Text

Insp Repts 50-259/86-06,50-260/86-06 & 50-296/86-06 on 860201-28.Violations Noted:Failure to Have Adequate Procedure for Fire Protection Surveillance,Failure to Follow Procedures During Chemistry Sample & for Locking Valves
	ML18030B228
Person / Time
Site:	Browns Ferry
Issue date:	03/20/1986
From:	Brooks C, Cantrell F, Patterson C, Paulk G; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	;
Shared Package
ML18030B226	List: ML18030B224; ML18030B227; ML18030B228;
References
	50-259-86-06, 50-259-86-6, 50-260-86-06, 50-260-86-6, 50-296-86-06, 50-296-86-6, NUDOCS 8604080275
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UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION II

101 MARI ETTA ST R E ET, N.W.

ATLANTA,GEORGIA 30323

Report Nos.:

50-259/86-06,

50-260/86-06,

and 50-296/86-06

Licensee:

Tennessee

Valley Authority

6N38 A 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 Nuclear Plant

0

C. A.

atterson,

Resi

C.

R. Brooks, Resident,

pe

or

Approved by:

F.

.

antrell, Sectio

'ef

Division of Reactor

Prospects

spc or

Inspection

Conducted:

February

1-28,

1986

Inspectors:

G.

L. Paulk,

Senior

e

d

Inspector

Da

e Signed

z.d

Date Signed

se

Date

igned

'

g

Date Signed

SUMMARY

Scope:

This routine,

inspection

involved

240 resident

inspector-hours

in the

areas

of operational

safety,

maintenance

observation,

reportable

occurrences,

unresolved

items,

surveillance

observation,

activity,

housekeeping,

and facility modifications.

Results:

Two violations:

Technical Specification 6.3 for inadequate

procedures,

fai lure to

follow procedures,

and control procedure

changes

of six examples:

b.

C.

d.

e.f.

Failure

to

have

an

adequate

procedure

for fire protection

surveillance.

Changing

a procedure

using

a temporary non-intent

change

instead

of a procedure

revision.

Failure to follow procedure

during chemistry

sample.

Failure

to

have

adequate

proc'edure

due

to not incorporating

a

previous non-intent

change.

Failure to follow procedure

for locking valves.

Failure to properly control clearance

tags.

8604080275

86040k

PDR

ADOCN 05000259

8

PDR

2.

Technical Specification 3.5.C.7

for failure to satisfy

the

minimum

required

Residual

Heat

Removal

Service

Water

(RHRSW)

Pump

Limiting

Condition for Operation

(LCO).

REPORT DETAILS

Licensee

Employees

Contacted

W.

C. Bibb, Site Director

T.

F. Ziegler, Assistant to the Site Director

R.

L. Lewis, Plant Manager

E. A. Grimm, Assistant to the Plant Manager

J.

E. Swindell, Superintendent

- Operations/Engineering

T.

D. Cosby,

Superintendent

Maintenance

J.

H. Rinne, Modifications Manager

D,

C. Mims, Engineering

Group Supervisor

R.

M. McKeon, Operations

Group Supervisor

C.

G. Wages,

Mechanical

Maintenance

Supervisor

J.

C. Crowell, Electrical Maintenance

Supervisor

R.

E. Burns,

Instrument Maintenance

Supervisor

A,

W. Sorrell, Health Physics Supervisor

R.

E. Jackson,

Chief Public Safety

J.

R. Clark, Chemical Unit Supervisor

B.

C. Morris, Plant Compliance Supervisor

A. L. Burnette, Assistant Operations

Group Supervisor

R.

R. Smallwood, Assistant Operations

Group Supervisor

S.

R. Maehr, Planning/Scheduling

Supervisor

W.

C. Thomison,

Engineering

Section Siipervisor

C.

E. Burke,

Radwaste

Group Controller

Other

licensee

employees

contacted

included

licensed

reactor

operators,

auxiliary operators,

craftsmen,

technicians,

public safety officers, quality

assurance,

design

and engineering

personnel-.

Exit Interview

(30703)

The inspection

scope

and findings were

summarized

on February

28,

1986, with

the

Plant

Manager

and Assistant

Plant

Managers

and other

members

of his

staff.

The licensee

acknowledged

the findings and took no exceptions,

The licensee

did not identify as proprietary

any of the materials

provided to or reviewed

by the inspectors

during this inspection.

Licensee Action on Previous

Enforcement Matters (92702)

(Closed)

Violation

(296/82-24-03)

The

response

to this violation

was

reviewed

and

the

inspector

has

no

further

questions.

A

more

recent

violation

was

issued

in Inspection

Report

85-36

concerning

failure to

conduct

post

maintenance

testing

on

a control

rod drive hydraulic unit.

