ML18033B384
| ML18033B384 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 05/31/1990 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML18033B375 | List: |
| References | |
| NUDOCS 9006210248 | |
| Download: ML18033B384 (56) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 SAFETY EVALUATION REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION EMPLOYEE CONCERN SUBCATEGORY REPORT NO. 30100 MECHANICAL E UIPMENT RELIABILITYDESIGN TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR POWER PLANT UNITS 1
2 and 3 DOCKET NOS: 50-259 50-260 AND 50-296 1.0 STATEMENT OF EMPLOYEE CONCERN SUBCATEGORY REPORT 30100 Description The concerns that comprise this subcategory are characterized by hardware deficiencies including issues concerning reliability and design of mechanical equipment such as valves, diesel generators piping, heat exchangers, steam generator
- manways, and fire doors.
Detailed description of the concerns can be found in Section V of the Technical Evaluation Report (TER).
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2.0
SUMMARY
OF ISSUES The issues addressed in this Safety Evaluation Report (SER) for the Browns Ferry Nuclear Power Plant (BFN) are in the mechanical equipment design, installation, operation, maintenance, and reliability of mechanical components.
This report addresses 44 issues categorized in the following 16 element sections:
Element No.
301.01 301.02 301.03 301.04 301.05 301.06 301.07 301.08 301.09 301.10 301.11 301.12 301.13 301.14 301.15 301.16 Kerotest Valve Leakage/Corrosion Diesel Generator Reliability Problems Vibration Problems Noted Retubing Problems (Heat Exchangers) guestionable Design/Const.
Practices Hardware Selection guestionable General Paint Concern, Rx Bldg.
Steam Gen.
Manway Installation (ALARA)
Socket Wrench Dropped into Unit 1 Turbine Spent Fuel Racks Problem Valve Closure Problem Improper Operation of System 31 guestionable Activities/Operational Problems MIalfunction of Doors Improper Hardware Identification Health 5 Safety Concerns 9006210248 900531 PDR ADOCN, 05000258)
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3.0 EVALUATION The NRC consultant, Parameter, Inc. has reviewed the subcategory report 30100 and has prepared the attached TER.
Those issues found to be similar in content were combined into a single element for review.
A collective assessment of these findings reflected adversely on corporate management effectiveness in overseeing and coordinating activities at BFN.
There had been a lack of corporate control over the implementation of the design/construction standards and requirements into the operational activities at BFN relative to the integrity and maintenance of paint in containment.
Also, there had been a
lack of corporate guidance in the maintenance and performance testing of diesel generators.
A lack of centralized control of component identification contributed to missing/incorrect equipment tags and to drawings and data base deficiencies.
Mhere corrective action has been warranted, the staff's acceptance is based upon satisfactory fulfillment of all commitments as described in the TVA corrective action plans.
In. some cases NRC inspection of the DBVP are acceptable verification of satisfactory completion of required corrective actions.
The staff has reviewed the TER and concurs in its bases and findings.
- 4. 0 CONCLUSIONS Based on the staff review of the attached TER relating to the employee concerns as described in subcategory report 30100 for BFN, the staff concludes that TVA has adequately addressed the issues.
Of the 44 issues identified in the report 28 issues were substantiated.
The staff finds that their conclusions and corrective actions are acceptable.
It is the responsibility of TYA to assure that implementation of corrective actions will be performed in keeping with the corrective action plans.
Any additional program changes should be submitted for staff evaluation and should not be implemented prior to review and approval by the staff.
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TECHNICAL EVALUATION REPORT EMPLOYEE CONCERNS PROGRAM TENNESSEE VALLEY AUTHORITY BROWN'S FERRY NUCLEAR POWER PLANTS UNITS 1 2
AND 3 OPERATIONS CATEGORY 30000 SUBCATEGORY REPORT 30100 MECHANICAL EQUIPMENT RELIABILITY/DESIGN I.
INTRODUCTION The issues addressed in this Technical Evaluation Report concern perceived problems with mechanical equipment
- design, installation, operation and maintenance, and the consequent reliability of the mechanical equipment at Brown's Ferry Nuclear (BFN) Plants, Units 1, 2 and 3.
II.
SUBJECT In Subcategory Report 30100 the employee concerns address 44 issues which are divided into 16 elements for evaluation.
These concerns and issues involve diverse plant equipment such as
- valves, diesel generators,
- piping, heat exchangers, fire
- doors, motors, paint, switches, indicators, fittings, spent fuel racks and freight elevators.
The concerns were at times directed specifically to BFN or other individual TVA nuclear plants and sometimes voiced as generic to all the TVA nuclear plants.
The TVA assessment of the substantiated concerns considered the specific effects and also the generic aspects affecting the BFN plant.
Subcategory Report 30100 presents the details of each issue, with reference to each applicable employee
- concern, and gives results of TVA's investigation and evaluation of each issue.
The root causes of problems are stated, along with TVA's evaluation of collective significance for all the issues included in the Subcategory Report.
Corrective action that has been taken is addressed both specific to substantiated issues
- and, where applicable, to the broad-based plant-wide corrective actions taken to resolve generic issues.
III.
SUMMARY
OF ISSUES The 44 issues regarding BFN mechanical equipment reliability included 28 that were substantiated upon evaluation;
'23 of these require corrective action.
Three of these issues identify problems of broad scope at BFN, and coincide with similar problems at other TVA nuclear plants.
They are being addressed by corporate-wide corrective actions.
These three issues, diesel generator reliability (Element No. 301.02) containment paint coating
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integrity (Element No.
301.07) and hardware identification (Element No.
301.15) are recognized as adversely reflecting on corporate management effectiveness.
- Thus, these issues.
on mechanical equipment x'eliability are part of the stimulus for the development of the TVA Corporate Nuclear Performance Plan (CNPP) and the Brown's Ferry Nuclear Performance Plan (BFNPP).
'hree other issues address problems on specific systems or components; instances of valve corrosion '(Element No. 301.01),
excessive pipe vibration (Element No. 301.03),
and spent fuel racks workmanship (Element No.
301.10).
These are cases of inadequate mechanical equipment design, procurement and installation, and ineffective quality assurance oversight.
Corrective actions described within the CNPP and BFNPP encompass prevention of occurrence or recurrence of these types of problems on BFN mechanical equipment.
The remaining 22 substantiated issues (Element Nos.
301.04, 301.05, 301.06, 301.08, 301.09, 301.11, 301.12, 301.13, 301.14 and 301.16) covered in subcategory report
- 30100, such as incidents of dropped
- hardware, repair operation
- controls, stopped floor drains, valve and pipe
- leakage, area
- heating, and switch mounting have been determined as isolated, non-generic discrepancies.
The corrective actions thus apply to localized hardware repair or procedure correction and to admonition and retraining of responsible craftsmen/technicians working in that section of the plant.
Six root cause conditions are recognized as contributing to the mechanical equipment reliability issues:
TVA has initiated extensive corrective
- actions, including those embodied in the aforementioned CNPP and BFNPP, to eradicate the lax conditions that contributed to the formation of these problems.
The Evaluation section of this report includes analysis of the issue; classification of the effects on plant safety; assessment of the adequacy of the root cause assignment; determination of the adequacy of the prescribed corrective action; and evaluation of the completed corrective action where it has been performed and reported.
