ML18036A692
| ML18036A692 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 04/17/1992 |
| From: | Christnot E, Kellogg P, Patterson C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18036A690 | List: |
| References | |
| 50-259-92-12, 50-260-92-12, 50-296-92-12, NUDOCS 9205120227 | |
| Download: ML18036A692 (22) | |
See also: IR 05000259/1992012
Text
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UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
t0'I MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323
Report Nos.: 50-259/92-12, 50-260/92-12,
and 50-296/92-12
Licensee:
Valley Authority
6N 38A Lookout Place
1101 Market Street
Chattanooga,
TN 37402-2801
Docket Nos.:
50-259, 50-260, and 50-296
License Nos.:
Facility Name:
Browns Ferry Units 1, 2, and 3
Inspection at Browns Ferry Site near Decatur, Alabama
Inspection Conducted: March 16 - March 27, 1992
<S-YC
C. A. Patterson,
Senior Reside t Inspector
E. Christnot, Resident Inspector
u-/y~
Date Signed
Approved by:
Pa
I
Reactor Pro
c s, Section 4A
Division of Reactor Projects
te
Igned
SUMMARY
Scope:
This special resident inspection included a review of contractor activi-
ties associated
with the 4160 volt loop upgrade.
The licensee inci-
dent investigation report, advance authorized forms, drawing updates,
design change closure, and previous enforcement actions were re-
viewed.
9205120227
920417
ADOCK 05000259
8
One violation with two examples for failure to control design activities
was identified, paragraph four. The first example was that a con-
struction contractor signed for design engineering on several design
documents without proper authorization.
The second example was
that a primary drawing was not updated for four months after modifi-
cations had been installed and the system returned to service.
Weaknesses
were identified in the licensee's incident investigation of
event, paragraph five. The root cause was incorrect.
Procedures
are
in place to control update of drawings.
Organization interfaces be-
tween Unit 2 and Unit 3 were questioned by the Operational Readi-
ness Team Inspection.
The licensee established controls prior to
restart of Unit 2.
Continuing problems have occurred with contractor controls, para-
graph nine.
This includes removal of fire wrap, boot incident, tele-
communication contractors, access control, and Bechtel stop work.
REPORT DETAILS
Persons Contacted
Licensee Employees:
"O. Zeringue, Vice President, Browns Ferry Operations
"H. McCluskey, Vice President, Browns Ferry Restart
"J. Scalice, Plant Manager
"J. Swindell, Restart Manager
M. Herrell, Operations Manager
"J. Rupert, Project Engineer
"M. Bajestani, Technical Support Manager
R. Jones, Operations Superintendent
A. Sorrell, Maintenance Manager
G. Turner, Site Quality Assurance Manager
"R. Baron, Site Licensing Manager
"J. McCarthy, Unit 3 Licensing
"P. Salas, Compliance Supervisor
J. Corey, Site Radiological Control Manager
A. Brittain, Site Security Manager
Other licensee employees or contractors contacted included licensed reactor
operators, auxiliary operators, craftsmen, technicians, and
public safety
officers; and quality assurance,
design, and engineering personnel.
NRC Personnel:
P. Kellogg, Section Chief
"C. Patterson,
Senior Resident Inspector
"E. Christnot, Resident Inspector
"Attended exit interview
Acronyms and initialisms used throughout this report are listed in the last
paragraph.
'tatementof Problem
During routine plant meetings, the inspector became aware. of the delays
associated
with completing Incident Investigation (II) II-B-92-006, Primary
Drawing Configuration Discrepancies Discovered During Restoration of 4160
Loop Line. Also, another
II concerning SWEC doing unauthorized design
work for a TACF associated
with temporary power from the 4160 Loop Line
had recently been completed.
After careful review of the II-B-92-006, the
inspector concluded the root cause and root cause statement were incorrect.
The II was defensive, contained inaccurate statements,
and only addressed
the specific event.
Further review revealed that three lls, 4 DCNs,
1 ECN,
1 FDCN,
1 TACF,
and
1 primary drawing were involved in the configuration control problem.
This represented
a significant breakdown in design control. The unit had
been shutdown for several years to reestablish the design baseline and
regain configuration control.
Procedures were in place to close designs and
update the drawings necessary to restore Unit 2 to operation.
