IR 05000259/1989048
| ML18033B044 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 10/27/1989 |
| From: | Carpenter D, Little W, Patterson C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18033B043 | List: |
| References | |
| 50-259-89-48, 50-260-89-48, 50-296-89-48, NUDOCS 8911140075 | |
| Download: ML18033B044 (32) | |
Text
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UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STR E ET, N.W.
ATLANTA,GEORGIA 30323 Report Nos.:
50-259/89-48, 50-260/89-48, and 50-296/89-48 Licensee:
Tennessee Valley Authority 6N 38A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Docket Nos.:
50-259, 50-260, and 50-296 License Nos.:
DPR-33, DPR-52, and DPR-68 Facility Name:
Browns Ferry Units 1, 2, and
Inspection at Browns Ferry Site near Decatur, Alabama Inspection Conducted:
September 15 - October 16, 1989
~n Inspector "
4~
-
.
-Fd R.
Car'p n er, NRC Site Manager C. A. Patterson, NRC Restart Coordinator Oat< Si ned g~ Cr D
e Si ned Accompanied by:
E. Christnot, Resident Inspector W. Bearden, Resident Inspector
~Ivey, si 'nspector
'
Approved by:
W.
S. L>ttle> Section Chief, Inspection Programs, TVA Projects Division Date Si ned SUMMARY Scope:
This routine resident inspection included reportable occurrences and action on previous inspection findings.
Results:
Eighteen LERs were reviewed and closed.
Six IFIs were reviewed and closed.
Four violations were reviewed and closed.
In reviewing these open item closeout reports the number of personnel errors and the impact they have on plant activities can be easily seen.
During a
management meeting with TVA on September 28, 1989 on the subject of procedures and related problems, TVA presented an analysis of LER's in 1989 that indicated 8911i40075 89103i PDR ADOCK 05000259 G
PNU
that personnel errors are by far the greatest single cause of events.
TVA described actions being taken by TVA which, if successful, should reduce the number of personnel errors.
(See letter from the NRC to TVA, Meeting Summary - Browns Ferry Nuclear Plant, Unit 2 Docket No.
50-260, October 18, 1989.)
The inspectors wi 11 monitor 'the licensee's progress on personnel error reduction, as well as the positive and negative effects on overall plant efficiency of operation REPORT DETAILS Persons Contacted Licensee Employee's:
0. Zeringue, Site Director
- G. Campbell, Plant Manager
, "M. Herrell, Plant Operations Manager
"R. Smith, Project Engineer
~J. Swindell, Plant Support Superintendent J. Hutton, Operations Superintendent A. Sorrell, Maintenance Superintendent G. Turner, Site Quality Assurance Manager P. Carier, Site Licensing Manager
"P. Salas, Acting Compli'ance Supervisor J.
Corey, Site Radiological Control Superintendent R. Tuttle, Site Security Manager Other licen'see employees or contractors contacted included licensed reactor operators, auxiliary operators, craftsmen, technicians, and public safety officers; and quality assurance, design, and engineering per'sonnel.
NRC Employees:
- D. Carpenter, Site Manager
- C. Patterson, Restart Coordinator
"E. Christnot, Resident Inspector
- M. Bearden, Resident Inspector
"K. Ivey, Resident Inspector
- Attended exit interview Acronyms used throughout this report are listed in the last paragraph.
Reportable Occurrences (92700)
The LERs listed below were reviewed to determine if the information provided met NRC requirements.
The determinations included the verification of compliance with TS and regulatory requirements, and addressed the adequacy of the event description, the corrective actions taken, the existence of potential generic problems, compliance with reporting requirements, and the relative safety significance of each event.
Additional in-plant reviews and discussions with plant personnel, as appropriate, were conducte a.
(CLOSED)
LER 260/88-11, Unplanned Containment Isolations Caused By Personnel Error.
This LER identified two separate unplanned ESF actuations resulting from personnel errors and a third unplanned ESF actuation for which no cause has been identified.
All three events occurred on October 17, 1988, during or immediately following performance of 2-SI-4.2.A-10,
"Reactor Building and Refueling Floor Ventilation Radiation Monitor Calibration and Functional Test".
Each resulted in the isolation of Unit 2 primary and secondary containments, the control rooms, reactor and refuel zones; a'nd actuation of standby gas treatment and control room emergency ventilation systems.
The inspector reviewed LER 260/88011 and other documentation provided by the licensee.
The licensee determined that two of the events occur red due to personnel errors.
The first error occurred when the instrumentation technician inadvertently skipped a portion of the procedure and subsequently removed a test jumper that was bypassing a
simulated high radiation signal prior to that signal being reset.
The second error occurred when the instrumentation technician inadvertently contacted exposed components thereby causing a
momentary short in the power supply and initiated the second isola-tion signal.