IV.
ELEMENT ISSUE EVALUATION PROCESS The element/issue review process consisted of six steps as listed 1.
Review of the issues in each element, both specifically as stated by the employee and in the broad context of TVA nuclear power plant design, installation, maintenance and operation history.
2.
Review of regulatory documents, industry standards, BFN FSAR, TVA Nuclear Quality Assurance Manual (NQAM), other TVA commitments, and design basis documents.
[See Attachment A Reference List, items No.
1 and 2)
C 3.
Review of TVA documents relevant to the
- issue, including contents of Subcategory Report 30100 and associated Corrective Action Tracking Documents (CATD's).
These documents are cited within the text of this report.
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Review of TVA documents containing generic corgective action commitments, including the Corporate Nuclear Performance Plan (CNPP),
the Brown's Ferry Nuclear Performance Plan (BFNPP) and other TVA verification and improvement programs such as the Design Baseline and Verification
'Program (DBVP),
the Surveillance Improvement Program (SIP),
the Maintenance Improvement Program (MIP), and the Preventive Maintenance Program Upgrade Project (PMPUP) fSee Attachment A Reference List, items No. 3, 5, 7, 10, ll, and 12) 5.
Review of NRC SER's pertinent to BFN performance improvement commitments, such as NUREG-1232 Vol. 1, July 1987 and NUREG-1232 Vol. 3, April 1989.
6.
Review of oversight actions of TVA's implementation, including NRC reports on Inspection reports, NRC's Master Inspection Safety System Functional Inspection (SSFI)
Attachment A Reference List, items No. 8, 9, corrective action plans and DBVP
- reviews, NRC Resident Program (Restart),
and the performed May-July 1988.
[See 13, 14, 15, 16 and 17]
V.
EVALUATION This Technical Evaluation Report utilizes a
parallel format to that of Subcategory Report 30100 where related issues are grouped together for analysis into 16 discrete elements.
The evaluation is based upon a review of TVA's investigations and evaluations, and documented corrective actions taken to resolve the substantiated
- issues, including corrective actions described in the Subcategory
- Report, the
- CNPP, the BFNPP and relevant Corrective Action Tracking Documents (CATD's).
Information from NRC inspection reports giving results of NRC review of TVA's Design Baseline and Verification Program (DBVP) implementation, and NRC field inspector overviews of actual hardware conditions and operations/maintenance activities on site are also used as a
basis for this evaluation.
The results of the TVA/contractor Safety System Functional Inspection (SSFI) conducted at BFN in May-July 1988, and consequent Condition Adverse to Quality Reports (CAQR's) also provided insight on the condition and present reliability of BFN mechanical equipment.
The 16 sections which discuss the evaluation of each element are numbered consistently with the element descriptions as given in Subcategory Report 30100.
Element 301.01
- Kerotest Valve Leaka e and Corrosion Issue 301.01-1
- Kerotest Valve Corrosion Leaka e
and Seatin Problems EX-85-085-003 XX-85-090-001 XX-85-090-002 QCP 10.35-8-9 QCP 10.35-8-21 IN-85-594-001 IN-85-86-285-001
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Concerns voiced at BLN, SQN and WBN alleged that Kerotest valves at Watts Bar Nuclear Plant (WBN) had corrosion,
- leakage, and seating problems due to inadequate drying of the valves after the vendor's hydrostatic tests.
One concerned individual (CI) believed that 30 of the valves had been inspected
" at WBN with a
90 percent rejection rate.
The CIs requested that Kerotest valves at Bellefonte Nuclear Plant (BLN) and Sequoyah Nuclear Plant (SQN) be checked for similar problems.
Evaluation of the Issue within Element 301.01 TVA considered the issue as substantiated, but non-safety-related because operation of the Kerotest valves installed in safety-related systems is not required for safe shutdown of the plant.
- However, TVA appropriately considered this issue as generic with effect on efficient plant operation, and revised valve standard specifications to require cleaning and drying of valve internals after hydrostatic tests.
TVA made a review of the performance of Kerotest valves used by BFN; this review found proper controls on procurement,
- storage, installation, maintenance and operation of Kerotest
- valves, since corrective action had previously been instituted at BFN to alleviate the problem and preyent recurrence.
The work had been done in response to CATD-30101-BFN-01, and included issuance of specifications MEB-SS-10.18 and MEB-SS-10.19 on Feb.
12, 1981 to supplement contracts for valve purchases, including Kerotest valves.
History of performance of Kerotest valves at BFN as reported by maintenance engineers has been
- good, with no failures attributable to corrosion and leakage.
Preventive maintenance
- activity, operations walkdowns and TVA QA surveillance as performed routinely are considered adequate control measures for future prompt interception of this type of problem should it occur.
Conclusion to Element 301.01 Evaluation TVA evaluation and action to resolve this issue is appropriate, comprehensive and complete, including correction of root causes, and is acceptable'lement 301.02
- Diesel Generator D
G Reliabilit Problems Issue 301:02-1 D
G Reliabilit WI-85-100-003 XX-95-122-003 IN-85-323-001 XX-85-122-009 XX-85-122-010 CIs (at all sites) believed that diesel generators at all TVA nuclear plants had reliability problems requiring a]
establishment of a
reliabil'ity program, b]
reduction in the number of starts done for
- testing, c]
upgrading of preventive maintenance, and d] more interaction with the Institute of Nuclear Power Operations (INFO),
vendors and other utilities'
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Evaluation of Issue 301.02-1 TVA considered the issue as substantiated and safety-related.
TVA said that NUREG CR-0660 provisions for increasing reliability of diesel generators (DG) had not been incorporated into BFN procedures and practices.
One of the corrective actions was to initiate changing the air start piping to stainless steel and installing ait dryers.
BFN responded to NRC notices of violation on DGs with a revised Mechanical Maintenance Instruction MMI-6 (adding prelube and prewarm, eliminating running unloaded, and emphasizing cleanliness of DG surrounding areas to provide clean air intake),
a completed engine rebuilding program, repair of battery racks, and addition of Emergency Raw Cooling Mater (ERCM) throttling valves on the cooling water heat exchangers.
Another improvement noted in the Browns Ferry Nuclear Performance Plan was the installation of a solid state diesel generator speed sensor.
Maintenance work was tracked by CATD-30100-NPS-01.
Documenting DG starts,
- failures, and out-of-service time began in 1986.
These specific modifications and improved maintenance practices will enhance DG reliability.
- However, SSFI Report No.
BFA 88811 noted a test of the DGs where the throttle valves were full open and did not reduce cooling water pressure as required.
Deficiency BF MAP-2 describes the event, and resolution is being tracked by Design Basis Punch List item 2-1313.
Reducing the number of test starts as suggested in an employee concern is not allowed, since an increased number of test starts following surveillance test failures is a Technical Specification requirement.
However, the physical improvements to DGs at BFN and the improved maintenance should contribute to fewer surveillance test failures and test starts and result in acceptable availability factors.
SSFI Report No.
BFA 88811 identified weaknesses in the dynamic load study of the BFN.diesel generators.
In Problem Identification Report BFN-EEB-8820, TVA decided to qualify BFN DGs by test alone and not use the dynamic load study.
