ML20213A596

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)

See also: IR 05000259/1987008

Text

<

-

.

UNITED STATES

[pK4 . 'o NUCLEAR REGULATORY COMMISSION

[I ,, REGION 11

101 MARIETTA STREET,N.W.

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

7

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 matters.

Results: One violation was identified. This violation was applicable to

Unit 2 only.

%[2$bo

,

G

i

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

. -. - -. . . .

.

-

i

>

1

4.

,

a

REPORT DETAILS

,

G

'

1. Persons Contacted

License : E.moloyees

j. *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.

1

I

NRC Resident Inspectors

*G. Paulk

• C. Brooks

4 *C. Patterson

' Attended exit interview

2. Exit Interview

i 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.

.

~

l.

i

'

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

r-

.

2

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

l

l

i

l

!

!

I

! l

l

!

.

-

3

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

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 startup.

-- y. +- -,y _ _ _ . , , ,

_

.

~

4

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

,

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 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, 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

.

.

'

5

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

(

,

,

.-

6

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.

. -- . _ .

.- . - - _ - .