IR 05000259/1987020

Insp Repts 50-259/87-20,50-260/87-20 & 50-296/87-20 on 870501-31.Major Areas Inspected:Operational Safety,Maint Observation,Ie Info Notice Review,Ros,Previous Enforcement Activities,Qa & Configuration Control Drawing Insp

ML20235G982
Person / Time
Site:	Browns Ferry
Issue date:	06/26/1987
From:	Bearden W, Brooks C, Crlenjak R, Ignatonis A, Andrea Johnson, Patterson C, Paulk G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II), NRC OFFICE OF SPECIAL PROJECTS
To:
Shared Package
ML20235G926	List: IR 05000259/1987020 ML20235G923 ML20235G951
References
50-259-87-20, 50-260-87-20, 50-296-87-20, IEB-83-03, IEB-83-3, IEIN-86-040, IEIN-86-055, IEIN-86-096, IEIN-86-099, IEIN-86-40, IEIN-86-55, IEIN-86-96, IEIN-86-99, NUDOCS 8707140449
Download: ML20235G982 (23)

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UNITED STATES

1. gm R8Guq'o NUCLEAR REGULATORY COMMISSION

'[" p REGloN la S j 101 MARIETTA STREET, * 't ATLANTA, G EORGI A 30323

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Report Nos.: 50-259/87-20, 50-260/87-20, and 50-296/87-20 Licensee: Tennessee Valley Authority 6N 38A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Docket Nos.: 50-259, 50-260, and 50-296 License Nos.: DPR-33, DPR-52, and DPR-68 Facility Name: Browns Ferry 1, 2, and 3 Inspectfon Conducted: May 1-31, 1987 Inspectors: h i d .A3 b . _ , k f e $//d/f)

G. L. Paulp Senior Resignt Uhspector Da'te S'igned Yuwb ln Y/(lT 7 Date Signed C. A. Patf.erson, Reside 6t yspector 040$C wm a he hS/Y7 Da'te signed C.R.Brool(4,ResidentIn[psetor ,

04h O->m b4\ [>l/b/R2 Da'te signed R. V. Crigjijak, Senior RWs(dent Inspector St. Lucie Ob0A$ w W. C. Betrden, Resident Ihspector Oem ~

N/G/E7 Date Signed Bellefonte Y mx A.H.Joh(sbn,ProjectInsppftor bbS/W7 Date Signed Approved by: Mm % ,

A. J. Igr[itonisV/S6ction Chief, Inspection

[/2[!K7 Datd Sign 6d /

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Programs, Division of TVA Projects SUMMARY l

Scope: This routine inspection was in the areas of operational safety, mainte-nance observatio IE Information Notice review, reportable occurrerices, I previous enforcement activities, quality assurance, configuration control drawing inspection, and the licensee's implementation of contractor recommendation DR 070708 ADDCK 05000259 PDR l

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Results: One deviation was identified - seismic mounting of control room panels is inconsistent with the mounting configuration used for seismic qualification as des ribed in FSAR 7.2.5.2.

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REPORT DETAILS Licensee Employees Contacted: ,

H.G. Pomrehn, Site Director J.G. Walker, Deputy Site Director P.J. Spiedel, Project Engineer R.L. Lewis, Plant Manager J.D.. Martin, Assistant to the Plant Manager

• R.M. McKeon, Superintendent - Unit Two J.S. Olsen, Superintendent - Units One and Three T.F. Ziegler, Superintendent - Maintenance

• D.C. Mims, Technical Services Supervisor J.G. Turner, Manager - Site Quality Assurance M.J. May, Manager - Site Licensing

• P.P. Carter, Compliance Supervisor A.W. Sorrell, Health Physics Supervisor R.M.' Tuttle, Site Security Manager

• B. C. Morris, Senior Licensing Engineer

• C. McFall, Compliance Engineer

• C. Madden, Compliance Engineer

• R. Erickson, Plant Operations Review Supervisor Other licensee employees contacted included licensed reactor operators, auxiliary operators, craftsmen, technicians, public safety cfficers, quality assurance, design and engineering personne * Attended exit interview Exit Interview (30703)

The inspection scope and findings were summarized on June 9,1987, with the Plant Manager and/or Superintendents and other members of his staff as indicated in paragraph 1 abov The licensee acknowledged the findings and took no exceptions. The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspectio . Licensee Action Previous Enforcement Matters (92702)

(CLOSED) Open item (259,260,296/81-37-04) This item was to add the torus and corner room flood level switches to a routine testing program. The level switches had not been previously checked for operability. A deviation was issued for this item (85-36-04) for failure to have the flood level switches operable and sesimically mounted as required t / the <

FSA Testing of the switches found 3 out of 18 not operable. An Electrical Maintenance Instruction (EMI-90) was written to perform testing

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of these switche The switches have been added to a preventive maintenance schedule. .This item is close '(CLOSED) Followup item (259,260,296/86-25-07) This item was to review the licensee's evaluation of the inspection ' interval for flood doors. The inspector performed a. visual inspection of these doors-and identified several deficiencies on the door to the radwaste building which could

potentially, prevent- the door from closing and dogging properly. The doors were being inspected on a five year interval. The licensee evaluated this time interval in light of a plant policy change to maintain the doors normally open and the identified deficiencies on the door, The licensee changed the inspection interval to semi-annually, corrected the deficiencies, and performed the required inspections. Copies of the procedure change, the inspecto Th is item is' closed. inspections, and maintenance. requests were revi (CLOSED) Violation (259,260,296/85-28-06) This item pertained to the licensee's failure to adhere to Standard Practice 8.3, Plant Modifications, in that workplan number 0049-84 did not list Surveillance Instruction (SI) 4.11. A.5, High Pressure Fire Protection System Valve Alignment, as one of the instructions requiring review and updating as a result of a field change request. SI 4.11.A.5 was revised to include the required changes and additional training conducted for modifications personnel on workplan preparations. . A. copy of the revised SI and copies of the training . attendance sheets were provided to the inspector for review. 'This item is close (CLOSED) Followup item (259,260,296/86-06-05) While performing Surveillance Instruction S.I. 4.2. A-10, . Reactor Building Ventilation-Radiation Monitors, on Unit 2 equipment, the logic circuit was found to l deviate from the as-constructed drawings. A drawing discrepancy was ,

