IR 05000259/1988036

Insp Repts 50-259/88-36,50-260/88-36 & 50-296/88-36 on 81208-31.Violations Noted.Major Areas Inspected:Plant Operations,Mgt Control Over Plant Activities & Work Control Process to Determine Readiness for Fuel Load

ML20244C428
Person / Time
Site:	Browns Ferry
Issue date:	04/07/1989
From:	Carpenter D, Little W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20244C407	List: IR 05000259/1988036 ML20244C405 ML20244C418
References
50-259-88-36, 50-260-88-36, 50-260-89-36, 50-296-88-36, 50-296-89-36, NUDOCS 8904200204
Download: ML20244C428 (19)

Text

_ ,

, i+ O

'

'<_ ,

37 -

.

UNITED STATES ~

' ,

s 4p2 Ka;2pg'o -

A :.. NUCLEAR REGULATORY COMMISSION '

~!  ; REGION 11

,.

~j

,

'g: 101 MARlETTA STREET, ' 'j

.

..* 2 ATLANTA, GEORGI A 30323 ' '

,o n .

__

.

(ReportNos'.: 50-259/88-36',:50-260/88-36, and 50-296/88-36 Licensee: -Tennessee Val. ley Authority-6N 38A Lookout Place 1101-Market Street Chattanooga,' TN '37402-2801 Docket Nos.: ~50-259, 50-260, and 50-296 OcenseNos.: DPR-33, DPR-52, and DPR-68

~

' Facility Name: Browns. Ferry 1, 2, and 3 Inspection at Browns Ferry Site near Decatur, Alabama

. Inspect. ion Conducted: . December-8-31, 1988-In spect'or #7 g[

. ; R. Cjttpenjifr, NRC Site. Manager Dtite/ Sign'ed Accompanied by: E. Christnot,-. Resident-Inspector

,

W. Bearden, Resident Inspector i A. Johnson, Project Engineer l A. Long, Project Engineer  !

. [/#I Approved by: YM 78 W.' S, tyfttif, Section Chief, DayeS4gned Inspection Programs, LTVA Projects Division Scope: This special, announced inspection assessed the conduct of plant operations, management control over plant activities, and the work control process, in order to make a determination of licensee

' readiness for fuel . loa Evaluations were based on control room observations, observation of shift turnovers,. accompaniment of watch-standers on their tours and rounds, personnel interviews, observation of surveillance tests, and direct observation of work items from tagout clearance installation through the post-maintenance testing phase and return to servic Resultsi l The inspection concluded that licensee activities in the areas of

. fuel' load readiness were adequate to support fuel loa As the licensee approached fuel load, continuing improvement was noted in l the conduct of operations, particularly in the areas of work control, shift turnovers, and effective communication l 8904200204 890410 J PDR ADOCK 05000239 Q PDC

_ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _

,; .

.

The following violations were identified:

VIO 259,260,296/88-36-01: Violation of Technical Specification (TS)- Requirements to Properly Establish and Implement a' Pro-cedure for Configuration Control (paragraph 5)

<- VIO 259,260,296/88-36-02: Violation of TS 6.8.1.1.a, for Failure to Follow SDSP 3'15 Regarding Qualifications Require-ments for Independent, Reviewers of Electrical Lineups (paragraph 8)

Adequate corrective action to support fuel load was taken for each of the violations. Final resolution of the violations is required prior to startu The following violations satisfied the NRC enforcement policy criteria for discretionary enforcement and were not cited:

LIV 260/88-36-03: Failure to Comply With The Logkeeping Requirements.of Procedure PMI-2.12 (paragraph 2)

LIV 260/88-36-04: Failure to Adequately Document Identities of Persons Performing and Verifying Clearance Hold

. Order-System Alignments (paragraph 7.e)

One unresolved item * was identified during the inspection:

UNR 259,260,296/88-36-05: Adequacy of Corrective Actions in Response to NRC Violations at Sequoyah in Area of Configuration Control (paragraph 5)

One Inspector Followup Item was ioentified:

IFI 259,260,296/88-36-06: Review of Operability Determinations for Nonconforming Items (paragraph 7.f.)

I The following aspects were considered to be particular strengths of '

the licensee program:

-

Effectiveness of operations shift turnovers (Paragraph 2)

- The creation of a Work Control Center in February 1988 and the <

refinement of that process in order to coordinate plant equip- l ment operations and to control clearances (Paragraph 7.b) ]

t

• An unresolved item is an issue for which additional information is l required in order to determine if the item is a violation of regulatory  !

l requirement j l

I

. _ _____________---__-___._a

_ _ _ - _ _ _ _ _ - _

.

L N

'

..

.,

Configuration control .was identified a s .. a n area of significant weakness, requiring substantial management attention. The licensee had failed'to establish an. administrative. procedure governing system

. status control in .accordance with TS requirement TheLlack of a~

. - properly reviewed controlling procedure, the licensee's practice of .

