IR 05000259/1987027
| ML20238E344 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 08/31/1987 |
| From: | Bearden W, Brooks C, Crlenjak R, Girard E, Ignatonis A, Andrea Johnson, Patterson C, Paulk G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20238E313 | List: |
| References | |
| 50-259-87-27, 50-260-87-27, 50-296-87-27, NUDOCS 8709140286 | |
| Download: ML20238E344 (32) | |
Text
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ATLANTA, GEORGI A 30323 %g..v ,[ ... I Report Nos.: 50-259/87-27, 50-260/87-27, and 50-296/87-27 Licensee: Tennessee Valley Authority
6N 38A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 l 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 Inspection Conducted: July 1-31, 1987 , Inspectors: k44Mtb%d.
[cm 8/47/87 G. L. Paul'K, Senior Residhnt Unspector Date' Signed k h S v a + b $ h-t sbr //D ' C. A. Patt(erson, Reside Q In4pector Date' Signed Rathed
_3 h7/77 C. R. Brobs, Resident IMsped.or D6te Signed $$$h j-wwh b:, S/27/Q_ R. V. Crl@;njak, Senior Residhnt Inspector, D' ate Signed ' St. Lucie - W)%h 8/R7/97 A. H. Joh'nson, Project f(nbineer Da'te Signed $h $/.f.E2/T ] A-w ~ .. W.C.Beatben,ResidentVInsyctor, D' ate Signed Bellefonte 6h b I/R7/21 a E. H. Gitsrd, Reactor Unspektor Date Signed Approved by: 6 d-f[7//?'7 +re A. J. Cfgnat6pfis, Section Chief, . Date S'ign6d ~ , Inspection Programs, TVA Projects Div % ion SUMMARY Scope: This routine inspection was in the areas of operational safety,. maintenance observation, surveillance testing observation, previous enforcement matters, reportable occurrences, Nuclear Safety Review Board, engineering change notice program status, vendor manual control, restart testing, 8709140286 870902 PDR ADOCK 05000259 G PDR
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-{ s-a j maintenance improvement prcgram,, radioactive by product material control, operating instruction revien inservice testing of pumps and valves, and seismic anchorage concerns.
j , n ,Results: One violation was identified for failure to maintain a current and i correct inventory of radioactive. byproduct material and other byproduct . material program requirements as specified in SDSP.23.2.
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Licensee Employees Contacted H. G. Pomrehn, Site Director
- J. G. Walker, Deputy Site Director P. J. Speidel, Project Engineer
- J. D. Martin, Assistant to the Plant Manager
- 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. Carier, Compliance Supervisor A. W. Sorrell, Health Physics Supervisor R. M. Tuttle, Site Security Manager J. R. Kern, Fire Protection Supervisor Other licensee employees contacted included licensed reactor operators, auxiliary operators, craftsmen, technicians, public safety officers, quality assurance, design and engineering personnel.
- Attended exit interview 2.
Exit Interview (30703) The inspection scope and findings were summarized on July 31, 1987, with the Plant Manager and/or Superintendents and other members of his staff.
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 inspection.
, 3.
Licensee Action on Previous Enforcement. Matters (92702) (Closed) Violation (259,260,296/85-45-05) This violation was against 10 CFR 50, Appendix B, Criterion XVI for failure to take corrective action for a diesel generator false start. The followup item was to review the final failure evaluation report. Maintenance was performed on the diesel immediately after it failed to start; and 'the diesel performed as required.
However, the cause of the original failure to start was not determined, documented, or reported to management..The governor was suspect and was sent to the vendor for inspection.
The vendor. found , nothing that would have prevented the governor from operating normally. A video recorder camera was positioned to monitor the movement of the engine fuel rack, fuel pressures, air pressures, and the engine push buttons during starts.
No other start failures have occurred. The six year maintenance has been performed on this diesel and no problems noted.
These facts were documented in a failure investigation report (85-100) to management.
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i There have been 23 successful fast starts since this failure. Tlis item is closed.
(Closed) Inspector Followup Item (259/84-26-14) The inspector questioned what Quality Assurance controls applied during maintenance of "open systems" to verify foreign mterial is excluded. During a routine tour of the Standby Liquid Control pump for Unit 2, maintenance was ongoing with the system fully opened in all respects and no person or work boundary was .; I ' noted at the work site to prevent any foreign intrusion. Browns: Ferry (BF) Standard Practice 3.10, Cleanliness of Fluid iSystems was revised ' April 7,. '.987, to require evalue fion and, when necessary, the application , of eethods to exclude foreign articles from critical pipingrsystems.
The Mechanical Technical section revised mechanical sinteriance instructions which opr:.n critical structures, systems, aral:orponents piping systems tc i include caution notations to assure compliance with ' BF 3.10.
The.
' inspector neviewed the rpplicable procedures.
This iten Ms closed.
, .(Closed) Violation (259,260,296/85-45-01) This violation was against i 10 CFR 50. Appendix B, instructions, Procedures, and Drawings with foer ) examples.
The first example was for failure to maintain the Heacter Protection System (RPS) Circuitry as prescribed in drawing 791E247-2A Rev. 22. TVA corrected the discrepancies with terminal block jumper link and fireproof metallic enclosures.
Copies of the maintenance requests to accomplish ! this work were reytwed.
The remaining RPS panels were inspected' for similar problems. Maintenance and modifications personnel were instructe6 regarding nroper installation " practices with regard to drawing details, Une inspector rwiewed the training attendance records. The violation was placed i n the monthly compliance training bulletin.
Each section supervisor is requirec' to assure the items in the belletin are reviewed face-to-face with their employees.
This example is closed.
l The, second example was for failure to maintain surv9111ance instructGn l tut data as required for quality assurance records with a lifetime
retention period. No Surveillance Instruction 4.9.A.1.a, Diesel Generater> l ^, < Monthly Test,. which was performed on units 1 and 2B Diesei' Generator ca l August 27 ano August 28, 1985, could be found.
The ' licensee issued a, I memorandum to. all operatiuns personnel to emphasize the procedures for J handling test deficiencies and incomplete surveillance instructions.
x Standard Practice 17.9, Surveillance P. requirements Prograin, was clarified to accuratch der,cribe proper han6 ting of surveillar/:e 1 packages.
This item was aho included in the monthly compliance tolhtin. The inmector
reviewed the operations memorandum, revised studard practice, and l compliance bulletin.
This example is closed.
The third uample was for failure to use a Plant Operations Review Committee (PORC) approved maintenance request whuv performing detailed j > step-by-step work instructions on safety related eactoment. The licensee ) , l did not agree that a violation had occurred but farther review by the NRC ' concluded a vfolation had occurrecs (J. A. 01sh mski's letter to ! - ' . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ & - _ - - -
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S. A. White dated April 18. 1986). TVA concluded that a new " Conduct of Maintenance" procedure, PMI 6.2, should prevent further violations. This procedure was distributed to all maintenance and modification personnel through the responsible Section Supervisor.
The inspector reviewed this procedure.
It gives a listing of the type of activities which can be considered as skill of the craft.
This example is closed.
The fourth example was that the plant operating instructions did not address the operation of the containment purge system charcoal bed heaters.
TVA concluded that both the operating instructions and training appear to have beer suffering from a lack of emphasis.
Operating Instruction, 0I-64, Primary Containment System was revised to include proper operation of the charcoal heaters.
The inspector reviewed 0I-64 and training lesson plan changes. This example is closed. This violation is closed.
(Closed) Violation (259,260,296/85-57-11) This violation was against 10 CFR 50, Appendix B, Criterion II for failure to carry out the Quality Assurance Program for inspection of six fuel channels. The fuel channels were found stored outside instead of inside as required.
Receipt inspection requirements were not followed in that the inspection personnel were not certified fuel receipt inspectors, the inspection was not documented on Attachment 4 of the Fuel and Component Receipt Inspection Master Checkoff Log, excessive chloride contamination on one of the fuel channels was not documented on the Site Fuel Discrepancy Report or resolution reviewed and approved by the appropriate personnel.
