IR 05000259/1989051
| ML18033B062 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 11/07/1989 |
| From: | Jocelyn Craig, Daniels T Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML18033B061 | List: |
| References | |
| 50-259-89-51, 50-260-89-51, 50-296-89-51, NUDOCS 8912070206 | |
| Download: ML18033B062 (12) | |
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UNITE D STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, O. C. 20555 OFFICE OF NUCLEAR REACTOR REGULATION TVA PROJECTS DIVISION Report Nos.:
50-259/89-51, 50-260/89-51 arid 50-296/89-51 Licensee:
Tennessee Valley Authority 6N 38A Lookout Place 1101 Market Street Chattanooga, Tennessee 37402-2801 Docket Nos.:
50-259, 50-260 and 50-296 License Nos.:
DPR-33, DPR-52, and DPR-68 Facility Name:
Browns Ferry Nuclear Plant, Units 1, 2, and
Inspection Conducted:
October 23 - October 27, 1989 o
an>e s, roy c anager II7'
e Approved by:
n
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rang, pecsa ss>
nt Associate Director for Specia Projects Office of Nuclear Reactor Regulation SUMMARY
~Sco e:
This special announced inspection was conducted in the area of allegation followup to establish validity and to verify corrective actions have been implemented for those determined to be valid.
The basis for this inspection was various allegations received by the NRC.
Results:
Ho violations, deviations, unresolved items or inspection followup items were identified.
Several allegation evaluations were completed as discussed in the report.
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REPORT DETA}LS 1.
Persons Contacted Licensee Em lo ees
- O. ieringue, Site Director
- G. Campbell, Plant Manager
"G. Turner, Site gA Hanagel
- L. E 1 1 is, ECSP
- P. Salas, Compliarce Licensing
- C. Elledge, ECP
- B. Norris, Corrective Actiors
- C. Hsieh, Compliance Licensing ard other personnel of the plant staff.
- T. Daniels, Project Manager A
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OSP 86-A-0010 (1)
Allegations were received by the NRC staff which stated:
The Watts Bar Control Room is likely not to be corrected since an SER from the NRC staff (NUREG-0847) states that the control room design is adequate.
Recommended Human Factors design changes at Watts Bar have not yet been implemented.
NRC has been derelict in not providing the industry with requirements in the area of human factors for nuclear power plant control rooms.
(2)
Since the allegation that recommended Human Factors design changes at Watts Bar have not been implemented could be a issue for all TVA nuclear plants, it is being reviewed and evaluated for each.
(3)
The Tennessee Valley Authority (TVA) submitted a generic Detailed Control Room Design Review (DCRDR) Program Plan to the Nuclear Regulatory Commission (NRC) on June 9, 1983 in order to satisfy the Program Plan requirements cf St pplement } to NUREG-0737, and the guiaance provided in NUREG-0700 and draft NUREG-0801.
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Supplement I ?o NUREG-0737 requires that a Program Plan be submitted within two months of the start of the DCRDR.
Consistent with the requirements of Supplement I to NUREG-0737, the Program Plan should describe how the following elements ol the DCRDR will be accomplished.
Establishment of a qualified multidisciplinary review team.
Function and task analyses to identify control room operator tasks and information and control requirements during emergency operations.
A comparison of display and control requirements with a control room inventory.
A control room survey to identify deviations from accepted human factors principles.
Assessment of human engineering discrepancies (MEDs) to determine which HEDs are significant and should be corrected.
Selectior of design improvements.
Verification that selected design improvements will provide the necessary correction.
Verification that improvements wi 11 not introduce new HEDs.
Coordination of control room improvements with changes from other programs such as SPDS, operator training, Regulatory Guide 1.97, instrumentation, and upgraded emergency operating procedures.
The staff comments on TVA DCRDR Program Plan review were forwarded to TVA by letter on November 17, 1983.
Based on the Program Plan review, the staff concluded that TVA addressed most of the nine requirements of a DCRDR specified in Supplement I to NUREG-0737.
However, the staff determined that certain elements, notably the
, task analysis, should be strengthened to provide reasonable assurance that the control room reviews based on the plan will produce results that satisfy NRC requirements.
In order to address the staff's Program Plan concerns, the NRC recommended that a meeting be held at NRC's Bethesda offices.
The meeting between NRC and TVA was held on June 14, 1984, in order to provide further detailed information and address the staff's program plan review concerns.
