IR 05000259/1993008
| ML18036B270 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 03/31/1993 |
| From: | Kellogg P, Patterson C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18036B269 | List: |
| References | |
| 50-259-93-08, 50-259-93-8, 50-260-93-08, 50-260-93-8, 50-296-93-08, 50-296-93-8, NUDOCS 9305100072 | |
| Download: ML18036B270 (12) | |
Text
~p,8 REGII, Mp0 UNITED STATES NUCLEAR REGULATORY COMMISSION REGION
101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323 Report Nos.:
50-259/93-08, 50-260/93-08, and 50-296/93-08 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:
Br owns Ferry Units 1, 2, and
Inspection at Browns Ferry Site near Decatur, Alabama Inspection Conducted:
February 24 March 19, 1993 Inspector:
atterson, endor s ent nspector ate lgne Accompanied by:
J.
Munday, Resident Inspector R. Musser, Resident Inspector Approved by:
au>
.
e g,
ie Reactor Pry eats, Section 4A Division of Reactor Projects SUMMARY ate cygne Scope:
This special inspection was conducted in response to errors discovered on several of the licensees controlled drawings.
The inspection included a review of randomly selected drawings that have been revised as administrative changes, and the process used to make such changes.
Emphasis was on electrical fuse identification, numbering and control.
9305i00072 9304ib PDR ADDCK 05000259
,2 One unresolved item was identified, paragraph five.
The unresolved item was for a lack of coordination among plant organizations involved in drawing changes classified as administrative that resulted in drawings being revised.that were different than the actual configuration of the plant.
Since 1991, an estimated 1400 drawings changes were made as administrative without the knowledge of other site organizations such as plant operations.
Hundreds of fuse identification numbers were changed on controlled drawings without corresponding labeling changes in the plant.
Others examples were locked valve designation and electrical contacts being changed.
An inspector followup item was identified concerning the meaning of configuration control drawings, paragraph five.
A drawing was issued as a configuration control drawing for Unit 3 that does not reflect the physical layout of the plant.
An inspector followup item was identified concerning the meaning of locked valve designation on drawings, paragraph, five.
The licensee's pos'ition is that locked valved designation on drawings have no meaning and are controlled by other plant procedure e l.
Persons Contacted REPORT DETAILS Licensee Employees:
- 0. Zeringue, Vice President
- J. Scalice, Plant Manager
- J. Rupert, Engineering and Hodifications Manager
- R. Baron, Site guality and Licensing Manager D. Nye, Recovery Hanager
- H. Herrell, Operations Manager
"J. Maddox, Engineering Manager M. Bajestani, Technical Support Manager A. Sorrell, Special Programs Manager C. Crane, Maintenance Manager
, "G. Pierce, Acting Licensing Manager J.
Corey, Site Radiological Control Manager A. Brittain, Site Security Manager Other licensee employees or contractors contacted included licensed reactor operators, auxiliary operators, craftsmen, technicians, and public safety officers; and quality assurance, design, and engineering personnel.
NRC Personnel:
P. Kellogg, Section Chief
- C. Patterson, Senior Resident Inspector
- J. Hunday, Resident Inspector
- R. Musser, Resident Inspector
"Attended exit interview 2.
Acronyms and initialisms used throughout this report are listed in the last paragraph.
Identification of Problem 3.
Plant operations personnel while tagging out various electrical equipment during the Unit 2 Cycle 6 refueling outage discovered numerous problems with fuse identification and labeling.
Electrical drawings have unique fuse identification numbers but the labeling of fuses in the plant was not correct.
The inspector reviewed the process that permitted this configuration control problem to occur.
Administrative Changes to Drawings The inspector determined that approximately 1400 drawings have been revised as administrative changes= since Unit 2 restart in 1991.
Administrative changes to drawings are allowed by Project Instruction 89-06, Design Change Control, Section 21.0, if the changes are non-technical in nature, for documentation changes only, and they are
S
approved by the Design Control Hanager.
A formal evaluation or review'f the proposed revision is not performed.
