ML20213A596
| ML20213A596 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 03/27/1987 |
| From: | Belisle G, Wright R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20213A578 | List: |
| References | |
| 50-259-87-08, 50-259-87-8, 50-260-87-08, 50-260-87-8, 50-296-87-08, 50-296-87-8, NUDOCS 8704280090 | |
| Download: ML20213A596 (7) | |
See also: IR 05000259/1987008
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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REGION 11
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101 MARIETTA STREET,N.W.
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ATLANTA. GEORGI A 30323
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Report Nos.: 50-259/87-08, 260/87-08, 50-296/87-08
Licensee: Tennessee Valley Authority
6N 38A Lookout Place
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1101 Market Street
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Chattanooga, TN 37402-2801
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Docket Nos.:
50-259, 50-260 and 50-296
License Nos.:
and DPR-68'
Facility Name:
Browns Ferry 1, 2, and 3
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Inspection Conducted:
February 9-13 and 17-20,'1987
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Inspector:
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D'te Signed
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R. W. Wright
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Approved by:
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G. A.-Belisle M bief
Date' Signed
Quality Assurance Programs Section
Division of Reactor Safety
SUMMARY
Scope:
This routine, unannounced inspection was in the areas of design
control, modifications, procurement, and licensee action on previous enforce-
ment matters.
Results:
One violation was identified.
This violation was applicable to
Unit 2 only.
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REPORT DETAILS
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1.
Persons Contacted
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License : E.moloyees
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- P. Becknell, Mechanical Maintenance Group Supervisor-
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-T. Brothers, Assistant Project Engineer (Civil), Division of
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Nuclear Engineering (DNE)'
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- P. Carier, Compliance Licensing Manager 1
- T. Cosby, Unit 1 Superintendent
D.-Coston, Quality Control Supervisorf
R. Davis, Compliance Licensing
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- R. Erickson,-Plant Operations Review Section
- R.-Lewis, Plant Manager
- M. .May, Site Licensing Manager
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- C. McFall, Compliance Licensing
D. Mims, Technical Support Supervisor
- B. Morris, Compliance Licensing
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- J. Norris, Quality Engineering and Control Supervisor
L. Parvin, Quality Engineering
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- W. Pratt, Maintenance Technical Section
- J. Savage, Compliance Licensing
T. Smith, Mechanical Maintenance Technical Section
J. Smithason, Modifications Branch
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- J. Swindell, Unit 3 Superintendent
- W. Thomison, Technical Services Supervisor
G. Turner, Site Quality Manager
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C. Wages, Assistant to Maintenance Superintendent
J. Walker, Quality Engineering Supervisor
J. Woodward, Mechanical Maintenance Technical Section
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Other licensee employees contacted included craftsmen, engineers,
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technicians, and office personnel.
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NRC Resident Inspectors
- G. Paulk
- C. Brooks
- C. Patterson
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' Attended exit interview
2.
Exit Interview
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The inspection scope and findings were summarized on . February 20, 1987,
with those persons indicated in paragraph 1 above.
The inspector
described the areas inspected and discussed in detail the inspection
findings.
No dissenting comments were received from the licensee.
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Violation, Failure to follow Instruction PMI-8.2 in that the Assistant
Plant Manager performed the technical review of Engineering Change
Notice (ECN) P-0859 rather than -the cognizant system engineer, and
the Unit 2 Shift Engineer's ECN files did not contain required
documentation pertinent to ECN P-0859, paragraph 6.b.
The licensee did not identify as proprietary any of the materials provided
to or reviewed by the inspector during this inspection.
3.
Licensee Action on Previous Enforcement Matters (92701)
(Closed) Unresolved Item 259/84-24-03:
Improper Material Used in the
Unit 1 Reactor Head Vent Piping (Feedwater System)
In accordance with Browns Ferry (BF) Standard Practice 16.5, the improper
material was identified as nonconforming and two safety evaluations
(NEB 840626-218 and NEB 840514-224) were performed on this matter by
Engineering Design.
The inspector examined the pertinent Corrective
Action Report (CAR) #BF 84-027, the cause of the deficiencies, corrective
actions taken, the actions taken to prevent recurrence and the previously
mentioned safety evaluations that permitted continued operations of
the unit.
Quality Survey SP-24-QAS-84-284, which was conducted by the
site to assure this was an isolated case, was also examined by the
inspector.
Review of the above supporting documentation and discussions
with responsible licensee representatives confirmed that this item was
dispositioned properly by the licensee and is therefore closed.
