IR 05000259/1994022
| ML18038A949 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 10/07/1994 |
| From: | Casto C, Miller W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18038A946 | List: |
| References | |
| 50-259-94-22, 50-260-94-22, 50-296-94-22, NUDOCS 9410190045 | |
| Download: ML18038A949 (32) | |
Text
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UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W., SUITE 2900 ATLANTA,GEORGIA 30323-0199 Report Nos.:
50-259/94-22, 50-260/94-22 and 50-296/94-22 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 1, 2 and
Inspection Conducted:
September 12-16, 1994 Inspector
.
H Mi ler, Jr.
/~
f5'ateSigned Accompa ying Inspectors:
J.
W. York J.
F. King (NRR Intern)
Approved by:
asto, Chief T st Programs Section Engineering Branch Division of Reactor Safety 7 eY Date Signed SUMMARY Scope:
This routine announced inspection was conducted in the areas of engineering and technical support activities, and design changes and plant modifications.
Results:
In the areas inspected, no violations or deviations were identified.
The inspection resulted in the following assessments:
Organization and staffing levels for site engineering, which included design engineering, and in the Technical Support group, Enclosure 94i0190045 941007 PDR ADOCK 05000259
The system engineers. demonstrated a good knowledge of their assigned systems.
This was considered a positive attribute-Paragraph 2.a.
The program for the identification and tracking of potential drawing discrepancies was a positive attribute
- Paragraph 2.b(7).
Adequate engineering resources and management attention were focused to control engineering backlogs
- Paragraph 2.b.
A very detailed and comprehensive program was provided for the review, prioritization and scheduling of plant modifications that emphasizes nuclear and personnel safety - Paragraph 3.a.
The reviewed Design Change Packages (DCPs)
and Temporary Alterations (TAs) were technically adequate with sufficiently detailed
CFR 50.59 safety evaluations provided when required-Paragraphs 3.b and 3.c.
The process for control, review, installation, and removal of TAs was adequate and had effectively reduced the total number of TAs-Paragraph 3.c.
An adequate program was provided for controlling, reviewing, and changing drawings
- Paragraph 3.d.
Site Engineering's self assessment to performance goals that were more restrictive than the station's requirements should be a
factor in assuring that the group's performance will continue to remain acceptable
- Paragraph.
Persons Contacted Licensee Employees REPORT DETAILS 2.
- T. Abney, Manager, Technical Support J.
Beasley, Manager, gA Audit/Assessments R. Delay, Acting Manager, Engineering Support, Engineering and Materials
- P. Hsich, Licensing Engineer, Compliance Licensing
- J. Johnson, Manager, Site guality
- J. Naddox, Manager, Maintenance and Modifications (Acting Plant Manager)
G. Preston, Plant Manager
- P. Salas, Manager, Licensing
- W. Thomison, Supervisor, Programs, Technical Support J. Walton, Manager, Design Control, Engineering and Materials
- R. Wells, Manager, Compliance Licensing
- H, Williams, Manager, Engineering and Materials-Other licensee employees contacted during this inspection included engineers, operators, gA personnel, craftsmen, and administrative personnel.
NRC Resident Inspectors L. Wert, Senior Resident Inspector
- J. Nunday, Resident Inspector R. Musser, Resident Inspector G. Schnebli, Resident Inspector
- Attended exit meeting Acronyms and initialisms used throughout this report are listed in the last paragraph.
Engineering and Technical Support Activities (37550)
a
~
Organization, Staffing, and Training Desi n
En ineerin The inspectors reviewed the licensee's organization and staffing to determine whether the engineering organization was adequately staffed to provide effective engineering support to the plant.
Procedure SSP-9. 1, Nuclear Power Engineering Program (Rev. 4, 2/18/94), established the Nuclear Power engineering programs and defined the responsibilities for these programs.
The Vice President, Technical Support is responsible for ensuring the development, control, and maintenance of design control; configuration management, and plant modification and design change control programs and procedures.
The Manager, Corporate
'
Engineering (Chief Engineer)
is the design authority for Nuclear Power and is responsible for ensuring technical adequacy in the Nuclear Power engineering programs at each site including the control of the design change/modification process and configuration management.
The Browns Ferry Site Vice President is responsible for implementing the site engineering program.
This responsibility has been delegated to the Browns Ferry Engineering Manager who is also identified as the Engineering and Materials Manager.
The Engineering Manager is the site design authority and is responsible for implementing the design control process at Browns Ferry to ensure that safe and reliable plant designs are prepared by TVA or contractor personnel.