The three lls involved are as follows:
11-B-91-1 60
Inadequate Control of Contractor and Sub
Contractor Work Activities on Communica-
tion and Telephone Equipment
II-B-91-1 68
Unit 3 Temporary Power Alteration Control
Form Approval
II-B-92-006
Primary Drawing Configuration. Discrepancies
Discovered During Restoration of 4160 V
Loop Line.
3.
Description of the Event
May 8, 1986
ECN P5235 was issued for the design of a new
4KV Loop Line. This design interfaces with the
4KV Cooling Tower Switchgear C and D. WP No.
0009-86, which was written for the ECN, closed
on May 27, 1988, modifying only Switchgear D.
When the drawings were updated, primary drawing
35W713-2 was "as-constructed" to reflect both
Switchgear C and D being complete, which was
the "as-designed" condition, not the "as-con-
structed" configuration.
Therefore, the configura-
tion of the new 4KV Loop'Line was incorrectly
depicted on the "as-constructed" drawing prior to
Unit 2 restart.
Prior to
Four other DCNs (W9277A, W9278A, W16713A, and
January 13, 1992 W16836A)had been issued and partially or totally imple-
mented.
None of the DCNs had been clo'sed and associ-
ated drawings had not been updated.
January 13, 1992 A storm knocked out the Athens 161 KV line tripping
power to the 4160 Loop Line. During restoration, Opera-
tions personnel discovered discrepancies between prima-
ry drawing 0-35E713-2
RC, the single-line wiring diagram
of the loop line, and the actual field configuration.
January 14, 1992 Complete restoration of the line.
Januaiy 15, 1992
Site Engineering issued drawing 0-35E713-2
ROOO to
supersede
as-constructed
drawing 0-35E713-2
RC and
added the four DCNs.
DCN W16713
4KV North Loop for Outage Contrac-
tor Facility and Contractor Specialty
Trailers
DCN W16836
4KV South Loop for Unit 3 Change
Houses and Restrooms
DCN W9277
4KV Cooling Tower Switchgear C
Loop for the Nuclear Telecommunica-
tions System Project Node 2 Building
DCN W9278
4KV Loop for the Telecommunications
and Computer Center Building
January 17, 1992 TACF 3-91-004-100
R4 issued for drawing No. 0-35E-
713-1 R001 to relocate S4 substation, correct switch
positions, add ground and minor revisions, add temporary
power for Unit 3 reactor building.
The problems associated
with the TACF were addressed
in ll-B-91-168.
The problems associated
with the control of subcontractors
in DCN W9277
and W9278 were addressed
in ll-B-91-160. Violation 91-42-02 was issued
for not following a site procedure for control of contractors.
The total configuration problem is addressed
in Il-B-92-006.
4
Problems with Design Control (37700, 37702)
Two problems occurred with the 4160 volt loop upgrade.
First, SWEC
performed the design work without adequate authorization from SE.
A Unit
3 PM gave verbal authorization to SWEC and followed up with a task
description with the FPB out of Knoxville. The FPB tended to act indepen-
dently from SE even though SE had been given responsibility for the 4160
volt loop line calculation.
The FPB was recently dissolved during a corporate
reorganization.
The Unit 3 PM overlooked the design interfaces.
signed for design engineering on DCN W16836A, on 12 AA forms for F-
DCN F16903, on TACF 3-91-004-100,
on drawing approval for work orders
91-44565-00 and 91-44565-01
and to a 10 CFR 50.99 safety assessment
for a temporary alteration.
Site procedure SSP-9.3 (formerly SDSP 8.11),
Plant Modifications and Design Control, establishes
the controls for design
change.
This is the first example of VIO 259, 260,296/92-12-01,
Failure to
Control Contractor Design Activities.
The second problem was that the primary drawing (control room drawing)
was not updated after modifications were completed and the system re-
turned to service.
Nuclear Engineering Procedure,
BFEP Pl 89-06, requires
that prior to return to service primary and critical drawings be revised and
issued.
This is the second example of VIO 259, 260, 296/92-12-01,
Failure
to Control Contractor Design Activities.
The inspectors noted that the onsite fire protection 1000 KVAbladder tank
load (138.8 amps) is powered from the 4160 volt loop. This fact was
discussed
in NQASE Audit No. BFA 92204.
