IR 05000259/1991013
| ML18033B708 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 05/10/1991 |
| From: | Ivey K, Kellogg P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18033B707 | List: |
| References | |
| 50-259-91-13, 50-260-91-13, 50-296-91-13, NUDOCS 9105210090 | |
| Download: ML18033B708 (24) | |
Text
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UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.IN.
ATLANTA,GEORGIA 30323 Report Nos.:
50-259/91-13, 50-260/91-13, and 50-296/91-13
~ Licensee:
Tennessee Valley Authority 6N 38A Lookout Place 1101 Market Street Chattanooga,
'TN 37402-2801.
Docket Nos.:
50-259, 50-260, and 50-296 Licenses Nos.:
DPR-33, DPR-52, and DPR-68 Facility Name:
Browns Ferry Units 1, 2, and
Inspection at Browns Ferry Site near Decatur, Alabama pector Inspection Conducted:
March 25 - 29, and April 14 - 19, 1991 Inspector:
K.
Da e
S gned Accompanied by:
Approved, by:
Pa In TVA D. Seymour, Radiation Specialist (HP)
T. Cooper, McGuire Resident Inspector (First Week Only)
E.
L
, Reactor Inspector (Second Week Only)
on P
rogects SUMMARY
Scope:
This special inspection was conducted to assess the adequacy of the surveillance testing program for the restart and operation of Unit 2.
The inspection included reviews of Surveillance Instruction (SI)
program procedures,.
completed SI documentation, and incident investigations; SI observations; follow-up on Nuclear Performance Plant (NPP)
commitments and NUREG-1232 concerns; and follow-up on licensee actions taken in response to Enforcement Action (EA)89-226 (VIO 89-43-01).
Results:
h The. surveillance testing program and surveillance instructions were found to be adequate to support Unit 2 restart.
Most of the issues to resolve NPP Volume
commitments, NUREG-1232 issues, and escalated enforcement item EA 89-226 were resolved with one exception.
91052i0090 950510 PDR ADOCK 05000259
REPORT DETAILS Per sons Contacted Licensee Employees:
¹O. Zeringue, Vice President, BFN Operations
¹*L, Myers, Plant Manager
¹S.
Rudge, Site Support Manager M. Herrell,"Operations Manager
¹*J. Allen, Site Procedures Manager
¹*M. Bajestani, Technical Support Manager
¹*P. Carier, Site Licensing Manager
¹*P, Salas, Compliance Licensing Supervisor
¹*D. Smith, Chemistry 5 Envi.ronmental Superintendent
¹G. Turner, Site guality Assurance Manager
¹"'G. Little, Operations Unit Support Supervisor
¹*M. Mor ison, Compliance Engineer Other licensee employees or contractors contacted included licensed reactor operators, auxiliary operators, craftsmen, technicians, and quality assurance personnel.
NRC Personnel:
- ¹K. Ivey, Jr.,
BFN Resident Inspector/Team Leader
- C. Patterson, BFN Senior Resident Inspector
¹E. Christnot, BFN Resident Inspector
- T. Cooper, McGuire Resident Inspector
¹E. Lea, Reactor Inspector
¹*D. Seymour, Radiation Specialist (HP)
"Attended initial exit interview on March 29, 1991.
¹Attended final exit interview on April 18, 1991.
Acronyms used throughout this report are listed in the last paragraph.
Surveillance Testing Program Surveillance testing has been an ongoing problem at BFN and contributed to the multi-unit shutdown in 1985.
In response to the identified problems, the licensee initiated various corrective actions to resolve SI problems d p ovide for adequate SIs.
This inspection was conducted to assess the licensee's surveillance testing program and verify that it is adequate to support the restart and operation of BFN Unit 2.
a ~
Pr ogram and Procedures The inspectors reviewed the licensee's procedures to ensure that they were adequate to control the performance of surveillance testing.
The procedures reviewed were:
b.
1)
PMI-17. 1, Conduct of. Testing.
This procedure provides the controls for performing tests at BFN.