issued to correct the discrepancy (2-86-0298). After an engineering '

evaluation the drawing was revised on May 9,1986. The details of this problem are discussed in licensee event report 259,260,296/86-09. The inspector reviewed the corrected drawing. This item is close ({LOSED) Unresolved Item 259,260,296/86-25-04. This item questioned the adequacy of control room. panel anchorage details. Drawing 47W605-3 required only that the panels be " tack welded at intervals to fasten in place". This was found to conflict with FSAR Section 7.2.5.2, Seismic Test and Analysis Results, which states that the seismic capability of control room panels was demonstrated by vibration testing and that the

panels were mounted on the shaker test table in a manner similar to service mounting. NE00-10678, Seismic Qualification of Class 1 Electric Equipment, describes this mounting to be floor mounted using 5/8 inch bolts in all mounting holes. The maximum safe tension and shear stress were assumed to be 28,000 and 21,000 psi respectively. This unresolved

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item has been upgraded to a deviation (259,260,296/87-20-01).

(CLOSED) Violation Example B.1 (259, 260, 296/86-25) This violation was for failure to remove a welded plug and perform an adequate flush as

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reguired' which resulted in the fire protection preaction sprinkler system being unable to provide water spray to cable trays and equipment in the area of the Unit 3 reactor building 593 foot elevation. A review by the inspector found that the pipe plug was removed and all cross mains in the reactor building preaction systems were flushed and a 30 percent random sample of the branch lines in the safety related preaction sprinkler systems were air tested. This item is close . Unresolved Items * (92701)

There was one unresolved item identified during this inspection and is noted in paragraph seve . Operational Safety (71707, 71710) )

The inspectors were kept informed of the overall plant status and an,y significant safety matters related to plant operations. Daily discussions were held with plant management and various members of the plant operating staf ,

The inspectors made routine visits to the control rooms when an inspector was on site. Observations included instrument readings, setpoints and recordings; status of operating systems; status and alignments of emergency standby systems onsite and offsite emergency power sources available for automatic opera; tion; purpose of temporary tags on equipment controls and switches; annunciator alarm status; adherence to procedures; adherence to limiting conditions for operations; nuclear instruments operable; tempo-rary alterations in effect; daily journals and logs; stack monitor

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l recorder traces; and control room manning. This inspection activity also included numerous informal discussions with operators and their supervisor General plant tours were conducted on at least a weekly basis. Portions of each reactor building and outside areas were the turbine visite building, included valve positions and system alignment; Observations snubber and hanger conditions; containment isolation alignments; instrument readings; housekeeping; proper power supply and breaker; alignments; radiation area controls; tag controls on equipment; work activities in progress; and radiation protection control Informal discussions were held with selected plant personnel in their functional areas during these tour Weekly verifications of system status which included major flow path valve alignment, instrument alignment, and switch position alignments were performed on the electrical distribution, pressure suppression chamber and residual heat removal system "An Unresolved Item is a matter about which more information is required to determine whether it is acceptable or may involve a violation or deviatio _ - _ _ - _ - _ _ - _ _ _ _ _ _ _ _ - _ _ _ _ _ _

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4 In the course of the monthly activities, the inspectors included a review of the licensee's physical security program. The performance of various shifts of the security force was observed in the conduct of daily activities to include; protected and vital areas access controls, searching of personnel, packages and vehicles, badge issuance and retrieval, escorting of visitors, patrols and compensator In addition, the inspectors observed protected area lighting,yprotected posts. and vital areas barrier integrit . Maintenance Observation (62703)

Plant maintenance activities of selected safety-related systems and components were observed / reviewed to ascertain that they were conducted ir accordance with requirements. The following items were considered during this review: the 1imiting conditions for operations were met; activities were accomplished using ap3 roved procedures; functional testing and/or calibrations were performet prior to returning components or system to service- quality control records were maintained; activities were accomplished by qualified personnel; parts and materials used were pro)erly certified; p, roper tagout clearance procedures were adhered to;  ;

Tec1nical Specification adherence; and radiological controls were '

implemented as require Maintenance requests were reviewed to determine status of outstanding jobs and to assure that priority was assigned to safety-related equipment maintenance which might affect plant safety. The inspectors observed the below listed maintenance activities during this report period: Diesel Generator Potential Transformer Fuse Contacts Installation of Fire Protection Ventilation Dampers No violations or deviations were observed in this are . Information Notice Review (92717)

The inspector reviewed the licensee's processing of Information Notices (IN)86-040 through 86-106 to determine appropriate dissemination of the received information audits and its closure as stated in licensee pro-cedure Standard Practice BF-21.17, " Review, Reporting, and Feedback of Operating Experience Items." The sampled ins were verified to receive an adequate review by the licensee for applicability determinatio They also appear to have been disseminated to the appropriate departments for preventive and corm tive actions. However,, it appeared that certain ins were being closed be:ure further work or review was to be described by the reviewer. Examples of ins in which premature closure appears to have taken place are discussed below: IN-86-099, Degradation of Steel Containments, based on recent problems at Oyster Creek pertaining to the drywell walls' wastag The reviewing engineer included into the evaluation of the in that the laterials Engineering Group was continumg to study this problem

