ML18033B716
| ML18033B716 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 05/15/1991 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML18033B715 | List: |
| References | |
| NUDOCS 9105230047 | |
| Download: ML18033B716 (11) | |
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UNITED STATES NUCLfAR REGULATORY COMMISSION WASHINGTON, D.C. 20555 ENCLOSURE SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION EMPLOYEE CONCERNS SPECIAL PROGRAM SUBCATEGORY REPORT 80200
" INSPECTION" TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT UNITS I 2
AND 3 DOCKET NOS. 50-259 50-260 AND 50-296 1.0 STATEMENT OF CONCERNS Within Subcategory Report 80200 (Reference I), there was a total of 123 con-cerns broken by common nature into 44 issues.
Each issue was evaluated by the Tennessee Valley Authority's (TVA) Quality Assurance Concerns Evaluation Group (QACEG) for safety significance, site applicability, veracity, and necessity and/or status of corrective action.
The TVA report stated, "many of the inspection and test procedures used by TVA had deficient inspection and acceptance criteria."
The report also stated, "Because TVA's inspection proce-dures did not fully implement regulatory and design requirements and TVA commitments and in some cases did not keep pace with the evolution of nuclear industry practices, substantial reinspection and reverification programs are now required."
2.0
SUMMARY
OF REVIEW The staff reviewed the issues for site-specific and generic applicability and found 15 issues relevant to the Browns Ferry Nuclear Plant (BFN).
The staff had previously studied the issues and accepted the corrective action program plans for Sequoyah Nuclear Plant (Reference 2).
This staff evaluation concerns the adequacy of the corrective action plans and programs for Browns Ferry.
3.0 EVALUATION Paragraph numbers are taken from Reference 1.
3.1.2 The concern was inadequate receipt inspection of Critical Systems, Structures and Components items.
Material listed as "Quality," "CSSC," or otherwise required to be within the scope of the Quality Assurance Program (QAP),
may have been inadequately inspected upon receipt and may have been installed without inspection and documentation as required by the QAP.
TVA did not substantiate this issue at Browns Ferry, but issued CATO-80251-BFN-01 to correct the use of uncalibrated measuring devices for performing dimensional checks.
The staff agrees with the disposition.
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The concern was that TVA did not have adequate control over the quality of vendor welds on hatch covers.
Although the issue originated at Watts Bar, the same vendor had supplied hatch covers to Browns Ferry.
CATD-80203-BFN-01 was issued to track the reinspection of all relevant hatch covers.
Subsequently, TVA inspected 7 of the 24 hatch covers and after verifying that the covers met the current requirements for weld quality, said that a sufficient inspection had been performed (Reference 3).
The staff agreed with the closure of the issue
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3.2.2 The concern was that TVA does not have adequate control over the quality of instrument fittings because of inadequate procedures.
The compression fitting installation program is inadequate due to lack of adequate procedures and training of personnel in installation and inspection.
TVA said the problems had existed within the nuclear organization for many
- years, and corrective actions had been initiated.
These actions included installation instruction courses for craft personnel, implementation of compression fitting installation procedures, and implementation of gC inspec-tion criteria for these fittings.
CATD 80202-BFN-Ol was written to track the issue of inadequate quality assurance controls being applied to the installa-tion of instrument tubing compression fittings; CATD 80202-BFN-02 originated from a nonconformance
- report, and both called for a walkdown inspection of a sample of the compression fitting installations.
CATD 80802-BFN-03 was written to address similar problems in Units 1 and 2.
An October 29, 1990 letter from TVA (Refer ence 4) said that the walkdown would be eliminated.
The justification was based on laboratory testing, previous operating history, and the system testing and correction of leakage that would occur prior to the restart of Unit 2.
The staff verified that the other correc-tive actions had been initiated and this Level II deviation was acceptable to the staff.
3.2.3 The concern was that certain TVA guality Assurance Procedures are lacking acceptance criteria, in that specific procedures do not provide qualitative and quantitative values sufficient to perform adequate inspections.
TVA did not substantiate this concern and the staff concurs with this finding.
3.2.4 The concern was that procedures used for equality Inspections have conflicting,
- unclear, and incomplete acceptance criteria, resulting in inadequate inspection results.
