ML18031A688

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Insp Repts 50-259/86-22,50-260/86-22 & 50-296/86-22 on 860601-30.Violation Noted Re 10CFR50,App B,Criterion III for Design Control of Cable Pulling Activities
ML18031A688
Person / Time
Site: Browns Ferry  Tennessee Valley Authority icon.png
Issue date: 07/18/1986
From: Brooks C, Cantrell F, Patterson C, Paulk G
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML18031A686 List:
References
50-259-86-22, 50-260-86-22, 50-296-86-22, NUDOCS 8608180003
Download: ML18031A688 (21)


See also: IR 05000259/1986022

Text

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UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION II

101 MARIETTASTREET, N.W.

ATLANTA,GEORGIA 30323

Report Nos.

SO-259/86-22,

50-260/86-22,

and 50-296/86-22

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,

OPR-52,

and

DPR-68

Facility Name:

Browns Ferry Nuclear Plant

Inspection at Browns Ferry Site near Athens,

Alabama

Inspection

Conducted:

June

1-30,

1986

Inspectors:

G.

L.

Pau

, Senior

Resi

nt

I

~/(s g(

Date Signed

C. A. Patt

son,

Reside

C.

R. Bro

s, Resident

Approved by:

F

~ S. Cantrell, Sectio

C

Division of Reactor Proj cts

Oa

e

igned

7/5 g

Oa

e

igned

0 te

igned

SUMMARY

Scope:

This

routine

inspection

was

in

the

areas

of operational

safety,

maintenance

observation,

surveillance

testing observation,

reportable

occurrences

and design modifications.

Results:

One Violation 10

CFR

SO Appendix B, Criterion III for design control

of cable pulling activities.

l8608180003

860728

PDR

4DOCK 05000259

PDR

REPORT DETAILS

Licensee

Employees

Contacted:

W.

C.

J.

G.

J.

P.

R.

L.

E. A.

J.

E.

R.

M.

T.

D.

T.

F.

D.

C.

J.

G.

M. J.

R.

D.

A. W.

R.

E.

Bibb, Site Director

Malker, Deputy Site Director

Stapleton,

Project Engineer

Lewis, Plant Manager

Grimm, Assistant to the Plant Manager

Swindell, Superintendent

- Unit Three

McKeon, Superintendent

- Unit Two

Cosby,

Superintendent

-. Unit One

Ziegler, Superintendent

Mairrtenance

Mims, Technical

Services

Supervisor

Turner,

Manager - Site guality Assurance

May, Manager

Site Licensing

Schulz,

Compliance

Supervisor

Sorrell, Health Physics

Supervisor

Jackson,

Chief Public Safety

Other

licensee

employees

contacted

included

licensed

reactor

operators,

auxiliary operators,

craftsmen,

technicians,

public safety officers, quality

assurance,

design

and engineering

personnel.

M. J.

May was

named Manager,

Site licensing.

Mr.

with General Electric managing startup operations

Plant,

Cleveland,

Ohio.

L.

S.

Richardson

was

named

Deputy Manager,

Site

responsibilities

were

with General

Electric

in

Engineering.

May's former position was

at the Perry Nuclear

Power

Licensing.

His previous

Licensing

and

Project

H.

P.

Pomrehn

was

named

new Site Director.

Mr .

Pomrehn,

a Bechtel

employee

on

loan

to

TVA, previously

managed

two reactor

plants

in

Korea with

a

capacity of 950 megawatts

per reactor.

He will assume

the Site Director's

duties

from

Management

Analysis

Company

employee

M.

C. Bibb during

a

transition period.

Mr. Pomrehn

plans to begin his full-time work at Browns

Ferry on July 14.

Exit Interview

(30703)

'he

inspection

scope

and findings were

summarized

on July 8,

1986, with the

Plant Manager and/or Superintendents

and other members of his staff.

The licensee

acknowledged

the findings and took no exceptions.

The licensee

did not identify as proprietary

any of the materials

provided to or reviewed

by the inspectors

during this inspection.