2)
PNI-17.12, Surveillance Program Implementation.
This procedure provides the administrative controls for conducting surveillance testing.
The inspectors verified that the procedures included controls for SI scheduling and performance, lead performer responsibilities, resolving TDs, control of compensatory SIs, and review and approval of completed SIs.
- The procedures also included required reports to provide information to plant management and the ASOS/SOS on SI'rending data.
An inspector reviewed reports for open TDs, SI performance extensions, and overdue Sls issued during the inspection.
No deficiencies were identified during the reviews of the procedures or reports.
Documentation Review The inspectors-reviewed completed documentation packages for 29 SIs and verified the following:
1)
Steps were completed satisfactorily or a TD was initiated.
2)
Steps were user friendly and could be performed as written.
3)
Acceptance criteria was identified.
4)
Expected reactor trips and ESF actuations were identified.
5)
The performance date met the TS frequency requirements and was-conducted in accordance with the licensee's schedule, or rescheduled, if necessary.
6)
Review of the completed SI was performed as required.
The inspectors found no instances'f inadequate SIs or Sls which could not be performed by trained personnel.
The inspectors reviewed
SIs to ensure that they tested the associated TS surveillance requirements.
No'nstances were found where the SIs did not implement the TS surveillance requirements and no apparent problems were found with the technical aspects of the SIs.
The inspectors reviewed the performance history for 32 SIs required to be performed prior to Unit 2 fuel load or required for. current plant conditions to ensure that TS surveillance frequencies-were being maintained.
The inspectors found no instances where required SIs had not been performed or maintained within the TS frequency.
c.
SI Observation The inspectors observed the performance of 11 SIs.
For each SI, the inspectors observed the conduct of testing, confirmed the proper removal from service and return to service of systems, verified that LCOs were met,.test instrumentation calibration was current, testing
was accomplished by qualified personnel, and the SIs were completed within the required frequency.
The inspectors also reviewed the procedures for technical adequacy and reviewed the completed test data.
I eneral the inspectors found no major concerns and noted that the per p rforming personnel were knowledgeable on the SIs observ ed Inspecto~
concerns arising during the observations were reso ve
d through discussions with performing personnel and cognizant management.
One problem was identified which requires further
.
inspection follow-up.
During the March 28, 1991, performance of O-SI-4.2.4.D(v.c),
Radwaste Building Exhaust Vent Monitor 0-RM-90-252
- Sample Flow Functional Test, the SI could not be completed as written b cause of labeling problems.
The identification labeling was incorrect for the two CAM isolation valves and four valves on e
th CAM.
This SI'as being validated during the performance.
Discussion with system engineering
'personnel indicated that the valves had been mislabeled as a result of FDCNs which were performed after the walkdown of the SI.
The resident inspectors will follow-up on this item as part of the routine inspection program.
From the reviews,-. observations, and discussions conducted during this inspection, the inspectors'oncluded that the licensee had a surveillance testing program in place, which should support the restart and operation of Unit 2; that the SI performance schedule should ensure that SIs are performed within required TS frequencies; that the licensee had a schedule to ensure that required SIs would be performed prior to Unit 2 restart; and that the licensee was implementing the documented program.
No violations or deviations were identified in this area.
Surveillance Procedure Upgrade Program In the BFNPP, the licensee committed to implement a surveillance upgrade
.
program to verify SI adequacy. prior to performance for Unit 2 restart.
The upgrade program commitment included the review, verification, walkdown, and validation of SIs to ensure that they are adequate prior to use.
Procedure SSP-2.3, Administration of Site Procedures, establishes the minimum requirements for SI preparation, review, approval, an validation.
This procedure was effective on January 22, 1991.
There have been several administrative procedures governing the upgrade program and f the SIs were upgraded in accordance with procedures which have been superceeded..
Each procedure required verification, walkdown, and validation of SIs.
Procedure SSP-2.1, Site Procedures Program, Appendix A states that the
1'dation method for SIs is "First Use."
