ML18033B387
| ML18033B387 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 05/31/1990 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML18033B375 | List: |
| References | |
| NUDOCS 9006210255 | |
| Download: ML18033B387 (10) | |
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SAFETY t UNITED STATES t
NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION EMPLOYEE CONCERN 30800, "MAINTENANCE" TENNESSEE VALLEY AUTHORITY BROMNS FERRY NUCLEAR PLANT, UNITS l.,
2 AND 3" DOCKET NOS. 50-259, 50-260 AND 50-296 1.0 SUBJECT Employee Concern Subcategory Report 30800 addresses employee concerns associated with various aspects of plant maintenance including: procedures, implementation, training, personnel qualifications, and Asiatic clam control.
The report contains the results of TVA's investigation of 76 employee concerns.
The report investigated 4 employee concerns specifically identified for Browns Ferry.
The remaining 72 were reviewed for applicability to Browns Ferry and investigated as needed.
2.0
SUMMARY
This subcategory is comprised of 76 employee concerns grouped into 7 elements as follows:
Element Element Element Element Element Element Element 308.01 308.02 308.03 308.04 308.05 308.06 308.07
- Adequacy of Procedures
- Preventive Maintenance
- Corrective Maintenance
- Program Deficiencies/Procedure Violations
- Training Program Deficiencies
- Subjourneymen/Journeymen
- Clams Clogging Heat Exchangers Many of the employee concerns were interrelated and the elements were further divided into individual issues.
TVA investigated each site-specific issue and then considered the issues for applicability to other sites.
The subcategory report identified 4 employee concerns as site-specific and 17 concerns as applicable to'Browns Ferry.
The remaining concerns were either invalid or specific to other sites.
Seven employee concerns were valid at Browns Ferry.
- 3. 0 EVALUATION The licensee's corrective actions are summarized in the subcategory report.
Additional issues identified during the licensee's review are also included in the corrective actions.
The staff's evaluations of TVA's corrective actions are discussed in the following paragraphs.
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Element 308.01 contained 18 employee concerns regarding the adequacy of maintenance procedures.
Two employee concerns were specific to Browns Ferry.
One concern said that craft personnel were not provided with sufficient proce-dures for the performance of, work.
The subcategory report stated that this was a valid concern and it was being addressed by the procedure upgrade program committed. to in the Nuclear Performance Plan (NPP)
Volume III.
This corrective action includes revising maintenance procedures to provide more specific work instructions, work requirements from General Construction Specifications, and updated vendor information.
The other site-specific concern was that the main steam relief valve (MSRV) handling procedure was inadequate.
The subcategory report found the procedure for removal and replacement of the Main Steam Relief Valves (MSRV) had a
precaution for rigging valves inside of the drywell, but did not include guidelines for safe removal.
The corrective action plan was to 'develop a
specific rigging procedure, add hatches in the drywell grating, and add jib cranes,and dedicated rigging equipment fot MSRV removal.
The staff considers the planned corrective actions adequate.
The subcategory report also identified one employee concern as applicable to Browns Ferry.
The issue was improper inspection of the motor operated valve (MOV) limit switch lubrication which TVA said was invalid because Browns Ferry inspects Limitorque MOV lubrication once per refueling cycle or every 18 months.
. In addition, the grease for all MOVs has been upgraded in Units I and 3 and Unit 2 is scheduled for completion prior to startup.
The report said the remainder of the concerns were either invalid or not applicable.
The staff accepts TVA's evaluations.
Element 308.02 contained six employee concerns regarding preventive maintenance (PH).
One concern applicable to Browns Ferry was that the PM program was not adequate because engineers had disregarded the use of vendor manuals for safety-related equipment.
The subcategory report stated that it was not substantiated.
A complete review of the PM program and maintenance procedures was verifying the incorporation of vendor information and a new vendor manual control program was ensuring that plant procedures are kept current with vendor information.
The staff concluded that this employee concern was adequately addressed.
The report concluded that the remaining concerns were either invalid or not applicable.
The staff accepts TVA's evaluations.
Element 308.03 contained 17 employee concerns regarding corrective maintenance.
A Browns Ferry site-specific concern stated that a non-CSSC valve was installed in a CSSC system.
The subcategory report said this concern was invalid because the particular valve was a fire hydrant that protects the high voltage switch yard and not a
CSSC component.
The subcategory report also identified three employee concerns as applicable to Browns Ferry.
One concern involved inadequate door maintenance and the subcategory report said door maintenance is a significant problem at Browns Ferry.
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3 maintenance was fixing the damage, but not solving the problem because chronic door maintenance problems were not programmatically addressed.
The corrective actions were to implement a detailed plan involving review of all similar items, complete all outstanding work on doors, initiate a PM program for doors, revise maintenance instructions for doors, and initiate work plans to return doors to their original'esign.
The corrective action plan included repair or replacement of all affected doors before Unit 2 startup.
The staff noted that the corrective actions are still ongoing and numerous door malfunctions, specifically the RHRSW pumping station doors, continue to be experienced.