This item is closed.

(Closed)

Open

Item (260/82-24-04)

Administrative errors

in

scram reports

were

noted

in Report 85-25.

There are

no

new reports to review due to all

the units being

shutdown nearly

one year.

Any future

scram reports will be

reviewed

as part of the routine inspection

program.

This item is closed.

(Closed)

Unresolved

Item (259/260/296/85-36-06)

The inspector

reviewed the

revision to Licensee

Event Report 260/85-04

R1 concerning

the

low pH in Unit

two reactor

and has

no further questions.

This item is closed.

(Closed)

Violation (259/260/296/83-33-03)

The inspector

reviewed the plant

drawings to verify the corrected

instrument setpoints.

This item is closed.

(Closed)

Open Item (296/85-15-09)

No definite reason

for the high pressure

coolant injection

minimum flow orifice bolted joint being

loose

could

be

found.

No similar conditions

were

found

on

the

other units.

The plant

records

showed

that

the last

time

the joint was

worked

the bolts were

torqued

per plant Mechanical

Maintenance

Instruction

MMI 143,

Torquing of

Mechanical

Bolted Joints.

The

procedure

requires

a quality control

inspector's

signature

for verification of the

torquing.

One

unconfirmed

explanation

for the loose connection

was due to plant personnel

lcosing the

connection

due to pipe

hanger

work in the

area.

The

cognizant

engineer

stated

the loose connection

was believed not due to vibration.

This item is

closed.

(Closed)

Violation (259/260/286/84-23-01)

The inspector

reviewed the

licensee's

corrective action

and

Licensee

Event

Report

25984-22

Rl.

This

addresses

the violation

concern

for inadequate

prompt corrective

action

dealing with a non-conformance

report.

Long tern resolution of the design

problem will be tracked

under Violation 259/260/296/84-20-01

which is still

open.

This item is closed.

(Closed)

Unresolved

Item (260/85-57-01)

The licensee

determined

that the

weld distortion was

due to excessive

weld material

and not due to any forces

exerted

on

the

restraint.

Calculations

were

performed

to verify the

structural

integrity of the

support.

No modifications

were

recommended

based

on the original plant design.

This support

has

not

been

evaluated

under Bulletin 79-14 which may require possible modifications.

This item is

closed.

(Closed)

Violation

(259/260/296/83-60-03)

The

inspector

reviewed

a

revision to Operating

Instruction

01-64,

Primary Containment

System,

which

contained

updated

instrument inspection list and

has

no further questions.

This item is closed.

(Closed)

Open

Item (259/84-07-06)

The licensee

reported

the problems with

the

EECW air release

valves in Licensee

Event Report 259/84-13.

This report

was

closed

in Inspection

Report

84-10.

The door to the

RHRSW/EECW

pump

rooms continue to remain partially open to prevent possible

flooding due to

a valve failure.

A security guard is permanently

stationed at the entrance

to the

pump

rooms

and routinely observed

by the inspectors.

This item is

closed.

(Closed)

Violation (259/260/296/84-15-01)

The

licensee

response

to this

violation

was

reviewed

and

the

inspector

has

no

fur the<

questions.

Increased

emphasis

has

been

placed

on control of system valve alignments

by

operations'upervision.

This item is closed.

(Closed)

Open

Item (259/84-10-02)

The

inspector

reviewed

the Operating

Instruction for the

standby

gas

treatment

system.

Several

revisions

have

been

made to system lineup checklists.

This item is closed.

(Closed)

Open

Item

(296/84-44-04)

The

diesel

generator

turbocharger

failures

are

addressed

in Violation 259/260/296/85-45-08 'his

item is

closed.

(Closed)

Open

Item

(259/260/296/82-15-01)

The

inspector.

reviewe~

the

revised

drawing update

on the core spray

system.

Interviews with operators

revealed

no

apparent

problems

with the

core

spray

system

high pressure

permissive

keylock

hand

switch

on

Panel 9-3.

Although Unit

3 switch

was

physically installed different

than

the

other

two units,

no operational

problems

have

been identified during testing.

This item is closed.

Unresolved

Items" (92701)

There

are

three

unresolved

items

in paragraph

five concerning

seismic

qualification of control

rod drive "insert

and

withdraw lines,

seismic'-

qualification of various venti lati.on

systems,

and

an

unanalyzed

condition

regarding diesel

generator

loading criteria.

In paragraph

10,

there is

an

unresolved

item concerning installation of instrument lines.

Operational

Safety

(71707,

71710)

The

inspectors

were

kept informed

on

a daily basis

of the overall plant

status

and

any significant

safety

matters

Daily discussions

were held with plant management

and various

members of the

plant operating staff.