Since some SIs will not be per formed for the first time until after Unit 2 restart, some SIs will t
b validated prior to restart but will be validated as they are performed at various power levels.
Thss includes long term SIs <i.e.
year frequency),
SIs requiring operating conditions for performance, and portions of SIs requiring operating conditions for performance.
However,
all SIs must be upgraded, verified, and walked down prior to Unit 2 restart.
During this inspection, the inspectors reviewed the adequacy and status of the upgrade, verification, walkdown, and validation processes to ensure that the commitments in the BFNPP were completed.
Upgrade Program Th re are approximately 870 Sls which are required to support the restart ere and operation of Unit 2.
All of these SIs have been upgraded, with t e h
exception of approximately 80 hydrostatic tests which are within their
year frequency.
These SIs will be upgraded prior to their next performance.
Verification and Walkdown All of the SIs required to support the restart and operation of Unit 2 h ve been verified and" issued.
The inspectors reviewed 50 SIs to ensure that they had been verified.
No deficiencies were identified.
he inspectors also reviewed 55 SIs to ensure that a walkdown was conducted and any walkdown comments were adequately addressed and resolved.
No d ficiencies were identified.
The inspectors concluded that the commitment to verify and walk down upgraded SIs had been complete
.
d Va'lidation From the review of the validation program during the first week of the i spection the inspectors concluded that the validation process was not adequately implemented.
In addition, the administrative controls for t e h
program were either not being implemented or were inadequte.
B ause of the findings of the first week, a management meeting between-the NRC and TVA was conducted on April 4, 1991, in the NRC Region ecau e
II office in Atlanta, Georgia.
At the meeting, the licensee addressed the prob'lems with the validation program and the corrective actions taken and planned for the findings of the first week of the inspection.
Licensee management stated that the root cause for not implementing the validation program was inadequate monitoring and control of the process.
During the second week of the inspection, the inspectors continued to review the licensee's validation process and conducted a review of the licensee.'s preliminary actions from the management meeting.
The findings from both weeks of inspection are summarized below.
a.
First Week The inspectors evaluated the SI validation program by reviewing the program procedures, SI validation checklists, and proposed changes to SIs; observing the validation performance of SIs; and holding
The SI validation process was not adequately implemented.
Management involve-ment in the monitoring of this process was ineffective.
No single person or group had responsibility for tracking the complete process.
The Site Procedures Group only monitored the documents provided to it and inadequately tracked completed versus validated SIs.
Corrective actions were taken validation process.
However, performed without validation.
this issue and close EA 89-226 by the licensee to effectively implement the there remained 61 SIs which were previously Validation of these SIs is necessary to resolve (VIO 89-43-01) for Unit 2 restar discussions with cognizant plant personnel.
The inspectors reviewed validation documentation for 48 SIs and observed the validation performance of several SIs.
The inspector's findings from these reviews are detailed below.
1)
The status of the SI validation program was indeterminate and the process was not adequately tracked or controlled.
This finding was evidenced by the following:
a)
No single person or organization had responsibility for the validation program.
Each group was responsible for a
portion of the program, but no one ensured that the overall program was implemented.
b)
There was no accurate listing of the SIs which had been validated.
Dates from validation status lists and validation dates from procedures were not the same.
2)
Plant personnel did not realize the importance of the validation program and were unfamiliar with and not implementing certain procedural requirements for validation.
This finding was evidenced by the following:
a)
SSP-2.3, Section 3.7
"DCRN", Step 3.7.1 requires that a
FORM SSP-2.3 be issued for SI working copies when it is determined that validation is needed.
An inspector asked for w'orking copies of two SIs which were not validated and no Form SSP-4 was issued for either one.
b)
PMI-17. 1, step 4.3. 11 states that the test director or lead performer will ensure that the procedure has a validation review completed or perform a validation review.
This step would require a procedure
'to be validated every time it is'erformed until the validation has been documented.
If this was being implemented, there would be many duplicate validations for numerous procedures because of the delay in incorporating validation comments; however, no evidence could be found that this was occurring.