.The affected drawing is simply marked to indicate the desired change and following approval by the Design Control Manager, is revised.
The inspector reviewed 'a number of administrative changes and noted that many of the changes appeared to be technical in nature.
Fuse Numbering Operations determined that revisions had been made to drawings which changed the unique identifiers for many fuses, many of which were made as administrative changes.
The old unique identifiers had not been removed nor the new ones installed in the field.
Design engineering was requested to identify all the fuses that had their unique identifiers changed since December, 1991.
This list included approximately six hundred fifty fuses which consisted of both safety and non-safety related fuses approximately ninety of which were a result of administrative changes.
The licensee committed to identify all safety related fuses with unique identifiers and label them in the plant by the end of Unit 2 Cycle 6 refueling outage.
These commitments are discussed in IRs 89-59 and 91-40.
Because of the large difference discovered between the drawings and labeling, operations assigned two operators to work on the problem.
Additionally, changes were made to the plant procedures (SSP 12.53) to require routing of drawings changes made as administrative to operations.
One example of this problem was documented in IR 93-02.
On February 11, 1993, the inspector noted a discrepancy in a clearance on the Reactor Recirculation Pump ATWS/RPT breakers.
The discrepancy was a result of drawing revisions which changed the unique identifiers for the control power fuses to these breakers.
Revision 7 to drawing 2-45E763-10 issued October 21, 1992, changed the fuse identifiers on the drawing but did not revise-the labels in the field.
This resulted in confusion by plant operators when the hold order was being hung.
SSP-12.3, Equipment Clearance Procedure, requires that clearances shall be prepared using only controlled drawings and if they do not exist, physical verification on as-constructed components shall be performed.
Since the drawings did not agree with the labelling in the field, positive identification of the fuses was made in the field and operations installed the correct labels and revised the clearance tags.
Additionally, six fuses were determined to be safety related 1E fuses that should have been listed on the 1E fuse list required by SSP-12.56, when originally installed in the system.
A modification'involving'these fuses was taking 'place in parallel with the development of the fuse list and the licensee failed to add them to the list.
The licensee initiated PER 93-0032 'to address the problem.
Other Administrative Changes The inspector requested drawings that were revised as administrative changes but for reasons other than fuse identification.
Engineering provided approximately sixty drawings-made since October 1992, which
included such revisions as wiring number changes, reference drawing changes, construction note changes, wire determination corrections, and relay contact logic corrections.
The inspector randomly selected five of these drawings and after walking them down found the follqwing discrepancies:
a
~
Revision ll to drawing 3-47E858-1 issued October 19, 1992 added a "Locked Closed" designation to valve 3-23-514.
This valve is the demineralized water supply to the RHRSW Heat Exch'anger A.
The drawing indicated that this designation was inadvertently removed on a previous revision; The procedure which identifies the valves designated as
"Locked", O-GOI-300-3, General Valve Operations, does not list this valve as a "Locked Closed" valve.
b.
Drawing 2-45E777-5 identifies a set of contacts for the Turbine Supply and Exhaust fans in two separate places on the drawing.
Revision 2 showed one set as "Normally Closed" and one as "Normally Open".
Revision 3 to this drawing, issued October 15, 1990, changed one set from "Normally Open" to "Normally Closed".
The other set was not revised.
Revision 4 issued January 29, 1993 revised both sets from
"Normally Closed" to "Normally Open".
Had a proper review of Revision 3 been performed the reviewer would have identified that the wrong set of contacts had been changed and it would have been corrected prior to issuance.
This review indicates that these dr awings, revised as administrative changes, lack the control necessary to ensure that plant configuration is accurately depicted.
Revising a drawing did not have close scrutiny by other site organi-zations to determine the impact the change will have on the areas of responsibility for that organization.
Because coordination among the various site organizations did not take place, drawings depicting fuses and other items exist which do not accurately reflect the condition of the plant.
This will be reviewed further and tracked as UNR 259, 260, 296/93-08-01, Design Control Coordination Discrepancies, to determine if a violation exists.