The inspectors

made frequent, visits to the control

rooms

when

an inspector

was

on

site.

Observations

included

instrument

readings,

setpoints

and

recordings;

status of operating

systems;

status

and alignments of emergency

standby

systems;

onsite

and offsite emergency

power sources

available for

automatic

operation;

purpose

of temporary

tags

wer e

not properly control ling the

cl earance

boundary.

During a daily tour on February

17,

1986, yet another

clearance

problem

was

noted.

Tag

No.

11

on Clearance

No.85-510

was attached

to the

Limitorque valve

operator

hand

wheel

for valve

2-FCV-74-77

in the

Residual

Heat

Removal

(RHR)

system

on Unit 2.

This valve operator

had

been

removed

from the valve

and

was laying

on the floor with the tag

attached.

The

valve itself

had

also

been

removed

from the

system.

Work on this valve

had

been

allowed to proceed

even

through it was

established

as

a clearance

boundary for work on different valves in the

system.

Discussion

with

licensee

representatives

indicated

that

although this type of activity was not specifically prohibited by the

clearance

procedures,

a

breakdown

in

the

coordination

of

the

two

competing maintenance activities

had occurred.

The tag

was subsequently

authorized to be removed

by the Shift Engineer.

In all of the above cases,

the clearance

discrepancies

were immediately

reported, to the responsible shift engineer or assistant

shift engineer

who took prompt corrective action.

Each

instance

was

discussed

with

members

of the plant

management

during

the

routine daily meeting.

These

are also

included

as

examples

of

a violation for failure to

adhere to procedures

(259/260/296/86-06-04).

7.

Surveillance

Testing Observation

(61726)

The

inspectors

observed

and/or

reviewed

the

below listed

surveillance

procedures.

The inspection

consisted

of

a

review of the

procedures

for

technical

adequacy,

conformance to technical

specifications,- verification of

test instrument calibration, observation

on the conduct of the test,

removal

from service

and return to service of the

system,

a review of test data,

limiting condition for operation

met,

testing

accomplished

by qualified

personnel,

and

that

the

surveillance

was

completed

at

the

required

frequency.

Fire Protection Surveillance

The

inspector

observed

part of the

annual

Surveillance

Instruction,

S. I.4. 11.A. l.e, Testing of Fixed Water Nozzles for Blockage.

Over the

course

of several

days,

four non-intent

changes

were

necessary

to

complete

the procedure.

( I)

Observation

on 2/5/86

After several

people

were

assembled

in the reactor building, the

surveillance

was

immediately

stopped

because

the craft personnel

recognized that the procedure did not require isolation of all the

necessary

valves.

This portion of the

procedure

tests

the

dry

pipe

in the

reactor

building

by blowing air through

the lines

while the

nozzle outlets

are

checked

for passage

of air.

The

surveillance

was

being

performed

in

the

unit three

reactor

building for zones

3C

3D - 3E

3F.

A non-intent

change

made

on

1/29/85

had left only

one

isolation

valve for these

zones.

Although Units I and

2

had previously

been

tested prior to the

1

inspector's

observations,

a

change

was

not

made for those units.

If the

procedure

was followed, -only

one

valve

was

isolated

to

perform the test.

The valves

are

closed

to prevent

inadvertent

initiation of the

deluge

valve

and

spraying

down

the

reactor

building.

After a non-intent

change

was

made

the test continued

in the afternoon for zones

3C - 3D - 3E - 3F which were isolated

by shutting

valves

3-26-993

and

3-26-1162.

Next the inspector

observed

testing

on

zones

3A and

3B

which

were

isolated

by

shutting valves 3-26-992

and 3-26-1165.

Upon further review of the procedure

the inspector

noted several

inconsistencies

and

problems.

The non-intent

change

performed

1/29/86

changed

the valve isolated for 20 valves

from isolating

the individual deluge valve for a zone of nozzles

to isolating

a

header

valve in the line which isolated

several

zones.

Although

the deluge valve was listed by number

and the deluge valve listed

as

the

isolation,

this

valve

is

not isolated.

Other

header

isolations

are

closed

to isolate

the deluge

valve but were not

specified

by valve

number.

Also,

16 header

valves were deleted.

This was

a major revision to the procedure affecting nearly all of

the valves

and the

number of fire protection nozzle

zones .isolated

at

one

time.

The

inspector

reviewed

the definition of intent

changes

and non-intent

changes

defined in Browns Ferry Standard

Practice

1.3.

One of the -definitions applicable

to this

change--

was change

in scope,

technique,

or sequential

order of instruction

steps that would affect the result or nuclear safety.