On the contrary, the inspectors identified that many SIs were being performed on a routine basis which did not have a
validation date on the cover sheet.
c)
Plant personnel stated that they were often not validating procedures because they were aware that earlier validation performances had been completed, and at other times, personnel relied on their supervision to notify them if a SI needed validation.
3)
Some SIs were performed without being validated or incorporating validation comments.
By the end of the inspection, the licensee
r had 'identified 32 SIs required for Unit 2 fuel load which had been performed without being validated.
Several of the SIs reviewed by the inspectors were completed without validation including:
a)
2-S1-4.2.B-21, Core Spray Pump Discharge Pressure Calibration (PS-75-7,16,35,44).
2-SI-4.2.K.2.a, Reactor Building Vent Exhaust Monitor Source Calibration 8 Functional Test (2-RM-90-250).
c)
2-SI-4.2.K.2.d, Reactor Building Vent Exhaust Monitor Sample. Flow Calibration and Functional Test (2-RM-90-250).
d)
2-SI-4.5.A.l.d(I), Core Spray Flow Rate Loop I.
4)
"Branch" procedures, which are performed as required during the conduct of an SI, had not been validated even though the SI had been validated.
In many SIs,
"Branch" procedures are used to satisfy acceptance criteria and, therefore, should be validated when the SI is validated.
An inspector reviewed approximately one-half of the issued TIs and determined that only two of the sample Tls had been validated.
Many of the TIs are used to satisfy part of or all TS surveillance requirements for SIs.
Other procedures, such as CIs are also used to satisfy SI acceptance criteria and have not been validated.
Procedures reviewed by the inspectors which included unvalidated branch procedures were:
a)
b)
2-SI-4.3.A.1, Reactivity Margin Test.
This SI was validated by walkdown in July, 1989.
This SI assures that testing is completed to satisfy TS requirements but does not specifically gather the data or perform the calculations.
Instead, it references TI-115, Full Core Shutdown Margin, which actually performs the testing.
Procedure TI-115 had not been validated, even though the SI was validated.
The SI acceptance criteria is the successful completion of the TI.
This SI was validated prior to core load, as required.
The TI should have been validated at the same time as the SI, to prove that the surveillance requirements were being satisfied.
2-SI-4.5.A.l.d(I),
Core Spray Flow Rate Loop I... This SI requires.the performance of O-TI-230, Vibration Mon'itoring and Diagnostics, to gather and analyze pump vibration data for SI acceptance criteria.
The SI had been validated and the TI was not validate o
c)
2-SI-4.8.8..2-2, Airborne Effluent Analysis - Particulate Filter Analysis (Monthly, Gross Alpha).
This SI requires the performance of CI-717, Composite Samples For Air Particulate Monitoring, to prepare the monthly particulate composite sample.
The information gathered by the CI is the basis for determining if the SI acceptance criteria are met. This CI had not been validated.
5)
Validation check'lists were being delayed and were not being incorporated or documented in a timely manner.
a)
SIs required for core load were often performed for validation prior to core load, but the validation comments had still 'not been incorpotated at the time of the inspection.
Examples of this included:
I)
2-SI-4.1.A-2, Reactor Protection System - Manual Scram Functional Test.
2)
2-SI-4.2.8-45A( II),
Loop II RHR Logic System Functional Test.
3)
4)
2-SI-4.2.C-5, Rod Block Logic - Instrumentation That Initiates Rod Blocks.
O-SI-4.2.K.4.a, Radwaste Building Vent Exhaust Monitor Source Calibration 8 Functional Test (O-RM-90-252).
5)
2-SI-4.5.H.1(II),
RHR System Venting Loop II.
b)
Technical Support personnel had comments from approximately 174 SI validation checklists which had not been recieved by Site Procedures.
Some of the SIs in question were required to be performed prior to Unit 2 fuel load.
The inspectors identified some SIs where two different revisions of the same SI were still awaiting incorporation of the validation.
comments even though subsequent revisions had already been issued.