3.

Licensee Action on Previous

Enforcement Matters (92702)

(Closed)

Inspector

Followup (259/84-26-18)

A preventive

maintenance

program

item has

been initiated to require

an annual

inspection of the containment

atmosphere dilution system foundation bolts.

This item is closed.

(Closed)

Violation

(260/84-26-01)

Standard

Practice

BF-14.25

has

been

revised to require

second party signoff on the condensate

storage

and supply

system

as

well

as all safety-related

systems.

Also,

the

procedure

was'hanged

to address

proper clearance

procedures

to be followed for situations

involving unmarked valves.

This item is closed.

(Closed)

Inspector

Followup (259/84-26-13)

An item has

been

added

to the

laboratory shift supervisor's

tour -sheet

to check for pressure

gauges that

are reading

maximum or pegged.

This item is closed.

(Closed)

Inspector

Followup

(259/84-26-14)

Mechanical

Maintenance

Instruction

MMI-18 has

been

revised

to require that unattended

openings

in

fluid systems

be covered to prevent introduction of foreign materials.

This

item is closed.

0

5.

(Closed)

Inspector

Followup (259/84-26-16)

The plant emergency battery

room

floor drains

and sinks were flushed.

A preventive

maintenance

item has

been

added to require quarterly flushing -of the drains.

This item is closed.

Unresolved

Items* (92701)

There is one unresolved

item in paragraph five.

Operational

Safety

(71707,

71710)

The

inspectors

were

kept

informed of the overall

plant

status

and

any

significant safety matters

related

to plant operations.

Oai ly discussions

were

held with plant

management

and various

members of the plant operating

staff.

The inspectors

made routine visits to the control

rooms

when

an inspector

was

on

site.

Observations

included

instrument

readings,

setpoints

and

recordings;

status of operating

systems;

status

and alignments of emergency

standby

systems;

onsite

and offsite emergency

power

sources

available for

automatic

opqyation;

purpose

of temporary

tags

on

equipment

controls

and

switches;

annunciator

alarm status;

adherence

to procedures;

adherence

to

limiting conditions for operations;

nuclear instruments

operable;

temporary

alterations

in effect; daily journals

and

logs;

stack

monitor

recorder

traces;

and control

room manning.

This inspection activity also

included

numerous

informal.discussions

with operators

and their supervisors.

t

"An Unresolved

Item is

a matter about which more information is required to

determine

whether it is acceptable

or

may involve

a violation or deviation.

General

plant tours were conducted

on at least

a weekly basis.

Portions of

the turbine building, each reactor building and outside

areas

were

visited.

Observations

included

valve positions

and

system

alignment;

snubber

and

hanger conditions;

containment

isolation. alignments;

instrument

readings;

housekeeping;

proper

power

supply

and breaker

alignments;

radiation

area

controls;

tag controls

on

equipment;

work activities

in

progress;

and

radiation protection controls.

Informal discussions

were held with selected

plant personnel

in their functional areas

during these

tour s.

Weekly verifications of system

status

which included major flow path valve

alignment,

instrument

alignment,

and

switch

position

alignments

were

performed

on the fuel handling

systems.

A complete

walkdown

of

the

accessible

portions

of the

fuel

handling

system

was

conducted

to verify system operability.

Typical of the

items

checked during the walkdown were:

lineup procedures

match plant drawings

and

the

as-built

configuration,

hangar s

and

supports

operable,

housekeeping

adequate,

electrical

panel

interior

conditions,

calibration

dates

appropriate,

system

instrumentation

on-line,

valve

position

alignment

correct,

valves

- locked

as

appropriate

and

system

indicators

functioning

properly.

In the course of the monthly activities,

the inspectors

included

a review of

the licensee's

physical security program.

The performance of various shifts

of the security force

was

observed

in the conduct of daily activities to

include: protect'ed

and vital areas

access

controls,

searching

of personnel,

packages

and vehicles,

badge

issuance

and retrieval, escorting of visitors,

patrols

and

compensatory

posts.