The staff considers the corrective action plan adequate to resolve this employee concern; however, the corrective actions have not yet been completed.
The second concern said that torque wrench calibrations need to be checked immediately following a job.
This concern was found to be invalid.
The subcategory report concluded that the measuring and test equipment (METE) program at Browns Ferry complied with Nuclear guality Assurance Manual requirements and does not require a calibration check of torque wrenches after each usage.
The Browns Ferry program includes methods to identify and resolve concerns for out-of-calibration MME.
The third concern said repairs were being made which did not meet ASME requirements.
The concern was too vague to be substantiated, but a problem was identified pith the usage of furmanite on non-code equipment.
The subcat'egory report said no MRs could be identified showing the use of furmanite, yet purchase orders indicated that the product had been used at Br owns Ferry in the past.
The corrective action plan was to process future furmanite repairs as temporary alterations in accordance with Plant Manager' Instruction (PHI) 8. 1 "Temporary Alterations."
PMI 8. 1 controls and tracks temporary plant alterations and requires their eventual removal or permanent incorporation through the design change process.
The staff considers the corrective action adequate to resolve this issue.
The subcategory report concluded that the remainder of the concerns were either invalid or not applicable.
The staff accepts TVA's evaluations.
Element 308.04 contained 19 employee concerns regarding maintenance program deficiencies and procedure violations.
There was one site-specific concern that said an uninspected hanger being removed and never replaced.
TVA could not identify the hanger and the concern was not substantiated.
An inspection program was initiated in accordance with NRC Bulletin 79-14 to evaluate the adequacy of piping system supports at Browns Ferry.
An additional program was in progress to inspect and evaluate all piping supports that were riot initially inspected in 1979.
The subcategory report determined that the "79-14" program was a "one shot" correction of identified problems and did not address the control of removal and subsequent reinstallation of hangers during the maintenance/modification activities required to gain access to equipment.
The corrective action plan was to initiate procedures to control these maintenance and modification activities.
Based on the implementation of the corrective actions, the staff considers this employee concern resolved.
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The subcategory report also identified six employee concerns as applicable to Browns Ferry.
One concern was that non-gA material was used in gA applications and traceability was falsified on the MR.
This concern was evaluated in the subcategory reports which investigated quality assurance and harassment and intimidation issues.
The other five concerns were not substantiated at Browns Ferry.
These included the control of drawings in vendor manuals, engineering dispositions of Notice of Indications (NOI) and Maintenance Requests (MR) without fixing them, inadequate limitorque motor operator grease inspections, MRs signed off without the performance of work, and violations of maintenance procedures.
Browns Ferry has approved programs in place governing vendor
- manuals, engineering dispositions, limitorque maintenance, and the conduct of maintenance.
These programs should ensure that these deficiencies do not occur at Browns Ferry.
The report concluded that the remaining concerns were either invalid or not applicable.
The staff accepts TVA's evaluations.
Element 308.05 contained six employee concerns regarding deficiencies in the maintenance training program.
There were three site-specific Browns Ferry concerns.
One concern was that the maintenance training was deficient and the subcategory report found that the entire maintenance training program had not been implemented.
In October
- 1987, TVA became a member of the National Academy for Nuclear Training by achieving INPO accreditation for all ten training programs.
These programs included mechanical maintenance, electrical maintenance, and instrumentation and controls technician training.
Based on the accreditation of the licensee's training programs, the staff concluded that this employee concern has been adequately addressed.
Two concerns said operators were side-loading cranes.
The subcategory report said side pulls had occurred, but no crane damage was identified.
The corrective action plan was to hold training sessions and reemphasize the importance of avoiding side-load conditions during lifting operations.
The staff considers these corrective actions adequate.
The report concluded that the remaining concerns were either invalid or not applicable to Browns Ferry.
The staff accepts TVA's evaluations.
Element 308.06 contained ten employee concerns regarding work performed by unqualified journeymen and subjourneymen at Watts Bar.
The subcategory report said the concerns were not applicable to Browns Ferry and the staff accepts TVA's evaluation.
Element 308.07 contained three employee concerns regarding insufficient control for Asiatic clam infestation at Matts Bar.
TVA did not substantiate these concerns at Browns Ferry.
The licensee has had a program to prevent degradation of plant equipment due to clam fouling in place at Browns Ferry for several years.
During TVA's evaluation it was discovered that a
commitment had been made to evaluate equipment failures which result in extended loss of chlorination capability, however no procedures could be found to address the commitment.
The corrective action plan was to revise chemistry instructions to include an eva1uation of effected systems following the failure of chlorination equipment for periods greater than 14 days.
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0 the licensee's current clam fouling prevention program and implementation of the commitment to the NRC, the staff concludes that the employee concerns in this element are adequately addressed.
- 4. 0 CONCLUSION Employee Concerns Subcategory Report 30800, Maintenance, stated that 7 of the 76 employee concerns investigated required corrective actions at Browns Ferry.
The subcategory reports also identified two related problems which required corrective actions.
The corrective actions plans were reviewed and the staff concluded that the proposed actions should provide adequate resolution of the concerns at Browns Ferry.
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