Examples of this included:
I)
2-SI-4.2.8-45A(II),
Loop II RHR Logic System Functional Test.
2)
2-SI-4.5.B. l.a(II), Loop II RHR. Simulated Automatic Actuation Test.
b.
Second Week An inspector reviewed the licensee's corrective actions taken for the findings of the first week of inspection; reviewed the licensee's plan for validating SIs which had already been performed without
validation; and discussed the program improvements with the cognizant licensee manager.
The -inspectors findings were as follows:
I)
The licensee assigned the responsibility for implementation and completion of the SI validation program to the Technical Support Manager.
Appropriate plant procedures will be revised to reflect the Technical Support Section as the responsible organization.
2)
The licensee provided training to DCRN personnel to stress the need to issue a
Form SSP-4 validation checklist when working copies of unvalidated procedures are issued.
The inspector selected unvalidated procedures and request'ed'orking copies of each from DCRN personnel on each of the'three shifts in order to determine the effectiveness of the training.
The inspector was given one procedure without Form SSP-4 attached.
Training was also provided to individuals responsible for performing procedure validations.
An inspector attended one of the training sessions and noted that the instructor stressed the basis for the validation process, the scope of a validation, the validation methods, and the actual validation process.
3)
The licensee stated that SSP-2.3 would be revised to specify a
~
specific time requirement for the resolution of corments generated on Form -SSP-4.
Previously, some validation comments remained unresolved for more than one year.
In many instances it was difficult for the licensee to determine the actual location of the validation comments; The Technical Support Section created a procedure validation tracking form to aid in'racking SIs through the validation process.
The licensee also intends to implement a
computer tracking system for tracking validated and unvalidated SIs.
4)
At the time of the inspection 482 of the approximately 870 SIs required for'estart and operation of Unit 2 had been validated.
There are 431 SIs required for system operability for fuel load and ILRT.
As of April 17, 1991, approximately 313 had been validated,
were in close out, and
remained to be validated.
The inspectors reviewed the licensee listing of SIs that were not validated and the plans for validation.
The licensee intends to validate the remaining procedures during the next performance or by walkdown.
5)
The inspector reviewed PMT closure packages to determine what SIs were performed.
In a number of the packages reviewed, only a portion of the SI had been performed.
A specific example of this was 2-SI-4.7.D.l.a-l, Primary Containment Isolation Valve Operability Test, which was contained in PMT BF-0.008 for DCN W10017A (Blacksnake Modification).
A review of the package indicated that only about 25% of the valves listed in the SI were actually tested.
The procedure is intended to demonstrate
the TS operability requirement of containment isolation valves by verifying closure time.
Due to present plant conditions, the SI could not be completed.
The SI was scheduled to be. performed in its entirety and validated prior to Unit 2 restart.
6)
The definition of validation in SSP-2.3 did not agree with the
,type of questions in the SSP-4 checklist.
The definition implied that validation also checks equipment response; however, the purpose of the validation checklist is to provide user comments on the performability of an SI, not whether the procedure is technically accurate.
The SI verification process, TD process, and, procedure change 'requirements provide the assurance that SIs are technically accurate.
The licensee indicated that this definition would be. revised to reflect the
'actual purpose of validation.
The inspectors concluded that the licensee had implemented the BFNPP commitments for SI upgrade, verification, and walkdown.
The inspectors also concluded that the validation process had not been effectively implemented and that the administrative controls for the. program either had not been effectively implemented or were inadequate.
The validation of SIs which have been previously performed without validation must be completed prior to Unit 2 startup.
Validation of the SIs which have been performed without validation and the overall validation program will be tracked and reviewed by the resident inspectors on an ongoing basis until satisfactory resolution of the BFNPP commitment.
No violations or deviations were identified in this area.
4.
Followup on NUREG-1232 Issues The BFNPP surveillance upgrade program has been reviewed by the NRC on several occasions and was found acceptable as documented in Section 4.4 of Volume 3 to NUREG-1232,
"SER on TVA: Browns Ferry Nuclear Performance Plan."