In addition,

the

inspectors

observed

protected

area lighting, protected

and vital areas barrier integrity.

On June

20,

1986,

the inspector

observed

the start of new fuel inspection

on

the refueling floor.

A'review of the applicable

procedures

lead to discovery

of

a hoist which

had

not

been

load tested.

General

Operating

Instruction

GOI-100-2,

New

Fuel

Operations,

contains

a signoff that

the

stationary

electric hoist is

inspected

as

required

by Mechanical

Maintenance

Guide

2301.

This hoist is

used

to place fuel channels

over the fuel assemblies.

The procedure

requires

load testing for new or modified equipment prior to

use.

No

record

could

be

found that

the hoist

had

been

load

tested.

Additionally,

Browns

Ferry

Standard

Practice

BF-14.24;

Cranes

and

Hoist

Maintenance,

Testing

and

Inspection;

requires

an

annual

load testing of

hoists to

125% capacity.

Upon learning of the hoist problem,

the licensee

took immediate corrective

action

to

load test

the hoist.

Also, other

equipment

used

during fuel

handling

was verified to have

been

tested

as

required.

No basis

could

be

found for the

annual

load test

and

the

BF-14.24

requirement

was

more'tringent

than the

MMG 2301 requirement.

The inspector

reviewed

the

new program established

to correct

problems

in

this area.

The

new

program

is

managed

by

a

crane

specialist

on site.

The

program

consists

of reviewing all plant procedures

governing

cranes,

hoists,

and

rigging

equipment

to

ensure

they

are

in

compliance

with

corporate

procedures,

ANSI,

OSHA standards,

and

NUREG-0612.

A comprehensive

crane,

hoist,

and rigging manual

is being

developed

as

a

single

source

document

containing

all

site

requirements

pertaining

to

overhead lifts.

Included in this

manual will be

a

program

for training

operators,

riggers,

inspectors,

and maintenance

personnel.

Along with this

manual will be

a

comprehensive

preventive

maintenance

program

for all

cranes,

hoists,

and rigging equipment.

As part of this program

the licensee

has identified

a number of defective

hoists.

Out of 46 hoists tested,

3X failed the load test at

an

average

of

50 percent of their rated capacity.

The hoists that failed were

TUGIT brand

lever

operated

hoists

supplied

by

Dresser

Industries

Crane

and

Hoist

Division.

The test results

were

as follows:

a.

3/4 ton - model

R234

1500 lbs. rated capacity - tested

4 failed 1-

(800 lbs.)

b.

1 1/2 ton - model

R291 - 3000 lbs. rated capacity'

tested

11 - failed

4 - (1000 - 2000 lbs.)

c.

3 ton

model

R292

6000 lbs. rated capacity

tested

19 - failed

17

(4000 lbs.)

d.

6 ton

model

R295

12000 lbs. rated capacity

tested

12 - failed 9

(6000 lbs.)

These

hoists

were furnished with vendor certification that

they

had

been

load tested to

125% capacity.

The load regulators

on the defective hoists

were

adjusted

per

the

vendor

instructions

and

passed

a

load test.

The

licensee

plans to test all

new hoists prior to placing

them in service.

The

licensee

has determined this not to be

10 CFR 21 reportable.

The

inspector

initiated

a

review of

a

TVA gA audit conducted

March 24,

1986

April 4,

1986.

Four major areas

of weakness

were identified.

b.

C.

d.

Commitments

made

to

NUREG-0612

and

NUREG-0544

were

not

being

implemented

in a timely manner.

Requirements

of NUREG-0612 that

should

have

been

implemented

were not

currently being met by the plant.

Previously

identified deficiencies

with control

of

plant

rigging

equipment

are recurring.

Plant

instructions

that

implement

upper-tier

TVA requirements

in

support of NUREG-0612 were not fully adequate.

This audit, identified

deviations

from previous

NRC commitments

concerning

control of heavy loads .

This area. will remain unresolved

pending

a complete

review of the

gA audit and control of heavy loads.

