ML20081C897
| ML20081C897 | |
| Person / Time | |
|---|---|
| Site: | Bellefonte  |
| Issue date: | 10/20/1983 |
| From: | Mills L TENNESSEE VALLEY AUTHORITY |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| 10CFR-050.55E, 10CFR-50.55E, 2, 3, 4, M81-13, NUDOCS 8310310377 | |
| Download: ML20081C897 (6) | |
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o TENNESSEE VALLEY AUTHORITY CH ATTANOOGA. TENNESSEE 374o1 40') Chestnut Street Tower II g3 0 Cry Alg
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October 20, 1983 WBRD-50-390/82-06, -391/82-06 BLRD-50-438/82-03, -439/82-03 U.S. Nuclear Regulatory Commission Region II ATTN: James P. O'Reilly, Regional Administrator 101 Marietta Street, Suite 2900 Atlanta, Georgia 30303
Dear Mr. O'Reilly:
WATTS BAR AND BELLEFONTE NUCLEAR PLANTS - REPORTABLE DEFICIENCY -
ENGINEERING CHANGE REVIEW AND HANDLING - WBRD-50-390/82-06, -391/82 BLRD-50-438/82-03, -439/82-03 The subject deficiency was initially reported to NRC-0IE, Region II, Inspector Ross Butcher on December 15, 1981 as Audit M81-13, Deficiency Nos. 2, 3, and 4.
In accordance with paragraph 50.55(e) of 10 CFR Part 50, we are enclosing our final report for Bellefonte Nuclear Plant. The final report for Watts Bar Nuclear Plant was submitted July 20, 1983 If you have any questions, please call Ralph Shell at FTS 858-2676.
Very truly yours, TENNESSEE VALLEY AUTHORITY M'. Mills, Fanager i
Nuclear Licensing Enclosure oc (Enclosure):
Mr. R. C. DeYoung, Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Records Center Institute of Nuclear Power Operations 1100 Circle 75 Parkway, Suite 1500 Atlanta, Georgia 30339 OFFICI AL C0d, 8310310377 831020
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ENCLO6URE a
BELLEFONTE NUCLEAR PLANT ENGINEERING CHANGE NOTICE REVIEW AND HANDLING 10CFR50.55(e) REPORT NO. 7 (FINAL)
AUDIT M81-13, DEFICIENCY Nos. 2, 3, AND 4 WBRD-50-3 90/ 82-06, -3 91/ 82-06 P',RD-50-43 8/ 82-03, -43 9/ 82-03 Description of Deficiency (Deficiency 2)
EN DES-EP 4.02 R9, Figure 2, ' Engineering Change Notices (Ems) -
Handling,' states in part that Thermal Power Engineering (TPE) Branch review must be marked ' 'Yes' if the Em requires change to a saf ety-related system or change in a conceptual document for which at least one TPE branch is responsible'; and 'if 'Yes' above, the cover sheet original enters 'N/A' and his initials where a TPE approval signature is not needed: approval of all TPE branche; is not always r equire d. '
Contrary to the above, numerous Ems which involved saf ety-related changes were not routed or reviewed by the responsible branch (es).
(The audit cited one example for Watts Bar and nine examples for Bellef onte.)
Bellefonte Ems 1225,1231,1236,123 8,1274.1282,1290,1350, and 1352 were cited as being deficient in not receiving proper Thermal Power Engineering (TPE) Branches' approval. Further investigation of Ems cited in Deficiency No. 2 enabled the following conclusions to be made:
1.
EN DES-EP 4.02, ' Engineering Change Notices - Handling,' figure 2, page 28, can be misinterpreted as to when TPE approval is required.
2.
TPE approval was given in the form of a design criteria change, post TMI caused revision, or change as a design improvement not involving plant concepts.
3.
Changes involved only detailed design and, therefore, was of no interest to any TPE branch.
4.
' Reference and Description of Change' paragraphs do not adequately describe the changes in scue instances, thereby, misleading anyone not f amiliar with the changes.
5.
No deficiencies exist in determining TPE approval.
The results of the investigations were presented to 'IVA's Office of Quality Assurance and the audit deficiency has been closed.
Based on the above discussion, IVA considers deficiency 2 to have no applicability to the Bellefonte Nuclear Plant and is, therefore, no longer reportable under the requirements of 10CFR50.55(e). It should be noted that although there have been no deficiencies in determining proper approval, EN DES-EP 4.02 was revised to provide further clarifice tion on the requirements for review and approval of Ems by the Engineering Support Branches (f ormerly TPE branches).
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Descrintion of Deficiency (Deficiency 3)
EN DES-EP 4.02 R9, Figure 3, ' Engineering Change Notices - Handling,'
states in part that the 'nonconformance report (hCR) required' block must be marked ' 'Ye s' if the proj ect or a branch has prepared or will prepare a nonconf ormance report related to the design change.
See footnote 1, pa ge 1. '
Footnote 1, page 1, states, ' A nonconf ormance report (see EN DES-EP 1.26) must be processed when an issued design document must be changed to correct a significant or recurring condition which could have resulted in a required saf ety-related function not being fulfilled. This excludes changes for proplanned design development, improvement of an already satisfactory design, changes that are directed by new or revised standards or regula tions, and nonsaf e ty-rela ted change s.'
Contrary to the above, numerous ECNs which involved conditions adverse to quality were not generated as the result of an NCR.
( i. e, NCR s w er e no t being generated for some conditions adverse to quality). (The audit cited three examples for Watts Bar and 12 examples f or Bellefonte.)