"

incorrectly: initialling steps in the Operating: Instruction's' Valve and Electrical Lineup checklists as completed 1 verbatim without -l indicating that components were actually out of position, the lack of L . adequate reviews of deviations 'to initial checklist performances, the lJ ~:use of non-electrically qualified' AU0s for independent verification,

. and the failure to retain _ essential system status documentation as quality. records, raised questions about the validity-of_the' completed lineups on ~ file for systems required for' fuel ;1oad, Prior to fuel-load, the licensee was requested to demonstrate assurance of system status control. The licensee's commitments to resolve these concerns are described in paragraph .

d

,

---

.___.L '

. - _ - _ - - _ _ _ _ _ _ _ . . _ . _ _ _ _ _ _ _ _ . _ _ _ _ . - . _ _ _ . _ _ _ _ _ _ . _ _ - . , _ _ _ _ _ _ _ _ _ _ _ _ _ _ , _ _ _ _ _ _ _ _ , _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ , , _ _ , , _ . _ _ _ __ __ , _ _ _ _ _ _ _ __ __

_ _ _ _ _ _ _

_ - - _ . _ .

=. '.

.

-

t

'

i

'

I REPORT DETAILS l

Persons Contacted l Licensee Employees:

0. Kingsley Jr., Senior Vice President, Nuclear Power  !

C. Fox, Vice President and Nuclear Technical Director

• J. Bynum, Vice President, Nuclear Power Production

• C, Mason, Acting Site Director

• G. Campbell, Plant Manager H. Bounds, Project Engineer

• J. Hutton, Operations Superintendent

• T. Temple, Manager - Nuclear Engineering

• D. Mims, Manager - Technical Services Supervisor

• G. Turner, Manager - Site Quality Assurance

• P. Carier, Manager - Site Licensing

• J. Savage, Compliance Supervisor A. Sorrell, Site Radiological Control Superintendent R. Tuttle, Site Security Manager L. Retzer, Fire Protection Supervisor-H. Kuhnert, Office of Nuclear Power, Site Representative T. Valenzano, Restart Director Other licensee employees or contractors contacted included licensed reactor operators, auxiliary operators, craftsmen, technicians, and public safety officers; and quality assurance, design, and engineering personne NRC Attendees

• D. Carpenter, Site Manager

• Bearden, Resident Inspector

• Attended exit interview Acronyms used throughout this report are listed in the last paragrap . Conduct of Plant Operations The conduct o'f plant operations and control room activities were evaluated against TS requirements; Browns Ferry PMI 12.12, " Conduct of Operations";

and good operating practices. This included observation of overall control room decorum, operator cognizance and responsiveness, shift turnover, control room manning, and proper use of logs. The NRC inspectors con-ducted sustained control room observation activities on at least two occasions per shift, including backshift and weekend coverage, during the period of December 8-23, 198 l l

l

i

- _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

____ ____ _ _ - . _ _ _ .

,% } - .

.. .

. Th'e following observations were made:

'

-

'The shift manning requirements of TS were consistently me ~ Qualified reliefs were present whenever operators left the control ' Overall control room decorum and demeanor were goo Shift turnovers were very good. They were professional and thorough, making good use of checklists to ensure the . transfer of sufficient, accurate information regarding plant' conditions. panel walkdowns and reviews were appropriately. conducted. The inspectors found that the checklists accurately reflected plant condition System status boards were accurately updated. Operator cognizance of plant status was acceptabl Operation's communication was good. . During the performance of sis, orders-were clear, prec'se, acknowledged and repeated bac ' Alarms and annunciators were generally responded to in a considered, controlled fashion. .The first-out printer was out of. service' during the inspection and could have contributed to an' operator initially failing - to recognize the source of a. half scram that occurred on December 9, 1988. .The operators announced that- the half-scram was caused by SRM High Level (it was actually an APRM High/Inop Channel Trip), which resulted in subsequently receiving a full scra Test personnel demeanor and communications were not appropriate for an . operating plant. At times, the use of nicknames and humorous responses detracted from what was otherwise good control room decorum.

,

-

On occasions, communication could have been improved through the use of headsets rather than several people talking simultaneously over handset Control room access was adequately restricted to persons having legitimate busines At times, traffic noise through the walkway outside the control panels was excessive. Whenever possible personnel should use other route Control room area housekeeping was goo The Shift Operations Supervisor's desk had recently been relocated to the control room from an office adjacent to the control room. This appeared to have positive effects on control room activitie Operators displayed a conservative, questioning approach to surveillance testing activities, adhering to procedures, and contributing to successful SI performanc _ __-______-___ __- _ - _ _ _ _ _ _

m o=

'

,A, o,

, i p f

-,

i

.

t-

+

1 q

-

Four ' concerns with the- keeping of logs were identified:

On December 13, 1988, an RHR pump breaker failed, but the log'

did not identify'the affected-pump On1 December 15, 1988, the VO and ASOS logs.did'not record the- .