Also noted

was that the fire protection

engineer

had

reviewed

the original

procedure

but the non-intent

change

was

not reviewed

even

though

changes

to the

amount of fire pr~tection

equipment

taken

out of

service at one time were

made.

(2)

Review of Fire Protection

Equipment

Removal

From Service Permits

In addition,

the inspector

reviewed the Fire Protection

Equipment

Removal

From Service

Permits

in the procedure

package at the job

site.

Permit

197 for zones

3N

3g -

3P

had

expired

at

2400

2/4/86 but had not been

signed

as being returned to service

as of

2/5/86.

The craft personnel

discussed

this with the

foreman

who

stated

the master

copy in the control

room had been

extended.

The

inspector verified that the permit

which originally started

at

0700

on 1/29/86

had

been

extended

to 2400

on 2/6/86.

Later review

found the permit extended

again to 2400

on February 7,

1986.

The

inspector

noted that although permit

201

was for zones

3D - 3E-

3F that the method of isolating the zones

using the header

valves

isolated

3C

3d

3E - 3F.

No permit could be found for 3C zone.

Likewise,

no permit could be found for zones

3A 3B.

Discussion

with the fire protection

engineer

revealed

that

the

procedure

allows for equipment

to

be

removed

from service

for one

hour

without

a permit but the

procedure

was

being revised

and plant

personnel

had

been

instructed

to notify the fire protection

engineer

any time equipment

was

removed

from service.

The fire

protection

engineer

stated

the

following permits

had

been

completed:

199

Unit One

Zones

A, B, C,

D,

E,

F

198

Unit Two

Zones

P,

R,

N,

Q

200

Unit Two

Zones J,

K.

L

The

method

of

using

the

permits

appeared

to

be

totally

inconsistent.

Oelay oi 2/7/86

The test

was again delayed

on 2/7/86 for another non-intent

change

necessary

for testing

the

nozzles

in the high pressure

coolant

injection room.

The original procedure

required that

a test

hose

be

connected

for the air supply but the non-intent

change

was

necessary

since there

was

no test connection

and

a nozzle

had to

be

removed to connect

the air supply.

The inspector

noted

the

non-intent

changes

made

on 2/7/86

and 2/5/86 were

made

such that

a

historical

record of the change

might be lost.

On the non-intent

change

form a block is designated

"Change to Read" but instead of"

identifying

the

pages

or

procedure

step

changed,

the

block

contained

the words

"See attached".

If the

staple

was

removed

from the cover

sheet it would be difficult to tell what had been

changed

and

a historical record of the transaction

would be lost.

Observations

on 2/10/6

The

inspector

observed

the test for the Unit

3

high

pressure

coolant

injection

room.

After

completion

of

the

test

the

inspector

questioned

what

the

signature

in

the

procedure

represented.

The

procedure

was

nearly

completed

at this time.

The foreman stated

the

signatures

were for verifying the

nozzles

were

not obstructed

and

second

party verification was required.

However, the inspector

recalled. that the inspection

performed

on

2/5/86

had

only

a

single

person

in the

overhead

to verify the

nozzles

not blocked.

Also, due to the format of the data

sheet it

appeared

that the craft personnel

were signing for the test

hose

completion

and removal but not for verifying the nozzles

were not

obstructed.

The

column

heading

entitled

"nozzles

not blocked,

initials/date", aligned with the

second party signature

blank for

the test

hose,

but the

same

person

had

signed

in this vertical

column

indicating

the

signatures

were

for

the

test

hose

installation

and

removal.

No signature

could

be

found for the

nozzles.

The inspector

noted

the last time the surveillance

was

completed

using

a different data

sheet

format the

nozzles

were

10

verified twice as not blocked.

The cognizant engineer

stated that

a space

was

on the data

sheet for the signature

but the block had

no line for

a signature

like the

other

signature

blocks.

The

craft

people

were

instructed

to

now

go

back

and

sign for the

nozzles "not blocked" in the

space.

The double verification was

stated to not be required.

(5)

Review of Past Surveillances

The inspector

reviewed the completed Surveillance Instructions for

SI

4. 11.A. l.e

performed

on 6/9/85,

6/18/84,

and

5/31/83.

The

procedure

was basically the

same

as the procedure

used before the

non-intent

changes

were

made but was performed without difficulty

and

no major revisi~n.

Failure to have

an adequate

procedure for the non-intent

change

on

1/29/86 which was used for Unit

1 and Unit

1 testing

and failure

to

have

a

data

sheet

with adequate

format

such that

personnel

could tell what the signatures

signified were given as

an example

of a violation against

T.

S. 6.3, (259/260/296/86-06-04).

Likewise,

making

a

temporary

change

to the

procedure

for the

non-intent

change

1/29/86 which was

an intent

change

was another

example of the violation against T.S.6.3,

(259/260/296/86-06-04).-

b.