Supplement 1 to NUREG-0737 requires that a Summary Report be submitted at the erd uf the DCRDR.
As a minimum, it shall:
Outline proposed control room changes Outline proposed schedules for implementatio Provide summary justification for HEDs with safety significance to be left uncorrecteo or partially corrected.
TYA submitted a
Summary Report for the Browns Ferry Nuclear Power Station DCRDR by letter on December 30, 1986.
The Summary Report was reviewed by Science Applications International Corporation (SAIC).
The results of the staff and SAIC review of the licensee's Sumimary Report indicated a need for additional information and recommended that a pre-implementation audit be conducted to obtain this information arid resolve several concerns.
The audit was conducted between February 22 and 26, 1988.
In order to satisfy all nine requirements of Supplement.'f NUREG-0737, TYA will be required to provide NRC with supplements to the Browns Ferry Summary Report.
The supplements must confirm the modifications and schedule changes discussed in the Safety Evaluation.
All of these modifications and schedule changes were discussed with the licensee during the audit.
The DCRDR Program, including the new implementation schedule, is presently being implemented.
Browns Ferry is responsible for meeting its commitments as stated in the Summary Report and letters.
The NRC inspection program will monitor the implementation of the DCRDR program cosmitments.
Based on the above, the NRC staff believes that TYA has taken appropriate measures to implement Control Room Design Review requirements and will make appropriate changes to control rooms.
Therefore, this allegation is considered resolved.
b.
OSP 86-A-0117 An allegation was received by the NRC staff which stated:
During the control rod drive refueling platform modifications at Browns Ferry Nuclear Plant, Unit 3 in 1984, the following discrepancies existed:
(2)
No Engineering Change Notice (ECN) was issued to cover the work.
There were violations of procedure BF 8.3 in that no work plan or maintena>>ce request were issued to perform work.
No changes in drawings relative to the modification could be found in the Document Control vault.
The above allegations were substantiated.
An investigation, Employee Concern Program (ECP) Report ECP-86-BF-660-01, was conducted by the TYA ECP from July 14, 1987 through January 29, 1988 and issued on Viarch 25, 1988.
Tl>is investigation titled, Modification Work Performed Without Proper Work Authorization, was conducted in response to a concern expressed to the ECP in a letter and associated documents receivea on July 28, 1986.
Also, on October 28, 1986 the Browns Ferry ECP received notificatio>>
from the NPC of an allegation which was identical to the concern expressed by the aforementioned letter.
This Report of Investigation was found to have adequate findings and conclusions by the NRC staff.
Some of the corrective actions taken to preclude further problems in the area of controlling work included, revision of procedure BF 8.3, "Plant Modifications and Workplan," creation of a guality Assurance group to improve performance by tracking and trending problem areas, and compliance training has been given to appropriate site personnel.
The drawing relative to the modification was not revised to reflect the modification unti 1 June 1985.
Therefore, there was almost a
one year delay from when the modification was performed and the drawing was revised to reflect the modification.
This allegation is considered resolved.
c.
OSP 86-A-0147 (1)
An allegation was received by the NRC staff which stated:
There are significant problems with the Unit 3 computer cooling system both with operation and design.
The computer trips off the line and affects plant monitoring and control capability at a
routine interval over the past, three years due to cooling system deficiencies including system operational problems.
This problem has been known by TVA and kept suppressed to prevent "rocking the boat."
The allegation that there are computer cooling system deficiencies in the Unit 3 computer system were substantiated.
The allegation that the problem has been known by TVA and kept suppressed to prevent "rocking the boat" was not substantiated..
A review of ECP Report ECP-89-BF-963-Fl and associated ECN's and Design Change Request tDCR) Number 2491 revealed that a
new process computer was to be installed for each of the three BFN units.
In addition, Engineering Change Notice P0697 was issued to install additional Heating, Ventilation and Air Conditioning (HYAC) and redistribute existing HVAC'output.
This work was started in May 1983 and is still in the process of being completed.
Therefore, it does not appear that its existence as a problem was ever kept suppressed.
These allegations are considered resolved.
d.
OSP 87-A-0077 (1)
An allegation was received by the NRC which stated:
Browns Ferry Standard Practices, BF16.4 is not being followed in that power store personnel are performing verification of Form 575 instead of guality Control (gC)..
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(2)
This allegation was substantiated.