One additional factor that contributed to the errors was human factors problems with the procedure and the construction of the power supply.
The testing for all three units was contained in a
common procedure and the physical construction of the power supply is such that very little space is available between the test points and other conductive surfaces.
The third isolation occurred approximately five minutes after completion of testing.
Extensive troubleshooting investigation and the connection of continuous monitoring instrumentation to key points in the circuit failed to identify a cause for the third event.
The inspector reviewed various documents provided by the licensee including the associated incident critique sheets and Incident Evaluation Report, RCA-88-22.
The licensee performed the following:
corrective actions Personnel involved were counseled on need for greater attention to detai 1 while conducting surveillance testing.
The Surveillance Instruction has been revised to separate the testing associated with the radiation monitors for the three units and to remove the section associated with power supply checks.
Additionally, the power supplies are now checked as part of a separate surveillance that is performed on a
less frequent basis.
The testing is performed in conjunction with operation of the associated SBGT and CREV equipment so that an unplanned challenge to the initiation logic will not occur'.
The licensee has scheduled an upgrade to the respectiv U 't.
corn n
ponents with newer equipment prior to restart.
The licensee ive ni stated that the newer installation will eliminate the potential fo'
the human factors problems.
This item is closed.
b.
(CLOSEO)
LER 259/88-33, Missing Liquid Effluent Batch Sample Caused By Inadequate Procedures.
On October 4,
1988 while performing SI-4.8.A.2-1 the Septembe 1 88, monthly proportional composite sample, it was noted that one of
the batch samples was mi s sing .
Thi s resulted in the monthly composite reflecting only 40 of 41 liquid effluent releases.
This composite sample is intended to partially satisfy the requirements of T.S. 4.8.A.2.
The licensee evaluated the event and determined that the effect on the monthly composite sample was small since the missing batch sample's activity was estimated to be minimal and represented only 2.3'f the total monthly composite.
Therefore, the composite sample gave a reliable indication of the activity of the month's liquid effluent releases and was consistant with the previous months results.
The licensee determined that the missing sample occurred due t i adequate procedures in
.that the chemistry procedures that
'n e
o controlled the preparation of the monthly and quarterly composites did not adequately address sample tracking and storage control.
The missing sample was dated August 31, 1988, and most likely had been inadvertantly discarded along with the batch samples for the month of August.
The August, 1988, composite had been completed on August 31, 1988, and had not included the batch sample taken on that same date because it had not been released.
The licensee determined that revision of the applicable chemistry procedures was needed to improve accountability,.
sample labling, storage, and control of sample disposal.
The NRC inspector reviewed the latest versions of SI-4.8.A.2-1, SI-4.8.A. 1-1, SI-4.8.A.2-2, SI-4.8.A.1-2, and SI-4.8.B.2-2 and not d
at each had been revised subsequent to the event to more clearly define responsibility for control of samples, sample storage and disposal.
Also Chemistry Instructions CI-?11,
"Liquid Proportional Composite Sample Preparation,"
and CI-717,
"Composite Samples for Air Particulate Monitoring," were reviewed and noted to now contain greater clarification on sample labeling requirements.
There have been no similar recurrences of inadvertently discarding samples since the applicable procedures were revised.
The inspector concurs with the licensee's corrective action which should preclude recurrence of the event.
This item is close (CLOSED)
LER 260/88-14, An Inadequate Reviewed Clearance Request Results In The Generation Of A Scram Signal With the Unit Defueled.
On November 3,
1988, during a
maintenance activity involving the control rod drive system, the licensee
.indicated on the tagout request that no other system would be effected.
However, when the scram pilot air system was isolated, air to the scram inlet and outlet valves was cutoff.
This allowed the scram valves to open slowly as the air pressure died off and resulted in an increase of water flow 'to the scram discharge instrument volume.
When the level in the instrument volume reached the high level switches, a full scram was initiated.
The licensee attributed this to an inadequate review of the scope and effect of the job activity.
A new procedure was written, SDSP 7.9,
"Integrated Schedule and Work Control,"
initial issue dated November 30, 1988, which established the methodology for system evaluation prior to any work commencing on a
system.
The inspector reviewed SDSP 7.9, discussed it's application with work planners and system impact evaluators, reviewed NRs which utilized Attachment 1 of SDSP 7.9, "Plant Operation Impact Evaluation Sheet,"
and discussed the integrated schedule and work control BFNP methodology with TVA supervisors.
The inspector determined that the licensee'actions were appropriate.
This item is closed.
(CLOSED)
LER 260/88-17, Unplanned Initiation of ESF During Performance Of SI Because Of Inatt'ention To Detail.
This item involves the unplanned initiation of ESF equipment on December 18, 1988.
While performing SI 4.9.A. l.b-2, the operator inadvertently placed an incorrect keylock switch in the test position.