In response to the violation TVA conducted training for the maintenance foreman concerning this violation.
Tha fuel channels were inspected, cleaned, and returned to stores. Copies of the completed Master Checkoff and Site Fuel Discrepancy Report were provided to the inspector for review.
This item is closed.
(Closed) Inspector Followup Item-(259/84-26-12) This item was that the demineralized water system drawings do not reflect the plant ! configuration.
The mechanical flow (47E800 series), Instrument and Control (47E610 series) and associated valve tabulations (47B365 and 366 series) for the Demineralized Water system were walked down in accordance with BF-SDSP-9.6, Mechanical and Instrument and Controls System walkdowns.
This was completed May 26, 1987. The inspector reviewed a sample of these drawings and noted no discrepancies. This item is closed.
(Closed) Violation (259,260,296/86-36-05) This item was for failure to specify procedure changes or include a summary of the safety evaluation for each during the annual report as required by 10 CFR 50.59(6).
The licensee submitted on May 1,1987, a supplemental annual operating report for 1985 which reported changed procedures. Stated in the response to the violation is that TVA plans to review and report procedure changes for the 1986 annual operating report. This item is closed.
(Closed) Unresolved Item (259/85-49-07) This item concerned the appointment of members to the Nuclear Safety Review Board (NSRB) and the
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) quantity and quality of items reviewed.
Each of these items were j addressed by the past Chairman of the NSRB in a letter to the Plant Manager on June 11, 1986. Members are appointed for two year terms and serve until relieved.
Their appointment does not automatically expire after two years.
The inspector reviewed the letter to the Plant Manager concerning all of these items and has no further questions. Additionally, a meeting was conducted on site on July 6,1987, with the current NSRB chairman. The makeup of the present membership and NSRB reviews was discussed.
This item is closed.
(Closed) Inspector Followup Item (259,260,296/85-53-03) This item was that the unit three fuel oil day tank level indicators were not included
in the Systems Instrument Maintenance Instruction (SIMI-18) for ' calibration.
Unit One and Two level indicators were in SIMI-18.
The licensee revised the instruction to include the missing level indicators.
{ The inspector reviewed the revision and has no further questions. This j item is closed.
(Closed) Inspector Followup Item (259/84-52-05) This item was to review
the inspection of the Reactor Core Isolation Cooling Inboard Steam ' Isolation Valve 1-FCV-71-2. On March 21, 1984, the valve failed to open against operating pressure.
The licensee committed in Licensee Event Report 50-259/84018 to inspect the valve on the next short or refueling i outage.
Valve 71-2 was disassembled, inspected, reassembled and tested i per maintenance request MRA260409.
No defects were found. The operator worked good in both the manual and electric mode. An inspector followup item 84-52-06 remains open regarding the procedure for reopening this , l valve after maintenance. The inspection followup item is closed.
l (Closed) Unresolved Item (259,260,296/85-45-03) This item concerned the ' vacuum breaking system (VBS) associated with the condenser circulating water system. The inspector's concerns were that the VBS was not on the l critical system and components list (CSSC), instrumentation was not on a
program for periodic testing, the operator training lesson plan did not
identify the VBS as an engineered safeguard, and the Radiological ) Emergency Procedures contained no implementing procedure in event of a ) breach of Wheeler Dam.
The licensee took action to resolve all of these ' items. First, the inspector reviewed the CSSC list in standard practice BF 1.11 and the VBS had been added to the list. Calibration instructions i SIM I-27 was revised to include instrumentation for the VBS for periodic I calibration.
The inspector read a revised training lesson plan which provided a more detailed description of the VBS.
Emergency Plans Manual (EPM-7), Breach of Wheeler Dam was issued to specify actions in the event i of a breach of the Wheeler Dam.
A separate violation 259, 260, l 296/85-45-02 was issued for failure to maintain drawings of the VBS. This unresolved item is closed.
J (Closed) Violation (259,260,296/84-34-07) This violation was for failure I to require independent verification that the circuit breaker for core ) spray containment isolation valve (FCV 75-25) was opened as required by - ' procedure. The failure to open the circuit breaker for FCV-75-25 resulted I i - _ ~ _ _ _ _ _ _ _
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in the overpressurization of the core spray loop for approximately_15 minutes until this abnormal plant. condition was discovered.
During the original formulation of the ' surveillance 1nstruction ' independent verification was not required.
TVA has implemented a comprehensive program of second party ' verification.
Browns Ferry Standard Practice 3.11, Second-Person Verification, implements this requirement.
The.- following revised procedures were reviewed for second party verification: _ SI 4.28-39A Core Spray System Logic Functional Test SI 4.2.8-40A RCIC System Logic Functional Test SI 4.2.B-42A Instrumentation That Initiates or Con'trols the 'CSCS ' HPCI System SI 4.2.B4.45A LPCI - System Logic Also, the section instruction letters dealing with second person verification for the operations, fire protection, electrical maintenance, instrument, system engineers,- mechanical maintenance, and modifications groups were reviewed.
Samples of training attendance records 'on second-party verification were checked. A program for second party verification is in place.
This item is closed.
(Closed) Violation (259,260,296/86-32-07) This violation was for failure to document test deficiencies during testing as required by Browns Ferry Standard Practice BF-10.9, Handling of Test Deficiencies.
During performance of the emergency equipment cooling water system annual. flow q rate test, problems occurred with the operation of.the cross-connect-J valves (67-50) to the reactor building closed cooling water systems.. The problems were not noted_in the completed data sheets and no problems were indicated on the cover sheet of ' the test instructions.
Maintenance requests ( A-755513 and A-753912) were written to. correct problems with the q valves. Training was conducted for operations personnel in the handling of test deficiencies. The inspector reviewed the lesson plan covering i test deficiencies and the operator. training attendance sheets..This item is closed.
, i (Closed) Violation (260/80-37-01) This item was for failure to perform a J 10 CFR 50.59 safety evaluation for operation of the unit with the tcrus i access shield plugs not installed. TVA stated in their response that the j shield plugs were installed and had been marked to. indicate that they i cannot be removed with the plant at power. The inspector checked several. l of the shield plugs and found them stenciled as stated in the_ reply.
Changes were made to plant modification instruction to. provide more .i operations interface-and review of workplans. 'The shift engineer is required to verify that equipment removed from ' service.is returned to i service. This item is closed, i -! (Closed) Inspector Followup Item (259,260,296/86-40-01) This item was to i review. the licensee's evaluation of the impact for' a control bay and ' ! !'l -__-__ _ _ _ _ _ _ _ _
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i reactor building common drain header on secondary containment. Prior to j the question concerning the common drain header, the licensee performed an j Unreviewed Safety Question Determination (USQD) for a number of secondary { containment penetrations which were not seismically qualified.
The ] licensee provided a list of these penetrations and identified the drains in question on the list. Thus, this did not represent a new penetration of concern. Also, the USQD took no credit for secondary containment in a l postulated fuel handling accident. Alternatives for permanent resolution
of the secondary containment problem are still under evaluation.
These facts were reported in LER 50-259/86-24 which is still open.
This , followup item is closed.
4.
Unresolved Items * (92701) l Two unresolved items were identified.
The first item pertains to the removal of radioactive material from the Biothermal Research Facility addressed in paragraph 13.b.
The second item relates to the seismic qualification of the Standby Gas Treatment System Train C blower addressed in paragraph 16.
5.
Operational Safety (71707, 71701) The inspectors were kept informed of the overall plant status and any significant safety matters related to plant operations. Daily discussions were held with plant management and various members of the plant operating staff.
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 operation; purpose of temporary tags on equipment i controls and switches; annunciator alarm status; adherence to procedures; adherence to limiting conditions for operations; nuclear instruments operable; temporary alterations in effect; daily journals and logs; stack monitor recorder traces; and control room manning.
This inspection activity also included numerous informal discussions with operators and their supervisors.