Also, discussed
was that the
safety assessment
did not address loads listed in FSAR tables.
Periodic
testing of the outside loop fire pump is covered in Fire Protection Program
Plan Procedure,
This procedure is identified as a quality related
procedure.
Review of Incident Investigation Report (II-B-92-006) (40500)
The inspector reviewed the II and noted several items that were not ade-
quately assessed.
a.
Root Cause Incorrect
The root cause and root cause statement were incorrect.
The root
cause stated the DCN process does not specify a timeframe for
updating primary/critical drawings after work completion/appropriate
testing or overall accountability for processing the DCN through RTD.
0
These requirements
are in SSP-9.3 (formerly SDSP 8.11), Plant
Modifications and Design Change Control; and SSP-2.11,
Drawing
Deviation Control. These procedures or earlier versions were used to
recover Unit 2 for restart.
Also, a previous deviation issued July 13,
1990, was for 260/90-18-02,
Failure to Correct Drawing Discrepan-
cies, emphasized the importance of updating drawings.
The time
limits are clearly discussed
in the applicable procedures.
Contributing factor statement incorrect
The II stated
a contributing factor was that neither the TSD nor
applicable procedures established
a division of responsibility and
appropriate organizational interfaces between SWEC and Bechtel, SE,
or RE.
The NRC conducted an ORAT inspection prior to restart of Unit 2.
ORAT item 260/91-201-01
was to establish administrative controls
delineating responsibilities of communications between Unit 2 and
Unit 3 site organizations at management
levels.
The licensee issued a memorandum from H.F. McCluskey, V.P;
Browns Ferry Restart, and'O.J. Zeringue, V.P. Browns Ferry Opera-
tions to their respective supervisors dated April 18, 1991, to delineate
responsibilities and lines of communication between
BFN Operations
and BFN Restart Organizations.
In addition, SSP-1.51,
Unit 1 & 3
Restart Administration and Control was issued May 24, 1991
~ This
procedure defines the Unit 1 5 3 Restart organization principle duties,
responsibilities, and authorities, and its interface with the BFN organi-
zation.
Corrective action statements
incorrect
lt was stated that a process to verify adequacy of a TSD and the
readiness of a contractor to perform work did not exist.
A procedure did exist. This was SDSP-16.17,
Contractor and Con-
tractors Equipment Control ~ This was the subject of a previous
violation 50-259, 260, 296/91-41-02.
Also, after violation 91-26-02 concerning removal of fire wrap, steps
were taken to control contractor activities.
This was establishment of
a contractor work release program in August, 1991
~ Additionally,
after a deviation 296/91-41-02 concerning work on a secondary
0
containment penetration by SWEC personnel not authorized to do the
work, retraining of the CWL was performed.
In general, the II imputed the problems on inadequate procedures and situa-
tions not covered.
The inspector did not agree with this assessment.
The
assessment
was narrow in scope and only addressed
the specific event.
A
negative trend was identified in the quality of Level III incident investiga-
tions.
Another example of this is contained in IR 92-03 concerning an
inadvertent start of the DG.
For Level III lls, the highest level of signature is
the Plant Manager.
6.
Use of Advanced Authorized FDCNs (37700, 37702)
Procedures for AAs
The inspector reviewed the BFN AA-FDCN process.
The overall
controlling procedure SSP-9.3,
Plant Modifications and Design Change
Control, Section 3.2, Final Engineering, sub-section 3.2.9, F-DCN
Origination stated:
During the implementation of a DCN, the imple-
menting organization may identify the need for a revision to the design
of the modification that is within the scope of the original design.
The
F-DCN is intended to fulfillthis need.
The Browns Ferry Engineering Projects implementing procedure,
BFEP Pl 89-06, Design Change Control, Section 1, Purpose stated:
This procedure provides the Browns Ferry Engineering Project require-
ments necessary to implement the design change control process and
maintain configuration control; This process will be implemented by
the DCN as described herein.
The inspector noted during a review of these procedures that the SSP
did discuss AA-FDCNs in section 3.2, Final Engineering, Sub 3.2.9,
Step 3.2.9.A.2.d.
It was also noted that the BFEP PI, Section 18 discussed
AA-FDCNs
and Steps 18.1 through 18.7 stated:
18.1
An AA is the approval which allows modification work to pro-
ceed on a risk basis prior to final approval of the DCN.