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in detail. Yet, this item was closed on January 28, 1987, before the study was complete IN 86-096, Heat Exchanger Fouling Can Cause Inadequate Operability of Service Water Systems, the reviewing, eng,ineer included that although no s)ecific action is required at this time, BFN is in the process of esta)lishing a comprehensive preventive maintenance program for plant heat exchangers. This items was closed on December 30, 198 IN 86-055, Delayed Access to Safety Related Areas and Equipment During Plant Emerg,encies, the Davis-Besse loss of feedwater even The reviewing engineer included that Appendix R fire procedures-(which were in draft form as of May 15, 1987) should be audited to ensure keys for access and for padlecked valves are available and probably should be identified in the-procedures or another procedure under the Shift Engineer's contro This item was closed on November 18, 198 The inspector determined by further review that in 1985 the licensee QAB Audit,QBF-A-85-0016, identified that experience review items were being closed when the responsible supervisor stated that a particular action was committed to be done. BFN agreed with the QA finding in that a deficiency existed in the tracking and verification of corrective actions of operating experience review items. Further, that experience review items were being closed out when the responsible supervisor stated that a particular action was committed to be worked. Also, there was no followup after the work was committed to be done. BFN Standard Practice BF-21.17

" Review, Reporting, and Feedback of Operating Experience Items" was revised so that experienced review commitments would be tracked until complete Corporate QA stated by letter that an audit was planned for March 1987, to evaluate the implementation of the BF-21.17 precedure. The inspector learned that this audit has been delayed until September 198 The on-site QA Section is also planning their annual audit of operating experience reports in the near future. On May 6, 1987, the licensee replaced Program." procedure BF-21.17 with SDSP 15.9, " Nuclear Experience Review results will be inspected in the future. This item will be carried as an inspector followup item. (259/260/296/87-20-02).

8. Reportable Occurrences (90712,92700)

The below listed licensee events re) orts (LERs) were reviewed to determine i if the information provided met tRC requirements. The determination l included: adequacy of event description, verification of compliance with Technical Specifications and regulatory requirements, corrective action taken, existence of potential generic problems, reporting requirements satisfied, and the relative safety significance of each event. Additional in plant reviews and discussion with plant personnel, as appropriate, were _ _ ____ _-___ __ _ __ ____ - ___ -

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l conducte The following licensee event reports are closed:

i LER N Date Event'

260/78-14 6/27/87 Loss of High Pressure Coolant Injection (HPCI)PumpOperability 296/84-06 11/16/84 Jet Pump Instrument Nozzle Cracking ,

259/85-43 8/25/85 Inadvertent Scram 259/85-48 9/8/85 Inadvertent Scram 296/86-06 8/12/86 Welded Blank In Fire Protection Line 259/87-04 3/20/87 Accidental Bump of Radiation Monitor Output Cable Initiates Control Room Emergency Ventilation (CREV) System ,

The following licensee event reports were reviewed and remain open pending further review:

259/87-06 4/28/87 Impro3er Flow Testing of Control Room Emergency Ventilation 259/87-08 5/19/87 Failure of Potential Transformer Fuse Contacts The causedcause byofthe thefailure loss oftothe HPCI open thepump operability lubrication oil (line valve whichLER 260/78-14)

supplies oil to the pump and reduction gear resulting in pump failur All damaged p, ump parts were replaced. The HPCI oil system valve lineup was included in the HPCI operating instructio Tenweldsonthejetpumpinstrumentnozzles(LER 296/84-06) were examined and two weld were determined to need weld repair. The welds were repaired by the weld overlay procedur The inadvertent scrams (LER 259/85-43 and 85-48) occurred during the performance of a weekly surveillance instruction on the average power range monitors (APRM) when the APRM mode switch was placed in the standby positio The computer logs indicated that a half scram on the reactor protection system (RPS) produced by the previously tested APRM channel had not reset. The surveillance instruction was repeated but the failure of ,

the RPS channel to reset could not be reproduce To prevent recurrence

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the surveillance instruction was revised to add explicit steps to verify that the half scram is fully reset and the scram solenoid group indicating lights are illuminated before proceeding to test the next APRM channe _ _________-__ -

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The welded blank in the fire protection line (LER 296/86-06) was caused by system retrofits made in November 1977 when a pipe blank was welded in place to expedite testing and installation of the system. The pipe blank was removed and all cross mains in the. reactor building preaction systems were flushed and a 30 percent random sample of the branch lines in safety related preaction sprinkler systems were air teste The accidental bumping of a radiation monitor outaut cable which initiated the control room emergency ventilation system (C4EV) (LER 259/87-04) was caused by an assistant shift engineer who was working in the are The CREV system was secured and returned to standby statu LER Report 259/87-06 remains open. It was found to be deficient in a number of the requirements of 10 CFR 50.73. This event was the subject of an NRC inspection finding that resulted in a violation (see 259, 260, 296/87-14-02). The LER deficiencies are described below: No estimate was given of the elapsed time from discovery of the failure until the train was returned to servic No discussion was included regarding the cause of the personnel error related to the failure to properly zero test equipment prior to us Although the LER stated that further Control Room Emergency Ventilation (CREV) system studies are continuing, the supplemental re) ort expected block (number 14) was checked no and no expected su) mission date was provide Corrective Action for the failure to properly zero the test equipment was to instruct the involved personnel in correct procedures. This is unsatisfactory, as pointed out in NUREG 1022 Supplement 2. All personnel who may use the instrument should be instructed in its proper us The assessment of the safety consequences and implications of the event was inadequate in that failure to address whether the system could have fulfilled its function while train A was inoperable for maintenance and train B was unknowingly adjusted for low output flo Tha method of discovery was not included for the Technical Specifi-cation LC0 violation. This violation was actually discovered during an engineering review of a related event more than a month after the occurrence.