This caused the start signal for the
"2C" CS pump to remain uninhibited.
Therefore, when the next procedural step was performed, the pump received its auto start signal and started, in turn causing initiation of other ESF functions.
The cause of this error was determined to be inattention to detail on the part of the operator, in conjunction with a
procedure that did not require independent verification of the test switch positi:n.
The individual involved has been counseled as to the importance of attention to detail.
In addition, SI 4.9.A. 1.b-2 has been revised to incorporate the requirement for independent verification of all steps pertaining to system alignment prior to and during the performance of the test.
The inspector reviewed the revised procedure and determined it to be adequate to prevent recurrence,.
This item is close (CLOSED)
LER 260/88-18, Reactor Scram Initiated From Neutron Monitoring System Caused By Personnel Error And Spurious Channel Trip.
This item involves a full reactor scram which occurred on December 18, 1988, when RPS systems
"A" and "B" tripped almost simultaneously.
Although the cause of the system
"A" trip could not be isolated, system
"B" tripped when an instrument technician accidently grounded a jumper which was being installed in order to perform IRM cali-bration procedure 2-SI-4.2.C.-3(E).
The grounded jumper cleared a
fuse supplying power to the detectors, causing the "B" system trip.
Immediate corrective action was to replace the fuse, reset the scram, and perform a visual inspection to insure that the terminals where the jumper grounded had not been damaged.
To prevent recurrence, revisions to the IRM calibration procedures have been implemented to eliminate the necessity of using jumpers.
The inspector had reviewed the licensee's actions and determined that they were acceptable.
This item is closed.
(CLOSED)
LER 259/88-19, ESF Actuations Occurred Due to Personnel Error.
This item involved unplanned ESF actuations on June 8,
1988.
the licensee's investigation found that the actuations occurred when a
jumper accidentally fell off a
fuse block.
The jumper had been placed across fuse block 16AF63A in order to change the fuse.
Immediate corrective action was to quickly replace the fuse and reset each ESF actuation.
The individuals involv'ed were cautioned to exercise greater care when performing similar activities in the future and other operations personnel were directed to review the event as part of their required reading.
The NRC inspector determined that these actions were acceptable.
This item is closed.
(CLOSED)
LER 259/88-31, ESF Actuations Due to Grounded Test Jack.
This item involves three instances which occurred in October 1988, where unplanned ESF actuations occurred due to the inboard portion of PCIS logic being deenergized.
The cause of these events was found to
be a high resi stance ground between a test jack and the metal box cover in which it was mounted, panel 9-42.
This ground caused fuse 16AF19 to clear, resulting in the deenergizing of the PCIS logic.:
To prevent these high resistance grounds from occurring in the futuire, the box cover has been modified so that the test jacks are now mounted in plexiglas instead of metal.
This modification was accomplished per DCN F3038B.
The inspector has reviewed the DCN, including the licensee's safety evaluation, and determines that the corrective actions taken are appropriately This item is close (CLOSED)
LER 259/88-42, Inadequate Procedure Resulted In An Unplanned Engineered Safety Feature Actuation An unplanned ESF actuation occur red during the performance of a work plan to install fuses and fuse blocks in a
480 volt shutdown board
"1B", compartment 6A.
The work plan requi red that the instrument and control bus be transferred to its alternate supply.
The transfer switch is a break before make transfer and results in a
momentary loss of power during the transfer.
The loss of power caused the ESF actuations which were not identified in 'the work plan.
The affected systems were returned to their normal configuration and a four hour notification made to the NRC.
The inspector reviewed the instructions given to the SOSs to re-emphasize their obligation to ensure work procedures have sufficiently addressed the effects the work will have on plant equipment.
SDSP-7.9,
"integrated Schedule and Work Control,"
has been developed and issued.
It contains an impact evaluation form for evaluation, before implementation, of those activities that affect equipment operations.
The impact evaluation should help to reduce the number of unplannned ESFs.
This item is closed.
(CLOSED)
LER 259/88-44, Unplanned ESF Actuation Due to Operator Error During Transfer of Power Supplies.
On November 1,
1988, at 1:11 p.m.,
4160 volt shutdown board
"B" was momentarily deenergized while attempting to transfer the board from its alternate power supply to the normal supply.
This caused a trip of the
"1A1" RPS circuit protector, an RPS channel
"A" half scram, and the associated ESF components to start.
The loss of power occurred because the normal supply breaker did not close as the alternate breaker was opened.
The licensee attributed the failure of the normal supply breaker to close to the operator not holding the breaker control switch fully in the close position as the alternate supply breaker was opened.
Investigation at the time of the event and subsequent breaker operation verified that there were no physical problems with the breaker.
The operator involved was counseled and a description of the event was distributed to the operating staff.
