ML18030B189

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Insp Repts 50-259/86-04,50-260/86-04 & 50-296/86-04 on 860113-17.Violation Noted:Snubbers Stored in Open Crate W/O Caps,Plugs or Seals & Snubber Hold Tag Not Affixed for High Visibility
ML18030B189
Person / Time
Site: Browns Ferry  
Issue date: 03/05/1986
From: Blake J, Girard E
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML18030B187 List:
References
50-259-86-04, 50-259-86-4, 50-260-86-04, 50-260-86-4, 50-296-86-04, 50-296-86-4, GL-81-34, NUDOCS 8603180084
Download: ML18030B189 (13)


See also: IR 05000259/1986004

Text

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UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION II

101 MAR IETTA ST R E ET, N.W.

ATLANTA,GEORGIA 30323

Report Nos.:

50-259/86-04,

50-260/86-04,

and 50-296/86-04

Licensee:

Tennessee

Yalley 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

3

Inspection

Conduct d:

January

13-17,

1986

Inspector: f.

rd

ate Signe

Approved by:

J.

.

a e,

ect>on

C ie

f gin ering Branch

vision of Reactor Safety

ate

Soigne

SUMMARY

Scope:

This routine,

unannounced

inspection entailed

35 inspector-hours

on site

in the

areas

of licensee

action

on previous

inspection

findings

and inspector

followup items.

Results:

One violation was identified - Snubber storage,

paragraph

3.a.

8603180084

860312

PDR

  • DOCK 05000259

8

PDR

REPORT DETAILS

Persons

Contacted

Licensee

Employees

  • R. L. Lewis, Plant Manager
  • J. E. Swindell, Superintendent

- Operations/Engineering

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

ISI Programs

Engineer

  • B. C. Morris, Compliance Supervisor
  • D. C. Mims, Engineering

Group Supervisor

  • L. Clardy, guality Surveillance

Section Supervisor

J. Garison, guality Assurance

Supervisor

J.

M. Hammond, guality Assurance

Evaluator

M. E.

Gann, guality Control Inspector

S. Jones,

Compliance

Engineer

H.. Dean, Special

Project Coordinator,

Power Stores

W. Zimmerman, Supervisor,

Power Stores

NRC Resident

Inspectors

  • G. L. Paulk, Senior Resident

Inspector

  • C. A. Patterson,

Resident

Inspector

  • C. R. Brooks, Resident

Inspector

  • Attended exit interview

Exit Interview

The inspection

scope

and findings were summarized

on January

17,

1986, with

those

persons

indicated

in paragraph

1 above.

The inspector

described

the

areas

inspected

and discussed

in detail

inspection findings a.

through c.

listed below.

The inspector followup item listed

as d. below was identified

to the licensee

on January

21,

1986.

I

During the discussion,

the

inspector

informed

the

licensee

that their

responsiveness

to resolution of safety-related

issues identified during

NRC

inspections,

such

as the concerns

indicated through inspector followup items

and unresolved

items,

appeared

inadequate.

The inspector stated that,

based

on his experi'ence

during the current inspection, it appeared

that licensee

individuals

were

not assigned

clear responsibility for understanding

the

concerns

raised

by

NRC inspectors,

assuring

any necessary

corrective action

was promptly taken,

or providing

NRC inspectors with the information needed

to verify that the concerns

were satisfactorily

resolved.

No dissenting

comments

were received

from the licensee.

a

~

b.

c ~

d.

Violation 259, 260, 296/86-04-01,

Snubber storage,

paragraph

3.a.

Inspector

Followup

Item 259,

260,

296/86-04-02,

Implementation

of

corrective actions to resolve

procurement

problems,

paragraph

3.b.

Inspector

Followup Item 259,

260, 296/86-04-03,

Adequacy of work plan

records,

paragraph

3.c.

Inspector

Followup Item 259, 260, 296/86-04-04,

Storage of radiographs,

paragraph

3.a.

The licensee

did not identify as proprietary any of the material

provided to

or reviewed

by the inspector during this inspection.

3.

Licensee Action on Previous

Enforcement Matters

a ~

(Closed)

Unresolved

Item (296/82-04-02):

Valve Storage

Conditions.

This item was

opened to identify an

NRC inspector's

concern that valves

were

being

improperly stored

under conditions

that might result in

their deterioration.

The valves

were stored outdoors.

The inspector

noted that this storage

was in conflict with the requirements

of the

standard

normally applicable to storage of equipment at nuclear plants,

ANSI N45.2.2.

