ML18033B376
| ML18033B376 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 05/31/1990 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML18033B375 | List: |
| References | |
| NUDOCS 9006210233 | |
| Download: ML18033B376 (14) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION EMPLOYEE CONCERN 20400, "ORGANIZATION OF ENGINEERING PROCEDURES" TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT, UNITS I, 2 AND 3 DOCKET NOS. 50-259, 50-260 AND 50-296 1.0 SUBJECT The Employee Concerns Special Program identified 123 issues'aised by employees in 1985 and early 1986 that involved TVA's organization structure.
Subcategory Report 20400 (Reference I) summarized and evaluated the results of subtier reports concerning this topic.
These subtier reports found that (1) responsibility for nuclear activities was divided among departments that reported to separate managerial structures, (2) design change procedures and procedures to control vendor documents were inadequate or not followed, and (3) design reviews were not timely or thorough.
Reference 1 stated, "If the organizational and procedural changes had not been implemented, the mismatch between the actual plant configuration and the engineering drawings and other documents that support it could have persisted and could have resulted in an engineering design or plant operating error."
2.0
SUMMARY
OF REVIEW The staff had studied the issues and accepted the corrective action program plans for Sequoyah Nuclear Plant (References 2 and 3).
This staff evaluation concerns the adequacy of the corrective action plans and programs for Browns Ferry.
3.0 EVALUATION 204.1 Organizational Structure The concern that TVA's organizational structure was unwieldy was acknowledged and corrected by reorganizing the facets of nuclear power into one office.
The concern there were too many people in the review cycles was investigated by TVA who found it to be consistent with engineering firms in the nuclear industry and TVA concluded the issue was not valid.
The concern that there was too much paperwork and procedures was acknowledged by TVA.
The corrective action was to rewrite and issue engineering procedures in a single volume of Nuclear Engineering Procedures (NEP).
The concern about untimely responses for engineering assistance was unique to construction at Watts Bar and not relevant to Browns Ferry.
The staff found the TVA responses to be acceptable and the corrective actions to be adequate.
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0 204.2 System Design Responsibility The concern was that responsibility and monitoring for overall system design were not assigned to a specific individual who was knowledgeable of all aspects of the system, including interfacing with support systems.
TVA responded to the concerns by issuing the site-specific plant manager' instruction PMI-27.1 "System Cognizance,"
(Reference
- 4) which designated the plant section responsible for cognizance of plant systems.
The system cognizance duties were also defined.
The issue of knowledge scattered among many engineers and thereby affecting quality was not valid according to TVA because documents were routed to all affected engineering disciplines.
The staff reviewed the evaluations and found them to be acceptable.
204.3 Field versus Design Office Responsibility The concern was that TVA left too many technical decisions regarding pipe supports and hangers to craft personnel.
TVA said procedures do not authorize craft personnel to make design decisions and engineering approval of field changes has been required at all TVA nuclear plants.
TVA did not find any design inadequacies caused by craft decisions.
In Sequoyah Nuclear Plant Inspection Reports 50-327/88-10 and 50-328/88-10, the staff noted that the crafts made minor decisions when confronted with ambiguous
- drawings, but the as-built structures were satisfactory.
The corrective action was to strengthen and clarify site specific engineering procedures and provide additional training to prevent a recurrence of this problem.
The staff reviewed the site specific engineering procedures for Browns Ferry (References 5 through
- 13) and found them to be adequate.
204.4 Design Document Completeness/Adequacy The concern that design engineering inadequately addressed and considered construction, testing, operation, maintenance and general industry practices in the design process was not substantiated by TVA.
NSSS activities followed General Electric's procedures and practices.
The balance-of-plant activity followed the non-nuclear practic'es current at the time because nuclear construction methods had not yet developed as a separate practice.
The nuclear organization was fragmented and the experiences of the site were not given to engineering, but it was not found that this led to design deficiencies.
The staff accepts the licensee's response.
The concern that TVA's general construction specifications were inadequate, and drawings did not show the needed details or design requirements was substantiated by the staff on a TVA-wide basis through a review of welding procedures and drawings containing welding details.
The quality of drawings has improved and the Specification Improvement Plan Program is the long term corrective action to replace the general construction specifications.
The corrective actions and plans are acceptable to the staff.
The concern that engineering drawings were inadequate, lacked technical details and design requirements, and caused construction problems was substantiated by TVA.
The corrective actions were the implementation of site
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specific procedures (References 5-13) and the use of the Design Basis and Verification Program (DBVP) to resolve existing design inconsistencies.
The corrective actions are acceptable to the staff.
The concern that there are conflicts between TYA drawings and vendor drawings was verified by TVA.
The corrective action was to implement procedures NEP-6.1 "Change Control" and NEP-9.1 "Corrective Action" (References 14 and 15).
The concern that the design was not developed well enough to be constructible was verified by TVA.
There were instances of calculations being made after issuing the drawings, improper documentation of design, insufficient evaluation of design criteria changes, and criteria not reviewed by NSSS supplier.