General plant tours were conducted on at least a weekly basis. Portions of the turbine building, each reactor building and outside areas were visited.
Observations included valve positions and system alignment; snubber and hanger conditions; containment isolation alignments; instrument readings; housekeeping; proper power supply and breaker; alignments; radiation area controls; tag controls on equipment; work cctivities in progress; and radiation protection controls.
Informal i d'scussions were held with selected plant personnel in their functional I areas during these tours.
- An Unresolved Item is a matter about which more information is required to determine whether it is acceptable or may involve a violation or deviation.
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' 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 compensatory posts.
In addition, the inspectors observed protected area lighting, protected and vital areas barrier integrity.
6.
Maintenance Observation (62703) Plant maintenance activities of selected safety-related systems and components were observed / reviewed to ascertain that they were conducted in accordance with requirements. The following items were considered during this review: the limiting conditions for operations were met; activities were accomplished using approved procedures; functional testing and/or calibrations were performed prior to returning components or system to service; quality control records were maintained; activities were accomplished by qualified personnel; parts and materials used were properly certified; proper tagout clearance procedures were adhered to; Technical Specification adherence; and radiological controls were implemented as required.
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.
No violations or deviations were observed in this area.
7.
Surveillance Testing Observation (61726) The inspectors observed and/or reviewed the below listed surveillance procedures. The inspection consisted of a review of the procedures for
technical adequacy, conformance to technical specifications, verifict.cion of test instrument calibration, observation on the conduct of the test,
removal from service and return to service of the system, a review of test data, limiting condition for operation met, testing accomplished by qualified personnel, and that the surveillance was completed at the required frequency.
On July 10, 1987, the inspector toured the-irradiation facility used for performing calibration checks on dosimetry. The facility consists of a J. L. Shepherd Model 142-10 Panoramic Irradiator installed in a concrete building with a labyrinth pathway and various control, indicating and interlock devices.
The source is 1.2 curies of Cesium - 137 which provides a dose of about 1 Rem /hr at the dosimeter holding stand and about 50 mrem /hr at the entrance to the irradiation chamber when it is exposed.
During the tour the inspectors observed interlock testing performed per Section/VI.E of HP ISIL 14, Operation Procedure for J. L. Shepherd Model 142-10.
Additional details concerning the irradiation facility are discussed in paragraph 13.c.
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Nuclear Safety. Review Board (NSRB) The NSRB functions to provide an ~1ndependent review and audit' of ' designated activities-in! safety-related plant areas.. Technical Specification 6.2 specifies NSRB functional requirements and authority. A meeting was held with the Chairman of NSRB on-July 6,1987, ' to review processes.
Discussion areas included: (1) Requirements for configuration control of systems afterL restart test are complete.
(2) Seismic concerns in regards to Generic letter 87-02; (3) Fire Protection / Appendix.R code requirements and' exemptions.
(4) Advisors versus member' roles'on NSRBs staff.. ' 9.
Engineering Change Notice (ECN) Program. Status Browns Ferry implemented the trans' tional design change process in June i 1987.
This process provides the.necessary design change controisito-ensure that the design baseline' and the as-constructed configuration are maintained in design documentation.
Key elements of the transitional. program are the change control board, configuration control drawings,.and unitized ECN packages. The ' transitional process will be used until the. permanent plan, Plant Modification Package (PMP) System, is instituted.
Browns Ferry. Engineering Procedure BFEP-PI-86-03, Preparation and Control of ECN Modification Package, describes-the preparation, review approval and revision of the ECN Modification Package.
This procedure controls engineering activities for all design change requests initiated prior to restart, and new design change requests. after ' restart, but prior to - implementation of the PMP. About 10 ECNs have been initiated using the -- new process.
A review of field completed and in process ECNs was conducted.
Forty-eight ECNs have been field completed but not closed as yet. _These ECNs are scheduled for closure in the next several months. Approximately , 550 to 600 ECNs are in process with final closure scheduled'for April 1,. 1988.
Another aspect of the design change process is the design ~ change' notice
(DCN). A DCN will be used to approve changes to ECN packages controlled per BFEP PI 86-03.
Another purpose of the DCN is in lieu of ECN modification package for emergency or minor modifications.when. warranted.
The procedure for DCNs, BFEP PI 87-41, has been written but not yet implemented.
The inspector reviewed the Nuclear Performance' Plan. Volume 3 concerning ECNs. Appendix D gives the status of scheduled and unscheduled ECNs. The total scheduled ECNs during the Unit 2 outage is 501 with 221 designated . _ - _ _ - -
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as required for startup. The unscheduled items totalling 511 will undergo a review process for determination any required restart items.
10.
Vendor Manual Control During a routine tour on July 3, 1987, the inspector found several vendor manuals on the refuel floor which were not controlled copies. An example of these was the General Electric Manual GEK-779, Service and Handling Equipment Volume VI. (Fuel Servicing Equipment). The manual of the refuel floor was not designated as a controlled or verified vendor manual.
A note inside the manual stated that it was borrowed from the training office on 2/24/78. A controlled copy of this same manual was found in document control. Additionally, the shift engineer's office was toured and numerous copies of uncontrolled vendor manuals were found in the office.
As a result of this lack of control, the inspector reviewed the status of implementation of the vendor manual program (VMP). A brief outline of the background of this program is as follows: Salem ATWS Event - Circuit Breaker Failure - Maintenance Feb. '83 - not to latest Vendor Requirement July '83 - NRC GL 83-28 issued, requiring Vendor Information Control (and other requirements) NRC Violation IE 84-23 at BFNP - Diesel Generator July '84 - Maintenance to 2 revisions of procedure July '85 TVA response to IE 84-23: CSSC Manuals referenced in - plant procedures to be completed by February 1, 1988 June '86 - VMP turned over to DNE ' Jan. '87 DNE awarded Burns & Roe Contract for Non-NSSS Manuals - Mar. '87 - DNE awarded GE Contract for NSS Manuals ! Mar. '87 - TVA update to NRC on Vendor Manual Program - Reference GL 83-28: Confirmed February 1,1988 Commitment of July 1985 The vendor manual program consists of three phases. A summary of each ! phase is given below: l l Completed Phase I - 44 Manuals - General Electric Manuals and other stand alone documents used in troubleshooting CSSC equipment.
Phase II - In process 264 Manuals - They are mostly CSSC manuals referenced in plant procedure.-. - -. - _. _ - _ _ _ .
' ! j -, Of the 264 manuals, 210 CSSC manuals are references in'- plant procedures; 54 others are' required for Unit 2 restart.- ~ 159 of these manuals are assigned to contractors: .. Burns & Roe'has provided a completion; schedule for their , 82 manuals.36 completed.
l GE is developing a completion schedule for their 77.
One reviewed manual has been forwarded by.DNE to the Plant'for procedures review.
Scheduled completion-is February 1, 1988.
Phase III - The number of_ remaining CSSC and other manuals estimated:
to be reviewed is to be in the range of 2500 - 3000 manual s.' Manual . review has scarted, but most resources are being applied to Phase II' ' work. Thit. is a long-term program.
The manuals placed under control are governed by-. Site Director Standard Practice 10.1.
Vendor Manual Control Program. Three1 levels of control are applied to vendor manuals and are listed below: Designated by red stickers Administrative - Conditional Use ' Designated.by yellow stickers - Controlled.
Designated by: green stickers - " Administrative" control means that the manuals have'been page verified, researched to determine the latest applicable information received and placed under revision control.
Those manuals are. designated as-information only manuals.
... " Conditional Use" means that the manual has undergone a plant maintenance review and approval process.
. " Controlled" means that the document has been technically reviewed and - approved by a responsible Division of Nuclear Engineering discipline.
There are approximately 997 vendor manuals in the system with assigned' tracking numbers. They are statused as follows: 348 Red Stickers 182 Yellow Stickers 5 Green Stickers 462 manuals remain to be dispositioned.
11.
