Text

Insp Repts 50-259/89-10,50-260/89-10 & 50-296/89-10 on 890220-0322.Violations Noted.Major Areas Inspected: Seismically Unqualified Flow Discharge Paths
	ML18033A766
Person / Time
Site:	Browns Ferry
Issue date:	05/15/1989
From:	Bearden W, Carpenter D, Little W; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	;
Shared Package
ML18033A764	List: ML18033A763; ML18033A765; ML18033A766;
References
	50-259-89-10, 50-260-89-10, 50-296-89-10, EA-85-049, EA-85-49, NUDOCS 8905250291
	Download: ML18033A766 (28)
	v • d • e

~p,R RECy,

Mp,0

Op

I

)

I

o.

+>>*++

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION II

101 MARIETTASTREET, N.W.

ATLANTA,GEORGIA 30323

Report Nos.:

50-259/89-10,

50-260/89-10,

and 50-296/89-10

Licensee:

Tennessee

Valley Authority

6N 38A Lookout Place

1101 Market Street

Chattanooga,

TN

37402-2801

Docket Nos.:

50-259,

50-260,

and 50-296

It

License Nos.:

DPR-33,

DPR-52,

and

DPR-68

Facility Name:

Browns Ferry Units 1, 2,

and

3

Inspection at Browns Ferry Site near Decatur,

Alabama

Inspection

Conducted:

February

20, - March 22,

1989

Inspector.

~D.

R.

a'rpenter,

NRC Site Manager

../

W.

C.

ea

n,

Res1dent

Inspector

Approved by:

W. S..it,

ection Chief,

Inspection

Programs,

TVA Projects Division

Date

igned

Date Si

ned

D te

igned

SUMMARY

Scope:

This special

reactive

inspection

was

conducted

to follow up on the

problem

reported

by

TVA in which they identified that the flow

discharge

paths

for several

safety-related

EECW systems

were

not

seismically qualified.

This could

have resulted

in several

other

.

safety-related

systems

being inoperable- following a seismic event.

Additionally, inspection

was

conducted

into the inordinate

lapse of

time between

when the knowledge of these

conditions were

known by the

licensee's

engineering

group'nd that information being translated

into required plant actions.

Results:

Two potential violations were identified:

0

260/89-10-01:

Apparent failure to comply with Technical Specifica-

tion (TS) 3.5.A.5 during Unit 2 core reload.

(paragraph

3)

3905 50291

890515

PDR

ADCICK 0 0'00259

0

PDC

0

259,

260,

296/89-10-02:

Apparent failure to establish

an effective

program to promptly identify and correct

a known condition adverse to

quality.

(paragraph

3)

One unresolved

item* was identified:

260/89-10-03:

Potential

failure to assure

proper design control.

(paragraph

6)

All of the identified apparent

violations

and the unresolved

item

'must

be satisfactorily resolved prior to Unit 2 restart.

The

NRC inspectors

noted

a significant

weakness

in the

area

of

identification and correction of known significant conditions

adverse

to quality.,

t

This event constitutes

a failure by licensee

management

to exercise

sufficient

and

proper

management

controls

to

ensure

that

known

significant conditions

adverse

to quality received

an adequate

level

of attention

in order to guarantee

prompt

and effective corrective

action.

This failure resulted

in information concerning this issue

not being available to site management

and operations

personnel

from

January

16-30,

1989, while the Unit 2 core reload

was in progress

and

operability of certain affected equipment

was required

by TS.

It was

not until plant

management

and operations

personnel

were informed of

the potential

degraded

condition when the

CA(R was issued

and sent to

PRS for review

on February 8,

1989, that appropriate

attention

and

action was taken.

The event is similar to the event that occurred in

1984, which resulted in NRC Order Modifying License

(EA 85-49), which

is still open'gainst

Browns Ferry'Docket

Nos.

50-259,50-260,

and

50-296.)

Corrective actions

committed to by the licensee

appear

to

have

not

been

successfully

implemented

and

is- considered

as

an

additional

example of a recurring problem while under

an

NRC Order to

correct that problem.

When the problem

was identified to plant operations

personnel,

the

.licensee's

assessment

was considered

to be conservative,

complete

and

adequate.

Operations

personnel

acknowledged

the full significance of

the issue.

The interim corrective actions

were appropriately

con-

servative,

thorough

and acceptable.

In addition, corporate

manage-

ment

conducted

a

thorough

review of the

event

which led to

an

aggressive

corrective action plan.