The corrective actions were to resolve design deficiencies through the DBVP and implement site specific procedures (References 5-13).
These corrective actions are acceptable to the staff.
204.5 Design Review/Verification The concern that design drawings, technical specifications, design criteria documents and preoperational test packages did not receive a second independent technical review was.not valid.
The concern that second level independent technical reviews performed at Knoxville were inadequate was not valid.
The concern that technical reviews are not performed after the checkers have reviewed pipe support calculations was not valid.
The concern that calculations were not reviewed by technical supervision was not valid.
There is not a regulatory requirement for these second reviews.
The concern that TVA's verification of vendor calculations and reviews of vendor designs were inadequate was not valid.
TVA verifies vendor calculations through procedures NEP-3. 1 "Calculations" and NEP-4.1 "Procurement" (References 16 and
- 17) and reviews design through procedure NEP-5.2 "Review" (Reference 18).
The staff accepts TVA's response.
The concern that TVA does not conduct independent design reviews of its work was not valid.
An example is procedure NEP-3.1, "Calculations,"
(Reference 16).
The staff accepts TVA's response.
The concern that design checks of pipe supports were performed by unqualified people was not valid.
TVA said pipe supports are largely a standardized
- design, and competence is achieved through training and experience as well as education.
The staff accepts TVA's response.
The concern that the design analysis and verification processes were not adequately controlled was verified by TVA.
The corrective actions are to use the DBVP to resolve design deficiencies and to implement site specific procedures (References 5-13).
The staff finds the corrective actions to be acceptable.
The concern that the lack of engineering personnel could cause insufficient reviews of engineering documentation was verified by TVA.
In the original corrective action, one of the functions of Engineering Assurance was to audit
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engineering documentation.
After the 1989 reorganization, this function is being performed by the site design control organization.
The staff finds the corrective action plan to be acceptable.
The concern that people performing documentation review lacked adequate training was verified by.TVA for the years prior to 1984.
TVA said training is conducted on engineering procedures and documented.
The staff finds this corrective action to be acceptable.
The concern that design engineers did not document their original procurement specifications was not verified by TVA.
An Employee Concerns Special Program evaluation team sampled the original procurement specifications from the 1965 to 1968 time period and found the specifications were properly documented.
The staff accepts TVA's response.
204.6 Engineering Change Notice Process The concern that Engineering Change Notices (ECN) are prematurely closed out without knowing 'their status was acknowledged by Browns Ferry.
ECNs were closed at different stages of field implementation of the changes due to the lack of coordination between disciplines within the engineering division and the site organization.
The lack of an adequate tracking and closure procedure also resulted in the untimely closure of ECNs.
Some ECNs have been closed prematurely and others have remained open for long periods of time.
TVA's corrective action was to implement an improved design change control program through the use of the comprehensive Plant Modification Package (PMP) program found in site procedure PI 86-03 (Reference 10).
The staff reviewed engineering change notices and found them in conformance to site procedures.
The concern that the deletion of the checklist on the cover page of ECNs would cause.
a related document or system to be overlooked was not substantiated.
The 9 "yes" or "no" questions on the cover sheets were expanded into a 28 point list of considerations in OEP-11, Attachment 2.
The concern that design change requests were not documented properly was substantiated.
The corrective action has been the implementation of the new site procedures in References 4 through 13.
The staff reviewed design change requests and found them in conformance to site procedures.
The concern that the engineering scope and design activities required for modifications were not adequately identified was an issue of communications between engineering disciplines.
The corrective action has been the implementation of site procedure PI 86-03, Appendix H, "ECN Cover Sheet,"
(Reference 10).
The cover sheet requires a response from all of the engineering disciplines concerning their involvement with the ECN.
The staff reviewed ECN packages and the cover sheet conformed to the contents of the packages.
In addition, PI 86-03 requires a screening review to determine if a safety evaluation is required.
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The concern that an excessive number of ECNs hinders the quality of work by delaying construction activities and causing rework was partially valid.
The number of ECNs exceeded the tracking capability and there were delays due to overlapping ECNs.
However, it was not found that the number of ECNs had affected the quality of the work.
Browns Ferry's corrective action was to implement procedure PI 86-03 (reference
- 10) which requires coordination with engineering to identify any existing change notices, change requests, and Conditions Adverse to guality Reports which impact or are impacted by this ECN.
The staff finds the plan to be prograomatically acceptable.
The concern that ECN data sheets are unnecessarily revised and reissued every time the revision number or issue date of a drawing referenced on the data sheet was changed was not verified.
TVA said that revisions and changes are controlled by site procedures and the staff accepted the response.
204.7 Vendor Documents The concern that the plants did not use the correct revision of the vendor manuals and the quality of the vendor drawings was poor was acknowledged by TVA.
Updated vendor documents were sent to Knoxville or Chattanooga, but were not received at Browns Ferry in a timely manner.
