IR 05000259/1987008

Insp Repts 50-259/87-08,50-260/87-08 & 50-296/87-08 on 870209-13 & 17-20.Violations Noted:Assistant Plant Manager Signed for Review of Engineering Change Notice P-0859 Instead of Cognizant Sys Engineer

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: ML20213A576 ML20213A580 ML20213A596
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)

Text

<

-

.

UNITED STATES

[pK4 . 'o NUCLEAR REGULATORY COMMISSION

[I ,, REGION 11 101 MARIETTA STREET, g j

• g ATLANTA. GEORGI A 30323 e ,e

',

.

.....*

'

Report Nos.: 50-259/87-08, 260/87-08, 50-296/87-08 Licensee: Tennessee Valley Authority 6N 38A Lookout Place '

1101 Market Street '

Chattanooga, TN 37402-2801 -

~

Docket Nos.: 50-259, 50-260 and 50-296 License Nos.: DPR-33, DPR-52, and DPR-68'

Facility Name: Browns Ferry 1, 2, and 3 _

,

Inspection Conducted: February 9-13 and 17-20,'1987 ,

Inspector: [#Fudf]c'

.2 7 D'te Signed

R. W. Wright , /  ?

Approved by: .c J 7[f 7 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 matter Results: One violation was identifie This violation was applicable to Unit 2 onl %[2$bo

,

G i

_ , -- . _ , , , - - . . _ ..,,.--,m - . - _ , - , , . . , - . - ,_ - . - - - , - - , . . _ - - ,

. -. - -. . . .

.

-

i

>

1 ,

a REPORT DETAILS

,

G

' Persons Contacted License : E.moloyees *P. Becknell, Mechanical Maintenance Group Supervisor- ,

. -T. Brothers, Assistant Project Engineer (Civil), Division of

, Nuclear Engineering (DNE)'

*P. Carier, Compliance Licensing Manager 1

• T. Cosby, Unit 1 Superintendent D.-Coston, Quality Control Supervisorf

, R. Davis, Compliance Licensing i *R. Erickson,-Plant Operations Review Section

• R.-Lewis, Plant Manager

*M. .May, Site Licensing Manager i *C. McFall, Compliance Licensing D. Mims, Technical Support Supervisor

• B. Morris, Compliance Licensing l *J. Norris, Quality Engineering and Control Supervisor j L. Parvin, Quality Engineering i *W. Pratt, Maintenance Technical Section

*J. Savage, Compliance Licensing

T. Smith, Mechanical Maintenance Technical Section

'

J. Smithason, Modifications Branch <

• J. Swindell, Unit 3 Superintendent

• W. Thomison, Technical Services Supervisor

'

G. Turner, Site Quality Manager C. Wages, Assistant to Maintenance Superintendent J. Walker, Quality Engineering Supervisor J. Woodward, Mechanical Maintenance Technical Section i

i Other licensee employees contacted included craftsmen, engineers, j technicians, and office personnel.

I NRC Resident Inspectors

*G. Paulk

• C. Brooks 4 *C. Patterson

' Attended exit interview Exit Interview i The inspection scope and findings were summarized on . February 20, 1987, with those persons indicated in paragraph 1 abov The inspector described the areas inspected and discussed in detail the inspection

findings. No dissenting comments were received from the licensee.

.

~

l.

i

'

- _ _ _ _ . _ _ - __ _ . - - , _ _ . - - _ . , _ . _ . . _ . - _ _ _ _ . _ . _ _

r-

.

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 The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspectio . 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 uni 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 inspecto 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 close . Unresolved Items Unresolved items were not identified during this inspectio . 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 l

l i

l

!

!

I

! l l

!

.

-

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 require 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 specification . Design Control (37055, 35060) 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 requirement 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 necessar Audit / Surveillance Dat9 Performed

,

QBF-A-85-004 1/21/85 - 3/6/85 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,

!

257 TACFs have fixed milestones for removal or design change i requests / engineering change notices initiated for resolution. The l TSS supervisor is working with DNE to review ar.d resolve outstanding Unit 2 and common system TACFs prior to startu +- -,y _ _ _ . , , ,

_

.

~

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 Syste 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

,

change request within the prescribed time period. A violation is not I warranted in this case, since the plant Service Air System is classified as a noncritical syste 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 requiremen 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 criteri However, the problem escalated and things did not workout as originally intende 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, 1 and the lack of timely engineering assistance received from DNE I (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

.

.

'

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 implementatio 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 implementatio TVA's management should explore the possibility of having similar controls including DNE's review of TACFs prior to implementation at Browns Ferr 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 revie 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 Revie 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 tim 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 (

,

,

.-

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 offic These examples were identified as Violation 260/87-08-01, Failure To Follow Instruction PMI- 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 proble 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. 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 inspection Within this area, no violations or deviations were identifie . -- . _ .

.- . - - _ - .