Unresolved, items

are

matters

about

which

more

information i'

required

to determine

whether

they are

acceptable

or may involve

violations or deviations.

e

REPORT DETAILS

Persons

Contacted

Licensee

Employees:

0. Kingsley, Jr., Senior Vice President,

Nuclear

Power

C.

Fox, Jr., Vice President

and Nuclear Technical Director

"J.

Bynum, Vice President,

Nuclear

Power Production

"C. Mason, Acting Site Director

"G. Campbell,

Plant Manager

H.

Bounds, Project Engineer

J. Hutton, Operations

Superintendent

"D. Phillips, Maintenance

Superintendent

"D. Mims, Technical

Services

Supervisor

G. Turner, Site equality Assurance

Manager

"P. Carier, Site Licensing Manager

"J.

Savage,

Compliance Supervisor

A. Sorrell, Site Radiological Control Superintendent

H. Crisler,

Browns Ferry Engineering Project

"T. Bradish, Plant Reporting Section

Attended exit interview

Other

licensee

employees

or

contractors

contacted

included

licensed

reactor operators,

quality assurance,

design,

and engineering

personnel.

NRC Resident

Inspectors

"D. Carpenter,

Site Manager

E. Christnot,

Resident Inspector

"W. Bearden,

Resident

Inspector

K. Ivey, Resident

Inspector

NRC Employees

W. Little, Section Chief

A. Johnson,

Project Engineer

Acronyms used throughout this report are listed in the last paragraph.

0

Description of the Issue

and Sequence

Of Events

On February 8,

1989,

TVA notified the

NRC that they had identified three

EECW discharge

flow paths that were not properly qualified

as

Seismic

Class

I.

Following an earthquake

this could result in the loss of or

degradation

of cooling to the Units 1,

2 and

3 control

bays

and the Unit 2

shutdown

board

rooms,

and the subsequent

loss of safety-related

equipment

in these

areas.

(See

paragraph

3 for

a detailed description of the

equipment that could be lost).

The

NRC was very concerned

that the

EECW system

had

been

reviewed

and

declared

operable

per

TS prior .to fuel loading without identifying this

issue,

and

that

once

an

engineer first identified the

problem

on

January

11,

1989, it took until February 8,

1989, to notify the*NRC and to

take action required

by the TS.

The primary reason

that these

deficiencies

in the seismic

design of the

EECW discharge

flow paths

were

not identified earlier

appears

to

be

because

of TVA's reliance

on

a fuel

load position paper prepared

by the

Civil Engineering

Branch

in August 1988.

(Attachment 1)

This

paper

recognized

that the buried

EECW piping was required to be operable

by TS

at fuel load,

and that calculations for the buried piping did not exist.

The paper justified operability for fuel loading stating:

There are

no

known safety issues with the balance of buried piping or

conduit and experience

with buried structures

suggests

that

no safety

issues will be found.

It appeared

that the fuel

load position paper

was relied

on during the

System Preoperability Checklist

(SPOC)

process

to justify declaring

the

EECW system

operable

for fuel load,

and could

have

been

used to justify

delaying the performance

of the

DBVP civil calculations

for the buried

piping.

The following sequence

of events that are pertinent to the NRC's concerns

were

developed

based

on

background

material

prepared

by

TVA and

NRC

interviews with key individuals:

As part of the

ongoing

Design Basis Verification Program

(DBVP), on-

August 12,

1988,

the licensee

identified that

no civi 1 calculations

could be retrieved for buried yard piping for the Browns Ferry plant.

This condition

was

assessed

by the licensee

and

a fuel load position

paper

was

issued.

(See

attachment 1.)

Effort to regenerate

the

missing calculations

at

Browns Ferry

was

commenced

and scheduled

to

be complete for Unit 2 restart.

Between

August 12,

1988,

and January

3, 1989, the licensee

completed

work, with the exception of the

DVBP calculations for the buried yard

pipe,

needed

to declare

systems

operable that were required for fuel

load.

This included the

RHRSW,

EECW and

RCW Systems.

On August 26,

1988,

the licensee

completed revision

3 to the safety

evaluation for Engineering

Change Notice (ECN) P0956,

which provided

new Unit 2 Shutdown

Board

Rooms

"C" and "0" Air Conditioning Units.

This revision,

the latest to the safety evaluation,

states that the

resulting

new configuration would be seismically

and environmentally

qualified and would not adversely affect the safety of the plant.

On January

3, 1989, the licensee

commenced Unit 2 core fuel reload.

On January

5, 1989, fuel loading was suspended

due to core monitoring

pr obl ems.