For corrective actions, Browns Ferry Engineering Project (BFEP) Project Instruction PI 87-48 was issued to control restoration of drawings and SDSP-10. 1 (Reference
- 19) was issued to initiate control over vendor manuals.
The staff reviewed vendor drawings and found them to be legible and of a recent revision.
One. spot on one drawing had a hard-to-read computer code, but it was shown through use of the remote display computer in the Control Room to be of no consequence.
The staff reviewed the same drawings in the Technical Support Center and the drawings had the same revision.
The vendor technical and instruction manuals were reviewed and were up-to-date.
One illegible drawing was corrected by making a new copy from the master; the other illegible drawing required a new copy from the vendor.
The staff considers the responses to this issue to be adequate.
204.8 Communication and Interface Control The concern that communication and interface control within Engineering, and between Engineering and other organizations, were ineffective was acknowledged by TVA.
TVA found that the lack of teamwork and communications led to untimely actions, mistrust and duplication of effort.
The corrective actions included a general reorganization to effect uniform control and the use of new and better-written site-specific procedures (References 4 - 13) that conformed to corporate level directives and procedures.
The staff reviewed the completed corrective actions and found them acceptable.
204.9 Use of Reverse Prints The concern was that Watts Bar Unit 1 drawings were marked "opposite hand" and used for Unit 2, making the work confusing for engineering and construction.
TVA said this practice had resulted in construction delays and increased costs
I l'p, pl" at Sequoyah and Bellefonte.
Information was not found to show that this practice had caused problems at Browns Ferry.
The staff reviewed and accepted TVA's response.
The remaining issues in the subcategory report (Reference
- 1) were not relevant to Browns Ferry Nuclear Plant.
4.0 CONCLUSION
Many concerns about deficiencies in the engienering operations were substan-tiated.
The staff found the corrective actions and plans to be acceptable.
5.0 REFERENCES
1.
TVA Empl'oyee Concerns Special Program Report, Volume 2, "Engineering Category,"
Subcategory Part 20400 Revision 3, "Organization of Operating Procedures,"
December 22, 1987.
2.
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5.
Letter from Gary G.
Zech (NRC) to S.
A. White (TVA) dated March 11, 1988 transmitting the preliminary safety evaluations on the Tennessee Valley Authority employee concern elements reports, reference Sequoyah Nuclear Plant, Unit 2.
Letter from Suzanne C. Black (NRC) to S. A. White (TVA) dated November 4, 1988 transmitting the safety evaluations of the Tennessee Valley Authority employee concerns element reports for Sequoyah Nuclear Plant, Units 1 and 2.
Browns Ferry Nuclear Plant, Plant Manager's Instruction PMI-27.1 Revision 0 dated October 7, 1988, "System Cognizance" Browns Ferry Nuclear Plant Site Director Standard Practice SDSP-8.1 Revision 7 dated April 18, 1988, "Plant Modification/Design Change Approval" 6.
Browns Ferry Nuclear Plant Site Director Standard Practice SDSP-8.4 Revision 11 dated October 6, 1988, "Modification Work Plans" 7.
Browns Ferry Nuclear Plant Site Director Standard Practice SDSP-8.10 Revision 3 dated October 22, 1988, "Plant Review of ECN/DCN" 8.
Browns Ferry Nuclear Plant Site Director Standard Practice SDSP-8.11 Revision 2 dated September 28,
- 1988, "Design Change Notice" 9.
Browns Ferry Nuclear Plant Site Director Standard Practice SDSP-8.12 Revision 1 dated September 28, 1988, "Plant Modifications Overall Process" 10.
Browns Ferry Engineering Project (BFEP) Project Instruction PI 86-03 Revision 6 dated July 29, 1988, "Preparation and Control of Engineering Change Notice Modification Package"
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Browns Ferry Engineering Project (BFEP) Project Instruction PI 87-41 Revision 2 dated April 22,
- 1988, "Design Change Notice" 12.
Browns Ferry Engineering Project (BFEP) Project Instruction PI 87-86 Revision 0 dated February 19, 1988, "Administrative Handling of Field Change Requests" 13.
Browns Ferry Engineering Project (BFEP) Project Instruction PI 88-04 Revision 3 dated October 4, 1988, "Change Document Closure" 14.
TVA Nuclear Engineering Procedure NEP-6. 1 Revision 0 dated July 1, 1986, "Change Control" 15.
TVA Nuclear Engineering Procedure NEP-9.1 Revision I, dated February 20, 1987, "Corrective Action" 16.
TVA Nuclear Engineering Procedure NEP-3. 1 Revision 0 dated July 1, 1986, "Calculations" 17.
TVA Nuclear Engineering Procedure NEP-4. 1 Revision 0 dated July 1, 1986, "Procurement" t
18.
TVA Nuclear Engineering Procedure NEP-5.2 Revision 0 dated July 1, 1986, "Review" 19.
Browns Ferry Nuclear Plant Site Director Standard Practice SDSP-10.1 Revision 2 dated October 20, 1988, "Vendor Manual Control Program"
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