Restart Test Program The Browns Ferry Restart Test Program began full scale operation this - . month. Major testing is being conducted on the plant electrical systems.
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The restart test group is working ten hour shifts six or seven days a week.
Daily meetings are conducted at 6:30 each morning to discuss the testing activities.
Tests underway are being tracked on the daily plant status sheet. A meeting was held with the restart test manager on July 6, 1987 to discuss restart testing status.
Also, the new restart test facility staffed with 17 engineers was toured.
The Unit 2 restart test schedule was reviewed during this meeting.
Continuous testing is scheduled on the plant electrical systems ending with a loss of offsite power test in December 1987. Other major system testing such as the main steam system, residual heat removal service water, and others will be completed by September and October, 1987.
On July 13, 1987, a resubmittal of the Restart Test Program was received.
The resubmittal consisted of refinements since the initial submittal of October 7, 1986.
These refinements will be reviewed when inspector followup items 87-12-01 and 87-12-02 are closed.
On July 15, 1987, the inspector witnessed a portion of the restart test for the standby liquid control (SLC) systems.
A portion of the test consisted of running surveillance instruction SI4.4.A.2, SLC System Fur.ctional Test.
An injection test into the reactor vessel using demineralized water was observed.
This test consists of firing the explosive charge on the Squib valve and pumping water from the test tank into the vessel. Various alarms. indicating lights, and isolation of the Reactor Water Cleanup System was checked. The test was performed without diffictity and in accordance with the test instruction.
The inspector noted that the pre test briefing in the control room for all personnel involved in the test was beneficial and enabled the test to proceed smoothly.
12. Maintenance Improvement Program During the period of July 14-July 23,1987, an initial inspection was conducted of the Browns Ferry Improvement Program (MIP). Due to poor work performance, SALP performance, and work conditions; excessive maintenance related licensee event reports, audit deficiencies, quality control rejects, personnel dosage, corrective maintenance, rework, and personnel
turnover; inadequate root cause analysis and procedures; and I unavailability of spare parts the MIP was established.
The program is i discussed in the Nuclear Performance Plan (Volume 3) Revision 1 in
Section 4.1.
The plan covers ten points listed below: ! 1.
Organization and administration.
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Training.
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Facilities and tools.
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Procedures / programs.
5.
Materials.
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Work control.
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Maintenance information.
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Maintenance problem analysi _ _ _ _ _ _ _. ___________ ___________ _ _______ - _ _ . '
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Radiological control.
10.
Monitoring and evaluation of maintenance.
In describing the Browns Ferry Maintenance Program (MIP), TVA stated that it corrected deficiencies that had been found in previous reviews, audits, etc., covering the maintenance area.
A set of " cross matrix sheets" prepared by TVA listed the deficiencies from each of thcse sources and indicated numbered " objectives" to address the deficiencies.
Each objective was identified to identically numbered " task sheets" which stated actions to be taken by TVA to correct the deficiencies.
As a portion of their assessment of the Browns Ferry MIP, the NRC inspectors examined TVAs identification of examples of maintenance deficiencies and of their stated actions to correct the deficiencies as ( given on their cross matrix sheets and task sheets.
The examination was conducted as follows: (1) Two deficiency sources, the 1985 NRC SALP Report and the 1986 NMRG Report were checked against the related cross matrix sheets to determine whether the deficiencies from the two sources were accurately identified in the cross matrix sheets.
I (2) The task sheets identified by TVA for all twenty of the deficiencies listed in the SALP Report cross matrix sheets and for the first fourteen deficiencies in the NMRG Report cross matrix sheets were reviewed to determine if they stated actions to address each of the deficiencies.
With regard to (1) above, the inspectors found that 11 of the SALP Report deficiencies were listed accurately in the associated cross matrix sheets.
All but two of the NMRG Report deficiencies (identified A-1 and A-3) were accurately listed on the associated cross matrix sheets. These two were stated to have been omitted because they required " Corporate" actions rather than Browns Ferry actions. The inspectors verified the " Corporate" applicability of these two deficiencies and determined that their correction was being tracked separately, as described in a TVA memorandum dated April 28,1987, (File No. L 51 870420 856).
With regard to (2) above, the inspectors initially found that two of twenty SALP deficiencies were not addressed by the task sheets dated in the matrix and that ten of fourteen NMRG deficiencies were not completely addressed by actions in stated task sheets. MIP personnel subsequently indicated that some of the task sheet numbers were incorrect and provided corrections.
The inspectors conducted a re-review for the NMRG deficiencies using the corrected task sheet numbers and determined that all of the fourteen checked.
The deficiencies were addressed by task sheet actions, but that in some instances the actions were stated so generally that it was not clear that all of the deficiencies were being < , . addressed. A subsequent review relative to the specific actions taken for ' one of these, NMRG deficiency D-1 (which dealt with inadequate office and shop space), found not all aspects of it were being addressed, i - _ _ _ _ _ _ _ _
- - - _ _ _ _ - . _ _ _ _ _ .___ _-__ __ _ _ _ _ _ _ _ -_ . - . 13' l I Withir each point, several objectives ' are identified and'. evaluated on a-separate Evaluation / Task Description sheet.
This ' inspc'. ion activity - consisted primarily of reviewing the Evaluation / Task. Description Sheets and supporting -documentation which form the basis of the Maintenance Improvement-Program.
' a.
Area of Organization and Administration It was noted that the present maintenance. organization was fjudged unacceptable for efficient conduct of maintenance by the licensee's evaluation personnel. The action plan consisted;in.part.~of reviewing the organization at private utilities for, recommended changes. The-inspector took issue with the fact that this was.not considered a startup item and further noted' that it appears to conflict with the overall management improvement initiatives outlined in the Browns Ferry Nuclear Performance Plan which are being implemented.
b.
Training The inspector noted that the electrical and mechanical maintenance.
personnel training programs are being reviewed by the Institute of Nuclear Power Operations (INPO) for accreditation.- The instrument and controls technician training program was accredited in1May 1985.
It appeared that the INP0 recommendations, SALP findings, NMRG findings and the Nuclear Performance Plan commitments concerning maintenance training are all captured under the licensees maintenance program' cross matrix and description sheets.
The programs are inplace but the implementation of the program-is not at a stage where it is ready for NRC inspection.
Therefore this area. of INPO recommendations, SALP findings, NMRG findings: and' the Nuc1' ear Performance commitments concerning maintenance training will; be inspected at a future date.
_ c.
Facilities and Tools The inspectors examined TVA's implementation of.all of the task sheet actions intended to address deficiencies in' this area.
In order to determine if the actions were being completed as stated and if there was evidence of any significant deficiencies which would require correction prior to startup of Browns Ferry Unit 2.
The examination was conducted through interviews with responsible personnel, observation of office and shop facilities, observation. of tool storage and issuance practices, review of authorizations.for.
additional facilities (File Nos. R58 860902800 and R02 870218 897 and-memo from S. A. White dated 6/26/87) and bar code. tool traceability.
development (memo from C. C. Mason dated '11/10/86), and now : of rigging procedure MMI-102.
Based on their observations and reviews the inspectors determined; that the task sheet actions were being completed as stated.and there.
were no significant deficiencies that would require correction prior _ _ - _ - _ _ -
.
t'o Uni t - 2 startup.
Two very minor discrepancies were noted in procedure I-102: (1) The procedure did not provide requirements to assure physical separation of acceptable and unacceptable rigging. This change is required to correct NMRG deficiencey L-4.
(2) Some figures and data contcined minor areas of 11. legibility.
With regard to (1) the inspector was informed that a revision to the-procedure is currently in review would provide for segregation, With regard to (2), the inspectors were informed that all procedures were already being reviewed for such. problems ' and that it would be corrected.
The inspectors determined, based.on their assessment' of the importance and extent of completion of the task sheet actions for the MIP facilities and tools ' area, that actions on the following task sheets should be considered for further NRC review: III.E.1, III.E.2, III.E.3, III.H.1 and III.I.
d.