The inspector identified no discrepancies and had no further questions on this event.
This item is closed.
(CLOSED)
LER 259/88"47, Personnel Error During Performance of Preventive Maintenance Causes Unplanned ESF Actuation.
This item involves the inadvertent deenergizing of Unit,
RPS Bus "B" on December 2,
1988, resulting in an unplanned ESF actuation.
This bus had been transferred to its alternate power supply in order to perform PM on RPS MG set "B", its normal power supply.
During the performance of the PM, the bus was returned to its normal power supply although procedure, EPI-0-099-MGZ002, contained no direction to do so.
A subsequent procedural step was to check and adjust the
MG set output voltage to 120 VAC (
+
1 VAC).
Higher than acceptable voltage was observed, and when the voltage potentiometer was adjusted downward, the circuit protector received a
low voltage signal, opened, and deenergized the bus.
The licensee has determined the causes of this event to be:
I)
Personnel error,.in that if the bus had remained aligned to its alternate power supply, as was intended, it would not have received the low voltage signal and deenergized.
2)
Test equipment failure, in that it was discovered that an improperly reading multimeter was used to measure output voltage.
Although the meter was still within its calibration interval, it was subsequently checked and found to be reading 5 volts high.
Thus, when the attempt was made to adjust the erroneous high voltage reading downward, the actual effect was to lower the voltage to the point of causing the bus to deenergize.
The licensee implemented the following corrective actions 1)
Personnel were counseled on the necessity of paying closer attention to detail when performing maintenance in accordance with approved procedures.
2)
The defective multimeter was removed from service and an investigation was performed to assure that it's malfunction had not caused other equipment's test results to be in question.
The inspector reviewed the above corrective measures and considers them acceptable.
This LER is closed.
k.
(CLOSED)
LER 259/88-27, Inadequate Procedure Causes Unplanned Start of Emergency Equipment Cooling Water Pump.
(CLOSED)
LER 259/88-45, Unplanned Engineered Safety Feature Actuation Due to Breaker Malfunction Caused by Misalignment in Board Compart-ment.
(CLOSED)
LER 259/89-06, Loss of Secondary Containment Integrity Due to Personnel Error and Inadequate Communications.
(CLOSED)
LER 259/89-07, Unplanned Start of Diesel Generator A Because of Unclear Post Maintenance Test Instructio The above LERs are all similar examples of unplanned ESF actuations and systems being inoperable with each event being caused by inadequate post maintenance and post modification activities on the part of licensee personnel.
The inspector reviewed the licensee actions for the, above events which consisted of the following:
1)
The licensee revised several procedures such as SDSPs 7.4,
"Technical Review and Approval of Procedures,"
12. 1, "Restart Test Program,"
and 17.2,
"Preparation and Review of Post Modification Tests;"
PMIs 6.2, Tracking and Maintenance",
17. 1,
"Conduct of Testing,"
and 17.8 - "Special Tests and Instruc-tion;"
EMI 7.9, "Initial Installation Test and Checkout of 4KV Circuit Breakers, Alignment of Circuit Breaker to Cubicle, and 106 Wire Lifting/Determination Documentation and Trouble-shooting;"
and O-OI-82,
"Standby Diesel Generator System Operating Instructions."
2)
Training sessions and counseling of licensee personnel involved in the above events were conducted.
3)
Written descriptions of the events were initiated and provided to the personnel involved as.required reading.
The inspector reviewed the procedures indicated above, reviewed records which indicated the names of personnel who received training, observed activities in the field during and after a six month period, and discussed the
. issues with various licensee personnel.
The inspector determined the corrective actions for each event to be appropriate.
The inspector noted that these events occurred over a
six month period from September 1,
1988 to March 5, 1989, and that with each event specific corrective action was taken only for that individual event.
The inspector detected no in depth review or survey on the part of the licensee that would indicate a finding of an generic trend.
These events are more examples of the eneric type of activity cited in the violation documented in IR 89-38.
Based on that violation and corrective action taken by the licensee, these items are closed.
1.
(CLOSED)
LER 259/89-19, Unplanned ESF Actuation Caused By Failed Connection At Radiation Detector Due To Repeated Movement Of Detector Cable.
This item involves unplanned ESF actuations on July 26, 1989, caused by a spurious signal from radiation, monitor, 1-RM-90-140.
The signal was verified to be spurious by comparison with other monitors in the
area and local radiological surveys.
The licensee performed an investigation of the event and determined that the cause was the radiation monitor signal cable conductor pulling loose from its connector pin.
This occurred while the signal cable was being moved to read the indication on radiation monitor, 1-RM-90-1.
The corrective action was accomplished by repairing the failed electrical connection and providing additional support by wrapping the detector connectors with electrical tape.