l These deficiencies were discussed with the author of the LER and the Plant Operations Review Staff (PORS) Supervisor on May 1,1987. This LER will be revise J LER Report 259/87-08 remains ope It failed to address the previous similar events at the same plant that are known to the licensee. This I report describes a failure of potential transformer (PT) fuse contacts in the Diesel Generator Control Cabine The licensee has had many identical

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failures of this type of fuse contact but most have been in non safety-relatedswitchgearandwasthereforenotreportable. Although the report states that "no previous reportable events' had occurred, a full discussion of the non-reportable occurrences is necessary in order to gain the full significance of the cjeneric aspects of this failure. In 1973, General Electric modified their switchgear to eliminate these types of contact The plant has embarked on a comprehensive inspection throughout the site to identify all similar contacts in use at the facilit In the Browns Ferry Nuclear Performance Plan (Volume 3), section 1.2.7, Site Licensing, the facility commits to using NUREG 1022 and its .

supplements to ensure the quality of its LER's. Correct implementation of  !

a recommendation in Supplement 2, regarding the use of a detailed checklist, a text outline, and independent review could have prevented the LER deficiencies identified above. A licensee representative . indicated that the need for a detailed LER checklist, which is more consistent with the recommendations of NUREG 1022, Supplement 2, would be considere . Quality Assurance Program On May 8,1987 the residents reviewed the status of the new method of reporting conditions adverse to quality implemented on March 31, 198 Conditions adverse to quality are reported on a condition adverse to quality report (CAQR). This system replaces the old system of corrective action reports (CARS) and discrepancy reports (DRs). The licensee's status of CAQ items ending May 4, 1987, is as follows:

Total Open Total Late % Delinquent CARS 102 4 DRs 134 47 3 CAQRs 183 75 4 ......

TOTAL 419 126 3 The site quality assurance organization a)peared to be tracking all items in a thorough manne The CARS, DRs, anc CAQRs were being tracked as to the applicable TVA division and section. An evaluation was being made of ,

the delinquent CAQRs. The site quality assurance organization makes a I presentation to the site director monthly on the overall status of the progra The program appears to have the necessary monitoring and review needed for an effective progra . Emergency Equipment Cooling Water System Check Valve Failures On April 24, 1987 the licensee found 24 check valves inoperable in the emergency equi,pment cooling water (EECW) syste An inspection was being  !

performed to implement ASME Section XI guidelines for the first time on i these valves. The valve disks were so heavily coated with hard deposits i

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that they would not clos Licensee event report (LER) 259/87011, Inadequate Inspection Program Results in Inoperable Check Valves in the EECWSystem,onthissubjectwasissuedMay 22, 198 After reviewing this LER the inspector felt that someone reading this LER might misinterpret the problem as a new phenomenon. The history of corrosion problems with carbon steel piping was known since pre-operatio-nal testing of the plan While conducting the EECW pre-operational test, the flow rates measured through 11 out of 12 core spray bearing coolers did not satisfy design requirements. A heavy deposit of silt and rest was found on the inner surface of the EECW piping associated with the cooler Engineering change notice (ECN) L1970 was written in 1977 to change all four-inch and smaller piping, valves, and fittings in the EECW system from carbon steel to stainless steel. While most of the piaing has been changed to stainless steel on all three units, only the lnit 2 piping and check valves have been completely changed ou ECN L1970 went through five revisions with last revision being a) proved in July 198 Delays in component changeout were mainly attributec to procurement problem Additionally, problems were noted with the EECW check valves to the diesel generators during the inspection for IE Bulletin 83-03. During the inspection of the units 1 and 2 diesel generators in October 1983, two of the EECW check valves were found frozen open by crud, and two of the check valves would not operate through the full design range of the flapper swing. One of the check valves was cleaned and returned to service. The other three check valves were replaced. All of the diesel generator check valves were replaced with stainless steel type during the 1984-1985 time frame.

11. Configuration Management Program /CCD Inspection Browns Ferry Nuclear (BFN) Plant has experienced problems with the control l of design changes and plant modifications. Weaknesses have been identified in the depth and documentation of engineering work for design changes and in maintaining consistency between "n-configured" and

"as-designed" information. TVA recognized that its design, program was weak and identified several major areas tc be addressed in its implementa- ,

tion of a design baseline and design chcnge control program. This program '

is designed to ensure that the actual plant configuration is reflected on .

plant documents and conforms to design documents. The engineering depth l and documentation weaknesses derive from the following root causes: ) by-drawing BFN basis.hasThis performed system of plant desig,ndesign releasing modifications drawingson a drawingifficult made it d to establish the USQD (Unreviewed Safety Question Determination) of the final design configuration. The drawing-by-drawing approach made the comprehensive review difficult and resulted in many more problems for the designs being generated by different discipline design gr,oup ,

With each discipline group releasing its drawings to Modifications at different times, it is difficult to resolve design conflicts between

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'10 groups before construction begin This increases field problems with the desig i The large volume of modifications work in combination with the I associated prioritization of changes, planning, issuance, and control of design change packages, field implementation activities, documentation of completed design changes has presented a significant challenge to managemen In the past, BFN has not consistently followed through with the

)aperwork for plant change For example, workplans have been put on

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lold after work began and left on hold indefinitely. The design organization failed to incorporate field change requests into the design drawings in a timely manner, BFN has empiped a design control program using two separate drawings, an as-constructed" drawing maintained by the plant and an