This issue was investigated at all TVA nuclear sites.
At BFN, deficiencies with quality inspection procedures and criteria were identified in two areas:
hydrostatic test pressure calculations, and installation and support of piping systems in Category I structures.
The gACEG attributed the cause of the unclear, conflicting or incomplete acceptance criteria to a failure by management to establish an adequate review process for procedures, specifications,
- drawings, and instructions.
To correct the identified deficiency, General Construction Specification G-29M was revised to specify that piping elevation differences must be taken into account when calculating hydrostatic test pressures in order to ensure that piping at low elevations is not overpressurized.
The BFN instrumentation engineering group wi 11 conduct engineering analyses to determine if such piping may have been damaged as a result of past tests and, if such piping is identified, corrective action wi 11 be implemented.
TVA's corrective action for the unclear inspection procedures and acceptance criteria at BFN includes revisions to the BFN Nuclear guality Assurance Manual (NIZAM) to require a plant hardware impact review when deficiencies are discovered in quality inspection assurance procedures.
This change in BFN N(AM will apply to the questionable support and piping installations in Category I systems.
The corrective actions are tracked by CATO-80252-BFN-01 and -04 and CATD-80252-NPS-01 and this is acceptable to the staff.
The corrective action covered by CATO-80252-BFN-01 was to evaluate the 'effect of different static heads due to elevation differences in hydrostatic testing.
In the 1989 annual report on corrective actions implementation (Reference 3),
TVA said the hydrostatic test pressure limits included static head pressure.
The staff agrees with the Level II CAP deviation and the issue is closed.
3.2.5 The concern was that Notices of Indications (NOI) and Maintenance Requests (MR) do not have a proper tracking system, resulting in the NOI/MR originator not knowing the status of the NOI/MR at any given time.
TVA said if the disposition involves inspection of the work by a group other than the originator, the group performing the inspection is responsible for documenting and closing the MR. If an MR is canceled it is marked "rejected" and the second copy is returned to the originator.
In addition, MR initiators are notified prior to cancellation of an MR.
TVA did not substantiate the concern and the staff agrees with the disposition.
3.2.6 The concern was that excessive and uncontrolled procedure and drawing revisions have caused confusion for the craft regarding the installation and inspection of hanger supports.
TVA did not consider this issue to be applicable at Browns Ferry and the staff concurs.
3.3.1 Fundamental problems exist with establishing, implementing and enforcing program requirements for cable pulling, resulting in an inadequate cable pulling program.
The QACEG evaluated the cable pulling programs at all four TVA nuclear sites, and the concerns described in this issue were validated only at the Bellefonte and Watts Bar nuclear plants.
The issue was not verified as factual by the QACEG at the Sequoyah Nuclear Plant (SQN) and BFN.
Originally, the staff did not concur with TVA's evaluation of the cable pulling programs at BFN because, even though the procedures and supporting documentation may have appeared satisfactory, the implementation was not adequate.
This inadequacy was demonstrated by the current repulling of environmentally qualified cables in the drywell of BFN Unit 2 because their initial installations were unsatisfactory.
- However, subsequent corrective actions taken by TVA provided adequate resolution.
3.3.5 The concern was that inspectors cannot calculate torque conversions when using extensions.
This issue was found to be a problem at BFN in that, when questioned, none of the five Quality Control Inspectors 'could properly calculate torque.
The QACEG attributed the problem primarily to inadequate training of inspectors.
Corrective action has included retraining inspectors on torque calculations.
However, there appears to have been no material impact of this concern at BFN
- because, in accordance with the BFN General Torquing Guide, the onsite engineering group provides all the required torque values and associated conversion factors within work packages.
The corrective actions were tracked by CATO-80209-BFN-01 and the staff agrees with the disposition.
3.3.6 The concern was that there were numerous incidents of fai lure to follow procedures at Watts Bar and this issue was substantiated by TVA.
In addition, at the generic level, TVA noted that CAQRs were to be issued when adverse trends were identified.
No such CAQRs were issued because responsible per-sonnel had not been provided with a definition of "adverse."
CATO-80204-NPS-01 is tracking the corrective action and this disposition is acceptable to the staff.
3.3.7 The concern was that the engineers in Quality Control were accepting equipment by waiving the required quality control inspections.