The action to prevent recurrence was accomplished by repositioning the cable to provide an unobstructed view of the adjacent monitor.
In addition, a visual inspection of the corresponding installations in Units
and 3 verified that this was an isolated case.
The inspector reviewed the above licensee corrective actions and determined that they were appropriate.
This item is closed.
(CLOSED)
LER 260/89-20, Unplanned ESF Actuation During Fuse Replacement Caused By Personnel Error.
This event was also identified in IR 89-27 as IFI 260/89-27-01, whose closure is discussed in section 3.f of this report.
Therefore, this item is also considered closed.
(CLOSED)
LER 260/89-19, TS Violation Caused By Missed Surveillance.
This event was also identified in IR 89-27 as Violation 260/89-27-02, whose closure is discussed in section 3.j of this report.
Therefore, this item is also considered closed.
(CLOSED)
LER 259/89-22, Inadvertent Insertion Of Radiation Detector Check Source Results In Unplanned CREV Actuation.
This item involves an unplanned CREV Train A actuation, on August 10, 1989, from radiation monitor 3-RM-90-259B.
The cause of the actuation signal was the inadvertent insertion of the detector check source when it was bumped during maintenance activities in the area.
Maintenance personnel were replacing insulation above the detector assembly, and a piece of insulation bumped the check source assembly protruding from the top of the detector, causing the check source to enter the detector and initiate the high radiation signal
.
Immediate corrective action was to retract the check source and verify that no damage had been sustained.
A temporary wooden structure was then placed around the detector for protection while the insulation work in the area was completed.
To preclude future recurrence 3-RM-90-259B has been designated by the licensee as a
sensitive device requiring protection from adjacent activities, and a plaque
has been placed in front of it to identify it as such.
The NRC inspector reviewed these corrective measures and determined them to be appropriate.
This item is closed.-
No violation's or deviations were identified in the area of Reportable Occurrences.
3.
Action on Previous Inspection Findings (92701, 92702)
a.
(CLOSED) IFI 259/85-06-14, SDIV Fill Time, TI-74.
This item involves three observations made by an NRC inspector while reviewing the licensee's actions pertaining to the November 20, 1984 scram of Unit 3:
1)
TI-74, Scram Discharge Instrument Volume Fill Time Performance Data Sheet 74.2 was not maintained as a controlled document.
The completed data sheets were being maintained only in a
cognizant engineer's notebook.
2)
Computer data points for the TI-74 data sheets were incorrectly referenced.
3)
Although TI-74 required the recording of scram discharge volume fill times, no quantitative acceptance criteria existed in the procedure.
The licensee has taken the following actions to address these observations:
1)
In May 1989, TI-74 was superseded by PMI 15.8, which specifies that charts, printouts, scram reports and transient event reports will be considered gA records with a lifetime retention period.
2)
The correct data point references are now located on Attachment 9 of PMI 15.8.
3)
Due to hardware modifications performed per ECN P0392, the monitoring or recording of scram discharge volume fill times is no longer necessary.
Therefore, no requi rements for such recording appear in PMI 15.8.
The inspector reviewed PMI 15.8 and verified that the above actions taken by the licensee were complete and acceptable.
This item is closed.
b.
(CLOSED) IFI 259/88-23-02, Long Term Dose Rate Reduction Plans For The UlB Fuel Pool Heat Exchanger This item involves the licensee's plan for reducing dose rates to personnel working near, or traveling past the 1B fuel pool heat exchanger.
Dose rates well in excess of 1000 mr/hr had been observed in this vicinity due to higher than usual contamination levels in the heat exchangers.
The rise in contamination was attributed to the fuel reconstitution work that was performed in Units
and 2.
Actions taken by the licensee at the time included the placement of temporary shielding around the heat exchanger and restricting access to the immediate area by the use of a high radiation door watch.
Although these actions were acceptable for the short term, the inspector requested further information regarding the licensee's plans for long term maintenance of dose rates below the 1000 mr/hr high radiation area threshold.
The licensee has subsequently performed a
study to evaluate the feasibility of several proposed actions.
These include:
1) high volume flushing of the heat exchanger, 2) installation of a permanent shield wall or a
lockable fence around the heat exchanger, or 3)
chemical decontamination of the heat exchanger.
The option-of a
periodic high volume flush was determined to be the most attractive and.cost effective but, that chemical decontamination or installation o
the lockable fence may become more attractive in the future.
These options were left open for possible future implementation.
In August 1988, procedures 1-SOI-24 and 2-SOI-24 were initiated to provide instructions for periodically flushing the fuel pool heat exchangers and associated piping.
The inspector has reviewed radiological survey data taken following the performance of the first series of these high volume flushes.
The data shows that the dose rates'n the area have dropped appreciably, with readings of 230 mr/hr (Unit 2) and 65 mr/hr (Unit 1) being the highest recorded at a
distance of
inches from the heat exchangers.