Chemistry Surveillance

Three

samples

were observed

during this surveillance

The first sample

observed

was for the performance

of Surveillance

Instruction,

S. I. 4.8.B.2-3a

Airborne

Effluents

(Weekly

Gamma

Isotopic)

for

the

radwaste

building

monitor

0-RE-90-252

on

February

5,

1986.

The -S. I. referenced

Chemistry Instruction

430

and Section

430.3

was

used for the

sample.

During collection of

the

sample,

using

a marinelli beaker,

the

red alarm light on top

.

of the

monitor

was

received.

The technicians

stated

this

was

normal

and it was

a low flow alarm due to sampling.

The inspector

noted that the flow light on the side of the monitor was not lit

and the procedure

contained

no note that this should occur.

Next the

sample

was

taken to the chemistry

count

room where the

sample

was

placed into the counter.

The technician

had initiated

the

counting

from

a

computer

terminal

and

was waiting

as

the

sample

was

counted.

However,

another

technician

in

the

Lab

cautioned

the technician

that the

wrong terminal

was

being

used

for the

counter.

Although Chemistry

Instruction- 701,

ND 6620,

Acquisition and Data Reduction,

Section

VI, Step

B. 1. requires

a

check for the

proper detection

and terminal, this step

was not

11

performed.

The inspector

was particularly concerned

that

a count

of air

could

have

been

taken

without detection.

Thi s

sample

routinely has

a count rate

near

background

and

an error

such

as

this could easily overlook

a real

problem.

Next,

the

sample

was

counted

using

the correct

terminal

and

detectors.

One 'step in the

computer

program

asked for the stack

monitor count rate

in counts

per

second

(CPS)

and

a value of 17

was entered.

However, another technician

said the value should

be

around

6

or

7

CPS.

The

technician

determined

that

the

stack

flowrate of 17,000

in units of cubic feet

per

minute

had

been

entered

instead of the count rate in units of CPS.

The technician

stated this part of the

program

was irrelevant to the procedure

but data

had to be entered

to <<ake the program run.

The cognizant

engineer

was called to determine if the error could affect the

results

and if

a

recount

was

necessary.

The

stack

monitor

controls

were determined

irrelevant to the results

and

the test

proceeded.

Later,

the

cognizant

engineer

stated

the

software

needed

improvements

(2)

During the test

some discussion

occurred with the technician

about

the value of the marinelli beaker

as to whether it was

one liter

or two liters.

After the test it was

learned

that

the

beaker

volume

was

1240

CC

and

was specially calibrated.

The

geometry

was

such that the inside of the beaker

was

recessed

to fit over

the detector

probe for better

counting

geometry.

The inspector

noted that this volume was listed

on the computer

output sheet

and

the technicians

seemed

unfamiliar with their test equipment.

This

procedure

is performed routinely avery week.

This

same

procedure

was

observed

in the past

and is discussed

in

Inspection

Report

84-10.

A violation with

seven

examples

was

issued

for procedural

problems

at that

time.

An

example

of

a

violation

against

Technical Specification 6.3 for failure

to

follow

procedure

was

given

for

this

observation.

(259/260/296/86-06-04).

The

second

sample

observed was'or

the Turbine/Reactor

Building

combined exhaust

and

no problems

were noted.

(3)

The third sample

observed

was for the plant stack.

Taking of the

sample

was attempted

on February

5,

1986,

but

had to

be

stopped

pending

interpretation

of procedural

inadequacies.

The

sample

procedure,

BF CI 466.51, if performed

as written would have left

the continuous monitor inoperative after the

sample

was taken

due

to closing of valves

90-305A

and

90-282N.

Upon investigation it

was

noted

that

an

attempt

to correct this condition

had

been

previously

conducted

with

a

non-intent

change

drafted

during

November,

1985,

but the non-intent

change

had not

been

properly

12

implemented

in that it was absent

from both the chemist's

copy and

the copy that the inspector obtained

from the master file in the

drawing control center.

The procedure

was again revised

and stack

sample

was

resumed

on

February

6,

1985,

and

completed

with

no

further

incident.

Failure

to

have

an

adequate

procedure

is

another

example

of

the

violation

against

T.S.

6.3

(259/296/296/86"06-04).

c.

Electrical Surveillance

On February 4,

1986,

the resident

observed

surveillance,

S. I. 4.9.A.2a

(Auxiliary Electrical

Equipment - Battery Check).

The surveillance

was

satisfactorily

completed

on the

"A" and "B" shutdown

boar'd

250 V.D.C.

batteries.