On January ll, 1989,

as the result of drawing reviews which were part

of the

DBVP calculation regeneration effort, Stone 5 Webster

Company

(SWEC)

personnel

notified licensee

Division of Nuclear

Engineering

(NE), Civil Engineering

Branch

(CEB)

and

Mechanical

Engineering

Branch

(MEB) personnel

that vitrified clay piping appeared

to

be

located within the Seismic

Category I boundary

as defined

by TVA.

Based

on

SWEC experience

this type of piping was not normally found

in seismic applications

and there

were

no

code

allowances for clay

piping per

ASME or ASTI.

On January

16,

the licensee

restarted

the Unit 2 core reload activi-

ties

after

an ll day

delay for resolution

of core

monitoring

problems.

On January

17,

the Mechanical

Engineering'Branch

(MEB) notified the

CEB that three specific

EECW discharge

lines

were discovered

going

into nonseismic

Category

I since

they provide

a flowpath in the

event

the

downstream piping is blocked.

Even

though

licensee

NE personnel

had

known

about the,issue

since

January

11, 1989,

and

had determined

on or before January

17,

1989, that

a

potential

CAQ existed,

CAQR

BFP 890099

was not issued until February 3,

1989.

The

onsite

system

engineer

had

been told of the

issue

on

January

18,

1989,

during routine weekly contact with the

CEB engineer.

During this discussion

the issue

was identified

as

a potential

seismic

problem with a

RCW discharge

line.

The

system

engineer was'ot able to

recall

whether the subject discussed

specifically included clay piping or

that

a potential

condition adverse

to quality could exist.

The

system

engineer

had

been

reviewing

57

separate

DCNs associated

with seismic

issues

resulting

from the calculation regeneration effort during the

same

time period

and

he failed to realize

the significance of the issue.

He

did not identify this condition to his management.

After initiating the

CAQR on February 3,

1989,

the engineering

management

review of the

CAQR

appears

to

have

been

completed

on February 8,

1989, within the three

worki'ng

days

following

CAQR initiation,

as

required

by

NQAM, Part I,

Section

2. 16,

Paragraph

2.4. 1.

Plant management

and operations

personnel

were not informed of the potential

degraded

condition until the

CAQR was

issued

and sent to

PORS for review on February 8,

1989.

This finding that the three

EECW flow discharge

paths

were not properly

seismically qualified is

an

instance

of

an

unanalyzed

condition that

significantly

compromises

plant

safety,

as

defined

in

10 CFR 50.72(b)(2)(i), that requires

an

immediate four-hour report to the

NRC.

Once the

CAQR was initiated,

the event

was

evaluated

and reported in a

prompt manner.

It appears

that the reason that the report to the

NRC was

0

11

not

made

sooner

was

because

of the

untimely

issuance

of the

CARR.

Violation 259,

260,

296/89-10-02

addresses

the failure, to initiate the

CARR in

a

prompt manner.

Since this addresses

the root cause

of the

issue,

an additional violation for failure to

make

an immediate notifi-

cation is not warranted

and will not be issued.

This decision

was

made

after the exit meeting following additional

NRC management

review.

Unit 2 Shutdown

Board

Rooms Air Conditioning Modification

One of the nonseismically qualified

EECM flow discharge

paths

was

a recent

modification, while the other

two appear to have

been part of the original

design.

The

NRC was

concerned

that the recent modification (Fall 1988)

was

made resulting in a nonseismically qualified discharge

flow path,

and

that this might be indicative of problems with the current design

change

control process.

The

NRC inspector

reviewed Safety Evaluation

Number

P0956

Rev.3,

(B2288

0830 521), dated

August 26,

1988; drawing 2-47E859-1, "Unit 2 Flow Diagram

Emergency

Equipment

Cooling Water," which shows the water supply from the

EECW

system

to the

Unit 2 shutdown

board

room air conditioning units

(ACUs)

and

the

cross

connect

to the Unit 2

Raw Cooling Water

(RCW);

Drawing 2-47E844-2,

"Unit 2 Flow Diagram

Raw Cooling Mater," which shows

the piping configuration associated

with Unit 2 Shutdown Board

Rooms

"C"

and

"D" ACUs including

EECW discharge;

and

Drawing 2-47E831-3,

"Unit 2

Flow Diagram

Condenser

Circulatory Water," which shows the

RCW discharge

header

as it ties into the

16 foot diameter,

Unit 2 discharge

conduit to

Wheeler

Lake.