The inspector determined that the demonstrated success of the high volume flu h lo a ong with the avai l abi 1 ity of other options if needed, provides adequate assurance that the licensee can maintain dose rates in the area of the spent fuel heat exchangers below 1000 mr/hr.
This item is closed.
(CLOSED)
IFI 260/88-33-02, guestionable Relay Rating In Scram Discharge Volume Level Switches.
This item involves a
question raised during NRC observation of SI-4. 1.8.8(B),
"RPS High Water Level Scram Discharge Tank Calibration."
The inspector had noted that hand written changes had been made to the manufacturer's printed labels on relay R2 of 2LS85-45H and relays R1 and R2 of 2LS85-45M.
The
amp contact current rating on the labels had been changed to
amps.
The inspector had also noted that the Eg documentation stated th q alified relay to be a
amp relay.
These observations cau ed th u
e e
inspector to question whether the installed relays are acceptable for use e
this applicatio '
In order to address this question, TVA contacted the manufacturer, FCI, Their response was that the design called for a relay with a rating of
amps, but FCI uses only
amp and
amp relays.
For this application, they used a
amp relay, derated to 5 amps.
FCI also stated that only 2 and
amp preprinted labels were available, thus necessitating the hand written change.
Finally, FCI confirmed that the
amp relays were the ones qualified as stated in the Eg documentation, and could be positively identified by an "R10" at the beginning of the part number appearing on the side of the relay case.
Upon receiving the above information, TVA gA evaluated FCI's response and concluded that the hand written changes do not constitute a
problem.
The NRC inspector has also reviewed the manufacturer's response and field verified the presence of the
"R10" on the relay cases, and determined that the installed relays are acceptable for their intended use.
This item is closed.
(CLOSED) IFI 259, 260, 296/88-33-04, Limitorque Operator Failures.
This item involves a question as to the adequacy of the licensee's programmatic controls for preventing the inadvertent use of deficient components.
Specifically, the question pertains to items such as limitorque motor operators, H2/02 analyzer valves, or other. types of components which have been reported as being generically deficient in accordance with 10 CFR 21.
In many instances at BFNP, these types of items have been replaced with acceptable components in installations required to support the restart of Unit 2, but have not yet been replaced in Units
and 3. It has also been fairly common practice at BFNP to scavenge parts from Units
and 3 to repair or replace faulty Unit 2 items.
These circumstances caused the NRC inspector to question whether sufficient procedural controls were in place to ensure that deficient Part 21 components could not be scavenged from Units 1 or 3 and installed in Unit 2.
Since this question was originally raised, the licensee has implemented several procedural enhancements.
The inspector has reviewed the current applicable procedures and found that safety related material transfers between units are controlled in one of two ways, depending on the classification of component.
For items requiring environmental qualification in accordance with
CFR 50.49, procedure SDSP 30. 1 contains provisions for the identification and evaluation of components acceptable for use.
All other safety related components not requiring Eg are controlled by procedures PMI-6.28 and SDSP-16.9, which provide requirements for evaluating material transfer requests and verifying that, items are acceptable for their intended use.
The inspector determined that compliance with the requirements contained in the above procedures will provide adequate assurance that deficient Part
components will not be inadvertently used in Unit 2 installations.
This item is close e.
(CLOSED) IFI 260/89-03-01, Interference Between PSC Head Tank System and SRMs.
This item involved the observance of significant spiking by SRM channel
"C" during refueling activities, causing the channel to be declared inoperable.
Initial monitoring of the spiking revealed that it occurred whenever the 2A PSC head tank pump started or stopped, but the reason for this interaction was unknown.
As a result, MR A-77004S was initiated to troubleshoot and attempt to determine the cause of the spikes.
Checks performed per this MR resulted in the replacement of a DC amplifier card and preamplifier.
The channel was then recalibrated and functionally tested per SI 4.2.C-4(c).
Following the completion of the above actions, the head tank pump was started and stopped several times, with no spikes occurring.
Although the exact cause of the spiking could not be positively identified, cognizant licensee personnel have determined the probable cause to be noise in the preamplifier, which has been replaced.
The inspector has reviewed the"licensee's actions taken in attempting to determine probable cause and considers them to be acceptable.
This item is closed.
f.
(CLOSED) IFI 260/89-27-01, Fuse Replacement Jumpers.
This item involves an unplanned ESF actuation on July 2, I989 while a
fuse was being replaced in the circuit for the reactor and refuel zone radiation monitors.
The fuse to be replaced is an alarming type fuse.
When the fuse clears, a spring loaded contact pops out and completes an alarm circuit logic, causing deenergization of the circuit.
This simulates a high radiation signal =and initiates an ESF actuation.