"as-designed" drawing maintained by DNE. This has led to-inconsistencies in configuration information versus design information verus design information. Additional problems with the two-drawing , system are numerous, with the primary problem being the difficulty in establishing the design basis for the "as-constructed" drawing because modifications may be implemented out of seg'uence with design. There are also problems with the "as-constructed drawing not reflecting the plant s configuration due to workplans on hold, temporary alteration control forms (TACF), partially implemented workplans, and the time lag involved in closing some workplan Design criteria and design basis information have not been kept up to date and are difficult to utiliz The large scope of individual engineering change notices (ECN) and the number of workplans have been a proble Some modifications may take several outages to accomplis These root causes have been addressed in detail with the design baseline verification program. This program was established to assess the adequacy  ;

of past modifications work and correct deficiencies. Specific design control issues addressed include: Verification of actual plant configuratio Reconciliation to engineering design documents including sup-porting calculations and design criteri Reconciliation to the FSAR, licensing requirements, and Techni-cal Specification Performance of Safety Evaluation Reports and Unreviewed Safety Question Determinations (USQD) for system configuratio Issuance of revised key plant drawings which are essential for plant operation _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -

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A special team inspection was conducted on May 18-22, 1987, to evaluate the drawing upgrade portion of this program identified in item (e) abov The as-constructed plant flow diagrams, control diagrams, single-line electrical drawings, valve tabulations, and instrument tabulations for the systems as identified in NPP, Volume 3 were walked down, deviations were l reconciled within the TVA design organizations, and the drawings were u3 dated to match the actual plant functional configuration by TVA. After tie as-constructed drawings are updated to reflect the plant configuration and differences reconciled, they are issued as Configuration Control Drawings (CCD). The CCDs are unit specific and replace both the as-constructed used by operations and the as-designed drawings used by engineering with a single drawing system. The CCDs then become the drawings used for all engineering and operations activities. When issued eachnewCCDimmediatelysupercedestheold"asconstructed" drawing. The CCDs will replace the as designed" drawings only after validation when each system evaluation is complete. No drawings will be considered validated in accordance with SDSP 9.2 until the system is completely field verified and design evaluated. The evaluation process was scheduled to start in April 1987 and be complete by June 30, 1987, and any identified plant modification work is to be completed during the second half of 198 The inspectors reviewed the following Unit 2 and comon system CCDs as part of the inspection:

Reactor Core Isolation Cooling Residual Heat Removal Service Water System Diesel Generator Auxiliaries Standby Liquid Control System Core Spray System Control Rod Drive Radwaste System Containment Atmosphere Dilution Standby Gas Treatment System HVAC System The inspectors performed walkdowns of selected portions of the above systems comparing the newly issued CCDs with the actual hardware configuration. The functional utility of the drawings appeared to be much better than the drawings that were being replace Inspection findings and comments were divided into two catego, ries; generic implications and specific system deficiencies. The following generic implications were noted:

1) Operator Training General discussions with plant operators revealed that the operator's knowledge of the new CCD program was minima The operators ques-tioned had had no formal training classes on the progra In parti-cular the method used for the unit designation of drawings was not know Site Director Standard Practice 9.2, Configuration

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Control Drawings gives the following method: ,

0 - Common 1 - Unit 1 2 - Unit 2 3 - Unit 3 i 4 - Units 1&2

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5 - Units 1&3 6 - Units 2&3 7 - Units 1&2&3 Formal training for the operators will be completed prior to startup as noted by the Unit 2 Superintenden ) Discussions with plant personnel and problems detected during the inspection revealed a concern abcut the verification of drawing note Site Directors Standard Practice 9.6, Mechanical and Instrument and Controls System Walkdowns, lists 16 criteria and requirements for the initial walkdowns. Criterion 16 requires that drawing notes are accurate as applicable to the first 11 criteri Which notes be applicable and how this requirement was fulfilled was not clear. During the CCD validation process all notes should be verifie This verification should be completed prior to Unit 2 startu ) Housekeeping at the plant stack and in the Unit ~2 supply fan room was-not in keeping with typical plant standards. Additionally, the inspector questioned the potential fire hazard at the plant stack due to the temporary storage of forty drums of oil, paint thinners, and fuels and four drums of aci ) The Standby Gas Treatment System blower "C" seismic mounting should be verified since the inspector noted several loose blower foundation bolts and an incorrect angle on a foundation support spring attachmen ) System engineers should continue to verify their res CCD's when issued to note minor drawing deficiencie pective This was noted system as a beneficial and successful program aspect leading to prompt self-identification before audit ) "Out-of-Function" drawing updates should have a program to assure CCD revisions are correct after modifications and alterations are made or removed. Paragraph (f) below further delineates thi-s concer ) Some new identification tags recently hung could potentially l interfere with system operation. (i.e. damper linkages on SBGT system) Overall, the new valve and system labelling program is excellent as an operations and engineering ai All CCD systems will be relabeled prior to Unit 2 startu ) Management control in this program area was much improved over past inspections in this area. Program managers were familiar with system i

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histories, walkdown status, program deficiencies, and projected goal System engineer knowledge and interest was also noted to be a positive program attribut Specific system discussions and deficiencies are noted below: Diesel Generator Auxiliaries CCD 4-47E861-6, R000, Flow Diagram, Cooling System & Lubricating System Standby Diesel Generator B, Units 1 & 2, was compared to the plant hardware. The inspector noted that no components have been labeled under the new component identification / labeling program and many components have no identification at all. However, the drawing did match the actual hardware configuration with one minor exceptio Four small sections of 3/8" air tubing are shown on the drawing associated with the air starting motors but the actual tubing appears to be 1/4".