When the item was opened,

the inspector involved had not

determined

the identification of the valves

observed,

their intended

use (safety-related

or non safety-related),

or the storage

requirements

applicable to Browns Ferry.

The inspector

opened

the unresolved

item

for subsequent

evaluation of the storage

condition

and its signifi-

cance.

When questioned

by the

NRC inspector with regard to this item during

the current inspection,

the licensee

indicated that they had

no related

information

and

had apparently

not addressed

the concern

expressed

in

the item.

They stated

that they believed that this item pre-dated

the

time when they began

tracking

and maintaining information with regard

to

NRC inspection unresolved

and inspector followup items.

In examining this

item during the current

inspection,

the inspector

could not address

the specific valves originally observed

due to the

lack of information regarding their identities

and the

amount of time

that

had passed.

To resolve

the item, the inspector elected to examine

the licensee's

storage

of safety-related

equipment,

such

as valves, to

determine if they were currently stored

in compliance with the appli-

cable requirements.

The licensee's

requirements

for storage of equipment

were determined

by

the inspector

from a review of the following documents:

TVA Topical Report TVA-TR75-lA (Rev. 8), Section 17.2.13

(Handling,

Storage

and

Shipping)

and

Table

17D-3 (Regulatory

Guidance for

guality Assurance

During Station Operation)

Nuclear

Quality

Assurance

Manual

(Rev.

8/1/85),

Part III,

Section 2.2

(Receipt

Inspection,

Handling,

and

Storage

of

Materials,

Components

and Spare

Parts)

Nuclear

Power Standard

TS 01.00. 15. 14.03

(Rev. 0),

Equipment

and

Material Storage

Requirements

for Nuclear

Power Stores

Browns

Ferry

Standard

Practice

BF

16.4

(11/27/85),

Material,

Components

and

Spare

Parts

Receipt,

Handling,

Storage,

Issuing,

Return to Storeroom

and Transfer

Browns Ferry Standard

Practice

BF 16. 11 (8/7/85), Interim Storage

Procedure

U.

S.

NRC Regulatory

Guide

1.38

(Rev.

2), Quality Assurance

Requirements

for Packaging,

Shipping,

Receiving

Storage,

and

Handling of Items for Water-Cooled

Nuclear

Power Plants

ANSI 45.2.2-1972,

Part 6, Storage

Having

determined

the

storage

requirements,

the inspector

examined

their implementation

as follows:

The inspector verified that

the licensee

had

performed required'

surveillances

of

storage

through

discussions

with quality

assurance

(QA) surveillance

personnel

and examination of surveil-

lance reports

P-9-QAS-85-160 (2/7/85),

P-ll-QAS-85-462 (4/12/85),

MA-1-QAS-85-896

(7/30/85)

and

SP-32-QAS-85-869

(8/14/85),

as

examples.

(2)

(3)

(4)

The inspector

observed

storage

of equipment

in the

power stores

storage

area

to determine

its

compliance

with the

licensee's

storage

requirements

and

discussed

storage

with responsible

personnel.

As

a consequence

of the inspector's

observations

of two snubbers

that

appeared

inadequately

stored,

the

inspector

reviewed

the

manufacturer's

storage

instructions

for

the

snubbers.

The

snubbers

were identified

as

Contract

85P73

350933,

P/N 78000,

KB-21 snubbers,

QA-I.

The storage

instructions

were contained

in

procedure

BP-8396-51

(approved

12/14/84).

From discussions

regarding

storage

with QA and storage

personnel,

the

inspector

became

aware

of

a

serious

licensee

identified

storage

deficiency

which

involved

improper

storage

of items,

particularly electrical

cable.

The

matter

was

apparently

originally

identified

in

the

licensee's

Audit

Deviation

BF-8400-03-01.

The inspector

reviewed

the following,documents

related

to the matter

and questioned

involved personnel

regarding

the

actions

being

undertaken

to determine

that

they

appeared

proper:

v

1'L

Corrective Action Report 84-083

Memorandum

from T.

F. Ziegler to G.

W. Killian, Browns Ferry

Nuclear Plant - Oivision of guality Assurance

Audit Report

BF-84000-03-01,

dated

11/13/85

Memorandum

from R.

D.

Putman to L.

W. Jones,

Browns Ferry.

Nuclear Plant - Corrective Action Report 84-083-CABLE, dated

12/6/85

Memorandum

from J.