This manager is also responsible for the maintenance of documents such as drawings, calculations and other construction documents required for the configuration control of plant structures, systems and components.
The Site Engineering organization was comprised of six departments which reported via managers/supervisors to the Engineering Manager.
The staffing of the engineering organization was as follows:
SECTION ENGR MANAGER'
STAFF CIVIL DESIGN MECH.
DESIGN ELEC.
DESIGN ENGR.
SUPPORT OPS.
SUPPORT PROCUREMENT ENGINEERING UNIT 3 RECOVERY GROUP MANAGERS SUPERVISORS
/LEAD ENGRS DEGREED ENGINEERS
10
10 TECHNICIANS
ADMIN/
OTHERS The above staffing does not include the personnel in the engineering group assigned to the stores and warehousing organizations.
Otherwise, the above total of employees plus 40 contractors assigned to Unit 2 and approximately 300 contractors assigned to Unit 3 met the authorized staffing level.
This staffing level was expected to remain stable through the Unit 3 restart.
After the Unit 3 restart, the engineering contract work force will be significantly reduce The licensee considered the depth of technical expertise of the Site Engineering organization to be an overall strength and a key success factor to the effectiveness of the group.
Host of the engineering managers, supervisors and lead engineers have worked their way up through the discipline engineering or support engineering ranks and have an average experience at Browns Ferry of approximately 8 years and an average of 18 years experience in the nuclear industry.
However, in recent years there has been an infusion of younger employees into these positions.
This has resulted in a good balance of experience and allowed for personnel development.
Engineers in the group had an average experience level of approximately 9 years at Browns Ferry and 16 years in the nuclear industry.
The technicians had an average experience level of approximately 9 years at Browns Ferry and 15 years in the nuclear industry.
In addition to the normal design departments, the engineering organization at Browns Ferry in 1991 formed an Operations Support Department to provide "real time" response to operational plant issues requiring an engineering solution.
This multi-discipline organization, composed of a small group of civil, electrical, mechanical/nuclear, and procurement discipline engineers, provided prompt engineering response to plant problems, events, issues and operational requests.
Also, this group was the point of contact between engineering and the site maintenance and operations groups.
The licensee indicated that this new group had resulted in a reduction in the number of interruptions to the routine design work activities performed by the remaining engineering organization..
Previously, the design engineers had been required to respond to operational events and requests.
Only a very small number of the design engineering staff had operational plant experience; however, the manager and one supervisor in the Operations Support group had received STA or SRO training which should result in an improved understanding and appreciation of operational related problems.
The inspectors considered the operational support group concept to be good.
However, sufficient inspection effort was not directed to review the groups performance to obtain an evaluation as to the effectiveness of the organization's performance.
Desi n
En ineerin Trainin The inspectors also reviewed the training and qualification of the engineering organization.
Approximately 67 engineering and technical personnel assigned to site engineering were required to participate and complete the Engineering Support Personnel (ESP)
Training program by the end of 1994.
This training program was
~ initiated in 1992 and most employees had completed this training.
The remaining employees are on schedule and should complete this training by the end of 1994.
Employees were required to complete the training within two years.
The program was described by Procedures SEP-9. 1.2, Training of Personnel (Rev.
1 Change 4,
6/15/94)
and ESP 170.000, Engineering Support Personnel Training (Rev.
1, 10/8/93)
and included:
required reading of several site specific procedures related to design engineering such as SEP-9.5.6, Design Verification, SSP-12.6, Independent Verification, and SSP-12. 13,
CFR 50.59 Evaluations of Changes, Tests, and Experiments; short term training of approximately 25 days in several courses such as Applied Engineering Fundamentals, Print Reading, BWR Systems, and Introduction to Regulatory Requirements; and satisfactory performance of practical factors evaluation in areas such as independent design verification, engineering and ISI evaluations, and formal training in ASME Section III code requirements.
Also, annual-update training was performed.
This training consisted of reading selected material related to outage activities, NRC enforcement activities, vendor information, and recent plant and industry events.
,The employees received an open book examination on this material.
Prior to the current Engineering Support Training program, engineering and technical employees were required to complete a
training program which was described by Procedure BFEP PI 93-01, Orientation and Training of Site Engineering Personnel.
This training was primarily a self study program consisting of reading selective site procedures and instructions related to the engineeri'ng design effort as identified by the employee's supervisor.
Continuing training consisted of the employee maintaining an awareness of the issuance of new and revised site procedures and instructions which were applicable to the employees's position.