NRC Inspection Report 50-259/260/296/88-02 included an NRC overview of the BFN Maintenance Improvement Plan, commenting on minor flaws and noting overall progress.
NRC Inspection Report 50-259/260/296/88-10 examined the restart test program, including testing of diesel generators.
The BFN Diesel Generator Evaluation Report (Reference
- 1) demonstrated the BFN DG capability to start, accelerate and sustain required loads, and was indicative of the DG mechanical capability to function as designed.
This report was evaluated by the staff (Reference
- 2) and found adequate except for the EDG A steady-state overload condition.
TVA submitted an amendment to the technical specifications (Reference
- 3) on January 31, 1990 to provide for managing steady-state overloads.
,This issue wi1'l be resolved by the staff as part of the review of technical specifications prior to restart.
These on-.site activities show that the controls put into effect for start-up and surveillance provide proper monitoring of diesel generator equipment performance reIiability.
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Issue 301.02-2
- Diesel Fuel S ill IN-85-097-012 One CI at WBN called for corrective action to prevent recurrence of an incident at WBN in which Diesel Fuel Storage Tanks had been overfilled.
Issue 301.02-3 False Alarms on D
G Bearin and Stator Tem erature Recorder WBN-85-01 A CI at WBN thought there had been false alarms on the Diesel Generator Bearing and Stator Temperature Recorder.
Issue 301.02-4 D
G AC Lubricatin Oil Pum Tri s MAS-85-001 A
CI at SQN alleged that the Diesel Generator AC lubricating oil pump was tripping possibly because of gasket material in the pump.
Evaluation of Issues 301.02-2
-3
'and -4 TVA evaluation of the three other issues within Element 301.02, Nos.
301.02-2,
-3, and
-4, found them substantiated and specific to WBN and SQN sites.
Actions taken at BFN regarding improving the maintenance of diesel generators properly encompass such issues as these.
Conclusion to Issues 301.02-2
-3 and -4 The TUA evaluation and disposition of these issues for BFN is acceptable.
Evaluation of Element 301.02 Item 301.02-1 contains the significant issue, far outweighing the other three issues within this element.
The TVA recognition of the validity of this issue is evident in the extensive actions taken to get at and remedy root causes of the problem.
Subsequent overviews by both TVA oversight groups and NRC (see NRC Inspection Report Nos.
50-259-260,-296/88-10, June 3,
1988) support the TVA contention in subcategory Report 30100 that corrective actions are effective and that BFN diesel generators can reliably perform their intended safety function.
Conclusion to Evaluation of Element 301.02 TVA evaluation which accepts the validity of the central-issue and extensive corrective action to eliminate the root cause situations that created the problem is adequate and acceptable.
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Element 301.03
- Vibration Problems Noted Issue 301.03-5
- Re air of Defects Caused B
Pi e Vibration XX-85-102-003 The CI at BFN questioned the adequacy of repairs to the damage caused by vibration of the low pressure main steam line.
Evaluation of Issue 301.03-5 The issue which concerns movement or vibration of piping was identified as occurring in the low pressure main steam line. It was determined to actually be a
problem occurring with the Reactor Feed Water pump low load by-pass line, and involved a safety-related system at BFN.
TVA determined the issue to be
- valid, and noted that corrective action had been taken before the TVA investigation prompted by the employee concern.
CATD's 30103-BFN-001,-002, and
-003 are applicable to this issue.
Maintenance requests MR-A628229 through A628261 and MR-A633174 through A633189 (excepting A633175) had been issued to repair damage, and Design Change Request (DCR-B3291) had been issued to improve the design.
Support angles still
.were to be replaced and post-modification testing to be done at the time of the investigation.
TVA's evaluation of this issue as presented in report 30100 gives details of the evolution of the problem analysis, corrective design and modification work and actions to prevent problem recurrence.
Corrective design work was performed under ECN 0996 and DCR-B3291, and modifications under the MR's listed above.
Details presented include reference to memoranda exchanged between BFN groups participating in the problem resolution.
Plans for follow-up on units f/1 and g3 are also described in the memoranda, subject to formal review and approval action under the procedure for closing CATD's.
The BFNPP includes a description of special
- programs, one of which involves Piping and
- Supports, in Section 3-2.
The program plan BFEP-PI-86-05 describes the work, and cites a favorable report from an NRC inspection (81-33) made in 1983.
The final piping/supports reinspection program is defined in BFEP-PI-86-06, and the BFNPP gives a
commitment to correct any deficiencies which are revealed by this inspection.
Conclusion to Evaluation of Issue 301.03-5 TVA evaluation and corrective action, which includes redesign and modification of piping, is adequate to resolve the issue, and is acceptable.
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Issue 301.03-1
- Residual Heat Removal RHR Mini-Flow Pi e Vibration IN-85-289-002 IN-85-325-003 Two CIs at WBN expressed concerns involving the vibration of the RHR minimum flow line during hot functional testing at WBN.
Issue 301.03-2
- Fire Protection Pi e Vibration IN-85-922-01 The CI reported a fire protection pipe banging against the wall during testing at WBN.
Issue 301.03-3
- Main Steam Pi e Vibration IN-86-027-001 The CI reported drastic movement of the main steam lines at WBN.
Issue 301.03-4 Com onent Coolin Water CCW Pi e Vibration IN-86-296-001 The CI at WBN reported movement of a CCW Line on elevation 713 when the t
air blower is on.
Evaluation of Issues 301.03-1 3 and -4 Other issues within Element 301.03, Nos. 301.03-1,-2,-3 and -4 were concerns specific to WBN piping systems.
TVA analysis considered their generic implications, and determined that no other site evaluations were necessary.
Even so, actions taken under the BFNPP, notably the DBVP, testing for restart, Maintenance Improvement
- Program, and surveillance improvements, broadly encompass the issue of piping vibration.
These actions serve to either eliminate the cause of such
- problems, or provide for prompt detection and correction of any piping systems vibration problems should they occur.
Conclusion to Evaluation of Issues 301.03-1 3 and -4 TVA evaluation is appropriate in considering these issues relating to WBN piping systems'erformance under test as not extending to a
generic implication of BFN piping systems which have undergone both testing and operation, and which are of a
substantially different design.
The TVA evaluation is acceptable.
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Evaluation of Element 301.03 It is considered that TVA actions on the piping vibration probl,em at BFN were
- prompt, comprehensive and properly incorporating redesigned equipment modifi-cations and post-modification testing commitments.
The normal provisions for surveillance, testing and quality assurance overview are considered adequate to maintain piping systems, including piping supports, in a safe condition.
The redesign effort to correct this genre of problem is performed in concert with the TVA DBVP.
NRC review teams have visits BFN to note.
progress of the DBVP effort.
NRC inspection report 50-259,-260,-296/87-36, Jan.
21,
- 1988, includes a review of a pipe support design calculation BFN-50-07104, and gives an overall conclusion that "DBVP is structurally adequate in the area of mechanical components,"
despite specifically cited shortcomings that are identified for correction.
This report also takes note of TVA's Engineering Assurance organization, one of the BFNPP overall programmatic controls that exerts an influence over systems design adequacy.
In a later NRC inspection report 50-259,-260,-296/88-07 Sept.