M. McGriff to T.

F. Ziegler, Evaluation

Team

Report

on

Browns

Ferry

Nuclear

Plant

Power

Stores

Material

and Equipment,

dated

11/16/84

In his examination of storage

and storage

documentation

during the

current

inspection,

the

inspector

observed

ASME Section III

Class

2

and

3 valves stored

outdoors - an identical situation to

that for which item 296/82-04-02

was

opened.

However, licensee

personnel

informed

the

inspector

that

the

valves

and

other

materials

stored

in the area

were considered

surplus

and would be

sold or scrapped,

they would not

be

used

at Browns Ferry.

The

inspector

accepted

this explanation

and,

on the

basis

of his

examination of storage,

item 296/82-04-02 is considered

closed.

Unrelated

to the original item of concern,

the inspector

observed

two snubbers

identified in (3) above with the following improper

storage conditions:

NIZAM, Part III, Section

2.2,-Subsection

4.2,

requires

that

equipment

in storage

be maintained

in accordance

with the

manufacturer's

instructions.

The manufacturer's

instructions

specified

that all

openings

into the

snubbers

be

capped,

plugged,

or sealed,

and that the

snubbers

be

covered with

waterproof

tarps.

On

January

16,

1986,

the

inspector

observed

the snubbers

stored

in

a Kelly Building in an

open

crate with openings

into the snubbers

lacking caps,

plugs or

seals.

The inspector

also

observed

that the snubbers

were

not covered with a waterproof tarp.

C

The inspector

was informed,that the snubbers

had

been placed

on "hold", because

of removed parts,

in accordance

with the

requirements

of BF 16.11.

BF 16.11 requires that hold tags

be affixed for high visibility.

The

hold

tag for the

snubbers

was found in the bottom of the

open crate in which

they were contained.

It was not affixed for high visibility.

Further,

although

the

tag

did

have

a

number

which

was

traceable,

spaces

on the tag for entry of equipment

informa-

tion were left blank.

The conditions

described

above

are considered

noncompliance

with

10 CFR 50,

Appendix

B, Criterion V, requirements

for compliance

with instructions

and procedures.

This noncompliance

is identi-

fied as violation 259, 260, 296/86-04-01,

Snubber

Storage.

While inspecting

equipment

storage,

the inspector

inadvertently

became

aware that licensee

personnel,

who were

conducting

a

gA

audit,

had

found evidence

of improper storage

of safety-related

weld radiographs.

The

inspector

identified this for further

review as inspector followup item 259, 260, 296/86-04-04,

Storage

of Radiographs.

(Closed)

Unresolved

Item (259,

260, 296/83-41-01):

Conflicts Between

Plant

and

ENDES Procurement

Requirements.

This

item identified

an

inspector's

concern

that

the

licensee's

engineering

organization

and

the plant organization

were

applying

conflicting requirements

in the procurement

of materials.

During the

current

inspection,

the

NRC inspector

questioned

licensee

compliance

group

personnel

and

other

personnel

to

whom

he

was

referred

to

determine

the status

of licensee

actions relative to this item.

The

inspector also reviewed

the following memoranda

which were provided to

him with regard to this matter:

4

Memorandum

from J.

A. Crittenton

(Chief,

Procurement

Evaluation

'Branch)

to various

TVA personnel,

Minutes of Meetings to Discuss

Suggestions

for Short-Term

Improvements

in Receiving

Inspection

Rates at

TVA Sites;

dated

12/16/85

Memorandum

from E.

Kvaven (Chief, Nuclear

Procurement

Branch) to

J.

P. Darling (Manager of Nuclear Power);

Report of Task

Force for

Studying

and Solving Procurement

Problems in the Office of Nuclear

Power,

dated 8/10/84

Memorandum (with attached

report) from E.

Kvaven to J.

P. Darling,

Report of the

Task

Force

for

Studying

and Solving Procurement

Problems

in the Office of Nuclear Power,

dated 8/10/84

The inspector

obtained

no relevant

information from discussions

with

any licensee'ersonnel.

From

a review of the above

memoranda, it was

apparent

to the inspector that licensee

management

had

become

aware of

the material

procurement

problem 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.

On the basis of the information reviewed,

the

NRC inspector

believes

that the corrective actions

proposed

by the licensee for their material

procurement

problems

may satisfactorily

resolv'e

the

concern

expressed

by the

NRC unresolved

item.

The

unresolved

item will be

closed.

Additional

NRC followup will be

conducted

to determine

the

implemen-

tation

and

adequacy

of the licensee's

proposed

corrective

actions.

This is identified as inspector

followup item 259,

260, 296/86-04-02,

Implementation of Corrective Actions to Resolve

Procurement

Problems.