Engineering and technical employees not in the ESP Training program were included in this program.
The inspectors considered this program to be weak in that the employees do not receive specific operational type training covering BWR systems and plant operations.
Apparently, the licensee shared the inspectors'oncern.
Beginning in 1995, additional engineering personnel are scheduled for ESP Training with the long range goal to send most of the engineering and technical employees through the ESP Training.
However, this goal will probably not be attained until after the restart of Unit 3.
Technical Su ort S stem En ineerin System engineering support to Operations and other plant groups was provided by the Technical Support Group which is under the supervision of the Technical Support Manager who reports to the Plant General Manager.
The Technical Support Group was composed of five sections:
Electrical and 18C Engineering, BOP Engineering, NSSS Engineering, Reactor/Recovery Engineering and Programs.
The staffing of this organization was as follows:
SECTION TECH =-SUPPORT MGR.
STAFF ELEC
& I AND C BOP SYSTEMS NSSS SYSTEMS REACTOR/
RECOVERY PROGRAMS MANAGERS SUPERVISORS
/LEAD ENGRS'/2 1/3 1/2 1/3 DEGREED ENGINEERS
15
2 TECHNICIANS
ADMIN/
OTHERS The duties and responsibilities of the System Engineers include:
establishing and maintaining system performance standards; monitoring, trending and evaluating system performance; determining root cause of system performance degradation; evaluating corrective maintenance performed on the system; and coordinating and monitoring system modifications and post modification testing on their assigned systems.
The employees of the Technical Support group had worked at Browns Ferry for a number of years and had a depth of many years of nuclear experience at other nuclear facilities.
The managers and supervisors had worked for an average of 11 years at Browns Ferry
,and had a total of approximately 16 years of nuclear experience.
The engineers and technical employees had an average work experience of approximately 10 years at Browns Ferry and 15 years of total nuclear experience.
The inspectors interviewed several of the System Engineers to assess their knowledge of their assigned systems.
A walk-down inspection was performed of the RHR Service Mater, Containment Spray, and High Pressure Core Injection systems with the System Engineers assigned to these systems.
Overall, the System Engineers demonstrated a good knowledge of their assigned systems.
N Trainin of the Technical Su ort Staff The training and qualification requirements for the System Engineers were described by Procedure ESP-110.000, System-Engineer gualification Guide (Rev. 0, 9/9/93).
This training included engineering and operational training in BWR nuclear plant systems, theory, codes and standards, and event assessment and root cause evaluation techniques plus additional on-the-job type training as a System Engineer for a specific system.
All System Engineers
were required to complete this training by January 1,
1995.
The licensee informed the inspectors that the training was on schedule and that 80 percent of the System Engineers should complete the training by October 1,
1994.
Each System Engineer must be certified by the Technical Support Manager before the employee can independently perform the system engineering functions.
In the past, System Engineers received approximately eight weeks of formal training in engineering fundamentals, BWR systems and simulator training in addition to a self study program covering procedures and instructions applicable to the site.
The new training program is clearly documented and structured to assure that each System Engineer is fully qualified to perform his assigned tasks.
The inspectors held discussions with licensee personnel and reviewed documentation of selected plant activities to evaluate the engineering involvement and support of day-to-day plant operations.
This support included developing DCNs for plant modifications; preparing and reviewing temporary modifications; preparing and performing post modification testing; responding to and resolving design questions from station departments; reviewing results of surveillance tests; and preparing and coordinating the performance of special tests with operations.
Based on a review of the engineering work activities and low engineering backlog, the inspectors concluded that the current staffing levels within Site Engineering and Technical Support groups were adequate to provide the necessary plant engineering and technical support for the operating plant, i.e. Unit 2.
The engineering and technical support for Unit 3 was not evaluated during this inspection.
Engineering Backlog The inspectors reviewed the status of engineering backlogs to determine if sufficient engineering resources and management attention were being focused to prevent the buildup of a large engineering work backlog.
The following items were reviewed:
(1)
Design Change Notices (DCNs)
Procedure BFEP PI 89-06, Design Change Control (Rev.
12, 6/20/94), described the requirements for implementing design changes to the plant that were accomplished by a DCN.
Major modifications to the plant were accomplished by W-DCNs.
Routine operations and maintenance work to support an operating unit were normally accomplished by a T-DCN.
The inspector reviewed the engineering work load for FY-95 and noted that for Unit 2, a total of 21 T-DCNs and 12 W-DCNs were scheduled to be issued and a total of 104 various types
(2)
of DCNs were scheduled to be closed following completion of the modification or design engineering work.