4.
Unresolved Items
Unresolved items were not identified during this inspection.
5.
Reactor Water Cleanup (RWCU) System 69 (35065)
The inspector conducted discussions with the maintenance engineer
concerning post operating history and the current status of the redesigned
RWCU pumps and associated piping. General Electric (GE) Service Informa-
tion Letter (SIL) No. 258 identifies frequent failures experienced by
Ingersoll Rand (I/R) pumps used in the high pressure RWCU system on
operating boiling water reactors (BWRs).
This letter also contains
recommended actions to be taken for modifications and maintenance
applications for these pumps and states that GE was continuing to evaluate
different pump designs for possible replacement of the RWCU pumps.
The
inspector examined the I/R Purchase Requisition No. 839152 to design,
furnish, sell, and deliver eight RWCU pump pullout units and associated
equipment for their complete modification and restoration in accordance
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with the attached GE Specification 21A1187 (Contract Nos. 90744 and
91750). GE -Specification 21A1187, Section 4, Codes, specifies that all
parts of the pump, associated equipment and interconnecting piping subject
to reactor water pressure shall be designed, constructed and tested in
accordance with the applicable Sections of the Standards of the Hydraulic-
Institute, ASME Boiler and Pressure Vessel Code-Section III-Class C, and
the Code for Pressure Piping (USASI 31.1). A code stamp is not required.
Although classified as noncritical equipment (reference BF Standard
Procedure 1.11) the subject RWCU pump procurement documents received QA
Level I requirements. This includes a review by the Contract Engineering
Group for applicable administrative, technical and QA requirements and
separate reviews by Equipment Qualification and QA personnel.
It appears
that the modification work to be performed on the subject pumps will be
accomplished with quality materials required by vendor specifications.
6.
Design Control (37055, 35060)
a.
Use of Temporary Alteration Control Forms (TACFs)-
Plant Manager Instruction (PMI) 8.1, R0, Temporary Alterations, was
given a cursory review against the requirements of Nuclear Quality
Assurance Manual (NQAM) Part II, Section 6.4, Control of Temporary
Alterations and found adequate for implementing the upper-tier
requirements.
The inspector examined the following Nuclear Quality and Evaluation
Branch audits and Browns Ferry surveillances that were conducted on
the Temporary Alterations program for the extent of scope and depth
covered, to determine that findings were reported to upper management
and the audited organization, that corrective actions as reported are
being initiated, and that there is followup and re-audit by QA as
necessary.
Audit / Surveillance
Dat9 Performed
QBF-A-85-004
1/21/85 - 3/6/85
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QBF-S-86-0063
4/14/86 - 5/2/86
QBF-S-86-0109
7/31/86 - 8/31/86
The inspector conducted discussions with the Technical Support
Services Supervisor (TSS) concerning the status of open Browns Ferry
Nuclear Plant (BFN) TACFs and examined a copy of the latest
Semi-Annual Update on TACFs dated February 9, 1987. As of January 29,
1987, there were a total of 391 TACFs still open, but of this total,
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257 TACFs have fixed milestones for removal or design change
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requests / engineering change notices initiated for resolution. The
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TSS supervisor is working with DNE to review ar.d resolve outstanding
Unit 2 and common system TACFs prior to startup.
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The inspector conducted discussions with BFN health physicists,
technical support and maintenance personnel concerning the chronology
behind a contamination problem that developed in the noncritical
(BF 1.11,
Part II, Appendix A) Plant Service Air System.
The
inspector examined the following related TACFs and documentation
initiated to isolate the Radwaste Service Air from the Plant Service
Air System:
Date
PORC Review
Work
DCR D-3232
TACF #
TACF Written
of USQD
Done
Prepared
0-84-110-33
10/23/84
10/30/84
12/20/84 10/02/85
0-84-99-33
09/19/84
09/21/84
10/03/84 10/02/85
0-84-100-33
09/18/84
09/21/84
10/03/84 10/02/85
0-84-94-77
09/13/84
09/14/84
09/17/84 10/02/85
As noted above the TACFs were in effect for more than 60 days
(approximately one year) which is contrary to the BFN procedures to
return the alterations to normal or to issue and process a design
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change request within the prescribed time period. A violation is not
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warranted in this case, since the plant Service Air System is
classified as a noncritical system.
Although not a safety-related issue, this TACF example illustrates
how previous temporary plant alterations have quite often become
permanent plant modifications and have resulted in weaknesses
in documenting such, and weaknesses in maintaining up-to-date
consistency between "as-configured" and "as-designed information."
