ML18030B189
| 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
ATLANTA,GEORGIA 30323
Report Nos.:
50-259/86-04,
50-260/86-04,
and 50-296/86-04
Licensee:
Yalley Authority
6N 38A Lookout Place
1101 Market Street
Chattanooga,
TN
37402-2801
Docket Nos.:
50-259,
50-260
and 50-296
License Nos.:
and
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
- DOCK 05000259
8
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,
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
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
The
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
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
be
capped,
plugged,
or sealed,
and that the
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
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
Appendix
B, Criterion V, requirements
for compliance
with instructions
and procedures.
This noncompliance
is identi-
fied as violation 259, 260, 296/86-04-01,
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
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):
This item was identified for inspector
followup on actions
taken with
regard to
and
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
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