8, 1988, the same conclusion is affirmed that DBVP is
- adequate, again with several specific items identified for correction.
Conclusion to Evaluation of Element 301-03 TVA evaluation and action to resolve the issues within this
- element, including actions to correct mechanical piping systems and preventive actions to avert recurrence, is adequate and acceptable.
Element 301.04
- Retubin Problems Heat Exchan ers Issue 301.04-1
- Desi n of Com onent Coolin S stem CCS Heat Exchan ers IN-86-068-001 One CI at WBN questioned the adequacy of the initial design of WBN unit 1
Component Cooling Heat Exchangers A,
B, and C located on the 737 ft.
elevation of the Auxiliary Building.
Issue 301.04-2 CCS Heat Exchan er Tube Problems IN-86-068-002 IN-86-210-001 IN-86-189-001 Two CIs at WBN believed that the retubing and tube rolling of the heat exchanger tubes was being done improperly.
A third CI at WBN (IN-86-189-001) stated that unit 2 Heat Exchanger B had bent tubes caused by a foreman's improper packing instructions.
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Evaluation of Issues within Element 301.04 TVA evaluation of these issues which originated at WBN found them to be unsubstantiated, with no need to consider implications to BFN.
However the DBVP at BFN encompasses the design related issue and the Maintenance Improvement Program described within the BFNPP includes actions to exert better control over contractor on-site repair work and to apply more effective surveillance over all maintenance, modification and repair activities.
Conclusion to Evaluation of Element 301.04 The TVA evaluation coupled with actions undertaken under provisions of the BFNPP constitutes an adequate response to the issues and is acceptable.
Element 301.05 uestionable Desi n Construction Practices Issue 301.05-1
- Reluctance to Have a
C Check Performed EX-85-008-003 The CI at WBN reported the reluctance of a craft supervisor to have Quality Control personnel check the quality of a
valve that had been dropped.
Issue 301.05-5
- Location of Swin in Gate IN-85-411-001 The CI at WBN was concerned about the close proximity of a gate to a valve which leads to the valve being struck when the gate swings open.
Issue 301.05-6
- Incom lete 1 4" Stainless Steel Line IN-85-554-001 The CI at WBN reported a 1/4" stainless steel line ran out fifty feet from a'ontrol panel and was not connected to anything.
Issue 301.05-7 En ineerin Evaluation of The Essential Raw Coolin Water ERCW Pum Motor IN-85-839-001 The CI at WBN stated that TVA had not performed a
proper engineering evaluation of the ERCW pump motor anti-reversing problem.
Issue 301.05-9
- Leaka e of the Blowdown Line IN-85-930-001 10
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The CI at WBN reported leakage of the blowdown line where concrete and metal pipes join.
Issue 301.05-10
- Plastic Pi e Leadin to the Demineralizer WBN-0023 The CI at WBN questioned the use of plastic pipe leading to the demineralizer that has required numerous repairs.
Issue 301.05-11
- Use of Similar Fittin s WBN-0291 The CI at WBN was concerned that the use'f similar fittings for air,
- water, and contaminated drain connections could cause personnel contamination.
Issue 301.05-14
- Limit Switches MAS-86-002 The CI at SQN alleged that limit switches on a
specific butterfly valve had been improperly mounted.
Issue 301.05-15
- Condensate Stora e Tank CST Check Valves RCM-86-001 The CI at SQN reported possible failure of check valves on the "B" CST
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Evaluation of Issues 301.05-1 6 9 11 -14 and -15 TVA investigation disclosed nine issues
- where, indeed, practices were questionable or downright inadequate.
These nine substantiated issues occurred on diverse systems at various locations in the WBN and SQN plants, including safety-related-systems.
Although the TVA evaluation stated these issues posed no
- problems, and thus required no corrective action, the issues can be aggregated for consideration of effects at BFN based on the similar characteristic of plant personnel carelessness in taking shortcut, question-able practices in performing assigned tasks.
As
- such, TVA has taken significant, generic corrective action directed at improving BFN personnel attention to detail and accountability in meeting maintenance, operations and QA oversight requirements and regulations.
These include changes in managing activities and in the corrective action systems, as discussed in the CNPP Rev.
4, section II.B.4; changes directed toward "Instilling an Atmosphere Conducive to Quality",
section V.C; changes in getting at root causes of problems, section VI.D.2; inclusion of human factor considerations in procedures, section VI.E.1; attention to maintenance personnel skills and attitudes,Section VI.E.2.
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The BFNPP, section II.1.3 addresses the issue of personnel carelessness very directly:
"Mistakes have often been blamed on 'the system'ith no one being held accountable....
This is no longer the case as each BFN manager and employee is held accountable in his area of responsibility for achieving excellence of performance....
Position descriptions have been issued for each management position at BFN....
BFN managers know their areas of responsibility and will be accountable for the
- safety, technical
- adequacy, and quality of their work."
On the basis that recognition and admission of a
widespread problem is a
prerequisite for attacking it to form a solution, the BFNPP statements are a
good foundation for stopping questionable design/construction practices.
Issue 301.15-1, concerning a
supervisor's reluctance to have a dropped item inspected for damage, can serve as an example.
In the present
- time, in the face of BFNPP statements emphasizing quality and attention to detail, well known throughout BFN, it is unlikely that a
supervisor would survive in a
management function if he took such an anti-quality position.
The TVA SSFI conducted in May-June 1988 (Report No.
BFA 88811, ll/29/88) detected a poor practice in that a limit switch was artificially wedged open.
BFN management promptly investigated and corrected the deficient practice, issued a letter of admonition to involved employees and conducted employee re-training to stress the need to eliminate questionable practices.
The CAQR issued to document this item and its correction, CAQR 88-0420, was appropriately closed.on 10/28/88.
The BFNPP includes provisions for strengthening QA oversight functions, surveillance, audits and all other QA overviews as they are brought to bear on maintenance and operations activities.
An Engineering Assurance function has been established to specifically overview design activities.
Conclusion to Evaluation of Issues 301.05-1 6 9 11 -14 and -15 TVA evaluation and broad-based corrective action appropriately addresses root causes of questionable practices; the corrective action is extensive, covering a full range of BFN activities, and is acceptable, Issue 301.05-2
- Draina e of S stem 77 Waste Dis osal S stem Hot Panel IN-85-021-002 The CI at WBN questioned the drainage of the System 77 hot panel to floor drains rather than to a closed tank.
Issue 301.05-3 Coolin Coils in S stems 63 Safet In ection S stem and 68 Reactor Coolant S stem IN-85-089-005 The CI at WBN was concerned about the lack of serviceability of cooling coils in systems 63 and 68.
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Issue 301.05-4
- Unit 2 Floor Drains IN-85-238-004 The CI at WBN questioned the temporary spot-welding shut of unit 2 floor drains.
Issue 301.05-8
- Leaka e of Boron Level Indicator Isolation Valves for Cold Le Accumulators IN-85-889-NOB The CI at WBN reported leakage of isolation valves for the boron level indicators associated with the cold leg accumulators.
Issue 301.05-12
- Inade uate Heatin WBN-0287 The CI at WBN stated that there was inadequate heating in the East document control unit area of the Temporary Service Office Building.