' start. of 2-SI-4.5. A.1d(11), " Core Spray Flow Rate Loop' 2," as l late as 2h hours after the start of the tes l l

L On- December 14, 1988, the log. did not identify that an SBGT -

. Train C start was ' unauthorize On December 14, 1988, the ASOS log in the control -room did not

. state the location of the ASOS who had left the control room to conduct. activities on the refueling floo The overall-result.of.this part of the inspection indicated that licensee performance in this area supported their readiness for fuel. loading. The keeping of legs . appeared to be an a'rea of weakness, and -the failure to ,

promptly log the sta rt' 'of core spray test 2-SI-4.5. A.1.d(II) . on i December 15, 1988, was ' a failure to follow sections 4.4.1' and' 2.2.10 of PMI-2,12, " Conduct of Operations". When the. concerns M out the logs were brought to the_ attention of Browns. Ferry management, immediate corrective action was taken and improvement in the quality of the l logs was subsequently . noted by the inspector NRC management review of this violation. has concluded that this instance .was 'of minor safety ] !

significance, and that the licensee initiated appropriate corrective action. Therefore, in accordance with the NRC enforcement policy, no .]

violation will be issue The inspectors will continue to monitor this are (LIV 260/88-36-03) Surveillance. Testing The NRC inspectors observed portions of the performances of the following '

sis:

-

2-SI-4.2.B-45(A)(I)(II), "RHR Loop I, II Logic System Function Test"

{

-

2-SI-4.5.A.1.D(II), " Core Spray Flow Rate. Loop 2" l

-

2-SI-4.2.C(A), " Instrumentation that Initiates Rod Blocks / Scrams Source Range Monitor (SRM) Calibration and Functional Test"

-

2-SI-4.2.C.3(E), " Instrumentation that Initiates Rod-Blocks / Scrams Intermediate Range Monitor (IRM) Calibration"

'

-

2-SI-4.2.C-4(C), " Instrumentation that Initiates Rod Blocks / Scrams Source Range Monitors (SRM) Calibration and Functional Test" l

1

_ - - _ . . _ - _-__ - -

..

6 .j'( i ,

V

.

'

.,

-

2-SI-3.2.10 H, " Verification of Remote Position Indicators for Residual Heat Removal System Valves" Many of the surveillance procedures in use during the-NRC inspection'were being performed.by the licensee for the first time. These procedures had been walked' through' to verify their. adequacy prior to use. It appeared E that an excessive - number of ' temporary changes had to be made for-procedures which had been previously verified as being carrect. The NRC inspector reviewed the Immediate Temporary Changes (ITCs) written against'

-selected surveillance procedures and considered many of the changes to be significant, in that- they involved incorrect component numbers and steps which .were not'. adequate - to perform their' intended purpose. Many,of the procedural deficiencies corrected by the.ITCs were identified and resolved

~~

L by . the control room operators, .through consulting applicable system drawings and other references. For example, RHR Logic System Surveillance 2-SI-4.2.B-45 A (I)-(II) contained steps to verify that certain conta' cts had opened by ver.ifying'that no continuity existed between two particular

~

terminals. As the procedure was originally written, the' open contacts could not- be verified because a parallel closed loop existed in .the circuit. To satisfy- the intent of the procedure, an .ITC was written to remove'the indicator lightbulb from the parallel portion of the circui Interviews with operations personnel' indicated that the frequent need for

,

ITCs was'a burden.

y The .NRC ' inspector . expressed concern to management regarding the level of

'

reliance on operators to identify and correct inadequate procedure step Management responded that they were aware of this recurring proble Engineering personnel had been assigned to work closely with the personnel running surveillance tests to aid in identifying and resolving this type of procedural proble The' NRC -inspector reviewed the test deficiencies associated with Source Range. Monitor Surveillance 2-SI-4.2.C-4(C). During the performance of the

" SI, the neutron source used to establish .the discriminator setting had been moved before the surveillance was completed. Therefore, certain annunciators associated with SRM low count rate could not be cleared

.during the restoration of the system to normal. While witnessing the performance of Section 7.13.27, the NRC inspector observed that Test Deficiency #5 had been initiated to address seven steps of the procedure which could not be performed with- the SRM downscal The NRC inspector was-told that the cognizant engineer was not planning to require the steps identified in TD #5 to be reperformed for the SI to be considered complete, because the test deficiency resulted from a known system condition and it was assumed that all the annunciators would have properly cleared had sufficient neutron counts been availabl This was inconsistent with a thorough, conservative approach to plant activitie The NRC inspector questioned licensee management regarding the planne; disposition of Test Deficiency #5 to the SRM surveillanc After j

'

evaluation, the licensee reported that two of the procedure steps addressed by TD #5 had been reidentified as TD #7 and would be evalmted

_ _ _ _ _ _ _ _ _ _ _ l

_- - - - . _

-

.

. .

.' '

y U e

, - nyt - , S' ~

' further . to . determine ' if reperformance was . required. I The = other . test .

deficiencies . written against the procedure. were also reviewed by the

+ inspector . and discussed with cognizant licensee personnel. No other i

problems were identified.- The adequacy of test deficiency dispositioning b

'

. will,be given additional' review'during future NRC inspection No' violations or deviations were identified during the observations of

' surveillance te. stin , ., Implementation of Deportability Requirements

,, -The NRC inspector reviewed the LREDs generated during the period. of the

'

inspection:to verify adherence to reporting requirements. No deficiencies were identified in the deportability ' determination As a' specific e'xample, the NRC inspector noted that on December 14, 1988,

.

two ' SBGT' trains . were simultaneously inoperable and the licensee

'

L

'immediately complied with the restrictions in the appropriate TS action statement; When the cause of the low flow was identified, and determined

..

to be reportable, the licensee promptly reported the inciden No violations or deviations were identifie . System Status Control The NRC inspector determined that an Operations Section Instruction l etter, OSIL -43, " System Status Control", was the document governing the L wnfiguration control process and the completion of. 01 checklists for component alignment. TS 6.8.1.1.a requires that the a'pplicable procedures recommended _in Appendix A of Regulatory Guide 1.33 be establishe Administrative procedures for the control of equipment are required by

.