This did not appear to be excessive.
The DCNs for Unit 3 are being performed by the Unit 3 Recovery group and were not reviewed during this inspection.
Drawings Changes As of September 13, 1994, a total of 63 Unit 2 and 1489 Unit 3 drawings were in the process of being revised by Site Engineering.
Paragraph 3.d provides a description of the
~
drawing categories and revision time following completion of a
DCN.
Drawings revisions were also required following identification of a discrepancy between a drawing and an actual plant configuration or condition.
In general, for plant modifications, Procedure BFEP PI 87-48 required Primary, Critical, and Essential Secondary Drawings to be revised by Site Engineering within 15 days following receipt of a change request and Category 2 and 3 Secondary Drawings to be revised within 180 days following receipt of a change request.
Procedure BFEP 89-06 required drawing discrepancies, identified by the D-DCN process, to be revised by Site Engineering within 15 days of receipt of the change request.
A large number of modifications were in process for Unit 3; therefore, the inspectors did not consider the number of drawing revisions in process to be excessive.
Field Change to Issued DCNs Activities required to disposition and support field changes to an issued DCN in process were accomplished by a
F-DCN.
F-DCNs were issued to correct problems or to revise the work associated with a DCN.
As of September 12, 1994, Site Engineering was processing 394 F-DCNs, of which 374 were related to Unit 3.
Based on the large number of modifications in process on Unit 3, the inspectors did not consider this number to be excessive.
(4)
Request for Engineering Assistance One of the methods used at Browns Ferry to obtain assistance from Site Engineering was by means of a g-DCN.
A g-DCN was a question or request to engineering to provide clarification against issued DCN packages or other design documents which could not be connected with an issued DCN package.
Normally, g-DCNs were issued to resolve a single issue.
During the past 12 months, Site Engineering responded to 116 g-DCNs.
As of September 12, 1994, there
were a total of 14 open g-DCNs assigned to Engineering.
The inspectors did not consider this number to be excessive.
Corrective Action Program/Problem Evaluation Reports (PERs)
The inspectors reviewed Procedure SSP-3.4, Corrective Action Program (Rev.
11, Effective Date 8/17/94),
which established the process for documenting and resolving deficiencies identified by PERs.
In May 1994, the PER process was revised to lower the threshold requirements for issuing a
PER.
As of August 27, 1994, a total of 410 PERs were open on-site.
Of this total, Engineering was assigned 88 for Unit 2 and 22 for Units 1 and 3, and Technical Support was assigned 69 for Unit 2 and 17 for Units 1 and 3.
The PERs were the principal items listed in the licensees'racking and Reporting Open Items (TROI) list.
The following list provides a comparison of the PERs on Unit 2 and Common Units which were due for completion in August 1993 and August 1994'oe artment All Departments Site Engineering Technical Support Au ust 1993 162
30 Au ust 1994 410 119 199 The licensee indicated that none of the items assigned to Engineering or Technical Support were late; however, in view of the increased number of open items, the licensee is reviewing this data and the implementing process to determine if the increase in the number of PERs being generated could result in a work backlog for these two departments.
Open Work Orders The inspectors reviewed Procedure, SSP-6.2, Maintenance Hanagement System (Rev.
12, 7/12/94) which established the process for initiating, planning, performing, canceling, completing and tracking work performed by a site work order.
Work Orders involving high risk or other technical features may be assigned to the Technical Support group for technical oversite and review.
As of September 12, 1994, there were a
total of 18 Common and 30 Unit 2 work requests assigned to Technical Support, of which ll Common and 11 Unit 2 work orders were issued prior to 1994.
The inspectors were informed by the licensee that, in general, these old items involved systems and components
'which were not safety related or essential for Unit 2 plant operations, or
~,
involved equipment no longer in use.
The inspectors did not consider the number of open work requests to be excessive.
(7)
Drawing Deviation Program The inspectors reviewed Procedure SSP-2.11, Drawing Deviation Program (Rev.
5, 8/29/94),
which established the requirements for evaluating, dispositioning, and documenting apparent discrepancies between actual plant configuration and as-constructed configuration control drawings.
Procedure SSP-2.11 requires the Technical Support group to resolve a potential drawing discrepancy within 20 working days foll'owing initiation of a drawing deviation.
The Trending of Drawing Discrepancies Report of August 22, 1994, for April - June 1994 indicated that 91 potential 'drawing discrepancies had been initiated.