Several

minor

def>ciencies

were

~ointed

out

to

the

cognizant engineer

including:

( 1)

The

"B" shutdown

board battery

was

being maintained

at

a float

potential

greater

than that

recommended

by the

procedure,

2.25

volts/cell,

due

to

three

jumpered

cells.

The

licensee

had

previously received

vendor

concurrence

to exceed

2.25 volts/cell,

up to

a

maximum of 2.33 volts/cell for

a

one year time frame.

However, this time limit had

been

exceeded

and

no administrative

controls

had been

implemented to address

this occurrence.

(2)

The

data

sheet

was deficient

in that individual battery

pre-

requisite

and precaution

signoffs were not included.

Other minor

data

sheet

deficiencies

were pointed out to ease

in technician

procedural clarification.

(3)

The associated

battery chargers'nternal

cabinets

and the battery

rooms

were

observed

to be deficient in regards

to proper

house-

keeping requirements.

d.

Standby Liquid Control

System

On

February

10,

1986,

the

inspector

observed

the

performance

of

Surveillance

Instruction,

S. I.4.4.C.3

Standby

Liquid Control System-

Boron Concentration.

The surveillance

requires that the

SLC System

be

sampled

per

Chemistry

Instruction

(C. I.)

463. 1,

Sampling

Sodium

Pentaborate

from the

SLC

Storage

Tank.

Prior to

sampling,

air

is

sparged

through

the

SLC

storage

tank for

15 minutes

to obtain

a

representative

sample.

After the air lineup is isolated,

Step

VI.C

requires

that the air. supply valves

be verified locked.

Data

Sheet

S. I. 4.4.C.3

provides

sign off spaces

that

valve

63-536

is

locked

closed

and second

person verification that the valve is locked closed.

When

the

chemistry

technician

noted

that

no

locking

device

was

installed

on valve 2-63-536,

he engaged

in

a discussion

with the valve

operator

who assured

him that

an air isolation valve upstream of valve

2-63-536

was locked closed

and therefore

no locking device

was

needed.

13

Both the valve operator

and chemistry technician

then initialed on the

S. I. 4.4.C.3

Data Sheet that valve 2-63-536

was locked closed.

This is

another

example

of

a violation for failure to follow to procedures.

(259/260/296/86-06-04).

Diesel Generator

Testing

On February 21;

1986,

the inspector

observed

the

performance

of S.I.

4.9.A. l.b,

Diesel

Generator

Emergency

Load

Acceptance

Test.

The

surveillance

involved close coordination

between operations,

electrical

maintenance

and

Power Systems

Operations

(PSO).

The procedures

upgrade

engineer

responsible

for revising

the

procedure

also

observed

the

surveillance

in order to gain first hand

knowledge of the procedure

and

interview the

personnel

performing the test.

One typogra, hical error

and

many procedure

enhancements

were identified.

The surveillance

was

carefully controlled by the Assistant Shift Engineer

and was completed

without incident.

Reactor Building Ventilation Radiation Monitors

While

performing

Surveillance

Instruction,

S.I.

4.2.A-10,

Reactor

Building Ventilation Radiation Monitors,

on February

15,

1986,

on Unit

2

equipment,

the

logic circuit

was

found

to

deviate

from

the

as-constructed

drawings'his

deviation

was discovered after the

S.

I'as

revised

such that jumpers

used in the test were placed in different

locations

than

in previous test performances.

Specifically,

a contact

of the

Reactor

Zone

Exhaust

Radiation

Monitor upscale

trip relay

( 16A-K61A

shown

on

drawing

730

E

927

SH

18)

was installed

in

a

different location from that

shown

on <he, drawing.

Licensee

personnel

evaluated

the discrepancy

and determined

that the circuit would still

perform its intended

function.

A Drawing

Discrepancy

was

issued

to

revise

the

drawing

such

that it would

match

the as-built

plant

configuration.

(Drawing

Discrepancy

No.

730

E

927

SH

18,

dated

2/15/86).

The

inspector

questioned

whether

this

would

be

the

appropriate

corrective action

as

opposed

to re-wiring the contacts

to

match

the plant drawings.

The

same

drawing is applicable to all three

units,

however,

the deviation

is only present

on Unit 2.

Initial

discussions

with licensee

representatives

resulted

in an agreement

that

the plant configuration should

be changed

to agree with the drawing and

that

a Discrepancy

Report would be

issued to accomplish this.

Later,

licensee

representatives

stated

that

the

Standard

Practice

which

controls

the Drawing Discrepancy

program included sufficient checks to

ensure

that in cases

like this,

drawings

are

not blindly revised

to

match

the plant configuration,

but that

a proper evaluation

of the

required corrective 'ction is performed.

The plant will continue

to

track the deviation through the Drawing Discrepancy

program

as

opposed

to

issuing

a

Discrepancy

Report.