To prevent the completion of this alarm circuit logic when placing jumpers for fuse replacement, the jumper must be placed on the load side terminal for the fuse.
The electrician performing this action was unfamiliar with this type of circuit and incorrectly placed the jumper on the alarm circuit terminal, thus causing the unplanned ESF.
To prevent this type of error from recurring, the licensee has taken the following corrective actions:
All EM craft and planners have received training in the recognition of blown fuse alarm circuits as described above.
This training was completed on August 9, 1989.
Procedure EMI-92
,
Low Voltage Fuse Replacement Guide, has been revised to include caution statements alerting EM personnel to the presence of fuses with blown fuse annunciation terminals.
The inspector reviewed the above event and determined that the corrective measures are acceptable.
This item is close (CLOSED) VIO 260/88-24-09, Failure To Take Adequate Corrective Action On RHRSW Pump Rooms This item involves the licensee's failure to take prompt corrective action due to inadequate operability reviews.
On June 17, 1988 water was discovered leaking into RHRSM pump room D through a piping penetration.
Thi. led to the issuance of CAQR BFP880423, on June 21, 1988 to document that there was no approved design for sealing wall penetrations in the area, and that the design for floor penetration seals was inadequate'he CAQR was reviewed by the CAQR Coordinator and by PORS on June
and June 24, respectively.
These reviews inaccurately determined that the identified condition had no adverse effect on equipment operability.
This inaccurate determination was not discovered until July 22, when an engineering review revealed that equipment operability was potentially compromised, and constituted a
USQ.
In order to assure that future CAQRs are promptly and accurately reviewed for effect on operability, the licensee has established a
Management Review Committee, whose composition and responsibilities have been delineated in Revision 3 of SDSP 3. 13, "Corrective Action."
The NRC inspector reviewed th'is procedure, and determined that the added level of review provided by the Management Review Committee should result in prompt and accurate operability reviews.
This item is closed.
(CLOSED)
VIO 259, 260, 296/88-21-02, Failure to Perform CAQR Generic Reviews.
During a
NRC inspector's review conducted to determine the adequacy of licensee generic reviews of CAQRs written at other licensee facilities, several examples of late generic reviews were identified.
Although the CAQRs represented problems identified by the licensee, timely and effective corrective action had not resulted in that the licensee did not have a working program to ensure problems were reviewed for generic implications within a reasonable period of time.
This occurred inspite of the fact that licensee QA personnel had documented the failure. to perform timely reviews on two separate occasions during 1987 and separate NRC violations in this area were documented in NRC inspection reports 86-43 and 87-, 41.
The inspector reviewed the licensee's responses to the violation dated November 23, 1988 and May 5, 1989.
In those responses the licensee stated the reason for the violation was the fai lure of licensee procedures to take into account the effect of one organization's failure to meet time limits on other organization's activities.
The 70 day time limit specified in the NQAM did not allow for adjustment in cases where other organizations did not
perform their activities in a timely manner.
Procedures did not specifically require escalation of overdue generic reviews to higher levels of management when needed.
As corrective actions for this violation the licensee has committed to fully implement revisions to applicable procedures that were in progress at the time that the violation occurred.
The inspector reviewed Revision 4 to Section 2. 16 of the NQAN and Revision 8 to SDSP-3.7,
"Corrective Action".
The NQAM, Section 2. 16 was revised to restructure generic review timeframes to base the time limit on receipt by the 'responsible organization.
During the review of SDSP-3.7 it was noted that the procedure had been revised to require the CAQ coordinator to immediately distribute potentially generic CAQRs to the affected organization to perform a
generic applicability review within 30 calendar days.
Attachment ll which outlines the CAQR escalation process lists late response or not progressing satisfactorily as criteria for escalation to the next higher level of management.
On September 21, 1989, the inspector met with the Browns Ferry CAQR coordinator for the purpose of determining the current status of outstanding generic reviews.
The inspector determined that of
CAQRs; that site organizations were responsible for generically reviewing on September Zl, 1989, three (WBP 890112, SQP 890163, and BFE 890199P143 were classified as late.
Each of these were less than 30 days overdue and the file copy of "the respective CAQRs contained an SDSP 3.? Attachment 11 to show that the CAQR had been escalated to the first level of management.
The inspector agrees that the licensee now has a workable program to insure that generic reviews are conducted in a reasonable time period.
This item is closed.
(CLOSED)
VIO 259, 260, 296/86-43-03, Failure to Issue Potential Generic Condition Evaluation Reports and Untimely Response to those Reports by Other Plants.
This violation was identified during a
NRC Special Team Inspection conducted at TVA'
Knoxville Office of Engineering to evaluate the adequacy of licensee's performance in identifing CAQ, corrective acti on, and determi ning generic applicability of CAQs
.