Appendix A of _- Regulatory Guide 1.3 TS 6.8.1.2 requires that each

'.

administrative procedure required by TS -6.8.1.1.a shall be reviewed by PORC. As an OSIL, the procedure administratively governing system status control was issued by the Operations Manager without the level of review

'

and approval required by T Section 5.4.5 of the NQAM, Part III, specifically states that section instruction letters are not to be used in

' areas where review in accordance with TS is required. The failure to have a procedure as defined in the NQAM to administratively control activities controlling system status is considered to be a violation of TS 6.8.1. and TS 6.8.2.1 -(Violation 259,260,296/88-36-01). Resolution of this item was identified as a requirement for fuel loadin The inspector identified the following deficiencies in the configuration control program as imp ~lemented by OSIL-43:

-

System alignment checklists were being initialed even though the corrgonent was not positioned in accordance with the checklist. No indication was made on the checklist to identify that a TACF,

-

clearance ' sheet, or an abnormal status sheet existed that documented the actual position of the components; or that the component was not

.

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ . _ _ - _ _ _ _ _ _ _ _ _ _ _ . . - m.__ __~_m_ _ , _ _ .- m- . . _ _ . _ - __ . . . . . _ _ _ .

~ ..m . - _ _

.

yr

'

r L

'

.,..

-

6~

v.

t

,

H b L in the checkl;st' position'because the system was running. This was~

L/' ,

contrary to PMI' 12.12, " Conduct .of Operations," which states . that initialling a procedure step means that the ' step was completed "as

'

E >

stated."

--

. Deviations .from 01. checklist steps. during initial . checklist'

performance did not' receive the level of approval required by TS for a temporary change to a procedur .

-

Abnormal Status Sheets controlling deviations . from the specified i . positions during 01 checklist' performance were not being controllod as quality assurance records and were discarded when the deviation were' cleare The inspection . findings described above were discussed with. and acknowledged: by plant management, and are. to be addressed with th'e

' implementation of - an adequate configuration control procedure as corrective action for violation 259,260,296/88-36-0 On December 28, 1988 NRC and-TVA management had a telephone conversation-i to determine the actions needed to resolve these concerns prior to fuel loading. TVA agreed to do the following prior to fuel load:

Issue a-..new PORC approved system status control procedura, plant

'

-

managers instruction (PMI) 12.15 " System. Status Control ."

-- Perform PMI 12.15 on five selected systems, o

-

All deviations found during the initial system alignmerits using -

PMI-12,15 will be documented and' receive the same technical review as a procedure change.

!

'

-

All documentation required by PMI-12.15 will' be QA records. This will allow for a clear and auditable trails of system status contro TVA management stated they were confident that BFN was ready to refuel the p . Unit 2. reactor based on the existing alignment of the fuel load system ,

This confidence was based on the following: '

- -

During the system pre-operability checklist (SP0C) program, QA reviewed portions of al' the operations' checklists for the systems required for fuel load. This review resulted in one finding related to valve positioning. This finding was made early in the SPOC process and resulted in a heightened awareness as to the importance of proper system alignment. No other component mispositioning had been identifie As part of the SPOC program and in preparation for fuel load activities, an extensive amount of testing had been conducted. Most of this testing was in the performance of surveillance instructions

,

,

m-a-.,------1.,------__--:--- --------x- - - - _ _ _ - _ _ _ _ _ _ _ - - - - - - - , - - _ _ - - - - - - - - - - - - - - - - . _ - - - - - - . - - - _ _ - - - - - - - - - - - - - - - - - - - - - -

__-__- _ - _

_

,

gC ,

~

.

..

,

'

, . . .

'

and identified no system operation problems resulting from-lack of

, system status control.

o

-

As : a. result, of ; the. identified NRC concerns, -five systems were reviewed for proper alignmen These . system were core spray, residual heat removal, diesel generators, standby gas treatment,tand standby liquid control. All operations' checklists were performed lon these five systems and no alignment problems were foun TVA - documented the telepunne conversation in a letter to NRC dated December 29, 198 NRC management' concluded that while initially the licensee's system for system) configuration control was unacceptable, that program changes and commitments made during this inspection period were acceptable andithat system status and alignments were adequate for fuel loadin The inspectors noted that violations of NRC requirements similar to some of those-described above had previously been cited at TVA's Sequoyah facility. .Per 10 CFR Part 50, Appendix B, Criterion XVI, and implementing commitments and procedures, corrective actions should .have been taken at Browns Ferry in response to the violations identified at Sequoyah. The

,.

adequacy of the. licensee's corrective actions at Browns Ferry in response

"'

to configuration control violations at Sequoyah will be assessed during future :NRC: inspections and will be tracked as Unresolved Item

,

259,260,296/88-36-05.