(259/260/296/86-22-01).

6.

Maintenance

Observation

(62703)

Plant

maintenance

activities

of

selected

safety-related

systems

and

components

were observed/reviewed

to ascertain

that they were conducted

in

accordance

with requirements.

The following items

were

considered

during

this

review:

the limiting conditions for operations

were

met; activities

were

accomplished

using

approved

procedures;

functional

testing

and/or

calibrations

were

performed prior to returning

components

or

system

to

service;

quality

control

records

were

maintained;

activities

were

accomp'lished

by qualified personnel;

parts

and materials

used were properly

certified;

proper

tagout

clearance

procedures

were

adhered

to;

Technical

Specification

adherence;

and

radiological

controls

were

implemented

as

required.

Maintenance

requests

were

reviewed

to determine

status of outstanding

jobs

and

to

assure

that priority was

assigned

to

safety-related

equipment

maintenance

which might affect plant safety.

The inspectors

observed

the

below listed maintenance activities during this report period:

a.

Diesel-Generator

Fuel Oil Tank Cleaning

b.

Cable Pulling Activities (Discussed

in paragraph

9)

c.

Residual

Heat

Removal Injection Valve Maintenance

d.

New Fuel Unloading (Discussed

in paragraph

5)

No violations or deviations

were identified in the

above

areas

except

as

discussed

in paragraph

9.

7.

Surveillance Testing Observation

(61726)

The

inspectors

observed

and/or

reviewed

the

below listed

surveillance

procedures.

The

inspection

consisted

of

a

review of the

procedures

for

technical

adequacy,

conformance

to technical

specifications,

verification

of test

instrument

calibration,

observation

on the conduct of the test,

removal

from service

and return to service of the system,

a review of test

data,

limiting condition

for operation

.met,

testing

accomplished

by

qualified personnel,

and that the surveillance

was completed at the required

frequency.

a.

Surveillance

Instruction (SI) SI-4.3.A.2.d,

Control

Rod

Accumulator

Operability

0

b.

SI-4. 11.A.1.e,

Testing of Fixed Water Nozzles for Blockage

c.

General

Operating Instruction GOI-100-2,-New Fuel Operations

d.

Mechanical

Maintenance

Guide

MMG

2301;

Inspection,

Testing,

and

Maintenance of Monorail Systems,

Underhung

Cranes

and Overhead Hoists.

e.

Browns Ferry Standard

Practice

BF-14-24;

Cranes

and Hoist Maintenance,

Testing

and Inspections

Items

a

and

b were

two SIs

that

had

been

reviewed

by the Surveillance

Instruction

Review Project.

With the

aid of General

Electric contract

personnel,

a review of all SIs is being conducted

to verify the instruction's

technical

accuracy.

However,

SI-4. 11.A. l.e

data

sheets

were

still

confusing.

It was not clear which signoff applied to which procedural

step.

This was the subject of a previous violation in report 86-06.

The licensee

took action to revise the data

sheets'o

violations or deviations

were identified in this paragraph

8.

Reportable

Occurrences

(90712,

92700)

The below listed licensee

events

reports

( LERs) were reviewed to determine

if the

information

provided

met

NRC

requirements'.

The

determination

included:

adequacy

of event description,

verification of compliance with

technical

specifications

and

regulatory

requirements,

corrective

action

taken,

existence

of potential

generic

problems,

reporting

requirements

satisfied,

and the relative safety significance

of each

event.

Additional

in-plant reviews

and discussion

with plant personnel,

as appropriate,

were

conducted

for

those

reports

indicated

by

an

asterisk.

The

following

licensee

event reports

are closed:

LER No.

296/86-05

Date

2-15-86

Event

Random Relay Failure in

Refuel. Zone Exhaust

Radiation Monitor Results

in a Containment Isolation.

  • 296/85-14

4-29-85

Containment Isolation

Initiation.

260/86-05

4-03-86

Engineering

Safeguards

Actuations During Surveillance

Testing.