Procedures / programs The inspector reviewed the maintenance instruction upgrade status of the mechanical, electrical, and instrument sections.
For. the - sections reviewed, the number of procedures that' the licensee , identified to receive revision prior to Unit 2 startup'is as follows: j Section Number required for restart Mechanical
j Electrical 113 ' Instrument -- 50 Since most of the procedures identified for upgrade are still in the revision stage an opportunity did not exist for the inspectors to perform a meaningful inspection of maintenance instructions.
However, the inspector reviewed the licensee's-method of determining how many and which procedures needed upgrad prior to unit. restart.
This method is discussed in Appendix G of. the-MIP Outline which basically shows that the procedures to be reviwwed were' selected from a prioritization of systems' and hardware components based on the Browns Ferry Unit One Probabilistic Risk Assessment (PRA), dated-October 8,.- 1986-The systems were listed in decreasing order by . their importance to core melt frequency. The components were grouped , along with the system in decreasing order by importance to system ' unavailability.
The' inspector met with TVA risk analysts involved in the PRA development.
The PRA was reviewed to determine how the system / component priority list was developed. The priority list was ' not.
q _ _ _ _ _ _ _ _ _ _ _ - _ - _
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e taken directly from the PRA. The information from the PRA was analyzed in a couple of other documents and the list developed.
The other analyses documents were not referred in the MIP.
The inspector reviewed the PRA and noted this document was not con-trolled; the revision level of the PRA could not be identified, There was no way to identify what information changed from the last revision.
Also, the inspector recalled from past correspondence that the PRA was not finalized and some open issues remain. The following letters concerning PRA information were reviewed: n< July 21, 1986 R. L. Gridley to R. M. Bernero a ' August 19, 1986 R. M. Bernero to S.
A.. White November 17, 1986 C. C. Mason to R. M. Bernero November 20, 1986 R. L. Gridley to R. M. Bernero February 29, 1986 S. A. White to R. M. Bernero , June 9, 1987 S. A. White to NRC Document Control Desk The latest letter of June 9, 1987, stated that the PRA was suspect until the plant configuration is established in the design baseline and verification program. Therefore, the use of the PRA in the MIP
is also suspect.
This issue will need to be resolved during future inspections of the MIP and will be tracked as an inspector followup item (259,260,296/87-04).
During the inspection the inspector questioned if the restart task board had reviewed the procedure items designated as restart items against the restart criteria in Volume 3 of the Nuclear Performance Plan.
The procedure items were not reviewed and there was no coordination with the restart task board.
,
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e.
Materials The inspectors examined TVAs implementation of task sheet actions in I the materials area to determine if the actions were being completed as stated and if there was evidence of any significant deficiencies
' which would require correction prior to startup of Browns Ferry ,. Unit 2.
The examination was conducted through interviews with responsible personnel, observation of a demonstration of procedures for identification of materials (procedures SDSD 13.10 and 13.11, - task sheet V.C actions), observation of capabilities to identify and locate parts for important equipment (RHR heat exchanger gaskets identified TIIC ADK 657T and AGF 872Q and squib valve assemble part TIIC AJH 556C) and observation of storage practices.
l Based on their observations and reviews the inspectors determined that the task sheet actions were being completed as stated and there were no significant deficiencies apparent in these actions. The inspectors informed the licensee of the following minor concerns as discrepancies noted in their examination: . _ _ _ _ _ - _ _ _ _ _ _ _ _ _ - - _ - - _ - _ _ _ _ - _ _ _ _ _ _ _ _ - _ _ -
_ _ - - _ _ _ - - _ _ - _ _ .__ _ _ - _ - _ - _ _ _. . _ - _ _. - ! - .. ,
(1) ' Procedures SDSP 13.10 and 13.11 should bc considered"speciali processes :(similar to nondestructive examinations) and the procedures -and~ personn'el should be qualified in a. similar_ manner.
(2) Calibration standa'rds. used with the above' procedure 'should be-- traceable to the National Bureau of Standard.
(3) Personnel safety precautions in the.SDSP 13.10 should be adhered to or removed (if there is an. adequate basis,for their . decision). TVA personnel who demonstrated the procedures to'the-NRC inspectors had been observed.to violate the ; safety precautions.
(4) Task sheet V.B.2 actions included establishment of..a real time inventory.
Responsible ' personnel indicated this action was complete and provided for correction of inventory accounts within 24 hours of any changes. The. inspectors found that squib valve parts issued two days previously still appeared in, the inventory. The inventory was not correct within 24 hours, but was at least several days behind.
. (5) RHR heat ' exchanger gaskets were stored such.that access.was - difficult and chance' of damage was unnecessarily 'high.
(6) An instance was observed where parts shown in inventory: could - not be used when requested because their shelf life had expired (Squib valve o-rings).
The inspectors determined, based.on their assessment of,the importance and extent of completion of the task sheet. actions for the materials area, that actions on the following'. tasks sheets should be considered for further NRC review: V.B.1, V.B.2 (action (8) only), V.B.3, V.C,.V.D, and'V.F.
f.
Work Control The inspector noted that once again the conclusion was. reached that maintenance was not supervised to the degree indicated by the task.
It was not apparent from the action plan how this would be upgraded to acceptable.
, I The goal of maintenance objective VI.F is to supervise, the 'j performance of all maintenance work to ensure that is is accomplished ' in a safe, timely and efficient'. manner and in accordance with work' instructions and plant-performance. ' objectives.. _ The' licensee's evaluation of the current L status of this, objective: is that present maintenance is not supervised to the degree' indicated by the task and scope.
This is a recurring deficiency which was identified;in the last two INPO evaluations, the last Systematic Appraisal of Licensee.
__
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Performance (SALP), and the special Nuclear Manager's Review Group (NMRG) study of maintenance.
The -licensee judged the present performance.of work unacceptable and developed a two part action plan to upgrade this area.
It was not apparent to the inspector how the action plan would be successful in correcting this deficiency situation.
This was due to the-lack of specificity' and development of the plan.
The plan as stated in the MIP's is as follows: (1) Develop. simplified work performance objectives.
(2) Train all craftsmen and supervisors.
Nothing could be found to indicate what subjects should be included in the training'nor was any method outlined to verify that the action plan'was successful in achieving its objective.
g.
Maintenance Information TVA stated this area was not ready for inspection.
h.
Maintenance Problem Analysis TVA stated this area was not ready for inspection.
1.
Radiological Controls ~ The inspector noted that all of the objectives in this area were evaluated as acceptable and therefore no action plans were developed.
.3 This means that out of the ten major categories of-the MIP, no special activities are being undertaken.by the licensee in this area for improvements. The current radiological controls for maintenance work is satisfactory.
J.
Monitoring and Evaluation of Maintenance The inspector reviewed the current maintenance backlog.
There are about 9,200 open Maintenance Requests (MRs) for the facility. with a projected workload of 157,000 man-hours.
Of these totals, about 2,200 MRs have been designated.for restart requiring about 37,4000 man hours.
The maintenance organization is responsible for 1,780 startup MRs (22,600 man-hours) and 6,780 total MRs (78,140 man-
hours). Maintenance groups typically expend about 25,000 man-hours ' during a month. This implies that about a one month backlog exists for startup MRs and about a three month backlog exists for all MRs.
This backlog is not excessive; however, it has been increasing over ' the last six months.
For the month of June, about 130 startup MRs: were added to the backlog with an estimated 2,200 man-hours required.
For this same period, the backlog of all MRs increased by about 300.
13.
Radioactive Byaroduct Material Control l - - .-
! .
The inspector reviewed the licensee radioactive material control program to assure regulatory requirements had been met.
Technical Specifications (T.S.) 4.8.E, (T.S.) 6.6,10 CFR 30, and Site Director Standard Practice (SDSP) 23.2 delineate program requirements and procedures.
Inspection tours of byproduct material storage and in-use areas in the warehouse, chemical laboratory, Irradiation Facility, and turbine building were l conducted.