CCD 4-47E861-2, R001, Flow Diagram, Diesel Starting Air System Standby Diesel Generator B, Units 1 & 2, was compared to the plant l hardware. The inspector noted no major discrepancies. No control diagrams (610 series drawing) exist for this system and all instrumentation and controls are shown on the flow diagra The inspector noted that check valves 86-501B and 86-521B were denoted as not being verified. This is due to the physical design of the check valves which makes them appear to be no more than a oipe couplin However the inspector was informed during a previous inspection associated with an earlier revision of the drawing that testing had been performed which demonstrated the existence and operability of these check valve CCDs 0-47E840-1, R000, 0-47E840-2, R000, 0-47E840-3, R000, Flow Diagrams Fuel Oil System, 3-47E610-18-2, R000 and 3-47E610-18-2, R000, Mechanical Control Diagrams Fuel Oil System, were compared to the plant hardware. Theinspectornotednomajordiscrepancies. The new identification labels are not installed on system component The inspector noted that the 1/2 inch vent valve located on the transfer pump discharge line,18-541, that was required to be locked closed had no locking device attache The operator that accompanied the inspector agreed that the valve should be locked, notified the control room and obtained a locking device. Additionally, the inspector noted that two CAQRs (Conditions Adverse to Quality) had been recently issued concerning, the new CCDs on this system. CAQR BFP870223 identified that drawing 0-47E840-3 R0 had been issued without drawing discrepancy 2-86-1009 being implemented in its entirety resulting in several errors on the issued drawing. CAQR BFP870224 identified that drawing 0-47E840-3 R0 had been issued reflecting two pressure switches as being branch connections from the fuel oil system. Further investigation by the licensee revealeo that these pressure switches were not verifiabl ____ - ___ -

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b. Standby-Liquid Control CCD 2-47E854-1, R000, Flow Diagram, Standby Liquid Control System, Unit 2, was compared to the plant hardware.- The inspector noted no major discrepancies between the drawing and the actual configuratio No reference is made for one of two lines entering the top of the SLC tank. The line in question is for connecting demineralized water to the tank. The inspectors had been informed by licensee personnel that the component labeling effort for this system was complete however several valves and the drywell penetration, X-42, were noted without any component ID attached. . Manual valve 63-532, Demin Water Isol. to Test Tank, was shown on the drawing as requiring a normal position of locked closed but the valve check list (pa,ge 30 of 37, 01-63) only required the valve to be closed. The inspector determined that the position shown on the drawing was due to a recent change resulting from operations review of the CCD and that the valve position is to be changed to agree with the drawing in an upcoming revision to the Operating Instruction, 01-63. The SLC tank level indication (bubbler) was not shown on the drawing. No mention of the tank penetration for the level indication was made nor any reference to any other drawing which might contain such information. However CCD 2-47E610-63-1, R000, Mechanical Control Diagram SLC System, did show the tank level indicatio c. RHR Service Water The inspector completed a walkdown verification of portions of the residual heat removal service water (RHRSW) syste The walkdown concentrated on unit 2 conponents with an objective to verify that plant drawings represented what is actually in the plant. Both control (0-47E610-23-21 and flow (1-47E858-1 and 2-47E858-1) drawings were compared with actual plant configuration. The walkdown was 4 started at the intake structure, RHR SW pumas A1, 2(removed), & 3, I and B1, 2 & 3, proceeded to the RHR SW tunnels 1A & C and 2A & C, and ended in the unit 2 reactor building and RHR heat exchanger room Additionally, the inspector reviewed system material condition and plant cleanliness. No significant discrepancies were noted between the , plant as-built configuration and the configuration control-drawings referenced abov Approximately half of the RHR SW system components have been labeled with the new labeling plates. In general, system component material condition appeared good. The licensee has been notified of several minor deficiencies identified i by the inspector. Corrective action was promptly initiated, d. Control Rod Drive System The inspector performed an independent walkdown of selected portions of this system to compare the recently completed CCD drawings to the actual plant configuration. No major problems were noted. Several minor deficiencies were noted and corrective action was initiated by i

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the : licensee to correct the item The items are denoted by the-applicable drawin CCD 2-47E810-1, Flow Diagram, Reactor Water Cleanup System, was -

checked and valves labeled 85-269 and 85-270 ware shown as 85-6002 and.85-6003 on the drawing. The system engineer had identified.this same problem after the CCD had been issued and.was taking steps .to

~ correct the labeling of the valves. Valves85-269 and 85-270 were p used elsewhere in-the system and the drawing numbers were. correc ;

CCD. 2-47E820-2, Flow Diagram, Control Rod Drive Hydraulic System was

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-checked and the following noted:

? the hose connection for the drive water.

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. (1) Detail 2A2and filter vent showing dra in did not reflect the plant configuratio The system engineer. stated this detail on the drawing would be -

delete (2) The portable accumulator nitrogen charging system B was not 1 correctly' represented. The section of hose and piping between valves85-32B and 85-61C could not be located on the charging system. A licensee representative stated the portable systems were often scavenged during an outage but would be checked as part of the startup check (3) Written in a clear space on the drawing was note stating,

" Indicates self-sealing quick disconnect but no symbol or note-number telling what the note referenced could be found. This was thought to be a drafting error by the licensee and would be correcte (4) Several valves such as 85-23 and 85-27 were marked with an asterisk which meant that the valve type was not verifie However, the nameplate data was on the side of the valve which should lead to easy verification. The system engineer stated this was due because the vendor manual could not be located and quality assurance would not accept nameplate data only to identify the valve typ (5) A spool piece was indicated as a spool piece with strainer in parenthesi No strainer was apparen The licensee stated this was to indicate a strainer could be in place during testing or flushin (6) Valves85-20A, 85-208,85-21A, and 85-21B were drawn using a symbol designation for a solenoid operated valve with a built-in flow control valve. However, these valves were also indicated as the valve type not being verified. The licensee stated this designation woutd be clarifie .