< Management. Control ~

The: licensee's onsite management organization has experienced several changes within the last year including assignment of a new Plant Manager, Operations Manager, and Maintenance Manager. The new Site Director had-not:yet' been announced at the time of _ the inspection. -Interviews with

, senior managers indicated a well rounded level of management experience

- and technical abilit With the exception of the NRC concerns about system configuration and status control, there was evidence of improvement in major program area The licensee's commitment to improved management control of activities was evidenced by the recent decision to relocate the Shift Operations

, Supervisor into the Control Room directly adjacent to the Unit 2 controls area. Additionally, the Plant Manager and other key managers have been observed frequently on plant tours and were usually able to discuss  !

first-hand observations on such issues as maintenance housekeeping, and !

operational activities. Another positive step was tne ongoing program to reduce the number of outstanding open TACFs. The backlog of open TACFs

,

had been allowed to increase to a level too large to allow proper

administration of the program. Within the last year the licensee has made significant progress in the reduction of outstanding TACFs (see paragraph 9). J

_ _ . _ _ _ _ _

_ _ . . . __

.a1 _;

,

.

,

, 8 y

With. respect to routine' shift activities, management has effectively promulgated the required ' degree of professionalism expected among its

~

operations staff' (see' paragraph 2) and exercised appropriate monitoring techniques to assure that no " dual-system" of conduct exists for back-shifts. ' Management has maintained an awareness of the level of secondary. activity assigned to each shift with respect to support for maintenance, system return-to-service activities, testing, and modifications to ensure that these activities do' not-interfere with the primary duties of conducting plant system manipulations and monitorin ~The NRC inspectors' observations, including back shifts, are that shift and control room activities are conducted in a consistent and acceptable manne . Work Control Activities To ascertain whether the - lice nsee was implementing a program ' of wo'rk control adequate to support fuel load, the NRC inspectors reviewed administrative -controls, evaluated maintenance. organization work control procedures, reviewed maintenance work requests, and observed personnel in their daily activities. The inspection evaluated maintenance organization work control procedures, and the interface between the Maintenance organization and Operations. Interviews were conducted with maintenance supervisors, planning supervisors, system evaluators,. and a number of craftsmen, foremen, and supervisors in - the mechanical, electrical, and instrumentation / controls area War Room Meetings The licensee had established an upper level management control center, referred to as the War Room, to provide constant monitoring of .all plant activities associated with fuel load and pre-fuel load milestones, and - to facilitate communication between managers of interfacing organization The NRC inspectors' attended a number of War Room meetings to determine whether day-to-day plant activities ~

and planned future activities were. being adequately disseminated to i the applicable staff. Good participation and interface between plant groups was observed. Overall, members of the plant management staff appeared cognizant of plant status, ongoing or planned maintenance and/or testing activities, and general problem areas. There was good management control at the meetings and adequate multi-disciplinary attendanc The level of attention to detail displayed during the War Room meetings helped to ensure that individuals were well aware of their specific responsibilities and assisted in the dissemination of informatio The NRC inspectors observed adequate communication between members of plant managemen Work Control Center L

In February 1988, the licensee established a Work Control Center i

'

(WCC) to coordinate plant equipment operations and control clearance The WCC took an administrative burden away from the l j<

l

,

L' '

- _ _ _ _ _ ____ __ _ _ _ __ _ _ _____ .)

- _ - . _ _

__-___ _ - .

. q- ;- 9 : ? o, J m

'

'.

,

9-i

'

Operations crew, and was considered by .the NRC inspectors to be a strength of the licensee progra During the ~ period of this . inspection,- the NRC inspectors . wer U informed that . a major , change in ' the ~ method of controlling wor activities was in. progres The revised work control program is' l described . in- procedure ' SDSP 7.9,. " Integrated Schedule- and Work .I Control". Revision 0 of this procedure was effective December 1,

-198 I

.

. Although the. effectiveness of ~ the revised program could not' be evaluated until after full implementation and a settling period, the NRC inspectors concluded that licensee work control activities were adequate to support fuel load based on the following:

-

Establishment of the. War Room to provide constant monitoring of -

'

all plant activities associated with fuel load and pre-fuel load-milestone '

i

-

The revised work control methodology being based on the program '

used successfully at TVA's' Sequoyah facility. A number of the.

i - work control personnel had previously worked at Sequoyah under-that program.

'

Prior: to criticality, a further review of work control activities will be conducte ' Work Planning Effectiveness The NRC -inspector evaluated .whether the coordination among plant organizations and feedback to appropriate levels of management were  !

'

adequate to minimize the out-of-service time for critical components, limit entry into TS action statements, and control TS LCOs.

l During this assessment period, taking equipment out-of-service to perform specific work was done on a limited basis due to the emphasis on return to service in preparation for fuel loa This NRC inspection activity consisted of a review of procedure SDSP 7.9,

" Integrated Schedule and Work Control"; observation of the work control group's daily activities; and walk through of the processing of MRs. The NRC inspector noted that status updates of work activities were being made to senior managers on a daily basis

! including weekend The NRC inspector also assessed whether responsibility and acc. countability for plant systems and components had been accepted by L- the applicable licensee personnel, and whether responsibilities for L addressing discrepant issues were being clearly assigned.

!

l~ The NRC inspector reviewed the methodology outlined in procedures SDSP 2.12 " Document Distribution Control"; SDSP 6.7, " Post

-

-

J 4 !