In the SER, the NRC identified four issued related to SIs which required further followup.
These issues were also addressed in NUREG-1232, Supplements I and 2.
The issues were reviewed by the inspectors during this inspection and the results were as follows:
a
~
Issue:
The System Engineer Concept in Relation to the Plant Surveillance Program.
An inspector held discussions with the Technical Support Manager and reviewed plant proceudres to assess the licensee's program in this area.
Procedure SDSP-27.5, Systems Engineering Organization And Interface, describes the responsibilities of system engineers at BFN.
The responsibilities include cognizant review of assigned SIs and technical reviews of system-related procedures and procedure
revisions.
The Technical Support Manager stated that his organization, which includes system'engineering, had responsibility for approximately 803 of the 870 SIs required for Unit 2 restart.
The remaining SIs are the responsibility of the Chemistry organization. which includes engineers responsible for SIs:
The inspectors concluded that this issue was resolved.
b.
Issue:
SI Verification.
The verification of SIs was reviewed in detail during this inspection (see paragraph 3).
The inspectors concluded that this issue was resolved.
c.
Issue:
SI Validation.
The validation of SIs was reviewed in detail during this inspection (see paragraph 3).
The inspectors determined that the validation program had not been effectively implemented and this issue was still valid.
Enforcement Action 89-226 (VIO 89-43-01) will remain open pending resolution of the licensee's validation problems.
This issue will be resolved by the closure of the EA.
No further specific actions are required for this issue.
d.
Issue:
-Improved Management Practices to Foster Procedural Compliance Among Personnel.
The inspecto~
held discussion with licensee management and reviewed programs in place to assess the licensee's actions for this issue.
In response to numerous personnel errors, the Site Director and Plant Manager held discussions with plant employee groups to provide management's expectations for strict procedure compliance.
These expectations are reinforced through low level management meetings and event critiques.
In addition, BFN 'management has implemented a
progressive disciplinary policy, including personnel actions, for personnel errors.
This policy is outlined in SDSP-32.2, Personnel Policies And Procedures.
The inspectors noted that the number of personnel error s had decreased significantly within the last year.
The inspectors concluded that this issue was resolved.
No violations or deviations were identified during the review of this area.
5.
Incident Investigations The inspectors followed up on three surveillan'ce testing related events which occurred during the period of this inspection.
In each case, the licensee initiated an investigation in accordance with SDSP-15.14, Incident Investigations And Root Cause Analysis.
The inspectors held discussions with the cognizant licensee manager for each event.
All of-the invest'igations were still in progress at the end of this inspection.
A description of each event and associated inspector findings were as follows:
a.
II-B-91-072:
During preparations for the performance of 2-SI-3.3.1.B, Hydrostatic Pressure Testing of Reactor Vessel and Associated Piping, on March 29, 1991, a spill of approximately 400 gallons of reactor coolant water occurred.
The spill came from two open valves which provided an open flow path from the recirculation system.
These valves are located above reactor water level so no leakage occurred until the RHR system was placed in the shutdown cooling mode.
The licensee determined that the cause of the spill was a
valve misalignment in accordance with the SI steps.
Furthermore, the licensee concluded that the lineup error was the result of the SI reviewer overlooking questions concerning the position of the two valves.
The verification and walkdown for this SI was completed on August 14, 1989.
The SI was being validated during this performance; This was the only 'problem'dentified with the SI and was promptly corrected.
b.
II-B-91-088:
During the performance of 1/2-SI-4.9.A.3.a, Common Accident-Signal Logic, on April ll, 1991, all four Units 1/2 DGs auto-started.
The licensee determined that the auto-start occurred as designed when switch CASA-A was operated instead of switch CASA-1 as required by the SI steps.
This event was attributed to Operations personnel error in that an AUO operated the incorrect switch.
The inspector concluded that this was not a problem with the SI steps.
co II-B-91-091:
During the performance of 1/2-SI-4.9.A.3.a, Cordon Accident Signal Logic, on April 12, 1991, all four Unit 3 DGs auto-started.