The

NRC inspector

noted that item

19 of the Safety

Evaluation for

ECN

P0956,

stated that the cooling water supplg for the

ACUs will be provided

by the

EECM system,

System 67,

and that this system would provide

a safety

of cooling;

item

20 of the safety-evaluation

stated that

all

new equipment,

ductwork, conduit, piping,

supports

and other compo-

nents will be designed

and implemented in accordance

with the appropriate

criteria for Seismic

Class

I Systems;

and

item

20 of the evaluation

further stated

that the final configuration for Engineering

Change Notice

P0956 will be seismically

and

environmentally qualified and will not

adversely affect the safety of the plant.

A review of the above listed

drawings

and

a walkdown of the system

by the

NRC inspector confirmed what

TVA had reported:

that the discharge

piping from the A/C units ties into

the discharge

piping for

RCW,

System

23, which is not seismically quali-

fied outside

the reactor building.

This potential violation for failure

to adequately

control the design of the

EECM discharge

flow paths for the

installation

of Unit 2

A/C units for the

shutdown

board

rooms

was

discussed

with licensee

management.

The licensee

disagreed

that this constituted

a possible violation in that

they

stated

that their design

package

properly specified

the seismic

requirements

for the

EECM modification,

and identified that the

Design

Baseline Verification Program

(DBVP) had identified that calculations

did

not exist for the buried

RCW piping.

The licensee

stated that the design

0

12

change

process

was

adequate

within the

known seismic

boundaries

at the

time

and that resolution

of the

DVBP buried piping calculation

issue

would ensure

the correct seismic design for the

EECW discharge

flow path.

This issue

was identified

as

an unresolved

item and

wi 11 receive addi-

.

tional

NRC attention

as part of a future inspection.

Specifically the

licensee will need to provide

documented

evidence to support their disa-

greement that

a possible violation existed.

This issue will be tracked

as

Unresolved

Item

(260/89-10-03),

Control

of

EECW Modification Design

Changes.

This issue

must resolved prior to restart of Unit 2.

Licensee Corrective Actions

On February 8, 1989,

based

on the licensee's

review of affected equipment,

the

licensee

declared

secondary

containment,

all Unit 2 emergency

core

cooling systems,

both Unit 2 standby

coolant supply flowpaths,

and both

Unit 2 standby liquid control

systems

inoperable.

Based

on this assessment

fuel handling

and operations

over the

spent

fuel pools

and open reactor

wells

were

not permitted

by

TS until

secondary

containment

could

be

declared

operable.

Also,

no work was permitted which had the potential to

drain

the Unit 2 reactor

vessel

until core cooling systems

could meet

operability requirements.

On

February

10,

1989,

the

licensee

completed

a safety evaluation for

interim operation with the proposed

compensatory

measures

established

to

provide

an

EECW flowpath through the affected

components

in the event flow

was lost

due to

a seismic

event.

An

NRC inspector

attended

the

PORC

meeting

where this safety evaluation

and the associated

interim operating

criteria

were

presented

for review

and

approval.

The

compensatory

measures

involved isolating all

normal

RCW flow to Units 1,

2,

and

3

reactor

building

RCW discharge

piping

and

removing .one

24

inch

RCW

discharge

pipe coupling in each

RHRSW tunnel

and ensuring that

a 1/2 inch

gap exists

between

the pipe ends.

The licensee

performed calculations to

show that

a 1/2 inch gap would provide adequate

flow in the event that the

RCW

discharge

flow path

was lost.

The

NRC inspector

reviewed

the

licensee's

calculations

that support the adequacy of the 1/2 inch gap and

found it adequate.-

In the event that

a 1/2 inch gap could not be obtained

between

the pipe

ends

on any discharge

header,

additional flow area would

be created

by cutting

a six inch diameter

hole in that 24 inch discharge

header.

The

NRC inspector

reviewed the licensee's

safety evaluation

and

compensatory

measures

and considered

them

adequate

for the present plant

condition i.e.,

cold shutdown.

The

NRC inspector

noted that the eval-

uation was stated to be valid only for that condition.

On March 2, 1989,

a meeting

was held at the Browns Ferry site with members

of the licensee

management.

The licensee

and

NRC staff present at that

meeting

discussed

the various

causes

that led

up to the failure to iden-

tify the problem in a timely manner.

During that meeting licensee

manage-

ment committed that

as part of the corrective action, specific training

would

be

held for engineers

that are part of the Division of Nuclear

Engineering

and the onsite

systems

engineering

group.

This training would

include the following:

Q

13

Sensitivity training for line engineers

and management

to cover

Browns Ferry

TS and engineering

personnel 's responsibilities to

communicate potential

problems to management

in a timely manner,

and training on operability and reportability requirements.

Plant

systems

training to enable

engineers

to better understand

overall plant operations.

The training

had

commenced prior to the end of this inspection.