'

_ _ .__ ______ ___________________________ _.______ _ __ _ ____ _ _ _ ____ - h

-_ --

'

a :( )

i-

.

..

1 F

Maintenance Test Program;. SDSP 7.9, "Integrt.ted Schedule and Wor l Control"; and SDSP 14.9, " Equipment Clearar.:e Procedure". The NR I inspector' concluded that these procedures, together ' with the .f qualifications of the ~ assigned personnel, should be sufficient to adequately control wor >

The effectiveness of ; communications during work planning and implementation was also assessed by the NRC inspectors. This-activity was monitored throughout 'the assessment period and the NRC inspectors observed- a high degree of management involvement and-effective 'use of the system evaluators. . Communications between the work control shift managers and the integrated schedulers appeared to i< be effective in conveying to personnol what to_ work, when to work it and in ensuring that supporting activities took. place. On several occasions,1various personnel involved in this activity were observed updating the status of ongoing and upcoming work in a tinely manner, and effectively . communicating the status information to applicable managers or group Tracking of Outstanding Work Items

' The NRC' inspectors reviewed the day to day activities of the Work Control Group and observed that the licensee used a computer input to track each item identified as a maintenance request or a preventive maintenance ite The system evaluators maintained : continuous monitoring' of ' the outstanding work items associated ' with their assigned system This- process appeared to be adequate for ; those-items identified as being needed for fuel load. The Work Control Group issued four-day schedules listing items by systems and/or

support activitie e .- Clea~rance Hold Orders The NRC inspectors assessed the effectiveness of the c'earance process by interviewing personnel who coordinated and performed hold order tagging, reviewing the procedural controls over the clearance process, and auditing selected clearance hold orders for adherence to procedures and for good practic In reviewing the clearance records, the NRC inspector identified that the clearance sheets contained numerous illegible initials signifying the performance and independent verification of hold order taggin The names of these individuals were not identified on the documen In the efforts to determine the identities of approximately 15 selected individuals who had initia11ed steps on the clearance forms, several licensee personnel had to be interviewed at length, some contradictory information was obtained, and the identity of one individual was never established. Also clearance sheet 2-88-1358 dated December 2, 1988 had no initial recording that independent verification had been performed. The failure to provide an auditable record of an activity affecting quality was a violation of 10 CFR

o c y[, .

'

7 11 Part 50,. Appendix B, Criterion. XVII, Quality Assurance. Records. When the- issue was identified to the licensee, corrective action was initiate No system misalignments were identified, and the issue -

was primarily administrative resulting in the actual ' safety signifi-cance being minimal. Therefore, per the criteria of the NRC enforce-ment policy, this item was not cite (LIV 260/88-36-04). The-licensee.was requested to evaluate this violation for possible fuel load implications concerning the _ qualifications of- individuals performing work affecting quality. The' licensee was also requested to review other types of plant quality records'to ensure that similar traceability problems did not exis .NRC inspectors! identified that electrical lineups on clearances -were being independently verified by individuals who had not received the 2B electrical training required in order to be qualified to perform the verification This issue is discussed in paragraph CAQR Tagging The NRC inspector, during plant walkdowns, observed several examples of Nonconforming Item tags on installed equipmen These tags contained a CAQR number and described the nonconformance. There were check blocks for P0RS determination' of potential impact on

. operability and whether the component could be used or not. None of the tags had any conditional. release statement on them. The licensee explained ' that conditional' statements would be on' the CAQR. The NRC inspector reviewed the TVA Nuclear Quality Assurance Manual, Part I, Section 2.15, " Nonconforming Materials, Parts or Components" and the subtier document BFN ' SDSP _ 3.8, " Nonconforming Material, Parts or Components" and determined that they were at odds with respect to conditional-release . The NQAM requires a " Conditional Release Log" to be attached to the

" Nonconforming Item Log" and the accompanying form to be filed prior to use of that component under conditions less than fully operabl The licensee indicated that they were in the process of revising SDSP 3.8 to implement the requirements of the NQAM; however, the revision had not been released. Prior to the conclusion of the inspection, an Immediate Temporary Change was issued to SDSP 3.8 to bring it into conformance with the NQA The NRC inspector disagreed with some of the Nonconforming Item tags in the field with respect to the designation of impact on operabilit For example:

- CAQR BFP 870319 on LPCI Motor Generator (MG) 2DA was designated as having no impact on operability, yet this condition involved i

'

electrical terminations protected with tape vice the required RayChem splices on several pieces of electrical equipmen !

- = _ _ _ _ - _ _ _ _ _ _ - _ _ _ - - _ _ _ _ _ _ _ _ _ - _ - _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ - - - _ _ _ _ . _ - -_ - -_-

_ _ _ . _ _

___

? !C * 9

'

=

.

.

-

-

CAQR BFP 870542 on RCIC' control panel 25-31 was designated as having no impact on operability, yet the condition was -lifted-

1eads not tagged,' cables not supported, spare cables not sealed,

-insulation brittle and cracking and trash inside the pane CAQR BFP 881046P documented that weld 2RFW-03-40C1 was-inspected by a QC inspector prior to QC inspector qualificatio CAQR 0870541003 on valves 2-69-67 and 2F1-69-38 indicated that-L, the nonconformance had potential impacts but the item could be used. The nonconforming condition was that the bolting material l did not conform to design requirement None' of the above systems were required by TS to be operable at the time of the' inspectio ,

As a result of conversations with QA/QC personnel, a CAQR was written  !