The licensee's status report of September 13, 1994, indicated that eight of the open potential drawing discrepancies were late.
Seven of these late items were on Units
and 3, two were Common and one was on Unit 2.
The inspectors reviewed in detail the late Common and Unit 2 drawings.
The Unit 2 drawing involved an incorrect note on a primary drawing related to the process computer.
One of the late Common drawings was a
Critical drawing related to the amount of fire hose stored at a fire hose.station.
The other open Common drawing was related to a wiring problem on a Secondary drawing which was
.open pending additional review.
None of these late drawing resolutions were considered significant.
Overall, the inspectors considered the licensee's identification and tracking of drawing discrepancies to be a
positive attribute.
The inspectors concluded that adequate engineering resources and management attention were focused to control the engineering backlog.
Engineering Support To Operations In Narch 1994, the licensee initiated a new procedure/program involving engineering assistance for the Operations group.
The inspectors reviewed the implementing procedure for this program, SSP-12.57, Engineering Evaluations for Operability Determination (Rev. 0, 6/6/94).
This procedure provided guidelines for standardization of engineering input as an aid for determining operability.
This procedure did not change the fact that the ultimate decision on operability was with the duty Shift Operations Supervisor (SOS).
The primary focus of the Technical Operability Evaluations (TOEs)
was in determining whether a safety system or component could perform its intended function.
The TOEs
may be performed by either the plant Systems Engineer or by site engineering personnel.
The procedure was written using much of the guidance provided by GL 91-18.
The inspectors reviewed the following TOEs:
TOE No.
i Ills 2-94-075-0085 Unit 2 piping supports that did not receive ISI within 10 year intervals, dated April 20, 1994 0-94-086-0169 2-94-075-0432 0-94-050-0509 0-94-073-0569 EDG D instrument root valve, dated May 27, 1994 Operability evaluation for replacement indicating light base assembly, of 2-IL-075-14A-D527B with a gA level 3 component, dated July 22, 1994 Sodium hypochlorite system pipe support system pipe support calculations and drawings not issued, dated August 4, 1994 I/2/3-RFV-074-574 inadequately sized in accordance with ANSI B31. 1, dated August 23, 1994.
The TOE program appeared to be an effective tool for providing engineering support to plant operations.
The six TOE Reports reviewed were found to adequately address operability concerns..
Design Changes and Plant Modifications (37550)
a.
Planning, Development, and Implementation of Plant Modifications The inspectors reviewed Procedures BP-312, Browns Ferry Nuclear Plant Project Scope Control Process (Rev.
1, 2/16/94),
which provided the instructions to be followed in the originating, prioritizing and processing of a request to resolve a problem or issue with the plant.
The procedure permitted any nuclear power individual to initiate a
Plant Project Request (PPR).
The PPR originator or sponsor identifying the problem was required to complete the PPR Technical Evaluation form which provided: description of work, proposed solutions, initiating documents, scope of work, cost estimates, and cost benefit analysis.
Support from various site organizations, such as the Site Controller, Outage Manager, Engineering, or Technical Support were available to'evelop the PPR Technical Evaluation form.
The PPR was forwarded to the Scope Review Board (SRB) for technical review and disposition.
The SRB meets bi-weekly and is composed of:
Technical Support Hanager (Chairperson)
Engineering Hanager Operations Hanager Haintenance Hanager Work Schedule and Outage Hanager (Non Voting)
NSSS Vendor Representative (Non Voting)
Other personnel as designated by the SRB chairperson The SRB had the authority to approve for implementation any PPR that is less than
$ 100k.
These were items that could normally be corrected by minor modifications or by maintenance work orders; however, final review and approval for these PPR were still required by the Resource Hanagement Board (RHB).
PPRs which had been approved or PPRs for over
$ 100k were sent to the RHB for final review and approval of all work, budgets, and associated schedules.
The RHB met as needed but normally met at least once per month.
This board was composed of:
Site Vice President (Chairman)
Plant Hanager Engineering Hanager Site Controller Site Support Hanager Hanager of Project A detailed procedure had been developed to categorize and rank each PPR into one of the following three categories:
Category I: Nuclear safety/personnel safety items.
Category 2:
Items required by NRC and other regulatory organizations.
Category 3:
Items that improve plant reliability, efficiency or productivity.
Each categorized PPR was reviewed and ranked according to the nuclear and personnel safety, and financial and operations benefits that the modification would produce.
Approved PPRs were sent to engineering to develop a Design Change Notice (DCN) for implementation of the modification.
DCNs for Unit 2 were primarily prepared by the Site Engineering group.