On July 17, 1987, plant operations was notified by the inspector that 18 sealed check sources, each containing approximately five
microcuries of Strontium-90 had been found in a locked storage cage in the ! turbine building.
Each source is physically located inside of an area radiation monitor detector case and is provided by the manufacturer as a means of verifying the equipment's operability. Fifteen of the 18 sources were identified by NRC resident inspectors checking the adequacy of the ' storage location on July 10, 1987. The remaining three were identified by plant personnel. The sources, classified as byproduct material by 10 CFR 30, are required by plant procedures to be included in the radioactive material inventory. As a precautionary measure, the individual sources < were removed from the equipment on the next shift, checked for leakage and ' contamination, and placed back into storage, af ter being added to the . inventory.
The radiation monitors containing the sources were brought on' site as part I of a 1984 shipment.
The detector cases had not been opened since their arrival on site.
The equipment has been primarily.in storage since receipt.
The paperwork received with the monitors did not directly state , that byproduct radioactive material was included in the shipment, but referenced the purchase contract instead. Receiving personnel at the site warehouse would by procedure contact plant Radiation Control (RADCON) personnel for appropriate surveys to receive radioactive material. If the shipping papers had indicated radioactive materials present, the sources j would have been added to the inventory. When monitors were brought into j the plant, RADCON instrumentation personnel, to whom the equipment is i assigned, assumed that any nece'ssary leak checks had been performed, as usual when they are called to bring radioactive sources into the plant.
On July 31, 1987, plant technical support services personnel, conducting an historical warch on byproduct material inventory, determined that l another Strontium-90 sealed calibration source had been disposed of in the I
fall of 1984. No records can be found at this time to document the reason ' for its disposal, or if in fact the six millicurie source had been disposed of in accordance with Commission regulations per plant technical
specification (TS) 3.8.E.1.
However, the individual in' charge of radwaste ' at the time is confident that the source was disposed of properly and documented.
A sealed source is defined in 10 CFR 30.4 as any byproduct material that is encased in a capsule designed to prevent leakage or escape of the ! material.
Plant TS require decontamination and repair or disposal of { sources with removable contamination equal to or in excess of 0.005 ' microcurie and a report to the Commission. Sources in use are checked for leakage at least once every six months as a TS requirement.
l . _ _ _ _.
- . '19 There was no contamination received by plant personnel or by the'public as.
a result of. either of the above circumstances. A former RADCON supervisor-indicated that the disposed six millicurie source had-lost integrity. The 18 check sources, shielded inside of equipment stored..in a. locked f cage within a regulated area, did not pose a safety hazard to plant personnel or to the public.
Responsibility for the receipt of radioactive material, an adequate inventory, and retrievable documentation has in the past been divided.
- among two or more groups on site. TVA is working to better identify which radioactive materials require inventoried control in accordance with plant TS. A set of revised procedures will be established. Accountability for - byproduct and special. nuclear materials is being shifted to the RADCONE group.
RADCON will be required to countersign on radioactive material procurement and will.be present during receipt of such materials on site.
Further accounting for source material is ongoing by TVA.
The following procedural deficiencies. were noted and discussed with licensee management at the NRC exit meeting: a.
Eighteen Eberline Area Radiation Monitoring System instruments with DAl-5CS Detector Assemblies were observed, during a plant inspection-, to be not under source accountability; control' as. required by SDSP 23.2. The instruments contained a non-exempt quantity of Strontium-90 (5 microcu, ries each).
The instruments were received on the plant-site on September 10, 1984, under contract requisition number 959856.
The sources were never assigned to the byproduct source inventory i list.
Failure to maintain a complete and. current inventory of.
byproduct material and maintain' verifiable records of the same is a - violation of T.S. 6.6 and SDSP 23.2 (259/260/296/87-27-01).
Other examples of this violation for failure to follow SDSP 23.2 procedural-requirements was discussed with TVA management and is delineated ~ below:
(1) Additional record review by the licensee to address the inspector's programmatic concerns yielded two. additional sources I that should have been recorded on accountability records; one Cobalt 60 source, one Americium 241 source and two depleted j uranium blocks.
j s (2) SDSP 23.2 requires notification to the plant manager of byproduct material inventory discrepancies (Section 9.1.8).
This notification was not given when byproduct material was found on January 29, 1987, during a warehouse #9 search by' plant personnel.
Four sources were found that had not been on a.
previous byproduct material inventory.
(3) SDSP 23.2 requirement for source serial number specifications ', was not met for all sources as noted on the current Accountable Byproduct Material Irventory Data' Sheets.
There were numerous
examples of this procedural deficiency.
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(4) Four storage locations involving incore antimony and Americium sources were noted to be in error.
These errors had gone undetected for an extended period throughout several byproduct inventory reviews.
(5) A Cesium 137 (Serial #CS-9497) source was listed as a 40 microcurie source on the inventory list when it was actually a 40 millicurie source.
(6) Various receipt / manufacture dates were missing from the current inventory records.
(7) During a byproduct material receipt record search and program review as requested by the resident, the licensee identified another significant concern: It was determined that a Strontuim 90 sealed source of 6 millicurie loss integrity and had to be disposed of in the fall of 1984.
No transfer, disposal, or leak records of this event were available for review to determine if TS and regulatory requirements were met.
This is an additional example of lack of procedural adherence.
b.
The inspector became aware through the byproduct material control review that improper controls of radioisotope activities at the Biothermal Research Facility located adjacent to the Browns Ferry Nuclear Plant had taken place. This facility was licensed to handle DDT labeled with Carbon-14 as a tracer for the purpose of conducting phytoplankton and macrophyte research. Material License 01-16821-02 issued to the TVA Division of Natural Resource Operations authorized this activity.
The Browns Ferry Plant operating license for Unit 1, DPR-33, became entangled with this activity when the licensed material was l transported from the vendor erroneously under the Unit I license in ' December 1983. By October 1984, the DDT research activity had ceased and the only person on site authorized by the license to use the i material was no longer employed by TVA.
About ten months lapsed i until in August 1985, the Browns Ferry Health Physics Staff was requested to dispose of the remainder of the radioactive material from the Biothermal Research Facility. Initial activity conducted by the BFNP Health Physics staff discovered a contaminated fume hood and glass ware in a laboratory at the research facility.
By mid-September 1985, all of the Carbon-14 tagged DDT and contaminated waste had been removed from the facility by either Brwns Ferry personnel or the radiation health personnel from the Western Area Radiological Laboratory at Muscle Shoals, Alabama. By November 1985, TVA personnel had completed their investigation of the incident and concluded that a breakdown in management oversight and control of radioactive material and radiological safety had occurred.
On November 21, 1985, the licensee submitted an amendment to delete.the
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Biothermal Research Facility and the responsbile individual from the ~ license.
Several potential violations of - NRC requirements were identified during an initial inspection conducted by the. resident inspectors. These areas involve transportation ' aspects,- control of loose contamination, and inadequate radiological surveys.. It was determined that no radiation survey report was submitted to the NRC pursuant to 10 CFR 30.36(d)(v) prior to' releasing the area ;for unrestricted use.
Licensee representatives committed to immediately performing, documenting, and submitting such a survey. This is-an unresolved item (259, 260, 296/87-27-02) which requires' further NRC review and evaluation to determine the enforcement-action.needed.
c.
During a site tour the resident inspected the Irradiation Facility on the owner-controlled property, but outside the protected area security fence. The Irradiation Facililty was being used for TLD calibration functional checks-with. a-1.2 curie. Cesium source L under ; the current facility operating license...The use.of a facility operating license for this type of application _ was questioned whi.ch prompted further discussions with regional and headquarters offices on whether the facility should operate under a special license since it was outside the security fence. The outcome of these discussions was that 'this matter is still under evaluation by different NRC offices and that an NRC generic policy is. expected to be formulated in the near future. Once the NRC policy;is established the licensee-F will be informed of what action they should.take, d.
To address the inspector concerns the licensee took the following immediate corrective actions: (1) All RADCON instruments containing check /calibrati'on sources _have-been visually inspected and the appropriate inventory updated.