An

Inspector

Followup

Item

(259/260/296/86-06-05) will'e

opened

to

follow this

particular

deviation

through

resolution

as

well

as

to investigate

the

generic

potential that hardware deviations

may be resolved

by drawing changes.

14

8.

Reportable

Occurrences

(90712,

92700)

The below listed licensee

events

reports

(LERs) were reviewed to determine

if the

information

provided

met

NRC

requirements.

The

determination

included:

adequacy

of event

description,

verification of compliance with

technical

specifications

and

regulatory

requirements,

corrective

action

taken,

existence

of potential

generic

problems,

reporting

requirements

satisfied,

and the relative safety significance

of each

event.

Additional

in-plant reviews

and discussion

with plant personnel,

as appropriate,

were

conducted

for those

reports

indicated

by

an

asterisk.

The

following

licensee

event reports

are closed:

LER No.

259/86-01

Date

1/07/86

Event

Inoperable

Stack

Gas Monitoring

Recorder

"296/86-02

l/16/86

Inadvertent

Diesel Start During

Performance

of a Plant Instruction

Due to Personnel

Error.

260/85-19

"260/85-18

12/13/85

-

Inadvertent

Containment Isolation

11/06/85

'-

Creation of a Potential

to

Violate Secondary

Containment

260/85-04

"296/86-04

6/11/85

2/21/86

Reactor Mater Chemistry-Low

pH

Removal of Diesel Generator

From

Service

Leads to Prohibited

Configuration

LER 296/86-04

was reviewed to determine if the event satisfied the criteria

of

a licensee

identified violation pursuant

to

10 CFR 2,

Appendix

C.

A

compliance

engineer

identified that

the

plant

failed to satisfy

the

requirements

of Technical Specification 3.5.C.7

about

5

days after

the

occurrence.

A one-hour

report

was

made

to

the

NRC pursuant

to

10 CFR 50.72(b)(1)

on

January

30,

1986

and

the

followup

LER was

submitted

on

February

21,

1986.

A Notice of Violation will be

issued for this event

(296/86-06-06),

however,

since this violation could reasonably

be

expected

to

have

been

prevented

by the licensee's

corrective

action for

a previous

violation.

Violation 259/260/84-26-02

was issued

on October

17,

1984.

This

violation followed

an

enforcement

conference

conducted

on August 30,

1984,

during which the

NRC Regional Administrator

expressed

his concerns that the

licensee's

Technical Specification

must be clear

and understandable

and that

the

licensee

should

make

a

concerted

effort to

upgrade

the

Technical

Specification to eliminate confusion

and ambiguity.

LER 296/86-04 indicated

that

once

again

several

interrelated

TSs

were

involved and contributed

to

the

complexity of the event

assessment.

This

LER additionally failed .to

15

indicate that the prior violation (reported in

LER 259/84-29)

was

a previous

similar event.

A licensee

representative

indicated that the precious

LER

was considered,

but was judged

not to

be

similar.

Without

a

review of

corrective action for previous violations,

there

can

be

no confidence that

corrective

action instituted

as

a result

of the

recent

event

wi 11

be

effective.

The

NRC judges

these

two event to be similar for the following reasons:

a.

Both events resulted

in plant operation outside the limiting

condition for operation

( LCO) for

RHRSW as

specified in the Technical

Specifications.

b.

Both events

were contributed

Co by ambiguous

wording in the Technical

Specifications

dealing with RHRSW pump requirements

and the definition

of equipment operability

as it related

to the onsite

emergency

power

source (diesel

generators)

and

RHRSW pumps.

C.

The

cause

of both events

has

been attributed

to personnel

error.

In

response

to Violation 259/260/84-26-02,

the licensee

stated that "plant

personnel

misinterpreted

Technical

Specification

1.C.2".

This is the

LCO definition as it related to operability of offsite or diesel

power

sources.

For the recent'vent,

the

licensee

stated

in

LER 296/86-04

that "the

cause

of the

event 'is attributed

to oversight

by

shift'ersonnel

in determining all system operability requirements."

This item was discussed

in detail during

a routine daily meeting with

plant management

on February

25,

1986.

9.

Housekeeping

Observation

An inspector

toured

the

Reactor

and Control Buildings for the

purpose

of

determining

the status

of plant housekeeping,

General

cleanliness

was poor

and conditions

observed

indicated lack of effort to perform indepth cleaning

other

than routine surface cleaning.

Hard to get to areas

such

as crevices,

cabinet foundations,

cable trays, penetrations,

etc., did not

show adequate

cleaning effort.

Specific examples

of areas

of concern

are

as follows:

Many electrical

and

pipe penetration

areas

in Reactor

Buildings were

dirty.