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CCD -7-47E820-1, Flow Diagram, Control Rod Drive Hydraulic System was traced and one temporary alteration was found that needed to be updated. Connecting tubing and valves connecting to test connection at valve 85-507A was not as draw e. Radwaste System CCD 7-47E830-5, Flow Diagram Radwaste was checked and valves 1-77-929 -i and 3-77-931 were found not labeled. The licensee provided a copy of maintenance request A-754822 which previously identified these as missing label f. Containment Atmosphere Dilution (CAD)

The CAD CCD presented an example of a potential problem needing close attention by the licensee. The issue raised was how to assure update of "out of function" components added to the new drawing In order to assist the operators in establishing equipment tagout clearance boundaries, hydraulic and pneumatic components normally not shown on the process flow diagrams were added to the CCD. The components are which would normally be a duplicatedcontrol mechanical on thediagra " controlling drawing"ial problem arises from The potent the modification work plans and temporary alterations outstanding which had not identified these components on the older drawings and therefore did not identify the necessity for updating these drawing Several licensee representatives indicated that they were knowledgeable regarding this problem and had conceptual plans for additional control features. The control will most likely be in the form of an interface review in the Division of Nuclear Engineering (DNE) which would ensure that the mechanical disci,pline is involved in all drawing changes which affect instrumentation and control drawing The specific example of this problem was detected on drawing 2-47E862-1, Flow Diagram Containment Atmosphere Dilution System where details 2A1 and 2B1 added the backup pneumatic supply function of the CAD System to containment isolation valves. Although a temporary alteration was installed and accurately depicted on the drawing, the temporary alteration control number (TACF#) was not shown on the drawing, nor was the drawing referenced in the temporary alteration control form. Thus, there was no mechanism to insure the drawing would be changed after the temporar Additional problems with the CAD systems CCD'y were: alteration is remove (1) Continuation markings which depict transfer between drawings 2-47E862-1 (CAD Flow Diagram) and 2-47E865-12 (Reactor Building HVAC Flow Diagram) were confusing and could not be fully understood by the inspector or the licensee's system enginee (2) Drawing 2-47E865-12 indicates that Note 4 is applicable to several components on the drawing; however, no Note 4 could be found on the drawin _ _ _ _ _ _ _ _ -

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. 17 (3) Drawing 1-47E862-1 shows components common to all three units as well as . components specific to only Unit 1. The licensee's scheme for prefix numbers is not totally clear on this issue but the prefix should more accurately be zero (0) to indicate the common equipment. This single drawing may have to be split into two separate drawings in order to maintain core istency with the numbering schem (4) A problem was found with the stenciled identification on a 2-inch CAD vent line near FCV 84-2 Both the nomenclature and flow arrows were inaccurat (5) The half-inch line between test valve 84-126 and the process piping did not properly connec Reactor Core Isolation Cooling (RCIC)

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Several problems were found with drawing 2-47E813-1 which had previously been identified by the licensee's system engineer. The inspector reviewed the drawing discrepancy (DD) which was generated to correct the problems. Another stenciling problem was found on an instrument line between the core spray drain pump and PT 75-63. This line was incorrectly marked "RCIC Water". l Core Spray (CS)

a During temporarythe sampling licensee'srig walkdown consisting of of theacore spray flanged (CS) system,ible correction, flex hose and a one gallon poly bottle was connected to the head tan This rig was added to the CCD drawing. During the inspection walkdown of the drawing, the temporary rig was no longer presen The licensee was aware that temporary equipment may showup on the drawings after their " snapshot" walkdown. System engineer walkdowns of the drawings should correct these types of deficiencie An in process EQ modification lead to one discrepancy which routinely should be corrected by the work plan closecut process. ECN P3098 added FE 75-81, FS 75-81, FE 75-80, and FS 75-80 to the syste These components were not consistently de)icted when the CCD drawing i was developed. The flow elements were cepicted in-line with the process flow on loop 11 but were shown tapping off of a stub-tube on loop I. This applies to 2-47E610-75- Heating and Ventilation Air Flow Unit 2/CCD 2-47E865-12, Unit 2 - Heating and Ventilating Air Flow, was compared to the plant configuration. FC0 64-2B should be i designated PDC 0 64-2B. System labels were not hung on all system components to date. Labels will be hung as part of the ongoing labeling progra Standby Gas Treatment System  ;

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CCD'0-47E610-65-1 and CCD 0-47E865-11, Standby Gas Treatment System,.

were compared to plant configuration. New labels were noted on system damper linkages that could affect operability. The D0P and

~ freoa injection sample line connections were not labeled and were not scheduled tp be labeled. Label errors were 'noted on HS30-184, HS30-190 and similar building supply for switches. "C" SBGT blower mounting apparatus was loose. All deficiencies were discussed with plant management,

'Overall, the design implementation is satisfactorily in relation to the CCD upgrade progra The Unit 2 turbine floor and equipment area rooms were noted to have good housekeeping and preservation program . Contractor Recommendations The licensee contracted with several outside consultants to perform various' evaluations as part of the Regulatory Performance Improvement Program (RPIP). -The RPIP was imposed by Confirmatory Order (EA 84-54) on July 13, 1984.. In July 1985, the resident inspector followed up on one of these contracts and documented the results in Inspection Report 259, 260, 296/85-39. Basically, the inspection found that the licensee had not developed a coordinated program for resolution of the numerous deficiencies and recommendations identified by the contractors (Unresolved Item 85-39-04). Continued overall poor performance by the licensee led to a Request for- Information aersuant to 10CFR50.54(f) on September 17, 1985, in order to determine _ w1 ether or not the facility licenses should be modified or supspended. In this request the NRC asked for an evaluation and proposed' disposition of contractor recommendations. TVA' responded to