18.2
AA to proceed with urgent changes
may be allowed when all of
the following conditions apply:
0
a o
b.
The requested
change is clearly understood and docu-
mented for granting the authorization to perform work.
The time needed to obtain required NE approvals would
cause substantial and unwarranted delay in modification
activities.
C.
The responsible
LE reviewing the change can demon-
strate to the PE a high degree of confidence that the
change as authorized will receive NE final approval.
d.
Rework or repair can be accomplished without undue
impact on cost or schedule in the event that the change
is not subsequently approved.
18.3
Approval of AA shall be limited to the PE.
This authority may
be delegated only to the LEs, and those personnel assigned
these functions in the absence of these engineeis, i.e., second
shift and weekend project personnel.
18.4
The PE may delegate AA authority to individuals outside NE.
This authorization must be documented via a memo.
18.5
The originator shall clearly mark the DCN as "Advance Autho-
rization Requested."
18.6
An AA is not the ISSUE of a revision level of the DCN, it is a
status of a revision prior to issue but shall include an approved
10 CFR 50.59 review to support the authorized change.
18.7
The final approval DCN must clearly state that no changes were
made from the advance authorized DCN or identify the changes
from the advance authorized DCN.
The inspector concluded from this review that FDCNs were to be used
to facilitate field work activities and the AA-FDCNs could be used to
allow the modifications activities to proceed on a risk basis.
A review of recent design activities, that were completed from
May 23, 1991 to present, indicated that the use of AA-FDCNs was in
accordance with the design control process.
The DCN assignment log
indicated that for DCN W17480A, and AA-FDCN number, F17612
was issued in order to revise material.
A review of the AA indicated
that is was also used to change wiring. An additional review of DCN
W16951A indicated that an AA-FDCN, number F16952A was issued
and had two parts.
One part was to add a correction to a cable
schedule and remove some notes from DCAs. The second part was
to add notes to DCAs and a cable schedule.
Although this did not
result in hardware changes that were detrimental to the affected plant
systems, this process of initiating an AA-FDCN for a specific purpose
and using it for other purposes is considered
a weakness
in the
process.
This item was discussed with TVA Nuclear Engineering
Management.
b.
Additional reviews of the AA-FDCN process indicated that to initiate
an AA-FDCN the responsible engineer does not have to obtain PORC
approval.
This is clearly stated in procedure
BFEP Pl 89-06, section
18, step 18.1 which indicated that AAs can be used prior to the final
approval of the design change.
Drawing Updating and DCN Closure (37700, 37702)
The inspector met with the Site Engineering Manager and Technical Support
Manager to discuss generic issues with closure of DCN's and DD for Unit 2.
Drawing Update
The inspector reviewed procedures
SSP 9.3, Plant Modifications and
Design Change Control and BFEP Pl 89-06, Design Change Control.
Both procedures clearly outline the drawing updating requirements.
The inspector noted there is no clearly indicated timeframe in which
drawings are to be updated.
The inspector did note that procedure
SSP 9.3, section 3.4, Return to Operation, clearly indicates a verifica-
tion of primary drawing updates associated
with the design change
and before returning a system to service.
The inspector reviewed a list of DDs involving secondary drawings
and noted that the licensee identified a total of 1269 discrepancies
on
September 29, 1991.
The total number of discrepancies at the end of
this inspection was 831.
The inspector noted that the discrepancies
are being worked by the licensee at the rate of approximately 75 per
month.
The inspector also reviewed a list of discrepancies
involving
28 primary drawings and noted that seven were behind schedule,
three were due during this inspection and 18 were being worked.
A
licensee representative
informed the inspector that for DDs discovered
on primary drawings a self imposed 30 day limit was in place.
The
inspector discussed these reviews with TVA design management.
b.
DCN Closure
The inspector reviewed a total of 21 closed DCNs dated from May 23,
1991 to present.
The inspector noted that the DCNs involved field
work by electrical, mechanical, and civil disciplines and included such
items as change the diameter and thickness of flow element 2-FE-2-
191, notch a tube steel plate and widen a flange, and install wiring
from main relay board panel 32 to turbine trip auxiliary relay 294T.
The DCNs reviewed appear to have been closed in accordance
with
applicable TVA procedures.