Cables

in cable

trays

in Reactor

Building were dirty, Plant

Stack

ground floor, mesanine,

and

sample

areas

were dirty.

Ground floor had

large

amount of loose materials lying around.

Area inside

MOV Board

BD3D cabinets

was dirty.

Units

1 and

2 shared

shutdown

board battery chargers

contained

a thick

coat

of lint

and dirt within the

cabinets.

One of the

cabinets

contained

a large

amount of stripped

electrical

insulation

material

16

that

had

not

been

cleaned.

up from

a previous electrical

termination

activity. Additionally, the

two battery

charger

cabinets

appeared

to

have incorrect unit identification labels.

Cable spreading

areas

were dirty.

Units

1

and

2

shutdown

board battery

rooms

were dirty inside.

All

cells in both batteries

require external

cleaning.

a

damaged

battery

cell terminal

was lying on floor (the associated

cell

had

been

jumpered

over one year prior).

Several

sections of flexible conduit associated

with the battery rooms'entilation

fans

and dampers

were observed to

have loose connections.

The above conditions existed in spite of the fact that all three units were

in cold

shutdown with

a

minimum of outage activities in progress.

It does

not appear

that

the

licensee's

housekeeping

program,

as

implemented,

is

fully effective.

10.

Facility Modification (37701)

This

supplemental

inspection

was

conducted

to determine

whether facility

modifications that require prior review

and approval

from the

Commission

pursuant

to

10 CFR 50.59

are completed .in conformance with requirements

in

the facility license,

technical

specifications,

and

applicable

industry

codes

and

standards.

Specifically, work associated

with the replacement

of

certain

Reactor

Protection

System

and

Emergency

Core

Cooling

System

mechanical

type instrumentation

switches with analog transmitter/trip unit

(ATTU) instrumentation

was observed.

Engineering

Change

Notice

(ECN)

P0126

implements

the modification for Unit 2.

The.

ECN is scheduled for completion

prior to startup.

The actual

work is divided into

some

48 work packages

which

include

cable,

conduit,

and

junction

box

installation;

panel

installation;

panel

internal wiring; transmitter

installation;

instrument

piping installation;

cable

pulling;

and

post modification testing.

The

current

status

of work packages

is

as

follows:

4-complete,

6-not yet

written, 2-in approval cycle, 36-working.

The inspector

observed

work being

performed

under

Work Plan

No.

2040-85,

Install piping/tubing and supports for ins'trument

sensing

lines for the

new

trensmitters

at panel

25-5A, 25-6-1

and

new panels

25-5C,

25-5D, 25-6c,

and

25-6D.

This work plan requires

instrument lines to be installed

per General

Construction

Specification

No.

G-60

Rev.

1.

The preface to this construc-

tion specification states

that the Revision

1 issue of this specification is

applicable to Bellefonte Nuclear Plant only. Licensee representatives

stated

that this specifidation

was being

used for work at Browns Ferry since there

is

no existing

specification

applicable

to

Browns

Ferry.

The

licensee

intends to revise Specification

G-60 to make it applicable to Browns Ferry.

This will be tracked

as

an Inspector

Followup Item (259/260/296/86-06-07)

to

ensure

that

any

technical

revisions

that

may

be

needed

to

make

the

specification

applicable

to Browns Ferry are

reviewed for compliance with

the physical

work already completed.

17

Section

3.3.1

of Specification

G-60 requires

instrument lines to have

a

downward

slope of I inch per'o'ot

except

where this is impractical

due to

equipment

location or piping geometry.

In that

case,

the line could

be

sloped

as

much

as

possible,

but not

less

than

1/8

inch

per foot.

The

inspector

observed

many instrument

sensing

lines installed

under

the work

plan

which

had

minimal

slope

with

no

apparent

interference

which would

prevent

achievement

of

a full inch per foot slope.

Personnel

involved in

the installation

stated

that lines

were built to obtain

a 1/8 inch slope.

Modifications managers

were contacted

and

agreed

that

the intent of the

construction

specification

was

not

being

met.

A walkdown of the

work

located

one

section

of piping which did not satisfy the

minimum 1/8 inch

slope.

All other instrument lines would be considered

acceptable

based

upon

the minimum slope criteria.

Future work plans

wi 11 explicitly require

a

1

iach

per

foot

slope

to

be

attained

unless

the

cognizant

engineer

is

contacted

and gives approval for using the

minimum slope criteria

when the

geometry

prevents

attainment

of the

nominal

slop'e.

This

item will be

tracked

as

an

Unresolved

Item

(259/260/296/86-06-08)

pending

necessary

rework and final closeout

and acceptance

of the work plan.

ML18030B228

Text

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