(2) A preliminary review of RADCON source' receipt, leak testing', storage, accountability and approved source disposal procedures has been performed.
An evaluation of RADCON ' source account-ability procedures is continuing and will be completed by July 31, 1987.
(3) ISIL-18, Source Accountability, is being revised to reflect an increased frequency of visual source inspection and. include provisions to ensure the integrity of internal check / calibration.
sources contained in radiation detection devices.
A' more definitive guidance regarding. receipt and shipping of RADCON source material has been included in the'ISIL-18 revision. This revision will be completed by July 31, 1987.
(4) TSIL-5, Leak Testing of. Radioactive Sources, is being revised to ensure source integrity for instruments .containing-check / calibration sources.
This revision will be completed by July 31, 1987.
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~ (5) Instruments containing check sources resulting in the above-mentioned concern have been ' leak tested.', These sources have-been found' to be intact and meeting criteria as per -TSIL-5., ) i (6) A visual inspection 'and verification of all RADCON ~ instrument { has-been performed.
This inspection. included a review for .{ internal check / calibration sources contained in radiation detection devices.
RADCON source inventory has been verified and completed.
(7) Instrument and equipment storage areas have been ' reviewed.
RADCON source material consolidation, wherever practicable, has been done to improve accountability efforts.
This ' effort has
been completed.
.j (8) Special QA Evaluation of radcon controlled radioactive sources and implementing procedures.
(9) Byproduct Material Custodian review of inventory records for errors and search by all material holders for additional unknown sources on site.
(10) Implementing procedural. changes to SDSP.23.2.
O e.
An enforcement conference on this area of concern was held on August 12, 1987, with licensee-and NRC management. ~The licensee identified the following program concerns for corrective' action: (1) Program. procedural inconsistencies in control and implementation.
(2) Procurement receipt documents deficient without clear markings.
, (3) Responsibility and accountability of. program requirements not clear.
(4) Attention to detail not sufficient to assure adequate program.
(5) Process control inadequate from receipt to controller.to custodian to users to disposal.
Program improvements planned to prevent recurrence include: (1) Establishment of clear lines of responsibility.
(2) Reducing program fragmentation.
! (3) Establishing effective material' control and accountability.
(4) Providing centrol program guidance from corporate.
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(5) Setting up a single point documentation system.
! ' (6) Byproduct material accountability control will be shifted to the plant RADCON group.
f.
The inspector's review of byproduct material control area concludes that management attention and corporate involvement in this area should be increased to assure regulatory and licensee requirements are met.
Overall effective control of byproduct material on site i from contract to receipt, storagesto use, and use to non-use/ transfer was not readily apparent.
This programmatic concern should be addressed in the corrective action plan.
Failure to adequately monitor material licenses held by the utility (such as the Carbon 14 special research) could lead to additional regulatory and public
awareness concerns and should be promptly reported.
14. Operating Instruction and Abnormal Operating Instruction Review The inspectors reviewed Operating Instructions for Unit 2 which have been through the procedures upgrade program.
The following instructions were reviewed by the inspectors: f Operating Instruction 2-01-63, Standby Liquid Control System Abnormal Operating Instruction 2-A01-68-3, Recirculation Loop A or B Speed Control Failure Operating Instruction 2-01-92, Source Range Monitors Operating Instruction 2-01-92A, Intermediate Range Monitors Operating Instruction 2-0I-92B, Average Power Range Monitors Operating Instruction 2-01-92C, Rod Block Monitor Abnormal Operating Instruction 2-A0I-92-1, Rod Block Monitor Failure Operating Instruction 2-0I-94, Traversing Incore Probe Some examples of problem areas were: (1) Paragraph 4.7 of 2-0I-63 states to check the SLC storage tank heater controller, 2-TIC-63-2, is maintaining solution temperature 80-85% F.
This should read 80-85 degrees F.
(2) NRC Inspection Report 87-09 identified several examples of instructions that were misleading, unclear or needed more clarification to insure correct operator actions.
Several items associated with 2-0I-63 were identified in that report.
, Although, some of the identified items have been corrected, the following items still exist: (a) The operating instruction does not contain a section that provides for flushing relief valve piping.
The inspector l determined from discussions with licensee personnel that the licensee did not feel that this was necessary since the method of testing the relief valve had been modified so that it is shop tested with demin water and no borated water should be present downstream of the relief valve during normal operation.
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(b) Attachment 1, Valve Lineup Checklist, had valves arranged in'an order which' had the operator going back and forth between-different components which would resultLin less efficient'use.of time.
The inspector discussed this with licensee' personnel and was informed that an ongoing program existed to improve the , valve lineups and eliminate this problem.
The inspector noted that this problem did not exist on.other valve lineup checklists . reviewed by the inspector.
(c) In some cases the procedure did not consistently specify hand _ switch number for control manipulations.
Thei inspecter > noted that steps 8.5.16 and 8.5.21 specified operation of - the SLC pumps without stating the hand switch number.
(3) The precautions and limitations listed in 2-0I-92 contains warning statements concerning rod withdrawal blocks and detector retract' permissives' to assist the operator in - operation of the system.
However, the warnings do not reflect the fact that many of these-interlocks only apply to the companion IRM channels.
The inspectors reviewed several 01's and A0I's. :The. review consisted of . detailed walkdowns of some procedures' and step' by. step verification to ensure all references were appropriate.
The. combination of the labeling program and the procedure upgrade' program not yet being ' completed has resulted in the inability of the' inspectors to complete the detailed reviews.
Examples of. problems in completing the reviews are OI's and ' AOI's which have not yet been completed and walkdown verification of completed OI's and AOI's where all labeling 'is not installed.
The procedures upgrade program and the labeling program must be substantially completed in order. to perform effective inspections of the; upgraded procedures.
The ability to carry out or implement the'one procedure (0I-9.9) reviewed ) and walked down in detail was good. Other procedures included AOI-57-2, A01-32A, 01-32A and 01-82.
Labeling errors noted: 0I-99, paragraphs;. 4.1.1.2 panel 11 not labeled, 4.1.1.3 panels 9 and 11 not labeled.
Attachment 1 page 3 of 5, electric board room "D" is referenced, the in plant identification is "2D".
5.1.8 - Generator connected " red" light cover needs replacement (appears , amber)
i 5.1.10.1 - Switch 5A-52-A requires label 5.1.10.2 - Normal and test position require labeling 15.
Inservice Testing of Pumps and Valves a.
Squib Valve Test (Unit 2) .! l i _ _ _ _ _ - - _ _ _ - - - _ - _ _ _ _.
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The inspectors observed-t'he -testing' of; Standby ' Liquid Control System ' squib valve 2-FCV-63-8B and subsequently reviewed the test records to verify the conformance of the testing with the requirements ' of Surveillance Instruction 2-SI-4.4.A.2 and'. the' applicable inservice testing code. The applicable inservice testing' code is ASME Section XI (80W80).
b.
Inservice Testing Program (Units 1, 2 and 3) Region II has been reviewing the Browns Ferry program fortinservice testing of pumps and valves,(submitted to the NRC in a letter dated - 12/23/86) pursuar.t to preparation' of a safety evaluation of the ' program and : its contained relief requests. -During the current ~ i nspection.. the inspectors reviewed -the : licensee's proposals. for revised vibration' testing requirements and. questioned.certain information described in the program.
Questions asked of licensee personnel and information provided are as follows: (1) Question: Relief request PV-1, in part, appears to indicat'e you - want relief from requirements 'to measure pump -lubricant level / pressure. You provide no basis for this relief. Is there an error in the request' wording.
! Reply: We will check and let you-know.
(2) Question: In relief request PV-2, you indicate that y'our Diesel- ~ Fuel Transfer (DFT) pumps are positive displacement.
Is this: correct? Reply: Yes (3) Question: A're the pump acceptable and. allowable range multipliers stated irr~ relief request PV-5, Alternate Testing, correct: Reply: No. They should be 1.02 to 1.05 and 1.03 to 1.05.