It appears that 575 issue forms were being reviewed by QC prior to issuance of Critical Systems Structures and Components (CSSC) until October 1987.
It was determined by TVA management this was no longer necessary in October 1987, but the revision to procedure BFI6.4 did not occur until January 1988.
This review was found by the NRC to be in excess of any licensed requirements in that:
QC was verifying components prior to installation, QC performed receipt inspection, and quarterly QC inspections are performed in the store.
Since this occurrence, all store procedures have been revised and none require a
QC inspection of the form 575 prior to issuance of CSSC material.
Although, the actual practice of issuing material was not in accordance with the procedure for over two months the significances of the error is very minor.
Therefore, this allegation is considered resolved.
e.
OSP 87-A-0097 (2)
An allegation was received by the NRC staff which stated:
The foreman of electrical inspectors inside the drywell was rushing all the jobs and modification work may have caused the Unit 2 drywell fire on November 2, 1987.
This allegation was not substantiated.
Although'there were some problems noted with electrical'connection in the area of the fire by NRC Inspection Report 50-259/87-43, 50-260/87-43, and 50-296/87-43 the investigation report by the Bureau. of Alcohol, Tobacco, and Firearms, Birmingham District did not find this as a contributor to the fire.
This report of November 2, 1987, found that based on information available the fire was determined to have been intentiona lly set by a person or persons unknown, using the accelerant, gasoline, and an undetermined ignition source.
According to the report, the fire progression was consistent with the laboratory findings of gasoline.
.All accidental causes were examined by NRC and TVA Accident Investigation Teams, but no conclusive findings were made.
Finally, the introduction of gasoline to this area of the drywell is totally foreign and could only be intentional.
Therefore, this allegation is considered resolved.
OSP 88-A-0081 (2)
An allegation was received by the NRC staff which stated:
Quality Control inspectors are being forced to perform inspections of work where work plans contain inadequate detai 1 to support inspections (Acceptance Criteria).
This allegation was not substantiated.
The work in question was the electrical cable trays, RR-ESI, RY-ESI, and GV-ESI located in Unit 2 drywell.
A Condition Adverse to Quality Report (CAQR),
BFP880351, was issued to correct the acceptance criteria used to inspect the cable trays.
This CAQR was completed on November 16, 1988.
The cable trays were inspected by the NRC on October 26, 1989
and found to be constructed in accordance with the acceptance criteria as established by CA(R BFP880351.
Therefore, this allegation is considered resolved.
g.
OSP 89-A-0001 An allegation was received by the NRC staff which stated:
Documents are not being closed.out properly.
(2)
This allegation was partially substantiated.
The closure of Significant Condition Report (SCR)
BFNEEB8627 was not adequate in that it contained an incorrected Records Information Management System (RIBS) reference for Drawing Discrepancy (DD) 2-86-0267.
The RIMS has since been corrected to reflect the proper RIMS reference for DD 2-86-0267.
The disposition of Condition
~
Adverse to equality Report (CARR) BFP880235 appears to have been handled properly, in that, it was an administrative problem and the requirements supposedly violated were not appropriate for a CARR.
This allegation is considered resolved.
h.
OSP 89-A-0006 (2)
An allegation was received by the NRC staff which stated:
The screening reviews for safety evaluation determination requirements are different for Bechtel than those performed by TVA Department of Nuclear Engineering.
This allegation was substantiated.
The conflict was a procedural problem between TYA procedure NEP6.6 which requires a safety evaluation for systems described in the Final Safety Analysis Report and Bechtel procedure EDPI 4.90K-38 which only required safety evaluations if the system was safety related.
On January 10, 1989 Bechtel requested approval from TVA for a variance to NEP 6.6 to allow them to continue to use their procedure EDPI 4.90K-38 since it contained sufficient safeguards to ensure appropriate safety evaluations were performed.
On February 2, 1989 this request was rejected by TYA.
Since the form in use required additional signatures than those required by NEP6.6 it was determined that no retro-fitting would be required, but the Bechtel procedure must be revised as soon as possible to comply with NEP6.6.
This was performed by Bechtel and revision one of procedure EDPI 4.90K-38 was issued on June 15, 1989.
The TVA procedure NEP6.6, revision I and Bechtel procedure EDPI 4.90K-38, revision I were reviewed and found to be in agreement.
Therefore, this allegation is considered resolved.
