The inspectors expressed concern to licensee management that Work Plan problems had continued too long.

This matter remains open.

e.

(Closed) IFI (259, 260, 296/86-04-02) Implementation of Corrective -

Actions to Resolve Procurement Problems. This item had been initially identified as an unresolved item and dealt with an inspector's concern that the licensee's engineering organization and the plant organization were applying conflicting requirements in the procurement of materials.

During a subsequent inspection, an NRC inspector reviewed the status

of licensee actions relative to this item and found that licensee management had become aware of the material procurement problems described by the inspector; that it and related problems had been openly acknowledged and extensively reviewed by them; and that corrective actions had been recommended.

In re-examining the item, the inspector found no indication that the inconsistencies in the licensee's engineering and plant procurement requirements had resulted in use of unsatisfactory material.

As a result of the actions identified above, the inspector closed the unresolved item and opened an inspector followup item to insure additional NRC followup would be conducted to determine the implementation and adequacy of the licensee's proposed corrective action.

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During the current inspection, the inspectors discussed this matter with the Materials and Procurement Service Manager and were informed

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that TVA was committed to a central source for procurement of materials -

at the site. The inspectors were informed that the following actions had taken place or were in the process of-being formalized.

(1) The TVA Manager of Nuclear Power had issued a directive to senior TVA managers directing that a central source of procurement be established at each site.

'(2) On - January 1, 1986, the Contract. Engineering Group -(CEG) was established on site. This group established a tentative agreement with ' the Division of Nuclear Engineering (DNE) to pass DNE's requisitions thru CEG.

(3) A formal agreement was scheduled to be signed between CEG'and DNE-on January 30, 1987. On February 3, 1987, the inspectors were-informed, per telecon with the Materials and Procurement Service

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Manager, that the agreement had been signed on February 2,1987 and that DNE would staff the centralized procurement group.

The licensee's corrective actions delineated above appear satisfactory

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and this item is considered closed.

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