260/86-03

2-26-86

Reactor Protection

System

Trip Because

of Transfer

Switch Being

Bumped

Due to

Personnel

Error.

260/86-04

4-18-86

Engineering

Safeguards

Actuation 'During Relay

Maintenance.

  • 259/86-02

1"08-86

Reactor Protection

System

Circuit Protector

1Al Trip

on

an Unidentified Cause.

The inspector

noted

on June

17,

1986, that

LER 259/86-02

was to be updated

by June 6,

1986,

but the

revision

to

the

LER could

not

be

located.

Discussions

with

plant

personnel

revealed

the

revision

had

not

been

completed.

The revision was submitted June

24,

1986.

No additional trips

occurred

during

the

seventeen

week

monitoring

period.

The

event

was

considered

random.

9.

Design Modifications

(37700)

Cable Pullin

Problems

0

On

June

16,

1986,

the

resident

observed

electrical

modifications

in

progress

in the plant's Unit 2 auxiliary instrument

room involving the

pulling of electrical

cables

as specified

in workplan 2047-85/ECN

P0126

( Install

ECCS

ATU Inverters,

Transmitters,

and Install

and Calibrate

Trip Units).

The

inspector

noted that

the

cable

pulls

were

being

conducted

in accordance

with the procedure

that was originally issued

during original plant design

(General

Specification 3).

On January

15,

1986,

the

licensee

had

revised

the

cable

pull

specification

requirements

to meet concerns

at the Watts Bar facility in keeping with

industry standards.

The licensee

had

implemented

the

new specification

(General

Specification

38) at all facilities with the

exception

of

Browns

Ferry.

The specifications

were

to

be

implemented

at

Browns

Ferry only

on future

design

modifications.

Failure

to

adequately-

specify

appropriate

quality

standards

on

the

current

design

'odifications

and fai lure

to control

the

cable

installation

known

deviations

were noted

as

a violation of 10 CFR 50, Appendix B, Criterion

III. (259/260/296/86-22-02).

The witnessed

workplan installation

referenced

the craftsman

to plant

instruction

MAI 13 for the installation of cables.

The inspector

found

several

deficiencies with regard to this instruction

as listed:

( 1)

Specific requirements

on

loops to

be

formed for multi-conductor

cables

were not provided.

(2)

Specification of material

to be used for pulling was not listed.

(3)

MAI 13 did not require

any pull force monitoring techniques

as

required in G-38

'he

above

i'nstruction

deficiencies

will

be

noted

as

an

inspector

follow up item. (259/86-22-03)

Actions taken

by the

licensee

during this report period

include the

following:

June

16,

1986

June

17,

1986

NRC identified concern

TVA pl aces

Hold

on

cable

pul 1 ing at

Browns

Ferry.

June

20,

1986

TVA design

engineering

sent

memo to all plant

sections

specifying

the

use

of

General

Specification

38.

gC

~ veri fied

no

cable

instal

1 ations

in

progress.

gC

began

writing instruction

to

assure

future modifications are

installed per

G-38.

June

24,

1986

NRC/TVA meeting

in Region II to discuss

cable

pulling

concerns

and

review

TVA

proposed

corrective

actions.

Site Director at

Browns

Ferry committed to insure

new cable

pulling

speci Acations

are

implemented with adequate

training

and

gC verification

before

cable

pulling is resumed.

b.

Drawin

Control Trainin

Session

The inspector

attended

a training session

concerning

the

new drawing

control

system

on June

23,

1986.

The

session

covered

the history of

the drawing control

problems

and

new procedures

for regaining control

of the change

process.

4,

In the past

TVA design

personnel

in Knoxville worked from as-designed

drawings

and

as-constructed

drawings

were

used

at

the plants.

As

design

changes

were

implemented

the

as-constructed

drawings

were

updated to reflect the design

changes.

Both Knoxville and Browns Ferry

initially used

a single drawing for all. three units.

However,

as only

one unit was in

an

outage

at

one time,

the plant changed

to unitized

drawings

as modifications were

made to

a single unit.