Issue 301.05-13
- Tem orar Rubber Hose I-86-233-SQN The CI at SQN reported that a,temporary rubber hose was being used on the Condensate Demineralizer Waste Evaporator while extensive welding was being performed in the vicinity.
Evaluation of Issues 301.05-2
-.3 8 -12 and -13 TVA investigation of these six issues determined that they were not valid or were factual items that did not require specific corrective action.
This determination is considered appropriate when taken in conjunction with the overall TVA efforts to enhance performance at BFN.
Conclusion to Evaluation of Issues 301.05-2 4 12 and -13 The TVA evaluation of these issues is acceptable.
Evaluation of Element 301.05 The broad scale action at BFN to have work performed at a necessary dependable and efficient quality level is judged to be
- adequate, and is subject to constant overview by the TVA QA function, which in turn is subject to on-site overview by NRC resident inspectors.
An added emphasis is now being placed on the effectiveness of the TVA QA oversight functions.
NRC letter to B.
D.
Liaw from F.
R.
- McCoy, Feb.
13, 1989 "Brown's Ferry Master Inspection Program (Restart)" incorporates a Quality Verification Team Inspection to module MC
- 35702, scheduled for March-April
- 1989, which has as its explicit purpose an assessment of the problem
-finding and
-solving capability of the TVA QA activity.
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The TVA actions are directed accurately at the root causes of questionable practices.'onclusion to Evaluation of Element 301.05 The TVA evaluation and reaction to the issues in this
- element, as interpreted and incorporated within the CNPP and BFNPP commitments, is adequately directed to the underlying problems, applies follow-up provisions and overview controls, and is acceptable.
Element 301.06 '
Hardware Selection estionable Issue 301.06-1
- Unsuitable Door Latches and Knobs IN-86-247-002 One CI at WBN thought that some door latches and knobs at WBN occasionally malfunctioned due to their not being suited for the size and weight of the doors.
Issue 301.06-2
- Rust Bearin s In Valves PH-85-003-010 Another CI at WBN believed that there were rusty bearings in 14" valves on the WBN Auxiliary Building elevation 713.
Issue 301.06-3
- Im ro er Hardware Identification XX-85-071-004 A third CI at SQN expressed a general concern over hardware at SQN which was not able to be evaluated due to lack of detailed information in the concern.
Evaluation of Issues within Element 301.06 The three issues were found to be unsubstantiated by TVA investigation, and also without safety-related aspects.
- However, TVA action to bring about improvement in two TVA work functions, undertaken because of other
- issues, vill bring improvement to hardware selection.
- One, TVA has made arrangements for better design engineer communication to functional groups (in this
- case, Purchasing),
as discussed in BFNPP Section III'2.2.
- Two, of greater significance, TVA's extensive upgrading of Equipment Qualification
.(EQ) parts/components procurement includes design engineer interaction with the entire process of parts selection, procurement, inspection, storage and installation.
This is described in BFNPP Section III-1; these actions have established skills and practices that extend to related hardware requisitioning, and procurement activities thus contributing to consistent and correct hardware selection.
14
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The issue on 14" valves was traced to'4" Motor Operated Valves in the RHR system; these valves were scheduled for Motor Operated Valve Analysis and Test System (MOVATS) testing.
In SSFI Report No.
BFA 88811, Nov. 29, 1988, section 6.1, auditors reported that "MOVATS testing.....
was found to be a
valuable asset in the MOV maintenance program."
Conclusion to Evaluation of Element 301.06 TVA actions taken based upon other concerns than the three issues described in this element are nonetheless relevant to the topic of hardware selection for use at BFN.
The actions are constructive and will support proper hardware selection, requisition, procurement, inspection and installation.
- Thus, TVA evaluation that these three specific issues are not valid, coupled with TVA overall action to improve performance at BFN, provides a basis for acceptance.
Element 301.07
- General Paint Concern Reactor Buildin Issue 301.07-1
- Paint Coatin s
XX-85-087-001 A CI at SQN questioned the integrity and maintenance of containment paint coatings at SQN.
This issue is considered generically applicable to WBN and BFN.
Evaluation of the Issue within Element 301.07 General Paint Concerns Reactor
~Bu11dtn TVA recognized the issue as substantiated, safety-related and generically applicable.
Investigation at BFN disclosed no formal protective coating
- program, coating repairs made without adhesion tests and more than one coat of
- primer, no "unqualified coating log" as recommended by NUREG 0800, and coating repairs made without QA surveillance overview.
CATD's 30107-NPS-01, 2/5/87 and 30107-BFN-Ol, 10/31/86 were issued to track the corrective actions through resolution, both at Corporate level and at BFN.
The corrections at BFN included these recovery actions:
baseline inspection per MMI-167 to determine existing coatings; performing repairs in accordance with requirements and commitments, including maintenance under procedures MMI-29 or MMI-32 and upkeep of an "unqualified coating log";
establishment of periodic inspection with preventive maintenance to follow inspection, per Surveillance Instruction (SI) 4.7.A.K. and procedure MAI-33.
Three primary root causes of the problem are cited by TVA:
1) lack of design control specific to containment paint coatings,
- 2) improper handling of noted deficiencies, and 3) inadequate surveillance of paint contractors.
The TVA actions at BFN were supported by Corporate issuance of G
55 R5, 3/13/87, underwriting, the BFN procedure (NIA-930, N2A-931, N3A-932 and N4A-933) revisions, which incorporate these positions, including requirements for periodic inspection and maintenance.
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The BFNPP commitment item 31 desciibes improvements in training of maintenance personnel, utilizing INFO guidance.
BFNPP commitments Nos.
33 thru 35 address other aspects of BFN initiatives to improve the maintenance function, and commitment No.
99p prescribes completion of containment protective coating corrective action prior to unit g2 restart.
Surveillance over maintenance on coatings is an important measure to prevent recurrence
'of this
- problem, and the SSFI Report No.
BFA 88811, ll/29/88 makes note in section 6-1 "Particular Strengths Observed" that Surveillance Instructions at BFN were found to be better than average.
Also an SSFI finding resulted in issuance of CAQR 88-0472 and revision to two Surveillance Instructions.
Other Surveillance Instructions were reviewed as part of CAQR 88-0472 resolution and found to be comprehensive and correct; the CAQR was closed 10/28/88.
It is considered that the root causes of this issue have been accurately identified.
Changes to both TVA management and crafts attitudes and changes to maintenance and surveillance practices will be effective (including reporting and tracking of deficiencies) to prevent problem recurrence.
The specific actions to bring the BFN containment coating into full compliance with requirements are also considered adequate.
Conclusion to Evaluation of Element 301.07 The TVA evaluation and ensuing corrective action, both specific to containment coating and generic to BFN management, maintenance and surveillance practices, are considered appropriate and comprehensive to correct the problem and prevent recurrence.
The TVA evaluation and corrective action is adequate and acceptable.
Element 301.08
- Steam Generator Manwa Installation ALARA Issue 301.08-1
- Steam Generators S
Gs Access WBN-0284 A CI at WBN stated that entering and exiting the steam generators was difficult.
IN-85-872-001 Another CI at WBN requested that the floor grating near the manways be extended to provide increased work space.
IN-85-869-001 XX-85-052-001 CIs at SQN and WBN reported that manway doors took excessive time to close due to their poor design.