Browns Ferry Standard Practice (BFSP) 8.3, R8, Plant Modifications,
defines a modification as a planned change in plant design or
specific operational requirement.
The final solution,
i.e.,
the
isolation of the radwaste service air (and adding compressors etc.)
from the main plant service air system constitutes a change in plant
design.
Discussions with licensee personnel revealed that the plant
had originally intended to find the source of contamination, isolate
and remove it and restore the plant air system to its original
configuration thus meeting the temporary alteration criteria.
However, the problem escalated and things did not workout as
originally intended.
Plant management can technically initiate any change they wish for
60 days under a TACF provided they perform an Unreviewed Safety
Question Determination (USQD) of the item.
Because of this fact,
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and the lack of timely engineering assistance received from DNE
(formally Office of Engineering) in handling design changes, this
promoted the abuse of the TACF system in the past.
Because TACFs
are closely monitored and restricted now, there is no reason to
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believe conditions may revert to the past once Browns Ferry becomes
operational. PMI 8.1, requires the Plant Operations Review Committee
(PORC) to review all plant procedures that will install temporary
alterations, to review TACFs prior to installation for normal
temporary alterations, and to review by the next regular work day
temporary alterations installed during an emergency. DRE now has
offices on site but is not represented in PORC.
DNE has the exten-
sive knowledge of the plant's original design bases but is not
involved in impact considerations nor approval of TACFs prior to
their implementation.
TVA has made several recent committments to upgrade the Sequoyah
Nuclear Plant (SNP) TACF program, one of which is DNE safety
evaluation of all future safety-related TACFs before implementation.
TVA's management should explore the possibility of having similar
controls including DNE's review of TACFs prior to implementation at
Browns Ferry.
b.
Engineering Change Notice (ECN) Controls
The inspector selected ECN P-0859 (Modification to the Control Rod
Drive insert and withdrawal pipe supports to meet seismic require-
ments for the system) which is one of numerous ECNs listed in Browns
Ferry Nuclear Performance Plan, Volume 3, scheduled to be implemented
during the current outage for review.
Examination of the handling
and processing of the subject ECN's documentation resulted in a few
discrepancies being identified with the implementation requirements
contained in PMI-8.2, Plant Design Change Review.
The inspector's review of a copy of the subject ECN package revealed
that on July 15, 1986, the Assistant Plant Manager rather than the
Cognizant / System Engineer signed for the technical review of this ECN
which was contrary to PMI-8.2, R0 in effect at that time.
On February 11, 1987, the inspector, accompanied by a BFN Compliance
Licensing representative, went to the Unit 2 Shift Engineer's office
to inquire about the work status and to examine pertinent documenta-
tion concerning this ECN. The Shift Engineer's files were found to
contain several ECN packages; however, an approved ECN P-0859 package
could not be located.
PMI-8.2, R1, Section 4.4, states that "after
review by PORC and approval by the Plant Manager, a copy of the
ECN package with USQD will be submitted to the Shift Engineer for
information. The Shift Engineer will maintain a file containing the
signed PMI-2 forms (ECN review forms), the PMI-3 forms (a status
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of work in process forms) and other pertinent information deemed
necessary."
Section 4.4 further states, "the Shift Engineer will
document the approval to work the specific Work Plan and Inspection
Reports (WP & irs) associated with an approved ECN on a WP & IR Work
In Progress Form (Form PMI-3)." Modification work was supposed to be
underway for this system, yet none of the above documentation could
be located in the Shift Engineer's office.
These examples were
identified as Violation 260/87-08-01, Failure To Follow Instruction
PMI-8.2.
BFN Discrepancy Report No. BR-DR-87-0081 was initiated by
the licensee prior to the inspector leaving the site. BFN personnel
were taking immediate corrective action to resolve the problem.
The inspector conducted discussions with Quality Engineering
personnel responsible for reviewing WP & irs in accordance with
Quality Manager Instruction (QMI) 605.6, R0.
This instruction
appears to provide an excellent review for acceptability of WP & irs
prior to their PORC approval.
7.
Procurement (35065, 35060)
The inspector examined existing site procurement procedures and had
discussions with the Power Stores Manager concerning this program.
The
inspector examined several of the most recent QA surveillances performed
and resulting findings found in the procurement area. Program implemen-
tation will be reviewed during additional inspections.
Within this area, no violations or deviations were identified.
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