A meeting was held to discuss these issues on March 1, 1993, with operations, engineering, technical support, and quality assurance.
Two areas of concern were noted.
For drawing 3-47E858-1, the drawing was a
configuration control drawing but since it was a Unit 3 drawing only resolution of paperwork discrepancies and combining of the "as-constructed" and "design" drawing into a single drawing had been made.
It was stated that although this was a
CCD the drawing did not necessarily reflect the physical layout of the plant.
The locked valve designation change on the drawing was only to clear up the paperwork and was of no significance.
This was contrary to the inspector's previous understanding of a CCD.
A CCD, as defined in the Nuclear Performance Plan, Volume 3, was to be issued following a plant walkdown.
The CCD
was to be the drawing that replaced all previous drawings and reflected the actual physical layout of the plant.
Correction of the loss of configuration control problems, with the CCDs as the end product, was part of the basis for the plant restart.
This item will reqgire further followup to determine the real meaning of CCD's and be assigned as IFI 259, 260, 296/93-08-02, Purpose of Configuration Control Drawing.
Further discussion with the licensee revealed that the locked valve designation on the drawing was of no significance since all locked valves were controlled by GOI-300-3.
The inspector questioned the significance of locked valve designations on drawings.
What'as to be considered as reliable information on drawings?
This will be tracked as IFI 259, 260, 296/93-08-03, Purpose of Locked Valve Designation on Drawings.
Further, the inspector questioned this overall process of making a non-significant change to a
CCD that conflicted with plant procedures without operations knowledge using an administrative change.
This further"weakened the accuracy and confidence in the CCDs.
,Conclusions Due to the processing of administrative changes numerous fuse numbers were revised on plant drawings without the corresponding labels being changed in the plant which resulted in a mismatch between the plant and the drawings.
Operations was unable to effectively follow plant hold order procedures which required the use of drawings to generate hold orders.
Other examples of apparent technical changes were made as administrative changes resulting in discrepancies.
One problem identified was with the class IE fuse list not identifying some lE fuses.
These examples of problems are not the total number of errors but only a sampling readily identified.
Other problems may exist that can only be identified by reviewing the total population.
The drawing discrepancies appear to be isolated to the revisions which were accomplished as administrative changes.
When drawing changes are made as part of a DCN there are steps which ensure the drawings are accurate and the components in the field are labeled.
Exit Interview (30703)
The inspection scope and findings were summarized on March 9, 1993, with those persons indicated in paragraph I above.
The inspectors described the areas inspected and discussed in detail the inspection findings listed below.
The licensee did not identify as proprietary any of the material provided to or reviewed by the inspectors during this inspection.
The Site Vice President stated that this concern was riot a design control issue.
The changing of the fuse numbering was part of a recovery issue to be corrected.
The IFI concerning a
CCD was for a Unit
3 drawing that was not considered under configuration control until the system return to service reviews were completed.
Further discussion was desired on these issues.
A followup discussion was held between the Site Vice President, Section Chief, and Senior Resident Inspector on March 19, 1993.
A review of the administrative drawing process was made and the licensee concluded no discrepancies were identified.
The licensee committed to provide a
letter to the NRC addressing the concerns in this report before the end of Unit 2 cycle 6 outage.
Item Number Descri tion and Reference 259, 260, 296/93-08-01 259, 260, 296/93-08-02 259, 260, 296/93-08-03 Acronyms and Initialisms UNR, Design Control Coordination Discrepancies, paragraph 5.
IFI, Purpose of Configuration Control Drawing, paragraph 5.
IFI, Purpose of Locked Valve Designation on Drawings, paragraph 5.
ATWS CCD DCN GOI IFI IR PER RHRSW RPT SSP UNR Anticipated Transient Without Scram Configuration Control Drawing Design Change Notice General Operating Instruction Inspector Followup Item Inspection Report Problem Evaluation Report Residual Heat Removal Service Water Recirculation Pump Trip Site Standard Practice Unresolved Item