Licensee

management

met with

NRC management

on March 14,

1989 to describe

their

corrective action for permanent

technical

resolution of the issue.

This

meeting

was

documented

in an

NRC memorandum

dated April 3, 1989.

Resolu-

tion involves connecting

the three

EECW discharge

lines in question

to

other seismically qualified

EECW discharge

headers.

These modifications

will be complete prior to restart.

8.

Exit Interview (30703)

The inspection

scope

and findings were summarized

on March 22,

1989, with

those

persons

indicated in paragraph

1 above.

The inspectors

described

the areas

inspected

and discussed

in detail the inspection findings listed

below.

The licensee

did not, identify as proprietary

any of the material

provided to or reviewed

by the inspectors

during this inspection.

The

licensee

provided dissenting

comments

pertaining to all but

one of the

potential violations.

The inspectors

stated that the Unit 2 modification in 1988 to the shutdown

board

rooms air conditioning that resulted in the

EECW discharge

flow path

not being seismically qualified (see

paragraph

6) appeared

to be

a viola-

tion of 10 CFR 50, App.B., Criterion III for failure to exert adequate

design control.

The licensee

disagreed

that this design

change

package

either was not adequate

or was not adequately

implemented.

As,a result of

this

discussion

the 'potential violation was

changed

to Unresolved

Item

260/89-1-03,

pending

the

NRC's review of the information presented

by the

licensee

in the exit.

The licensee

expressed

their position that they should not be cited for

either the

LCO violation (paragraph

3) or the failure to promptly notify

the

NRC of an unanalyzed condition (paragraph

5) since they both resulted

from their failure to take

prompt corrective action,

which they did not

dispute.

The inspectors

stated that the

NRC will take their comments into

consideration

in developing the final form of the Notice of Violation.

Item

260/89-10-01

Descri tion

Violation, apparent failure to comply

with

TS 3.5.A.5 during Unit 2 core

reload

(paragraph

3)

e

259,

260, 296/89-10-02

260/89-10-03

Acronyms

14

Violation, apparent failure to establish

an

effective

program

to

assure

conditions

adverse

to quality are promptly identified

and corrected

(paragraph

4)

Unresolved

Item, Control of EECW

Modification Design

Change

(paragraph

6).

AOI

CAQR.

DBVP

NE

NQAN

NRC

OE

PORC

PORS

PRS

RCW

RHRSM

TS

USQD

I

Abnormal Operating Instruction

Condition Adverse to Quality Report

Core Spray

Diesel Generator

Design Baseline

and Verification Program

Engineering

Change Notice

Emergency

Equipment Cooling Water

Final Safety Analysis Report

.Heating, Ventilation,

8 Air Conditioning

Department of Nuclear Engineering

Notice of Violation

Nuclear

Performance

Plan

Nuclear Quality Assurance

Manual

Nuclear Regulatory

Commission

Office of Engineering

Plant Operations

Review Committee

Plant Operating

Review Staff

Plant Reporting Section

Quality Assurance

Raw Cooling Mater

Residual

Heat

Removal

Residual

Heat

Removal Service Water

Restart. Test Program

Standby

Gas Treatment

System

System Pre-Operation

Checklist

Senior Reactor Operator

Technical Specifications

Tennessee

Valley Authority

Violation

Unreviewed Safety Question Determination

> ~r

C,

~,,~

~

ay

'TTACHHEr,T

1

SROAS

FERRY NUCLEAR

PLAN'iVIL

FVKL LOAO ISSUKt

~

I

~ SPECIAL PROORW,'

u a f n

a

U

V<<l,

E

I

taho tI-

m

t

8 a

0

DlSCOVKRY 'CRIPLETKD:

Y

JVSfIFICAfION QF STATVS OF REFVELIHQt

~

The review of'he buried st'ructuros

subcategory. identified that

calculations

l'or burjod structuros,

piping and conduit, are not ro'triovablo,

1'he buried Residual

ffeat Removal Service Mater'iping (System

23) and

Eeorgency

K'quipmont Cooling locator Piping (Systoie 50) aro roquirod to be

operabl ~ by the technicgjpyocif'ications at fuel load,

Hoover, the

finding on buriod structures

doas

noL affect operability

The interface

bet~eon

structures

and soil, tho'est critical part of'uried piping, has

boch evaluated.

Yhes ~ interfaces

have boon~it'led

and documented

in

calculations,

There are

no kneun sal'ety isfufs with the balance of buried

piping or conduit and exporionco with buriod structures

sug9osts

that no

sal ~ ty issvos vi,il be found,

0418c-21

~

0

ML18033A766

Text

Navigation menu

Search