DCNs for the Unit 3 restart effort were primarily prepared by contractors.
Following the restart of Unit 3, future Unit 3 DCNs will be prepared by the Site Engineering group.
Of the
PPRs reviewed by the SRB since January 1994, 43 were approved for. technical merit and sent to the RHB, 10 did not require RHB review and were approved for implementation, 7 were tabled for additional information, and 5 items were disapprove Of the 43 items reviewed by RMB, 23 items were approved, 15 items remained outstanding pending additional review, 3 items were tabled for addition information, and 2 items were disapproved.
The inspectors reviewed the following PPRs which had recently been issued and verified that the licensee had properly categorized and ranked these PPRs:
PPR No.
Title Descri tion 94-022 94-038 94-059 94-xxx Reactor Water Cleanup System Appendix R
Modifications (Cat.
2, Rank 3)
Install Chemical Decon Taps on RHR System (Cat. 3, Rank 18)
Replacement of CCW Inlet/Outlet Valve Operator (Cat. 3, Rank 8)
Develop Procedure to Accurately Measure Pipe Wall Thickness of Carbon Steel Piping in RHRSW and ERCW Systems (Cat. 3, Rank 10)
Note:
PPR number not yet assigned to this item.
Based on discussions with licensee engineering personnel, and review of the above documentation, the inspectors concluded that the licensee had a detailed and comprehensive program for the review, prioritization and scheduling of plant modifications which emphasized nuclear and personnel safety.
Also, based on this review, the inspectors concluded that this program was effectively implemented.
Review of Completed Design Change Notices The inspectors reviewed two site procedures that were utilized for design and modification.
The first procedure was an engineering specific procedure and the second procedure covers both engineering and the other groups that interface with engineering in this area.
The procedures were:
BFEP PI 89-06, Design Change Control (Rev.
12, 6/6/94)
.BFNP Site Standard Procedure SSP-9.3, Plant Modifications and Design Change Control (Rev.
14, 6/21/94)
A review of these engineering procedures for implementing design change control process and maintaining configuration control indicated that the process was implemented by a multiple part
Design Change Notice (DCN) which used one form to accomplish the following; A-DCN D-DCN E-DCN F-DCN G-DCN N-DCN Q-DCN Makes documentation changes to issued DCN packages.
Document and resolve discrepancies between plant configuration and issued As Constructed/Configuration Control Drawing (AC/CCD).
Emergency design changes Identify and disposition field work changes to issued DCN packages Revisions to Generic Substitution N-Spec or used to process generic material equivalencies Documentation change with, no design input change Disposition questions and provide clarifications S-DCN Documentation.changes only T-DCN Operations and/or Maintenance support V-DCN Material Equivalency Replacement W-DCN Modification to plant X-DCN Modification within an exclusion area In addition, the inspectors reviewed, in part the four Design Change Notices listed below to: (1) determine the adequacy of the-safety evaluation screenings and the
CFR 50.59 safety evaluations; (2) verify that the modifications were reviewed and approved in accordance with TS and applicable administrative controls; '(3) verify the modifications were installed and had proper signoffs; (4) verify that applicable design bases were included and design documents (drawings, plant procedures, FSAR, TS, etc.)
were revised or placed in the revision process (dependent on priority evaluation);
(5) verify that the modifications were properly turned over to Operations; (6) verify that both installation testing and post modification test requirements were specified and that adequate testing was performed.
The following plant modifications were examined:
DCN No.
W21635A
.TTit1 TO Weld Overlays For RHR, CRD, RWCU, Reactor Recirculation Piping, and Core Spray
T29781 W17433A Replacement of Obsolete Transmitters With Current Nodel Rosemonts K
Revises the Set Point Data For Feedwater Level Control T2789A Hodify 2-F-66-111 Low Flow Set Points and Dampen the Narrow Range (-111A) Signal The inspectors'eview of the above DCN packages indicated that the modification packages were complete, contained a work instruction package, contained additional information such as the design basis, and required that Category 1 (operator/control room significant) drawings be revised before turnover to Operations.
The inspectors also verified that affected drawings, tables, and figures had been updated (or were scheduled to be updated within an acceptable time frame) to accurately reflect the modifications.
The inspectors identified no significant findings for the modifications reviewed and concluded the documentation of the modifications packages was satisfactory.
Temporary Alterations The inspectors reviewed and assessed the licensee's Temporary Alterations Control Program to determine its adequacy for controlling and tr'acking Temporary Alterations (TAs) to the plant's configuration.