.the request in the Browns Ferry Nuclear Performance Plan (Volume '3),

' Appendix B, Evaluation of Contractor Recommendations. During this reporting period the inspector selected several contractor recommendations for- review of the licensee's actions. In way of clarification, these recommendations consist of the following subjects (as excerpted from revision 12oftheRPIP): Utilize outside contractor (GE) to:

(1) Evaluate NSSS operation. This includes normal operation surveillance procedures and shift activitie (2) Evaluate plant trip history and present test methods to assure causes of plant trips have been correctly identified and corrective action take ;

(3) Evaluate outage scope and duratio Utilize outside contractor (SAI) to perform evaluation of:

(1) Implementation of technical specification changes since January 1, 198 (2) Technical Specification in place prior to January 1,1980, to )

verify adequate implementation (by sample). l

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. 19 Contract outside utility (IMPELL) and perform evaluation of modification program, Utilize outside contract (MAC) to:

(1) Evaluate administrative burden on the plan (2) Evaluate RPI This month's inspection activities were focused on item 1, GE recommenda-tions. The first activit list of recommendations. yThe was a verification of the computer tracking Nuclear Performance Plan (NPP) states that the recommendations are tracked on a computer listing showing open/close implementation status and required for restart status. About one-third of the line items reviewed failed to indicate if the item was a restart requiremen Several completion dates shown on the printout were inaccurate, either showing a date in the future (such as 11/6/87 for Sy/26/75 for System 74 item 9).But 9 stem the74 itemconcern major numbers 1,3, and relates 7) or a date in t to the l comprehensiveness of the list itself. As detailed in the system-specific reviews that follow, several findings made by the contractors were not placed on the computer tracking list. For example, it was pointed out that due to an abnormally wide reset band on the shutdown cooling ,

interlock pressure switch, operators had to routinely reduce reactor '

pressure to less than 20 psig while cooling down the plant before the reset wruld allow entry into the shutdown cooling mode of RHR. The setpoint of this switch is 100 psig. A recommendation was made to change to a switch having a 5 ps,ig reset band and several manufacturers and models were suggested. This recommendation did not get evaluated by the Plant Operations Review Committee (PORC). The BFN NPP stated that PORC reviewed and approved all dispositions of the contractor recommendation Licensee representatives confirmed that not all items identified by the GE reviewers were placed on the tracking list. It was essentially up to the j judgment of the cognizant engineer as to which items were placed on the 1 lis Some individuals placed everything on the list even including tagging and labeling problems on component Whereas other individuals I only placed items on the list that presented a clear hazard to the safety of the plant. This inconsistency makes the tracking list less useful to an audito The actual system review documents must be reviewed to obtain the actual recommendations. On the example above, the inspector learned that a Design Change Request (DCR) had been submitted on the pressure switch but that it was subsequently cancelled. The extent of PORC's involvement in those decisions is unknow One further general observation of the program relates to the progress (or ,

lack of progress) on the many material deficiencies found during the system )

walkdowns. These items range from missing labels, burned-out indicator lamps, dirty rotameter flow tubes, low oil level in bearing sight glasses, etc. on which Maintenance Requests (MRs) were written. Although some of l these items are up to 3 years old and have been tracked by PORC and the  !

system engineers, they remain uncorrected. This raises the question of how readily the plant can correct minor deficiencies of a routine nature.

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The following items discussed in the RHR System Review Report could not be located on the computer tracking list: BFN has no policy or procedure related to two-valve protection requirements in general and specifically as it relates to surveil-lances such as pump and valve operability and flow test Operators identified a problem with the wide trip reset band of the 100 psig shutdown cooling interlock pressure switch. All units must depressurize to less than 20 psi,g to reset the interlock. GE recommended a 10-15 psi switch with a 5 psig reset band (as opposed to the current 50-1200 psi switch). )erators routinely exceed 125 degree F. alarm setpoint while in slutdown cooling with little decay heat. This may result in piping exceeding design temperatures & excessive heat exchanger foulin Several recommendations were made to avoid this, It was noted that the use of red and yellow tape on control room meters as an operator aid was inconsistent within and among unit The following items discussed in the Off-Gas System Review Report could not be located on the computer tracking list: SIL to allev 263,iate problems experienced at BFNP. Modifications to Improve Mo SIL 264, Modification to Improve Flow Sensor. The present sensor location results in erroneously high stack release rate calculation SIL 246, Control of combustion in Offgas System. Additions were recommended to abnormal section of Operating Instructions to extinguish the sustained combustio S.I. 4.8.B.1.a, Airborne Effluent release rate log was poorly laid out and in need of human engineerin One of the recommendations made by SAI in their evaluation of the I technical specifications was inspected this month. From the NPP, Appendix B, this recommendation was as follows:

Establish a " Required Technical Specification Action" Data Base to identify required actions when: Limiting Conditions for Operation (LCO) and surveillance limits are exceede j Equipment or systems are inoperable.

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, 21 BFN Response '

A computer based system is now available with capability to perform this task on a limited basis. Full implementation of this recom-mendedactivityisjudgednotnecessar i The inspector conducted a thorough search for this limited syste Discussions with site licensing, plant management, and senior operators indicated that this system was so " limited" that it could not be foun Some licensee representatives, however, did indicate that such a system is available on the open market that would allow the operator to determine action statement and LC0 requirement ,

Although this is not a significant item, it is another example found recently where TVA commitments and statements made in the NPP Volume 3, may not be completely clarified and could lead an auditor to erroneous 4 conclusion ;

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