ML18033B388
| ML18033B388 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 05/31/1990 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML18033B375 | List: |
| References | |
| NUDOCS 9006210259 | |
| Download: ML18033B388 (8) | |
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0 Cy Vl UNITED STATES LEAR REGULATORY COMMISSIO WASHINGTON, D. C. 20555 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION EMPLOYEE CONCERNS SPECIAL PROGRAM SUBCATEGORY REPORT NUMBER 30900 "ENGINEERING" TENNESSEE VALLEY AUTHORITY BROWS FERRY NUCLEAR POWER PLANT DOCKET NOS. 50-259 260 AND 296 I.
STATEMENT OF CONCERNS Mithin Subcategory Report 30900, there were a total of eleven issues broken into three topically related elements.
TVA determined whether or not each issue was nuclear safety related.
Six of the eleven issues were determined to be non safety-related and applicable only to TVA's Matts Bar Nuclear Plant (WBN);
as such, these issues were not subjected to generic applicability evaluation for all TVA nuclear plants, and they will be evaluated as part of the WBN Employee Concerns Special Program (ECSP) review.
The remaining five issues, all of which t
were determined to be safety-related, are described in the following subparagraphs, grouped by.,their respective elements.
Element 309.01 - "Adequacy of Procedures Issue 309.01 Procedures lack clarity and acceptance criteria The concerned individual reported that several procedures at MBN need to have portions rewritten for clarity or more defined acceptance criteria.
Issue 309.01 Teflon tape is not adequately controlled This concern addresses the implementation of MBN programs to identify and replace the teflon tape used os the Reactor Coolant System (RCS) and those systems that return to the RCS.
Element 309.04 - Procedure Violations Issue 309.04 Lax inspection criteria This issue involves the lack of procedural adherence at WBN which apparently led to modifications of permanent plant ladders without revising the appropriate drawings and to the improper reassembly of a shielding enclosure.
Issue 309.04 Violation of Out-of-Service tags At Bellefonte Nuclear Plant (BLN), the concerned individual reported that 900b2i0259 90053i PDR ADOCI( 05000259 P
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personnel had violated out-of-service tags on valves and electrical l
equipment,'hus jeopardizing personnel safety.
Element 309.05 - Engineering Training Issue 309.05 Inexperienced Shift Technical Advisor (STA) Course Instructors It was reported that individuals with no STA exper ience were instructing STA classes at MBN.
SUMMARY
OF ISSUES All issues associated with this subcategory report were first identified at plants other than Browns Ferry (BFN).
Because the five issues discussed in the above subparagraph were determined by TVA to be safety related, they were required to be evaluated for generic applicability to all TVA nuclear plants, per the requirements of the ECSP.
Issue 309.01-3 Procedures lack clarity and acceptance criteria.
The concerned individual provided two examples of procedures at WBN which lacked clarity and/or acceptance criteria.
In one case, the NRC had pre-viously identified the concern and corrective action had already been initiated.
In the other case, the specific concern was found to be without basis.
The ECSP personnel determined that this issue was limited to specific NBN procedures and that adequate corrective action'ad been initiated prior to ECSP investigation.
Therefore, the ECSP staff concluded, that no other site evaluations were necessary.
The staff agrees with TVA's disposition of this issue as it applies to BFN.
Issue 309.01-4 Teflon tape is not adequately controlled.
This issue, which originated at WBN, dealt primarily with the potential misapplication of teflon thread sealing tape in violation of General Construction Specification G-29M, Process Specification 4-M.1-1.
Each TVA nuclear site was requested to initiate a tracking mechanism to ensure that such potential misapplications be replaced before the teflon tape begins to undergo radiation induced breakdown at a cumulative dose of 10,000 rads.
BFN management has revised Plant Manager's Instruction (PMI) 6.2, "Conduct of Maintenance,"
to prohibit the routine use of teflon tape as a thread sealing material.
'For those cases where equipment manufacturers specify that teflon tape be used, prior approval for such use must be obtained from the BFN chemistry organization.