The inspector

was unable

to fully assess

the expediency with which the

licensee

responded

to the

concern for material

procurement

problems

expressed

by the original

NRC unresolved

item.

However, it appeared

that the

concern

was

not promptly resolved.

Information provided to

the inspector,

principally mern&'anda, failed to even

acknowledge

the

NRC concern.

The response

did not appear

to be prompt .in that the

earliest action described

(in the licensee's

memorandum of 8/10/84)

was

a task force study requested

in May 1984,

months after identification

of the concern

in

a

1983

NRC inspection report.

In addition, complete

corrective actions

remain to be implemented

over two years later,

(Closed)

Unresolved

Item (259,

260, 296/83-41-05):

Material Requisi-

tion Discrepancies.

This

item identified

an inspector's

concern

that

gA personnel

were

being relied

on to detect

a high incidence of errors,

such

as material

requisition discrepancies,

in completed

Work Plans

(records).

The

gA

personnel

were reviewing all completed

Work Plans

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 satisfac-

tory before they were submitted to gA.

During the current inspection,

the inspector

discussed

this matter with

the

gA Evaluator

who was currently responsible

to review completed

Work

Plans for safety-related

work.

The Evaluator

informed the inspector of

the following action that

had

been

taken relative to the matter of

concern:

Responsibilities

for assuring

the

completed

Work

Plans

were

satisfactory

had

been clearly assigned

to personnel

responsible

for the work

gA was

now only to check

a sample of Work Plans

Discrepancies

previously identified in Work Plans

by gA had

been

documented

on Corrective Action Reports

(CARs)

and dispositioned

for correction

by Modifications personnel

responsible

for the work

(the

NRC inspector

examined

as

examples

CARs84-094 and 83-163)

The last significant

gA check of Work Plans

revealed

continued

deficiencies

The Evaluator stated

that

a

gA check of newer completed

Work Plans

was

about to begin

and

showed

the inspector

the checklist to be used.

The

checklist

was

based

on criteria from the

TVA Division of gA Management

Surveillance

Manual.

Based

on his review relative to this unresolved

item, the

NRC inspector

is satisfied that the original concern

was resolved

and that the item

may be considered

closed.

However, the effectiveness

of the licensee's

corrective actions

in assuring that continuing deficient completed

Work

Plans

are

not

submitted

was identified for further

NRC review

as

inspector

followup item 259,

260, 296/86-04-03,

Adequacy of Work Plan

Records.

4.

Unresolved

Items

Unresolved

items were not identified during the inspection.

5.

Inspector

Followup Items (IFIs)

'a ~

(Closed)

IFI (260/80-28-02):

Erosion of Jet

Pump Nozzle Ring.

This item was identified for inspector followup of a condition observed

on

a Unit 2 jet pump nozzle ring.

The subject condition appeared

to be

minor erosion.

The inspector initiated followup to determine

whether

the condition might become

more severe

during subsequent

operation.

Based

on his previous

observations

and

on discussions

with licensee

personnel

during

the current

inspection,

the inspector

is satisfied

that the condition is being adequately

monitored by licensee

personnel

and that observations

to date indicate

no increase

in the severity of

the condition.

The matter is considered

to require

no further specific

NRC attention

and the item is closed.

b.

(Closed)

IFI (259, 260, 296/82-17-01):

NUREG 0803.

This item was identified for inspector

followup on actions

taken with

regard to

NUREG 0803

and

NRC Generic Letter 81-34.

These

documents

provided guidance for assuring

the integrity of scram discharge

volume

piping

and

requested

the

licensee

to

respond

the stating

their

conformance with the guidance.

In the current inspection,

the inspector

determined that his primary

remaining interest

in this item was to verify that inservice inspection

commitments

stated

by the licensee

in their January

20,

1982 response

to

NUREG 0803

and Generic Letter 81-34,

had

been accomplished.

The

commitment

was that the licensee's

scram discharge

volume piping

would

be

incorporated

in their

inservice

inspection

program

in

accordance

with ASME Section

XI requirements

for Class

2 piping.

The

NRC

inspector

verified this

through

a

review of the

licensee's

inservice

inspection

program

and determined

that the followup item may

be closed.

c.

(Closed)

IFI (259,

260, 296/85-07-03):

Procedures

for Dealing with

Allegations.

This

item

was identified

by the

inspector

to further consider

the

licensee's

lack of any procedure

for dealing with allegations

reported

to them.

In the current inspection,

the inspector

was

informed that

the licensee

had developed

a procedure for allegations.

The inspector

verified the procedure

and finds that the followup item may be closed.

,L