Site Standard Practice 12.4, Temporary Alterations Control Program (Rev. 8, 1/28/94), provided controls for preparation, review, installation, extension, and removal of TAs.
At the time of this inspection, there were 96 open TAs for Units 1, 2, and 3.
Unit 2, the only operating unit, had only 2 open TAs.
Whereas, Units
and 3 had 47 and 37 active TAs, respectively.
In addition, there were 10 active TAs common to all three units.
A select number of active TAs were examined to verify that:
(1)
adequate safety evaluations were performed; (2) testing was specified and performed where applicable; (3) independent verification was performed; (4) adequate review by qualified individuals was performed; and (5) the TAs were temporary and the licensee had a plan to remove the TAs.
The inspectors also examined the cause of delay and the overall effect of some of the TAs that were in place for more than nine months.
The following active TAs were reviewed:
TACF Number Descri tion 2-94-02-262 Install Sliding Panels on Unit 2 Generator Bus Duct Cooling Exhaust (Requested 1/12/94)
3-94-01-067 2-94-03-003 2-94-04-003 0-94-01-260 0-94-2-067 0-93-02-024 3-93-01-026 Weld Repair Flow Element that Honitors EECW Flow to Unit 3 Board Room Chiller (Requested 5/9/94)
Install Plug in Reactor Feedwater Pump 2A Casing Drain Line and Install Brace to Support the Plug (Requested 6/15/94)
Install Proximity Probes and Associated Equipment to Nonitor Reactor Feedpump Speed (Requested 5/26/94)
Install Key-Lock Switch in Communications Room Door Card Reader
.(Requested 2/15/94)
Remove Valve Disk From Hand Control Valve (0-HCV-067-088) in EECW Line (Requested 5/19/94)
Remove Valve Disk from Control Bay Chiller 1A Isolation Valve (1-ISV-024-711A)
(Requested 7/29/93)
Connect Hose from Fire Protection Drain Valve (2-26-1991) to Temporary Air Conditioning Unit to Supply Cooling Water to the Air Conditioning Unit (Requested 8/12/93)
The inspectors reviewed the TAs and verified that each TA had an appropriate safety evaluation and had been reviewed and approved in accordance with SSP 12.4.
A walkdown inspection was conducted for TAs 0-94-2-067, 0-93-2-024, and 3-93-01-026.
For these TAs, the inspectors verified that the appropriate valves were tagged and logged with the Operations group.
In addition, for 3-93-01-026 the inspectors traced the path of the hose which connected the Fire Protection Drain Valve to the Temporary Air Conditioning Unit Cooling Inlet Line; the hose was installed according to the procedures and did not present a hazard to plant equipment.
The inspectors also discovered that 0-93-2-024 has been active for more than 404 days.
According to the licensee, the replacement parts, needed to complete the job, were ordered and are scheduled to be delivered by the end of September 1994.
The inspectors also noted that this TA, along with all a'ctive TAs, receive adequate management attention; management reviewed all active TAs weekly.
In addition, the active TAs were presented to the PORC quarterly.
The inspectors concluded that the licensee's process for control, review, installation, and removal of TAs was adequate and in accordance with established procedures.
Also, based on historical data, the licensee has effectively reduced the total number of
TAs.
Much of the total reduction is attributed to the recovery efforts towards Unit 3.
Drawing Control The inspectors reviewed the licensee's program and procedures that were developed and implemented to maintain drawingcontrol..
The
'documents reviewed for the drawing control program included the following procedures and Site Standard Practices (SSP):
- 2.8 Drawing Control (Rev. 4, 4/Ol/94)
- 2.11 SSP
- 9.3 Drawing Deviation Program (Rev. 6, 9/13/94)
Plant Modification And Design Change Control (Rev.
14, 6/21/94)
BFEP PI 87-48 Revised And Controlling As-Constructed/Configuration Control Drawings (Rev.
4, 3/14/94)
BFEP PI 89-06 Design Change Control (Rev.
12, 6/20/94)
These procedures describe the controls for correcting and. updating drawings as a result of a DDCN, drawing deviation, or plant modification.
The inspectors reviewed these procedures to verify the licensee's procedures stipulated that required drawings revisions would be accomplished in a timely manner.
The four drawings categories at Browns Ferry and the required revision time were:
Category 1:
Category 2:
Category 3:
Primary and critical drawings.
These drawings are required to be revised following completion of the modification but before the completed modification is returned to Operations.
Safety-related drawings which were not Category 1 but are required to be maintained to support the design, operation or maintenance of the plant.