In support of this policy, Site Director's Standard Practice (SDSP) 24.2, "Chemical Traffic Control," has been revised to provide specific guidelines on how teflon tape is to be controlled.
Rather than initiate a tracking mechanism to ensure the removal of teflon tape which may already be installed in the BFN RCS, TVA plans to remove such installations on an "as found basis."
This requirement is embodied in PMI 6.2, Revision 9.
TVA's decision not to implement a teflon tape tracking a~>d removal program was based primarily on nuclear util'ity
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operating experience, in which there have been no occurrences of stress corrosion cracking directly'ttributable to teflon tape breakdown.
In addition, there is evidence that the radiation stability of teflon in oxygen free environments, like that encountered at BFN, extends to between I and 100 Nrad.
This cumulative level of radiation exposure approximates the total expected exposure accumulated throughout the plant's lifetime.
The staff finds TVA's plans to remove existing misapplications of teflon
- tape, when found, and to control its new use, acceptable to support the restart of BFN Units I, 2 and 3.
Issue 309.04-1 Lax inspection criteria.
The ECSP staff determined that the concern in question identified one instance of non-compliance with procedures and another of a minor flaw in an administrative procedure.
Both these instances occurred at WBN and the ECSP determined that no further evaluation of this issue was necessary at other TVA nuclear sites.
The staff concurs with TVA's assessment of this issue regarding BFN.
Issue 309.04 Violation of Out-of-Service Tags.
Through extensive personnel interviews and 'review of training documen-tation and procedures, the ECSP staff was unable to substantiate the stated concern at Bellefonte.
Because the concerns were not verified, no generic applicability review was performed.
The technical programs staff concurs with TYA's evaluation of this issue.
Issue 309.05 Inexperienced Shift Technical Advisor (STA) Course Instructors.
The ECSP reviewers determined that the condition described by the concerned inaividual was factual for both the Sequoyah and Watts Bar nuclear plants.
However, the instructors in question possessed the proper experience to effectively teach their assigned subject matter.
In addition, they were sufficiently qualified, per.TVA training instructor criteria, to teach their assigned classes.
Because the condition described was found to be factual, but the issue was determinea not to be a problem, no further site evalua'tions were performed.
The staff firds TVA's disposition of this issue acceptable.
III. EVALUATION The staff concurs with TVA's disposition of all eleven issues contained in this subcategory report with regard to their relation to nuclear safety.
- Further, the technical evaluations performed by the ECSP staff for the individual issues contained in this subcategory
- report, as they pertain to BFN, were satisfactory.
These staff assessments are based on review of.the technical data contained in ECSP Subcategory Report 30900, the ECSP corrective action closure package for Issue 309.01-4, and discussions with ECSP personnel.
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The issues addressed in element 309.01, "Adequacy of Procedures,"
represent the problem of generally inadequate procedures throughout the TYA nuclear organization.
TYA has recognized that this problem exists, and has embarked on a program to upgrade all types and levels of procedures.
The details of the procedure upgrade programs are contained in the TVA Nuclear Performance
- Plan, Volumes 1 through 4.
The procedure upgrades have met with some success thus far, ana further improvements are underway.
The staff is satisfied that TYA has attempted to address the generic problem of inadequate procedures at its nuclear sites, including BFN, but recognizes that continued effort is required to complete the needed upgrades.
The staff finds TVA's plans to remove misapplied teflon tape from the BFN RCS, when found, and the measures taken to control future use of teflon tape acceptable.
The safety related issues embodied in elements 309.04 and 309.05 describe conditions which were either not factual, not a problem, or were not applicable to BFN.
IV.
CONCLUSIONS The technical programs staff finds that TVA's disposition of the safety related employee concerns contained in ECSP Subcategory Report 30900, as they apply to the Browns Ferry Nuclear Plant, satisfactory to support the restart of BFN Units 1, 2 and 3.
Y.
REFERENCES t
Browns Ferry,. Plant Hanager's Instruction (PNI) 6.2, "Conduct of Maintenance,"
Revision 9.
Browns Ferry Site Director's Standard Practice 24.2, "Chemical Traffic Control," revision approved on 7/13/89.
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