Evaluation of the Issue within Element 301.08 TVA evaluation of this issue identified no generic application to BFN, where, because of plant design differences from WBN and
- SQN, there are no steam generators.
This determination is considered appropriate on the basis given by TVA and also on the basis that there is no comparable NSSS equipment manway access in a BWR unit.
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Conclusion to Evaluation of Element 301.08 The TVA evaluation and disposition for this issue is considered appropriate and of sufficient breadth in regard to BFN mechanical equipment; it is acceptable.
Element 301.09
- Socket Wrench Dro ed into Unit 1 Turbine Issue 301.09-1
- Socket Wrench Dro ed into Unit 1 Turbine IN-85-294-001 A
CI reported that a
socket wrench was dropped into the WBN Unit 1 Turbine.
Evaluation of the Issue within Element 301.09 TVA evaluation of this issue was that it was unsubstantiated by inspections of the turbine and by turbine roll test conducted in 1984.
Broad review of employee
- concerns, plant incident reports, deficiency reports, CAQR's, and NRC inspection
.reports does not disclose a pattern of such events.
Throughout all industry an occasional, inadvertent dropped tool or other item does
- occur, and is reported for recovery by personnel involved.
The TVA significant efforts to promote employee openness without reprisal are a basis for confidence that TVA employees would act responsibly in events of dropped foreign objects, and would follow through with necessary reports and recovery operations.
Conclusion to Evaluation of Element 301.09 TVA evaluation is considered adequate and of sufficient depth and breath in regard to applicability at BFN; it is acceptable.
Element 301.10 S ent Fuel Racks Problem Issue 301.10-1
- Shodd Workmanshi IN-85-323-003 A
CI at WBN believed that specific problems existed with the construction of the WBN spent fuel racks, including lack of verticality, presence of protruding edges, and improperly leveled edges.
Evaluation of the Issue within Element 301.10 TVA evaluation of this issue identified no specific or generic application to BFN.
This determination is considered justifiable in that BFN is operational and WBN is in the construction stage.
One key aspect of the issue of poor workmanship is that of contractor control.
For BFN, use of contractors occurs under plant maintenance activities.
BFNPP section II 4.0 addresses a
ten-point Maintenance Improvement
- Program, that includes upgrading of maintenance
- planning, maintenance procedures, and methods for deficiency 17
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reporting, tracking and correction.
The BFNPP section 5.0 also describes provisions for strengthening the QA surveillance function, so that overview of maintenance activity occurs as the activity progresses and the surveillance is effective in detection and correction of problems.
It is considered that these actions get at the root cause of this issue and form a basis for confidence that contractor controls at BFN are effective in preventing poor workmanship.
Conclusion to Evaluation of Element 301.10 TVA evaluation that specific corrective action for this issue is not needed at BFN is considered appropriate, coupled with overall actions at BFN on improve-ment to maintenance and surveillance functions that comprise appropriate problem preventive actions.
Therefore, the TVA evaluation and action is acceptable.
Element 301.11
- Valve Closure Problem Issue 301.11-1
- Valves Do Not Close Com letel IN-85-400-001 A CI at WBN stated that certain flow control valves and automatic open-close valves in WBN units 1 and 2 do not completely close to prevent flow of water.
Affected systems included Residual Heat Removal (RHR),
Safety Injection System (SIS),
Chemical Volume Control System (CVCS),
and Reactor Coolant System (RCS).
Evaluation of the Issue within Element 301.11 The TVA evaluation and investigation of this issue found that it was unsubstantiated, and therefore had no safety-related aspects.
The TVA analysis found the probable basis for the concern was that Motor Operated Valve (MOV) limit switches are typically set at 98 percent closure to prevent stem overtravel.
BFA 88811, 11/29/88, Section 6-1, the audit team review of the 1'imit switch setting function concludes:
"the team found technicians to be knowledgeable in setting limit and torque
- switches, and the upgraded procedures were accurate and detailed."
Of greater significance, achievement of valve closure is not determined from limit switch
- settings, but actual evidence that valves properly close is obtained from leak rate test programs.
TVA concluded that neither specific nor generic actions were needed at BFN on this issue.
Conclusion to Evaluation of Element 301.11 The TVA evaluation, investigation and disposition of this issue is acceptable.
Element 301-12
- Im ro er 0 eration of S stem 31 18
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Issue 301.12-1
- Flow Control Indicators IN-85-772-001 IN-85-772-009 IN-86-064-001 One CI at WBN thought that the WBN
- Heating, Ventilation and Air Conditioning (HVAC) general ventilation chiller packages A and B had not been operating properly.
Other CIs at WBN expressed concern over 'arious air handling units missing air flow indicators or having inoperable air flow switches.
Evaluation of the Issue within Element 301.12 The TVA investigation and evaluation of the three concerns found one of
- them, concern IN-86-064-001 to be substantiated, in that flow switch probes in an Air Handling Unit (AHU) at WBN were slow-acting and the AHU had tripped on low flow.
Field Change Request FCR-NP-921 had been initiated to correct the
- problem, and a
later evaluation identified no further deficiencies.
The performance of comparable switches on SQN AHUs was reviewed and was found satisfactory.
TVA determined that the issue was an isolated matter specific to
Appropriate controls on operation and maintenance of HVAC equipment are in place at BFN and considered effective.
The other two concerns were not substantiated.
Conclusion to Evaluati'on of Element 301.12 The TVA investigation, evaluation and disposition of the issue is acceptable.
Element 301.13 uestionable Activities That Produced 0 erational Problems Issue 301.13-1
- Steam Generator S
G Cleanliness Violation IN-85-600-005 One CI at WBN was concerned that steam generator cleanliness requirements had been violated when sandblasting operations had been conducted near an open steam generator manhole.
Issue 301.13-2
- Plu ed Drains IN-86-246-007 WI-85-054-003 Two CIs at WBN alleged plugged drains.
Issue 301.13-3
- Valve Pi e Seal otor Leaks IN-86-024-001 IN-86-246-006 IN-86-246-008 IN-86-246-009 IN-86-246-010 IN-86-246-011 19
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Valve leakage problems were identified by CI's at WBN in the Turbine Building and Reactor Building as well as leaks from pipes, from a seal
- drain, and from a pump motor in the Reactor Building Unit 1 raceway.
. Evaluation of the Issues within Element 301.13 The TVA evaluation found all three issues as not valid, and isolated concerns at WBN.
It is considered that if the S/G manway was open during nearby sandblasting, any ingress of particulates would be overcome by interior cleaning prior to completion of activities within the S/G and by flushing of the S/G prior to lay-up.
Likewise effects from leaking sump pumps and leaking valves in the Turbine Building in the interim before repair would not be deleterious to equipment and therefore the TVA conclusion of no safety-related impact is appropriate.
While each single incident reflected in these issues carries little significance, they do have collective significance.
The BFNPP recognized this and incorporated commitments to improve controls on operations and maintenance practices which will result in better mechanical equipment reliability.
The relevant commitments and efforts to obtain improved design/
maintenance controls and progress on their attainment are described within this report under the Evaluation of Element 301.05.