1. and a. review of all1 Nonconforming Item Logs on systems required for fuel load was performed. At the close of.the inspection period,.nine operability impact determinations had been reversed and :six additional. tags were being considered for a change classificatio The NRC inspector believes that with the revised SDSP 3.8 and increased sensitivity to operability determination, that the licensee performance in this' area is acceptable.for fuel' load. This area will continue ' to be monitored during future NRC inspections and is identified as IFI 259,260,296/88-36-0 This item will be reviewed prior to Unit 2 startu . Independent Verification Policy

'

While: reviewing work requests and clearance hold orders, an NRC inspector observed on the AVO work schedule that only 15 of 84 AU0s were designated as 'being electrically qualified. When NRC inspectors questioned licensee management on the independent verification policy for clearances, management stated that only electrically qualified AV0s were allowed to clear and tag electrical equipment, but that non-electrically qualified fourth period student AU0s could perform the independent verification This position was based on SDSP 14.9, " Equipment Clearance Procedure",

which differentiated between the qualification requirements for personnel hanging and verifying electrical clearance hold order tag Similarly, an NRC inspector noted that the OI electrical lineup checklists required the "first person" check to be performed by personnel who have completed 2B electrical training, but allowed the "second person" check to '

be performed by a fourth period student without electrical trainin The scope of Site Director Standard Practice SDSP 3.15, " Independent Verification", specifically included applicability to both clearance tagging .and system alignment checklists. Step 6.3.2 of SDSP 3.15 stated  ;

that the individual assigned to perform independent verification must have 1 completed appropriate training requirements and shall be qualified to l perform the test, alignment, or temporary alteration being independently

. _ _ _ _ _ - _ - _ _ _

[ ^pc e _-

.

'

-

.

verified. SDSPJ3.15 also stated that the term second~ person verification,

-

when .used: in procedures, shall be synonymous with independent verification. The independent verification requirements of SDSP 3.15 were

,

Ein definite conflict with the requirements. of SDSP 14.9 and the OI-checklists regarding independent verifications for electrical component Adequate independent verification of an action requires the same qualification level as that established to perform. the action, as is specified in SDSP 3.1 Therefore, if SDSP 14.9.and the 01 checklists required 28 electrical training to position or tag electrical components, the same training requirements .should apply for the independent verification of these action The NRC inspectors reviewed recent clearance sheets and identified a number of. examples where the operation and tagging of electrical breakers had apparently been independently. verified by persons without the electrical qualification Examples included clearances 2-88-1208,

-2-88-1241, 2-88-1314, and 2-88-135 The performance of_ independent verifications of electrical alignments by individuals who had not received the 2B electrical training required to perform the steps was identified as Violation 259,260,296/88-36-02 for failure to follow SDSP 3.1 . Temporary Alterations A total of 46 open TACFs existed on December 19,.1988, down from 64 during June 1988. The NRC inspectors selected 16 TACFs for review that were li:ted as open on the Unit 2 and common TACF indexes located in the Control Room area. The TACFs selected for review were chosen because by nature. of Title or description contained in. the TACF index, there existed a potential for affecting systems needed for refueling operation No discrepancies or significant impact on the associated systems were noted and'a planned permanent modification was reference For TACF 2-84-106-92, which bypassed the SRM function, the Unit 2 TACF index listed this TACF as open although no TACF file could be locate The NRC inspector determined after . further discussion with licensee operations personnel that the TACF had been recently closed and the Unit 2 index had not yet been annotated to reflect the closure. The Unit 2 index was updated and no open TACFs exist for the Unit 2 Nuclear Instrumentation Syste Two TACFs associated with the Unit 2 Refueling System were ope TACF 2-86-020-79, associated with minor structural modifications to the Cask )

Decontamination Chamber has no significant impact on refueling, and will ,

remain open after fuel load. TACF ?-88-006-079 disabled a portion of the i refueling interlocks by removing track switches form the Unit 2 refueling pl at f orm. These track switches provide signals to the Rod Block Systcm when the refueling platform is positioned over the core. The interlocks were disabicd in order te perform functional testing of the RBS associated with LPRM and neutron source installation work in the Unit 2 Reactor

!

J

- ___ --.

.

.("

'

,

.