The inspector identified several examples of untimely PGCE responses and failure to establish corrective action.
This issue was followed up in NRC Inspection Report 259, 260, 296/87-46 where the inspector determined that no noticeable improvement had occurred for timely review and closeout of CAQRs for potential genelic implications.
Out of 65 CAQRs generated at other licensee facilities between August
and November 30, 1987, which
were listed for review by Browns Ferry for potential generic implications, only five had been closed prior to the required due date.
The inspector reviewed the licensee's response to the violation dated July 10, 1987.
In the response the licensee stated the violation was the result of a number of root problems associated with weaknesses in functional areas such as the corrective action process.
The licensee referred to various actions as described in the NPP, including standardization of the corrective action program and consolidation of engineering functions into one organization.
TVA further stated that successful implementation of these actions would serve as adequate corrective action for this violations Based on the review of the current Corrective Action Program and the September 21, 1989, meeting with the Browns Ferry CA(}R coordinator as discribed in paragraph 3.h, the inspector determined that the licensee now has a
workable program to insure that reviews of
'otentially generic items are conducted. in a reasonable time period.
This item is closed.
(CLOSED)
VIO 260/89-27-02, Failure To Meet TS Requirements For Operable RHR Loops.
This item involved the licensee's failure to maintain the required number of RHR loops operable between June
and 22, 1989.
TS 3.5.B.9 requires at least one RHR loop with two pumps or two loops with one pump per loop to be operable when the reactor pressure is atmospheric with irradiated fuel in the vessel.
During the above stated, time, Loop I was inoperable due to a
scheduled maintenance outage and Loop II was inoperable due to a failure to perform functional testing of valve 2-FCV-74-68 within the required surveillance interval.
During the June 8, 1989 performance of 2-SI-3.2.2, it was determined that valve 2-FCV-74-68, an RHR testable check valve, could not be tested because scaffolding in the area prevented installation of hoses needed to perform the test The inability to test this valve at the time was documented on TD02, but due to a
number of procedural inadequacies, the TD was not reviewed by the SOS or STA.
Therefore, when the SOS declared Loop II inoperable for its scheduled maintenance, he was unaware that Loop I was technically inoperable due to the incomplete testing of the check valve.
To prevent furture similar occurrences, the licensee has completed the following corrective actions:
The portion of 2-SI-3. 2.2 required to prove operability of valve 2-FCV-74-68 was completed on June 21, 1989 and Loop I was declared operable On June 22, 198 '
Procedure PMI-17. 1, "Conduct of Testing",
was revised to require SOS and STA review of all TDs generated during the performance of SIs, and document their review on Form PMI-47, Test Deficiencies Log.
I Procedure PMI-17.1, "Conduct of Testing,"
was revised to require SOS and STA review of all Form PMI-34s, Data Cover Sheet for SI Not Performed, to ensure that potential LCOs are tracked as required.
Procedure SDSP-7.9,
"Integrated Schedule and Work Control," has been revised to provide for LCO tracking, by the STA, of work which could effect equipment operability.
The inspector reviewed the above procedure revisions and determined that they now contain appropriate controls to assure timely and accurate notification to operations of TDs impacting system operability.
This item is closed.
No violations or deviations were identified during the Followup of Open Inspection Items.
Exit Interview (30703)
The inspection scope and findings were summarized on October 13, 1989 with those persons indicated in paragraph
above.
The inspectors described the areas inspected and discussed in detail the inspection findings.
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.
5.
Acronyms BFNP CS CFR CREV DCN ECN EM EMI EQ ESF FCI IFI IR IRM KV LCO Browns Ferry Nuclear Plant Core Spray Code of Federal Regulations Control Room Emergency Ventilation Design Change Notice Engineering Change Notice Electrical Maintenance Electrical Maintenance Instruction Environmental Qualification Engineered Safety Features Fluid Components, Inc.
Inspector Followup Item Inspection Report Intermediate Range Monitor Ki1ovol t Limiting Condition of Operation
LER MG
,MR NQAM NRC OI PCIS PGCE PMI PM PORS QA RHR RPS SBGT SDIV SDSP SI SOS STA TD TI TS TVA USQ Licensee Event Report Motor Generator Maintenance Request Nuclear Quality Assurance Manual Nuclear Regulatory. Commission Operating Instruction Primary Containment Isolation System Potential Generic Condition Evaluation Plant Managers Instructions Preventive Maintenance Plant Operations Review Staff Quality Assurance Residual Heat Removal Reactor Protection System Standby Gas Treatment System Scram Discharge Instrument Volume Site Directors Standard Practice Surveillance Instruction Shift Operations Supervisor Shift'echnical Advisor Test Deficiency Technical Instruction Technical Specifications Tennessee Valley Authority Unreviewed Safety Question