The inspector reviewed the licensee closure of DCNs process in
previous IR 92-05.
The activities were controlled by SSP 9.3, Plant
Modifications and Design Change Control, and applicable engineering
program instructions.
The ongoing observations by the inspector
indicated that the licensee continued to follow the process in accor-
dance with the approved procedures.
The inspector concluded that adequate tracking and closure of DCN's and
DDs was occurring for Unit 2.
No backlog was occurring.
Although, the
Unit 3 list were not reviewed, the only work thought to be completed and
energized was the 4160 volt loop. The other equipment and systems will
undergo rigorous review when returned to service.
8.
Action'on Previous Inspection Findings (92701, 92702)
(CLOSED) URI 259, 260, 296/92-03-03,
Failure to Update Primary Drawing.
This item was identified when during an audit it was discovered that primary
drawing 0-35E713-2 had not been updated as prescribed by procedure.
This URI has been upgraded to a violation in this report.
9.
Summary
Although the licensee's
II on this event was narrow in scope and contained
inaccurate statements,
followup reviews by the inspectors indicate this
problem concerned contractor activities for Unit 3.
Unit 2 engineering and
technical support are updating primary drawings prior to returning a systems
to service and have time limits for resolving drawing discrepancies.
The
main concern of this event was that a TVA Project Manager exceeded
his
10
authority and authorized SWEC to perform design work without the knowl-
edge of site engineering or restart engineering.
SWEC was unfamiliar with
the design procedures and requirements.
Several problems involving control
of contractors have occurred since August 1991.
NRC enforcement action
has occurred for the following:
VIO 91-26-02
Fire Wrap Removal
DEV 91-41-01
Boot Incident
VIO 91-41-02
Control of Telecommunication Contractor
VIO 91-43-02
Access Control of Contractors
ln addition, the licensee's
QA finding resulted in a Bechtel Stop Work for
DCN issue.
A DEV concerning drawing update occurred within the last two
years on July 13, 1990, DEV 260/90-18-02.
Although procedures and organization controls were in place, control of
contractors continues to be a problem.
The actions of the project manager
are an indication of weaknesses
in the licensee's project supervision of
contractor activities.
In addition, lessons learned from Unit 2 restart regard-
ing drawing update and DCN closure were not utilized.
10.
Exit Interview (30702)
The inspection scope and findings were summarized on March 27, 1992
with 'those persons indicated in paragraph
1 above.
The inspectors de-
scribed 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 V.P. Browns Ferry Operations commented this system did not undergo a
SPOC review. The inspector commented that the onsite diesel driven fire
pump and bladder tank was powered from the 4160 volt loop. The V.P. of
Browns Ferry Operations stated that the SPOC of fire protection system
would be reviewed.
The V.P. Browns Ferry Restart commented that the summary of previous
enforcement concerning fire wrap removal was performed by TVA personnel
and not contractors although TVA personnel did what Bechtel told them to
do.
0
Item Number
Descri tion and Reference
259, 260, 296/92-12-01
VIO, Failure to Control Contractor
Design Activities
Licensee management
was informed that
1 URI was closed.
Acronyms and Initialisms
BFEP
BFNP
CFR
DCN
DEV
FDCN
FPB
II
IR
KV
LE
NE
NOAE.E
NRC
QDCN
RE
SDSP
TACF
, Advance Authorization
Browns Ferry Engineering Project
Browns Ferry Nuclear Plant
Code of Federal Regulations
Design Change Authorization
Design Change Notice
Drawing Discrepancies
Deviation
Diesel Generator
Engineering Change Notice
Field Design Change Notice
Facilities Planning Branch
Final Safety Analysis Report
Incident Investigation
Inspection Report
Kilovolt
Lead Engineer
Nuclear Engineering
Nuclear Quality Assurance
5, Engineering
Nuclear Regulatory Commission
Operational Readiness
Assessment
Team
Project Engineer
Project Manager
Plant Operations Review Committee
Quality Assurance
Quality Design Change Notice
Restart Engineering
Site Director Standard Practice
Site Engineering
System Pre-Operability Checklist
Site Standard Practice
Stone 5 Webster Engineering Corporation
Temporary Alteration Change Form
TSD
12
Task Scoping Document
Valley Authority
Unresolved Item
Violation