These drawings were required to be revised within 180 days of completion of the modification.
Non-safety related drawings which were required to be maintained to support the design, operation or maintenance of the plant.
These drawings were required to be revised to be revised within 180 days of completion of the modification.
Category 4: Drawings which did not depict configuration information or were not necessary to be maintained for
the design, operation or maintenance of the plant.
These drawings were not required to be revised.
However, there w'ere some Category 2,
3 and 4 drawings which were classified as Essential Secondary Drawings.
These drawing were maintained current like the Category 1 primary and critical drawings.
~
'
e The inspectors examined a select number of DCN packages and respective drawings to determine if the drawings were updated as required by the licensee's procedures.
The inspectors randomly selected
DCNs and reviewed the list of drawings to be changed by the DCN.
The inspectors reviewed a sample of Category 1 and Category 2 drawings from the selected DCNs to determine if they were updated to reflect the design change.
Category 1 and
drawings were chosen because of their importance; Category
drawings are Primary and Critical drawings and Category 2 drawings are Safety-related drawings, not in Category 1, which are required to be as-constructed to support the design, operation, or maintenance of a nuclear unit.
The following DCNs and associated drawings were reviewed:
DCN Number W22568A Drawin Number 2-47E611-1-4 2-47E611-71-1 2-45N2712-4 2-45E714-1
~Cate or W21933 2-47E610-46-1 2-45E620-7 0-728E990-1 2-45E2643-1 2-791E319-7 2-791E319-8 2-791E319-11 W17820A W17491A 2-47E850-2 2-47E610-26-1 2-45C800-2R-36 0-47W491-10 2-45E614-5 2-45E2641-7 2-47E610-64-3 2-45E620-4
1
2 T27897 2-45E620-15 2-47E610-55
e
The inspectors noted that all of the drawings were updated according to the licensee's procedures.
The inspectors concluded that the licensee's process for controlling, reviewing, and changing drawings was adequate and in accordance with established procedures.
4.
Self Assessment The Site Engineering organization has developed a program to monitor the groups performance in ll areas, e.g.,
the time required to incorporate design comments into the design documents; time required to update or revise drawings; and, time required to close DCN packages following work completion.
The target completion goals established for these items were more restrictive than the time established by the plant procedures.
For example, the goal for updating primary, critical or essential secondary drawings was 7 days or less where as Procedure BFEP PI 87-48 required 15 days.
The goal for updating secondary drawings was 40 days or less where as Procedure BFEP PI 87-48 required 180 days.
The inspectors reviewed the July 1994 quarterly Performance Indicators Engineering Report and noted that the current score was an average of 4.5 which was below the target goal of 5.
The score scale was from
for poor to 7 for outstanding.
Site Engineering's self assessment to performance goals that were'more restrictive than the station's requirements should be a factor in assuring that the group's performance will continue to be acceptable.
5.
Exit Interview The inspection scope and results were summarized on September 16, 1994, with those persons indicated in paragraph 1.
The inspectors described the areas inspected and discussed in detail the inspection findings.
Proprietary information is not contained in this report.
No dissenting comments were received from the licensee.
6.
Acronyms and Initialisms AC ANSI ASHE BFEP BFNP BOP BP BWR CCD CCW CFR CRD DCN EDG As Constructed American National Standards Institute American Society of Mechanical Engineers Browns Ferry Engineering Project Browns Ferry Nuclear Plant Balance of Plant Busines's Practice Boiling Water Reactor Configuration Control Drawing Component Cooling Water Code of Federal Regulations Control Rod Drive Design Change Notice Emergency Diesel Generator
.. NRC
" NSSS PER PORC PPR QA RHR RHRSW RMB RWCU SEP SOS SRB SRO SSP STA TA TACF TOE TROI TS TVA
Emergency Equipment Cooling Water Engineering Support Personnel Final Safety Analysis Report Generic Letter Instrumentation and Controls Inservice Inspection
.Nuclear Regulatory Commission Nuclear Steam Supply System Problem Evaluation Report Plant Operations Review Committee Plant Project Request Quality Assurance Residual Heat Removal Residual Heat Removal Service Water Resource Management Board Raw Cooling Water Site Engineering Procedure Shift Operations Supervisor Scope Review Board Senior Reactor Operator Site Standard Practice Shift Technical Advisor Temporary Alteration Temporary Alteration Control Form Technical Operability Evaluation Tracking and Reporting Open Items Technical Specification Tennessee Valley Aut'hority