The cause of this deficiency was determined to be the inadequate training of those responsible for the preparation of ECNs.
Safety Imolications Failure to generate an NCR could result in the potential generic implications of the deficiency from being fully examined. Actions to prevent the deficiency from recurring are also not addressed. This condition could adversely affect safe plant operations.
Corrective Action ECN s 1225, 1231, 123 6, 123 8, 1245, 126 2, 1274, 12 82, 12 87, 1290, 13 45, and 1352 were cited as being deficient in not requiring NCRs be written as a result of the change required by the ECN.
Further review of the ECNs listed above resulted in concluding that NCRs should have been issued f or the following:
1.
ECN 1262 was written to add automatic air release valves to the CCW heat exchanges,- CCW air handling units, and diesel generator cooling water per DIM N4-KE-D740-6.
Reanalysis of the essential raw cooling (ERCW) system requires this addition. NCR BLNQAB8203 was issued to document corrective action, assignable cause, and action to prevent recurrence for this design deficiency.
2.
ECN 1282 was issued to provide for expansion loops in the section of boric acid pumps af ter thermal analysis of the system. NCR BLNQAB8201 was -issued to document corrective action, assignabl e cause, and action to prevent recurrence for this design deficiency.
3.
Upon further discussion and evaluation of Ems 1274,1290, and 1352, it was determined that nonconforming conditions did not exist for these Ems as reported in our third interim report on this subj ect.
Ems 1225,1231,1238,1245,1287, and 1345 were also reevalua ted and did not require NGs to be written.
4.
Em 1236 was issued to brace powerhouse ladders because of 4
excessive deflection. Investigations of this subj ect conclude that docuented seismic analysis calculations do not exist. NG BLNEAB8206 was issued to document corrective action, assignable cause, and action to prevent recurrence due to lack of seismic analysis.
4 The Bellef onte Design Proj ect (BLP) conducted an audit of 100 Ems to determine the extent of this deficiency. The audit indicated one addi tional instance where an NG resulted. Upon further investigation of the N 3, it was determined that a problem did not actually exist and that the NG should not have been written. Based on the results of this sampling, it was determined that no additional sampling is necessary.
To prevent recurrence of this deficiency, BLP has instituted a training program to educate all personnel in the requirements of Engiaeering Procedures with respect to ECN review and handling.
This inf ormation has been presented to IVA's Office of Quality Assurance and accepted for closure of this deficiency.
Description of Deficiency (Deficiency 4)
EN DES-EP 4.02 R9, Figure 3, ' Engineering Change Notices - Handling,'
includes instructions for filling out the Em cover sheet. For example, I
it requires the QA applies block to be marked Yes' if the Em is l
saf ety-related.
.' and the Nm required block to be marked Yes' if l
the proj ect or a branch has prepared or will prepare a nonconf ormance report related to the design change Contrary to the above, numerous Em cover sheets were marked improperly, thus omitting requirements for the QA applies, Saismic Analysis Required, or NG Required blocks.
(The audit cited four examples for Watts Bar and 15 examples for Bellefonte.)
The cause of this deficiency was determined to be the inadequate trais ing of those responsible for the preparation of Ems.
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Safety Isolications Failure to properly and completely mark Em cover sheets could result in insufficient review and/or dispositioning of a safety-related design change. his condition could ultimately result in a deficient design being approved for use and thereby adversely affecting safe plant operations.
Corrective Action Em s 1225, 1231, 123 6, 123 8, 1245, 1262, 1274, 1282, 12 84, 1285, 12 86,
1287,1290,1345,1350, and 1352 were cited as being deficient in improper marking of the cover sheet, thus omitting requirements for QA appl ie s, seismic analysis required, or NG required blocks. Further review of these potentially deficient Ems produced these results:
1.
ECN 1282 was deficient in not properly marking QA applies and seismic analysis required blocks. As a result of thermal analysis, the ECN was written.
2.
Em 13 50 - ne ' QA Applie s, ' ' Seismic Analysis,' and 'NCR Required blocks' were incorrectly marked
'no.' A nonconformance report had been written to cover this incorrect de si gn, i.e.,
NCE 1553. hCR BLNQAB8205 was issued to document corrective action, assigntble cause, and action to prevent recurrence for incorrect application of QA and seismic analysis. No change in equipment design was made, only equipment relocation (i.e.,
level transmitter) resulted from this ECN.
(Conclusion 4 in the Description of Deficiency for Deficiency 2 would apply to this EG.)
3.
Ems 1236,1262,1274,1290, and 1352 were addressed in Deficiency No. 3.
4.
He other nine Ems were determined to have been marked correctly or handled correctly as indicated below.
The audit of 100 Ems identified in the response to deficiency No. 3 was also conducted to determine if there were problems with the marking of cover sheets as discussed in this deficiency. He audit revealed five cases where the ' Seismic Analysis Required' block was incorrectly marked 'No.'
In each of these cases, however, the required analysis was in f act performed, ne audit also revealed nine cases where the 'QA Applies' block was incorrectly marked
'No.'
In each of these cases, however, the QA program was in f act applied to the saf e ty-rela ted changes.
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.o Based on the results of this sampling and the f act that all required steps were perf ormed, it was determined that no additional sampling is nece ssary. To prevent recurrence of this deficiency, BLP has instituted a training program to educate all personnel in the requirements of the engineering procedures with respect to Em review and handling.
This information has been provided to IVA's Office of Quality Assurance and accepted for closure of this deficiency for the Bellefonte Nuclear Plant.
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