But, Knoxville

retained

a single

set

of drawings.

As engineering

change

notices

(ECNs) were processed

problems resulted.

For example,

the following shows the change

process

that was in place:

Knoxville

Browns Ferr

Drawin

Revision ¹

ECN ¹

Unit One

Unit Two

Unit Three

A

A

A

(License Basis)

Unit one is modified by

ECN ¹5 and the drawings were

revised

such that each

had

a unique revision number

different from all other revisions.

The revised drawings were sent to Knoxville which

retained only the latest revision

and eliminated

revision

B of unit one.

Next, unit three enters

an

outage

and is modified by

ECN 6.

6

B

D

E

The revised drawings were sent to Knoxville which eliminated

units one

and two drawing revisions.

As

more

revisions

were

made,

more

confusion

resulted.

As

attention

was devoted to keep

Browns Ferry operating

and building other

plants,

the document control problems

were never resolved.

Additionally,

a

number

of

ECNs

were

processed

out of sequence.

An

'assumption

made in each

Unreviewed Safety Question Determination

(USQO)

for each

ECN was that all previous

ECN's were completed.

This was not

the case.

Thus,

an indeterminate

number of USQDs

may be invalid.

As of June

2,

1986 all as-constructed

and as-designed

drawings

were

frozen at the latest revision.

A new

system of drawings called

con-

figuration controlled

drawings

(CCO) is being established.

After a

system

has

had

a walkdown, the as-constructed

drawing will be revised

to reflect the actual plant corrfiguration and

a

CCO revision zero will.

be issued.

Next, the design engineers will resolve all the differences

between

the design drawings,

as-constructed

drawings,

and various plant

modifications.

Resolution of these

items results

in

CCD revision

one

which should

be

an accurate

document of plant configuration.

Resolution of these differences

is

a major effort involving hundreds

of

engineers

and contract

personnel.

Additional modifications

and

even

- removal

of

some modifications

worked out of sequence

may result

from

the review.

Modifications in progress

on unit two

on June

2,

1986,

will have to be

reviewed

again

and system

walkdowns repeated

prior to

the unit startup.

It is conceivable

that

some modifications

now in

progress will have to be removed.

Applicable plant procedures

related to the program are

as follows:

I

Browns Ferry Standard

Practice

BF 2.5,

Drawing Control

Site

Director

Standard

Practice

SDSP

9.1,

Handling

Drawing

Oi screpanci es.

SOSP 9.2, Configuration Control Drawing

SOSP 9.3,

Design

Change

Supplement

Control

10

10.

Model

Shop (37700)

During this report period

TVA made

a management

decision

to delete

the model

shop

from the

Browns Ferry facility site.

The residents

have

toured

the

model

shop area for a number of years

in the monitoring of workplan review

activities,

torus modifications,

and

ALARA planning.

The

model

shop

has

typified over this period

the excellence

of craftsmanship,

professionalism

in the workplace,

and cooperative

demeanor

that

should

be the goal of the

Browns Ferry site

as

a whole.

All craft foremen

the residents

have

spoken

with over this period

have

indicated

the significant help provided

by the

model

shop in work plan activities

and

ALARA planning.

The resident staff

will continue

to

note

management

decisions

at

the

site

in regard

to

maintenance

planning.

This item was discussed

with the

Browns

Ferry Site

Director and the

TVA Manager of Nuclear

Power

in separate

meetings

during

this report period.

11.

Regulatory

Performance

Improvement

Program

(RPIP)

The responsible

section chief reviewed the status of RPIP and actions

taken

by TVA to implement specific items

as required

by

NRC Confirmatory Or'der

EA

84-34

dated

July 13,

1984.

This

evaluation

included

a

review

of

procedure/instructions

developed

to

implement

the

specific

action,

and

discussions

with personnel

involved.

Based

on the above review,

the following items are closed:

Short Term Item

3.6

4..1

Provide training oa regulatory, compliance.

Organizational

establishment

and approval.

Lon

Term Item

Permanent

plant facilities.

M

I

IP