The BFNPP also prescribes actions for improvement of operations phase practices in Section II 3.0 "Plant Operations" and Section V "Operational Readiness",
and for surveillance of operations activities in Section II 5.0 "Plant Surveillance Program".
Taken all together, these corrective actions are aimed at, and should be effective in, eliminating or significantly reducing questionable practices in the operations activities.
BFA
- 88811, ll/29/88, some specific deficiencies were noted; but overall the SSFI indicates progress on commitments given in the BFNPP for better start-up and operation activities.
The closure of CAQR 88-0515, which was issued following the
- SSFI, recognized that the Plant Maintenance Program Upgrade Project was in place and effective on 10/11/88.
The SSFI also includes an item favorable to operations personnel performance under the category of Section 6.1 "Particular Strengths Observed",
indicative of progress in operations personnel training and attention to detail in preparing for safe operations.
NRC resident inspectors at BFN have scheduled a
Quality Verification Team Inspection as noted in "Brown's Ferry Master Inspection Program (Restart)",
Letter F.R.
McCoy to B. D. Liaw, Feb.
13, 1989 to assess TVA QA effectiveness on site at BFN.
This NRC initiative, using newly developed inspection module MC-35702, is intended to measure TVA QA effectiveness and to hold TVA QA to greater accountability to their FSAR Chapter 17 charter/responsibilities.
This is a proper, necessary, constructive endeavor to determine whether TVA QA is discovering problems at the incipient stage, and maintaining a
pro-active QA presence that enforces problem resolution.
If so, TVA QA activity, as intended, will serve to sustain problem preventive measures at
- BFN, to avoid questionable practices and to promptly identify and institute correction to precursor problems.
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Conclusion to Evaluation 'of Element 301.13 The TVA evaluation, coupled with ancillary improvement actions as discussed in the BFNPP on start-up, maintenance, surveillance and operations activities, represents a proper direction for getting at root causes of questionable operational practices, and their future recurrence prevention.
- Overall, TVA evaluation and corrective action is acceptable.
Element 301.14
- Malfunction of Doors Issue 301.14-1
- Inade uac of Doors A56 and A57 IN-85-991-001 IN-86-137-005 IN-86-246-014 CIs at WBN expressed concern over the Auxiliary Building Secondary Containment Enclosure (ABSCE) airlock doors A56 and A57 at WBN either closing too hard and fast or being inoperable much of the time.
Evaluation of the Issue within Element 301.14 TVA evaluation found the issue substantiated at both WBN and SQN, confirming that the airlock doors were a personnel safety hazard.
At the same
- time, TVA investigation revealed that integrity of the Auxiliary Building isolation function was not jeopardized at WBN and
- SQN, and therefore the issue did not infringe on safety-related equipment requirements.
Actions have been initiated at WBN and SQN to modify the door mechanisms to remove the personnel safety hazard.
TVA further concluded that the issue did not have generic applicability to BFN, where plant design differs and there are no similar air lock doors.
Conclusion to Evaluation of Element 301.14 TVA evaluation and action is appropriate, addressing the personnel safety hazard without affecting the proper functional, safety-related aspects of the airlock doors at WBN and
- SQN, and concluding that the issue is not appli'cable to BFN; the evaluation and disposition of the issue is acceptable.
Element 301.15
- Im ro er Hardware Identification Issue 301.15-1 Im ro er Hardware Identification in the'ield XX-85-102-005 A CI at BFN thought that hardware in the field at BFN is not properly identified.
This concern is considered generic to other plants.
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Evaluation of the Issue within Element 301.15 TVA evaluation substantiated the issue at all sites; recog'nized it as safety-related,,compromising traceability of plant equipment for maintenance,
- testing, inspection and operations activities; and recognized that, root causes of the problem included a
lack of a
centralized component identification system and upkeep of multiple data bases in different departments.
CATD-30115-NPS-001 addresses the corporate-wide corrective actions, including issuance of DNE "Plant Component Identification Standards", applicable to all
27, 1987.
CATD-30115-BFN-Ol addresses actions at
- BFN, including system walkdowns under procedure SDSP 9.1.
An overall configuration management effort is described under procedure SDPM-30.
Equipment tagging requirements are contained in Standard Practice BF-8.11, and a
Drawing Discrepancy program exists to correct drawings and bring them into alignment with actual hardware configuration.
SSFI Report No.
BFA 88111, 11/29/88 (SSFI performed May-July, 1988) included observation BF-JLT-1 on uncompleted corrective action on a drawing error and observation BF-JLT-2 on weaknesses in plant valve identification; these items from the "vertical slice" SSFI are indicative of incomplete corrective action at BFN on hardware identification in mid-1988.
Beyond this one-time TVA QA internal
- review, hardware identification measures are under continual review by TVA QA surveillance and by NRC resident inspectors, for example:
NRC Resident Inspector Report 50-259,-260,-296/88-10, June 3,
1988, in closing Violation 259/260/296/84 02 acknowledged TVA proper actions in hardware verification walkdown activities and maintenance of drawings with proper configuration control.
The DBVP bears directly on the hardware identification issue, since validation of design must be based upon analysis of equipment as it is installed in the plant.
NRC reports 50-259,-260,-296/87-36, January 21, 1988 and 50-259,260,
-296/88-07, Sept.
8,
- 1988, provide information on NRC inspection of the DBVP at BFN.
The former report identified TVA practices of use of functional drawings rather than physical drawings as an inadequate practice to provide a basis for design analysis validation, and also identified certain walkdown results for electrical equipment as invalid.
The NRC inspectors
- found, overall, that the BFN DBVP contained essential elements needed to attain proper end results.
The latter report evaluated TVA's responses to DBVP Inspection Report 87-36 provided by TVA R.
L.
Gridley to NRC on April 20, 1988.
The TVA response to the concern on use of functional vs. physical drawings was found acceptable.
The NRC inspection team reviewed the area of electrical walkdown further and in Report 88-07 concluded that "the functional
.walkdown approach adequately verifies the functional configuration of the plant within the limited objectives of the DBVP," and further stated that the concern was resolved.
The NRC team again concluded that the DBVP contains essential elements needed to achieve its goals and objectives.
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Conclusion to Evaluation of Element 301.15 The TVA evaluation appropriately assigns the root causes of the problem and the TVA corrective actions are directed to building proper systems for maintaining hardware identification both in the plant and on the plant drawings.
The DBVP activity is highly relevant to this issue.
TVA evaluation and action is acceptable, subject to completion of DBVP and NRC inspection of
- DBVP, including NRC follow-up to relevant findings within NRC DBVP inspection reports.
Element 301.16
- Health and Safet Concerns Issue 301.16-1
- Frei ht Elevator IN-85-605-002 One CI at WBN stated that the passenger elevator in the WBN Auxiliary Building is used to haul freight.
Issue 301.16-2
- Sanitation Lines IN-85-924-001 A
CI at WBN believed that a health hazard was developing due to backing up of sanitation lines in a women's restroom.
Issue 301.16-3
- Anti-Skid Devices
~ I WI-85-054-005 A CI at WBN thought that anti-skid devices in the waste package area of the railroad bay had been placed on the wrong side of the door.
Evaluation of the Issues within Element 301.16 TVA investigation and evaluation substantiated the three issues at WBN, and found that corrective actions had been initiated prior to investigation.