Information was not found to substantiate this concern, rather a number of instances from 1979 to 1990 where QC Engineering overruled an inspector were reviewed.
Small diameter valves were rejected because they were not identified according to specification ANSI B16.34 listed on the purchase order, but TVA said that ASME Section III does not require 2-inch and smaller valves to be marked.
RHCU valves were rejected by an inspector and accepted by the engineer for the same reason.
Stainless steel valves were rejected by an,,inspector because desiccant bags were missing, but TVA had deleted the requirement in Knoxville without telling Inspection.
A control bay chiller was rejected for lacking requirements for welder qualifications and inspection criteria, but TVA said the component was not considered important to safety and details of the vendor's manufacturing qualification and inspection process are not needed.
Valves with cast discs'were rejected as impossible to inspect because Knoxville engineering had given approval prior to authorizing delivery of the material without informing inspection.
Voltage sensing relays were rejected for an incorrect part number, but were later accepted by TVA based on revised documentation from the vendor.
The staff reviewed and accepted the findings.
An inspector said the part number was not referenced on the Product guality Certification and DNE approval was required for test results, cer tifications, documentation and the procurement
- package, but TVA responded that the part number was listed as the Device Catalogue Number on the Test Data Sheet and DNE approval was not required by I(T or PEG evaluations.
The staff reviewed and accepted the findings.
In one instance, the staff identified material
- procured, received to SA 182
- F316NG, a non-existent forging grade.
actually SA 182 F316 stainless steel forging with a more grade chemistry.
In addition, there were several typing chemical analysis issued by Knoxville.
These errors are recurring.
manufactured and The material was restrictive nuclear errors in the considered non-Grease relief assemblies were rejected as improper by an inspector, but accepted by his supervisor.
These items were later returned to the supplier as incor rect.
The inspector was correct and the supervisor is no longer employed by TVA.
The staff considers this to be a non-recurring error.
Based on these examples, it is concluded that guality Control Engineering was properly accepting material.
3.3.8 The concern was about questionable behavior and job attitudes of inspectors.
There were contentions about an inspector being unfit for duty, inspectors being malicious and vindictive toward the workers, and excessive overtime affecting morale.
The concern about an inspector at Browns Ferry being unfit for duty was substantiated and the individual is no longer involved with inservice inspection.
The remaining concerns did not apply to Browns Ferry.
The staff concurs with the corrective action taken at Browns Ferry.
3.3.9 The concern that electrical cable installation inspections were inconsistent or not performed was limited to Watts Bar.
- However, CATO-10900-NPS-01 was created to track resolution of the problem about side-wall pressure values.
The staff concurs with the corrective action taken at Browns Ferry.
3.3.10 The concern was that rejected items at Browns Ferry were accepted by someone other than a supervisor or the appropriate higher grade personnel.
For
- example, the supervisor will send another examiner/inspector with less qualifications and experience to re-examine and accept previously rejected items.
Specific information was'ot provided and the concern was not substantiated.
The staff accepts the conclusion of TVA.
IV.
CONCLUSIONS The dispositions of the safety-related employee concerns contained in Subcategory Report 80200 and the deviation reports (References 3 and 4) as they apply to BFN, are adequate to support the restart of Browns Ferry Nuclear Plant, Units 1, 2 and 3.
Dated:
May 15, 1991 Principal Contributors:
P. Cortland and R. Wharton
REFERENCES TVA Employee Concerns Special Program Report, Volume 8, "guality Assurance Category,"
Subcategory Report 80200 Revision 6,
" Inspection,"
March 18, 1988.
NUREG-1232, Volume 2, Safety Evaluation Report on Tennessee Valley Authority:
Sequoyah Nuclear Performance
- Plan, Hay 1988.
Letter from E.
G. Wallace (TVA) to NRC, dated June 8, 1990, forwarding the "Second Annual Report of Employee Concerns Special Program Corrective Actions Implementation, October 1, 1988 - December 31, 1989."
Letter from E.
G. Wallace (TVA) to NRC, dated October 29, 1990, "Safety Evaluation Report on the Tennessee Valley Authority Employee Concerns Subcategory Reports - Browns Ferry Nuclear Plant, Units 1, 2, and 3-Hay 31, 1990."