Vessel. The NRC inspector noted that this TACF was planned to be closed, with SI 4.10.A.1 performed as a retest, prior to fuel loa The NRC inspector reviewed the TACF File for the Core Spray System and the Emergency Equipment Cooling Water System and noted there were no open TACFs for the CS System. However, four TACFs for the EECW were outstanding. The NRC inspector reviewed the system status file, located in the Unit 2 control room, for the EECW system and noted that TACF 0-86-020-67 was signed off as being completed. However, additional review indicated that the BFN Quality Monitoring group identified the TACF-as still being outstanding. The Control Room Status file was changed to reflect thi None of the open TACFs adversely affected the plants readiness for fuel loa . Preventive Maintenance Program The NRC inspectors reviewed SDSP 6.2, " Preventive Maintenance Program" and found it acceptabl During this assessment period, the NRC inspectors reviewed the PM activities involved with the overhaul and restoration of the 4160 volt circuit breaker This activity appeared to be well controlled and proceduralized. The NRC inspector also' noted the PM was tracked and controlled by the Work Control Group and was listed on the Four Day Look Ahead Schedul . Post-Maintenance Testing The NRC inspectors reviewed post-maintenance testing to evaluate its '

effectiveness in reducing component operability problems following a maintenance activit The NRC inspectors reviewed SDSP 6.7, " Post Maintenance Test (PMT)

Program", ten maintenance requests, and the Attachment A to SDSP 6.7. The NRC inspectors noted that on the MR form, the type of PMT required is indicated by the maintenance planners with the assistance of the Discipline Technical Group. The review of the ten maintenance requests indicated that some PMT requirements were very specific, such as requiring that a specific section of a procedure be performe The review also indicated that some PMTs were very general such as stating PMT to be performed per a procedure that may be more than a hundred pages in lengt These observations were discussed with plant managemen . Exit Interview The inspection scope and findings were summarized on December 23, 1988, i with those persons indicated in paragraph 1 above. The inspectors described the areas inspected and discussed in detail the inspection findings listed below. The licensee did not identify as proprietary any of the material provided to or reviewed by the inspectors during this inspection. Dissenting comments were not received from the licensee. The concerns over system status control were discussed with TVA management on December 28, 198 TVA's actions to resohe these concerns for fuel loading were documented in a December 29, 1988 letter to the NRC.

m z - - _ - - - _ _ _ _ _ _ __ _ _ _ __ -- - -.

j

. _ - _ _ _ _ _ - _ _

. ,

i i

'

• 15

,

Inspection Findings:

(0 pen) VIO 259,260,296/88-36-01: Violation of TS Requirements to Properly-Establish and Implement a Procedure for- Configuration Centrol (paragraph 5)

. -(O'en) p VIO 259,260,296/88-36-02, Example 2: Violation of TS 6.8.1.1.a, f6r' Failure to Follow .SDSP 3.15 Regarding Qualifications Requirements for Inde~ pendent Reviewers of Electrical Lineups (paragraph 8)

(Closed) LIV 260/88-36-03: Failure to Comply with the Logkeeping Require-ments of Procedure PMI-2.12 (paragraph 2)

(Closed) LIV 259,260,296/88-36-04: Failure to Adequately Document Identi-ties ' of Persons Performing and Verifying Clearance Hold Order System Alignments (paragraph 7.e.)

(0 pen) UNR 259,260,296/88-36-05: Adequacy of Corrective Actions in Response to NRC Violations at Sequoyah in Area of Configuration Control (paragraph 5)

(0 pen) IFI 259,260,296/88-36-06: Review of Operability Determinations for Nonconforming Items (paragraph 7.f) Acronyms ANSI American National Standards Institute APRM Average Power Range Monitor ASOS Assistant Shift Operations Supervisor AUO' Auxiliary Unit Operator BFNP Browns Ferry Nuclear Power Plant CAQR Condition Adverse to Quality Report CFR Code of Federal Regulations CS Core Spray CSSC Critical Structures, Systems, and Components EECW Emergency Equipment Cooling Water ESF Engineered Safety Feature IFI (NRC) Inspector Followup Item ITC Immediate Temporary Change IRM Intermediate Range Monitor LCO Limiting Condition for Operation LIV (NRC) Licensee Identified Violation (or Discretionary Enforcement)

LPCI Low Pressure Core In_iection LPRM Local Power Range Monitor l LRED Licensee Reportable Event Determination MG Motor Generator >

MR Maintenance Request NQAM Nuclear Quality Assurance Manual NRC Nuclear Regulatory Commission 01 Operating Instructions J

!

l l

h6ehhe_____-___-__m____ ___ _

g ,

, _ _

_

-- -____ _ - _ _ _ _ _ _ _

__ _ _ _ _ _ _ . _ _ ,

b j.og ,1 /

-

'*

.f+

p

'

..

~* .

,

<: I6 <-

.

(-.

J OSILL -Operations.Section Instruction ~ Letter Preventive Maintenance

'

PM-PMI Plant Manager Instruction-

'PMT Post Maintenance / Modification Test-n PORC ' Plant Operations Review Committee H ,

PORS

'

Plant Operations Review Section P-Q Quality Assurance QC' Quality Control-

RBS- Rod Block System RCIC- Reactor Core' Isolation Coolin RHR' Residual Heat Removal i SBGTS Stand By Gas Treatment System SDSP- Site Director Standard Practice SI . . Surveillance Instruction-SOS . Shift Operations Supervisor SP0C System Pre-Operation Checklist

. . SRM Source Range Monitor l TACF -Temporary Alteration Change Form-TD- Test Deficiency TS LTechnical Specifications-TVA . Tennessee Valley Authority UNR; '(NRC) Unresolved Item UO Unit:0perators

'

DVIO: (NRC) Violation

,

t

>

_

i f

__ h___.____.__..__.__.__.__ _ _ _ _ _ . . _ _ . _ _ _ _ _ . _ . _ _ _ . . . _ . _