OSP 89-A-0023 An allegation was received by the NRC staff which stated:
The'environmental equipment qualification work performed by Ebasco for TVA,Browns Ferry. was totally inadequate and TVA's Engineering Assurance organization should have spotted thi (2)
This allegation was not substantiated.
There were some problem areas noted in Ebasco's work, but it was rot considered sufficient to issue a stop work order.
This was determined by a minimum of three audits performed by Engineering Assurance (EA); Audits BFK8903, 88P-95, and 88P-88.
In total, eight Conditions Adverse to Quality Reports were issued to ensure deficiencies noted by the EA Audits were properly corrected.
A stop work order was not deemed necessary by TVA after further evaluation of Ebasco's environmental qualification (EQ) work since Ebasco's contract TV-72164A as a Major Engineering Contractor for Browns Ferry was at that time slate'd for termination.
Also, at that time the EQ work was transferred to TVA's Nuclear Engineering for completion.
So essentially, TVA recognized the problem with Ebasco's EQ work, issued documents to correct errors discovered during audits by EA, and transferred the EQ work to their own engineering staff.
The quality of EA's auditing was supportea by an NRC Inspection Report, 50-259/88-11, 50-260/88-11, and 50-296/88-11, which stated that the inspector's review of TVA EA audits at Browns Ferry were identifying the same type of findings found by the NRC.
Therefore, it appears that not only was EA performing audits, but they had actually been evaluated by the NRC staff and found to be acceptable.
This allegation is considered resolved.
OSP 89-A-0038 (2)
Allegations were received by the NRC staff which stated:
TVA collected approximately 118 potential civil engineering generic condition evaluations into Condition Adverse to Quality Report (CAQR)
BFP871018.
The CAQR was closed on a generic basis without performing specific reviews for identified hardware discrepancies that may exist in the field.
CAQR's are not resolved in a timely. manner.
The allegation concerning closing of CAQR BFP871018 was not substantiated.
The allegation concerning untimely resolution of CAQR was substantiated.
CAQR BFP871018 collected 110 (118 was a typographical error in the CAQR) generic condition reviews for Nuclear Engineering.
The CAQR was closed, but all conditions that were determined to be applicable to BFN were addressed in other corrective action documents that are referenced in the closure of BFP871018.
Of the 110 CAQRs listed on BFP871018, 72 were determined by engineering to not be applicable to BFN.
Justifications for non-applicability are included in the closure package for BFP871018.
The 38 determined to be applicable to BFN have been referenced on the closure of BFP871018, which resulted in the following corrective action documents that address the issues:
CAQRs BFP880379D01 BFP880379D02 BFP880379D03 BFP880643 BFP871145 BFP880356 BFP880357 BFP880359-8-
NCR SCRs PIR BFNCEB8304R2 BFNCEB8621 BFNCEB8501 BFNCEB8634 BFHEEB8543 BFNCEB8707 These corrective action documents were reviewed to verify that they contained the referenced issue.
Host of these are currently open and involve aspects of the design baseline verification program.
A matrix was constructed by the Employee Concern Program which showed the 110 items, the 38 applicable to Browns Ferry, and the corrective action documents initiated to address the issues.
This matrix was utilized to verify the actual documents.
No apparent discrepancies were noted during this review.
Therefore, this allegation is considered resolved.
The untimely resolution of CARR's has been a continuing problem for TYA since the implementation of the new corrective action program.
The NRC inspection program has found many instances of untimely resolution.
for example, Inspection Reports 50-259/87-41, 50-260/87-41, and 50-296/87-41 listed as a violation, 50-259/87-41-01, 50-260/87-41-01, and 50-296/87-41-01 the failure to take corrective action, which specifically was issued because of the unresponsiveness in addressing adverse trends.
This area has and will continue to receive extensive NRC inspection effort to ensure improvements are made in the responsivene'ss and promptness of corrective actions.
Therefore, this allegation is considered resolved.
3.
Exit Interview The inspection scope and findings were summarized on October 27, 1989 with the personnel indicated in paragraph 1.
The inspector described the areas inspected and discussed the status of each allegation reviewed.
The need to reduce processing time of Conditions Adverse to guality Reports (CAljRs) was discussed and TVA management responded by stating efforts are now being taken and will continue to be taken to reduce the untimeliness of processing CAgRs.
The licensee did not identify as proprietary any of the material provided to or reviewed by the inspector during this inspection.
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