The licensee could not repeat the auto-start and could not determine the cause of the event.
It was not apparent that the auto-start was even related to the SI.
There is only one relay associated with this test which could cause an auto-start of the four Unit 3 DGs.
The licensee verified that this relay was properly removed from service in accordance with the SI steps and would not function.
The licensee had not determined the cause of this event at the end of this inspection period.
The investigation into this event will be reviewed by the resident inspectors as part of the routine inspection program.
The inspectors concluded that none of these events could be attributed to an overall problem with the adequacy of SIs or the surveillance testing program.
No violations or deviations were identified in this area.
6.
Action on Previous Inspection Findings.
(Open)
EA 89-226 (VIO 259, 260, 296/89-43-01),
Surveillance Program Violations.
Since the multi-unit shutdown in 1985, the NRC performed many inspections involving SIs and identified numerous concerns.
During September 11-October 11, 1989, a special inspection was conducted on surveillance
testing (IR 89-43)
a'nd several violations were identified.
The violations included six examples of inadequate test procedures, failure to meet surveillance test intervals, failure to implement and maintain compensatory measures required by TS, and failure to follow procedures.
The violations were categorized in the aggregate as a Severity Level III problem and EA 89-226 (YIO 260/89-43-01)
was issued on March 2, 1990.
For each of the examples in the violation the licensee submitted a
LER to the NRC.
Each example and the corrective actions taken were reviewed by the resident inspectors during review of the associated LERs.
All of the LERs were closed out in previous NRC inspection reports.
The programmatic aspects of this violation were reviewed during this inspection.
In general, the programmatic actions taken for SI program improvement, personnel compliance with SI steps, personnel training, and the reduction of NICs should ensure that the problems addressed in the EA will not recur.
However, the inspectors noted-two examples where the programmatic actions either had not been fully implemented or were ineffective.
These examples were 1)
the validation process and 2)
management involvement in the verification and validation processes.
In paragraph 3 of this report, the inspectors concluded that the validation process had not been fully implemented.
In addition, there was no one person or group responsible for overseeing the implementation of the
'rocess.
Therefore, the responsiblity for program implementation lies with plant management.
Management oversight of the validation process was ineffective.
This item is required to be resolved prior to Unit 2 restart.
This item will remain open pending the identification and resolution of each SI which has already been performed without validation and implementation of an adequate process to ensure the remaining SIs to be performed are validated prior to Unit 2 restart.
The resident inspectors will follow-up on this item and assess the licensee's progress on an ongoing basis unti,l this item is closed.
Exit Interview The inspection scope and findings were summarized in a preliminary exit interview on March 29, 1991, and a final exit interview on April 18, 1991.
Exit interview attendees are indicated in paragraph
above.
The inspectors described the areas inspected and discussed the inspection findings in detail.
The licensee did not identify as proprietary any of the material provided to or reviewed by the inspectors during this inspection.
Acronyms ASOS AUO BFN Assistant Shift Operations Supervisor Auxiliary Unit Operators Brow'ns Ferry Nuclear Plant
BFNPP CAM DCRM DG EA ESF FDCN FT IR LCO LER NIC NPP NRC PMI PMT RHR RPS SDSP SER SI SOS SSP TD TI
'TS TVA VIO Browns Ferry Nuclear Performance Plan Continuous Atmospher e Monitors Document Control and Records Management Diesel Generator Enforcement Action Engineered Safety Feature Field Design Change Notice Functional Test Inspection Report Limiting Condition for Operation Licensee. Event Report Non-Intent Procedure Change Nuclear Performance Plan Nuclear Regulatory. Commission Plant Manager Instruction Post Maintenance/Modification Test Residual Heat Removal Reactor Protection System Site Director Standard Practice Safety Evaluation Report Surveillance Instruction Shift Operations Supervisor Site. Standard Practice Test Deficiency Technical Instruction Technical Specifications Tennessee Valley Authority Violation