Although not assigned as generic issues applicable to BFN, the TVA management position as expressed in the CNPP and BFNPP is more receptive than heretofore to consideration of employees health and safety concerns and more attentive to prompt correction of personnel safety hazards.
The TVA evaluation and action is adequate, Conclusion to Evaluation of Element 301.16 The TVA evaluation and corrective actions incorporated in the CNPP and BFNPP are acceptable.
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VI.
EVALUATION OF ELEMENTS 301.01 THROUGH 301.16 FOR COLLECTIVE SIGNIFICANCE TVA identified several major findings emanating from consideration of the 28 substantiated issues on a collective basis:
lack of corporate enforcement of design standards in regard to containment paint coating; lack of corporate guidance in maintenance and testing of diesel generators; and lack of central-ized control of equipment identification both on hardware and drawings.
TVA also extracted six broadly applicable root causes from review of issues on mechanical equipment reliability.
These are:
a)
Lack of understanding of regulatory requirements b)
Lack of systems for carrying out commitments c)
Inadequate acceptance criteria for certain tasks d)
Lack of attention to quality trends e)
Lack of controls on operating procedures and also on contractor work performance f)
Inadequate communication between departments.
The TVA definitions of these six root causes of the issues are considered correct with minor exceptions.
For item (a),
as well as lack of understanding of regulatory requirements, TVA personnel did not demonstrate full acceptance of regulations.
For item (f),
as well as inadequate between-department communications, TVA groups demonstrated a
lack of between-department cooperation.
Notwithstanding these exceptions, it is considered that TVA has correctly identified the primary root causes of the problems affecting mechanical equipment reliability.
TVA recognition of the impact of these problems on safe plant operation shows that TVA has grasped the significance of the pervasive problems that had existed at.
BFN.
The course of action determined by TVA to achieve correction to these six root causes included an emphasis on improvement of the entire TVA management structure, improvement of the major management systems and on verification programs to assess effectiveness of corrective action implementation.
Conclusion to Evaluation of Element 301-01 throu h 301.16 for Collective Si nificance The TVA actions on three major generic issues regarding diesel generator reliability (Element No. 301.02),
containment paint coating integrity (Element No. 301.07) and hardware identification (Element No. 301.15) are satisfactory.
The Maintenance Improvement Program in conjunction with equipment upgrade modifications address the diesel generator reliability issue; the Corporate Commitment Tracking System and Surveillance Improvement Program support the resolution of the containment paint coating integrity issue; and the
- DBVP, plant walkdowns and Drawing Discrepancy Program contribute to improvement of hardware identification.
Strong actions have also been taken to address the six primary root causes ascribed by TVA for the equipment reliability issues raised by employee concerns.
These include the DBVP activity to better define design baselines and to set forth improved equipment acceptance criteria; the new policy that 24
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increases engineering involvement with maintenance and operations; creation of the Engineering Assurance function; overall strengthening of the TVA guality Assurance activity; and establishing a pro-active guality Assurance outlook to promp r
romptly react to adverse quality trends.
These actions, described in the Corporate Nuclear Performance Plan and Browns Ferry Nuclear Performance
- lan, P
are substantive, appropriately broad-based, across-the organization endeavors involving organization restructuring, restatement of policies, revision to procedures and retraining of personnel.
Positive results from these extensive new approaches have been verified as described in the reports of NRC review
- teams, NRC resident inspectors and TVA audits, including a TVA SSFI (patterned after the NRC practice).
As noted in Section V. Evaluation, of this technical evaluation report, TVA actions to correct and resolve issues on specific mechanical equipment problems are appropriate and satisfactory.
Taken together, TVA's actions to resolve each individual mechanical equipment problem, correct the major mechanical equipment systems
- problems, and eliminate the root causes of problems affecting mechanical equipment reliability are considered appropriate, effective, and satisfactory.
VII.
CONCLUS ION TVA has completed the assessemnt of employee concerns and accurately identified the root causes of problems.
TVA's corrective action was appropriate--and comprehensive, and the follow-up and verification of the corrective actions was thorough.
Considering TVA actions to correct root causes and to resolve both specific and generic issues, the overall conclusion is that TVA's investigation, evaluation, and corrective actions on the mechanical equipment reliability issues applicable to Br owns Ferry Nuclear Plant as described in Subcategory Report 30100 are acceptable.
The Engineering Assurance organization was dissolved in 1989 and the functions of the organization are now performed by the site quality assurance and modification groups.
VIII. REFERENCES 1.
January 20, 1989, letter from R. L. Gridley (TVA) to NRC, "Browns Ferry Nuclear Plant (BFN) - Diesel Generator Evaluation Report" 2.
December 21, 1989, letter from S.
C. Black (NRC) to 0.
D. Kingsley, Jr.
(TVA), "Volume 3,Section III.4.1 (Electrical Calculations - Diesel Generator Loading Analysis) of the Nuclear Performance Plan - Browns Ferry Nuclear Plant', Unit 2 (TAC Nos. 62260/62264)"
3.
January 30, 1990, letter from N. 0. Hedford (TVA) to NRC, "Browns Ferry Nuclear Plant (BFN) - TVA BFN Technical Specification No. 277 - Diesel Generators" 25
e J
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REFERENCES TO PR(MVlMMATIC DOCUMENTS 2.
3.
4.
5.
6.
7.
8.
9.
10.
12.
BFN Updated Final Safety Analysis Report (UFSAR) through Amendment No. 6, Sept.
19, 1988.
TVA Nuclear Quality Assurance Manual (NQAM),
11/14/85 and Interim
- NQAM, 10/21/86.
TVA Corporate Nuclear Performance Plan (CNPP) Volume I, Rev. 4, 3/26/87.
Safety Evaluation Report of TVA's Corporate Nuclear Performance
- Plan, NUREG-1232, Vol. I, July, 1987.
TVA Brown's Ferry Nuclear Performance Plan (BFNPP),
Volume 3, 8/28/86.
Safety Evaluation Report of TVA Brown's Ferry Nuclear Performance Plan NUREG-1232, Vol. 3, April, 1989.
BFN Design Baseline and Verification Program (DBVP), Rev.
0, 7/7/86, NRC Inspection Report on DBVP, 50-259,-260,-296/87/36, 1/21/88.
NRC Inspection Report on DBVP, 50-259,-260,-296/88/07, 9/8/88.
BFN Surveillance Improvement Program (SIP) [Fuel load milestone completed
- January, 1989]
BFN Maintenance Improvement Program (MIP) [Fuel load milestone completed
- January, 1989]
BFN Preventive Maintenance Program Upgrade Project (PMPUP) [Fuel load milestone completed January 1989]
13.
NRC Resident.Inspection Report, 50-259,-260,-296/87-37, 12/3/87.
14.
NRC Resident Inspection Report, 50-259,-260,-259/88-02, 3/24/88.
15.
NRC Resident Inspection Report, 50-259,-260,-259/88-10, 6/3/88.
16.
NRC Letter "Brown's Ferry Master Inspection Program (Restart)"
B.
D.
Liaw from F. R. McCoy, 2/13/89.
17.
Safety System Functional Inspection (SSFI) Report No.
BFA 88811, 11/29/88.
ATTACHMENT A
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