(4) Question: How much of a safety margin is there in the flow capacity of your DFT pumps? Re' ply: The safety margin is about 2:1.
(5) Question: -It is our understanding that you have been performing _ I vibration tests like.those ' proposed in relief request PV-5 for some years.
The test you l propose is similar to the test proposed by ASME pump test. standard OM-6-1986, Draft 9. 'Are you familiar with that standard and would you have any difficulty complying with its requirements? .l
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1
Reply: Our current practices basically comply with OM-6, except that we have not calibrated..the equipment to verify compliance with the upper frequency limit of 1000 Hertz.
(6) Question: Relief request PV-7-. requests relief to perform MSRV' vacuum breaker tests at refueling outages rather than quarterly.
Why can't you perform the tests during cold shut downs.if the containment 1s-deinerted: i Reply: We can.
Within the areas examined, no violations or deviations were identified.
16.
Seismic Anchorage Concerns Three items of electrical equipment,. the' control room emergency ventilation system (CREV) filter blower assembly. Train B, the control room panels-unit 2, and the standby gas treatment blower-Train C.
were identified by the resident inspector as having potential anchorage problems for resisting a design basis seismic event. The concern with the CREVS blower was. identified as a part of a violation in Inspection Report 86-25.
The concern with the control room panels was identi_fiea as a deviation in Inspection Report 87-20. ;The. concern.with the sta'ndby gas-treatment blower was identifed to TVA by the resident inspector.
Two members of the Engineering Branch, TVA Division, OSP visited the site on July 13-14, 1987, to discuss the seismic anchorage concerns with TVA and to examine the equipment in question.
Their evaluation of. the anchorage of the equipment as well as the staff's understanding of -TVA's intended action regarding the equipment follows: (1) CREVS Filter Blower Assembly-Train B The staff observed the mounting assembly and discussed the evaluation of its anchorage with TVA.
Although,. the unit is' slightly cantilevered on the concrete pad, the mass of the. blower extending.
over the end of the pad is small. The unit ' steel frame is fillet
welded to embedded steel plates.
The staff concurs. with TVA's l ! findings that the anchorage of the unit is sufficient to defer final resolution of this item as a part of the implementation of USI-A-46.
We understand that TVA.will restate their evaluation in a response to
Inspection Report 86-25.
j . -
(2) Standby Gas Treatment System Blower-Train C ! The Standby Gas Treatment system Blower-Train C is mounted'on a steel.
frame and held by six springs. The' unit has no. lateral support. The.
! licensee could not provide an Janalysis to support the anchorage , configuration.
We" understand that TVA intends.to'l review the old 'j analysis to check its adequacy. ' The licensee indicated it will most l .e consider 'the .l likely. modify the anchorage of the equipment.
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'I . e anchorage of this item-an outlier from USI-A-M.
The unitchan a. .l '
large eccentric mass and no lateral support.
This item should be resolved prior to restart. The licensee stated their actions for this item. will be provided to the resident: inspector.
This will be tracked :as ' an Unresolved Item. pending resolution (259,260,296/87-27-03).
j ^ (3) Control Panels
The Main Control Room vertical-benchboard type control panels and' freestanding vertical control panels < were identified in Inspection Report 87-20 as deviating from the FSAR commitment with regard to'the anchorage of the panels. The Engineering Branch staff, on an audit basis, observed the anchorage of the bench type!and vertical panels in Units 1, 2, and 3.
From their observations, they have concluded that the anchorage of the benchboard panels essentially'were just tack welds as taken from the drawings rather than. an engineered anchorage.
Further, the vertical panels in Unit 2, appeared to have.
, been plug welded but the anchorage was not originally evaluated. TVA presented an evaluation to draft :USI-A-46 criteria for anchorage of the vertical panels for unit 2 that appeared reasonable..However,. the staff believes-that the plug welds in the unit 2 panels need to.
be visually inspected to assure. that' evaluation assumptions by TVA are reasonable.
The staff believes 'the lack of anchorage for the unit 2 benchboard panels represent a condition that is an outlier with regard to awaiting resolution as part of USI-A-46 and.should be I corrected prior to restart af the unit. We believe that anchotbge of the control panels for units 1 and 3 'should be assessed by the.- licensee and corrected prior to restart of those units.
We understand that TVA will provide its position on anchorage of the control panels in response to-the deviation identified in. Inspection Report 87-20.
- 17. Reportable Occurrences (90712, 92700) , The below listed licensee events reports (LERs) were reviewed to determine if the information provided met NRC requirements.
The determination. . included: adequacy of event description, verification of compliance with
Technical Specifications and regulatory requirements - corrective action ' taken, existence of potential generic problems, reporting i requirements satisfied, and the relative safety significance of each event. Addition in plant reviews and discussion with plant personnel, as appropriate, were.
conducted The following licensee event reports are closed: LER No.
Date Event , 259/85-21 6/4/85 Containment: Isolation Initiution-
n ' , ( . m__-__ ..__m _ _ _ _ _. _ _ _ _ _ _ _ __.-.__________a_,t__.._.__5.m _ _ _ _ _ _ _ _ _ - ' ' ' '
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28' y 259/85-25 6/5/85 Failure of Fuel Pool Cooling Pump Discharge
1 Flange p
,
4 259/85-27 6/20/85 Design. Deficiency - Inadequate Seismic Design'of the Reactor Building Crane 259/85-31 7/6/85 Seismically Unqualified Flange Joints , L W 259/86-32 11/10/86 Standby Gas Treatment' Surveillance Not % Meeting Technical Specifications Requirements " Two independent events resulted in conta'inment,isolations (LER 259/85-21).
On June 4, 1985, a primary containment isolation' occurred when on one primary containment isolation system trip channel was being removed ;from service for a relay changeout. An undetected blown fuse.in the redundant E channel caused the isolation.
The blown fuse. was replaced, and the isolation signal was reset, The relay replacement procedure was changed to ensure that. redundant r.11ays in the other channel are. functioning. correctly.
On ' June 5,1985, while performing a surveillance. instruction a radiation mode switch was taken out of the' operate mode resulting in a containment isolation.
A defective relay was. responsible for. the isolation. The relay failure was. considered random and the relay.was l replaced'and proper operati Q was. verified.
l l During maintenance the 1A fuel pool cooling pump l discharge flange cracked L' during torquing (LER 259/85-25).
The root.cause of the failure was the joint design did not meet American National Standards Institute requi rement s'. All the fuel pool pumps discharge. pipe flanges have been.
modified by removing the raised faces. A design study was completed' to determine tif there were any other similar installations of other raised face flanges.in safety systems.
This is discussed in LER 259/85-31 below.
An Office of Engineering evaluation of th'e reactor' building crane (LER 259/85-27) indicated that the potential loads transmitted to the-crane ~ rails during' a seismic event could have resulted. in their overturing and/or 's11 ding. A modification-was performed to replace the crane rail clamps with ones of -a' larger sin (one half inch to one inch) which returned the reactor building crane.to a seismicall/ qualified condition.
An engineering review (LER 259/85-31) discovered that the chilled water f recirculation pumps in the control bw, the unit 3 diesel generator-I building, and the water regulator valve on the control bay. emergency cordensing units were found to have'unmatching flanges.' All of the: raised flanges were ground flat and Eretortjued to design' valves.
Al so,; the. - residual ' heat. removal service water pump discharge release valves were i replaced with seismically-qualified' east-. steel body valves.
/ L
- .__ _ _.
__ _ _ __ _ _ _ _ _ _ _ _ i - .
. ! ) i It was discovered that the surveillance instruction (SI) acceptance criteria for the standby gas treatment system (LER 259/86-32) did not meet
the technical specification setting requirements.
A review of ths $SAR j showed that the $1 acceptance criteria met the design bases. A technical '{ specification change was submitted on May 29, 1987, to correct. the" > i ' acceptance criteria error.
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