ML18033A894

System,

System

63,

was

BFN-50-7063.

The

NRC

inspector

found

that

the

restart

design

criteria

acted

as

a

focal

point

for

design

commitments

and requirements

and

as

such contained

very

few details

or system

specifics.

For example,

NEP 3.2 required

system material

requirements

to be specified,

including

such

items

as compatibility

and

corrosion

resistance.

Section

3. 12 of BFN-50-7063

specified

material

requirements

as follows:

Specific material

requirements

for components

of the

SLC system

are

identified

by

the

original bills of material,

vendor

documentation,

specifications

as

they

exist,

and

original

purchasing

requirements,

plus additional

material

requirements

covered

by Commitments/Requirements

made

to later editions

of

codes,

Standards,

and Regulatory Guides.

Various

comments

were

made

through

the

design criteria

document

regarding materials;

however, all referred

back to Section

3. 12 for

details.

The

format of the

document

was

not conducive

to

easy

review.

In general,

however,

the

NRC inspector

found that the restart

design

.criteria

document

BFN-50-7063

and its references

did address

the

design

input requirements

of ANSI 45.2. 11 -

1974Property "ANSI code" (as page type) with input value "ANSI 45.2. 11 -</br></br>1974" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process.

as stated

in

NEP

6.6.

No violations were identified.

d.

ECN/DCN End Product

Review

The inspector

selected

P 7010,

and

OCN

H 1239,

Revision A, for

review.

This review was to evaluate

the

end

product

against

the

process

and included the following:

t

Verification

that

the

establishment

process'nsures

that

original design information

was available

to the design

change

group.

Also, verification through interviews,/for

a

sample of

contractors

performing

design

work, that

access

to original

design

information was readily

available'valuation

of the controls

of the

Design

Analysis to ensure

that:

They were performed in a controlled

and planned

manner.

Design

analyses

were controlled

as

gA records.

(Several

were

sampled

to

ensure

they

are

legible,

suitable

for

reproduction,

retrievable,

and technically adequate.)

0

The

Program

required

documentation

of

analyses

to

contain:

Method of analysis

Purpose

Assumptions

Basis or design input

Person

performing analysis

Date

Reviewer

Results

or conclusions

Evaluation

of controls to ensure

that

equipment accessibility

for maintenance,

inservice

inspections,

and

replacement if

necessary

was considered

in the design

process.

Review of the

design verification process

and

ensure

that it

required

design

verification

by

independent

design

review,

alternate

calculations,

or qualification testing.

ECN Number E-2-P 7010,

Revision

0

The

above

was

prepared

to provide design

basis

documents

that

showed

design-verified

thermal

overload

heater

size

and

setting

for motor control

centers

required

to support Unit

2

restart.

Responsibility for preparing

the

ECN was assigned

to a

licensee

contractor

in accordance

with Task

Scoping

Document

TSD-E034,

"Thermal

Overload

Heater

Documentation",

dated

July 13,

1987.

The

detailed

task

description

specified

activities to be

performed

by the contractor

and

included

the

preparation

of TOL calculations.

Subsequent

to. the completion

of the design-engineering

activities for

P 7010,

licensee

management

identified

an error

in the calculation

used

for

determining the

TOL relay size

and trip current setting.

CARR

No.

BFP

850447,

dated

June

27,

1988,

was

prepared

by

the

licensee

to

document

the

design

deficiency

and

initiate

corrective action.

The

root

cause

of the

design

deficiency

was identified

as

improper

use

of General

Electric

Heater

Tables.

The

error

involved the calculation

of the

TOL relay trip setting

as

1.25

times the

maximum motor full load current listed in the heater

tables.

The correct

value

is calculated

as

1.25

times

the

heater

minimum current.

The inspector

reviewed

selected

copies

of the calculation

and verified that the calculations

had been

revised to incorporate

guidance

from the

vendor contained

in

a

General

Electric Application Tips letter dated

March 11,

1988.

Corrective action for this design deficiency was completed with

the

issue

of the revised calculations.

This design deficiency

was characterized

as

a Licensee-Identified

Violation,

50-259,

50-260,

50-296/89-17-03,

Inadequate

Thermal

Overload

Calculations.

This violation

met

the criteria

specified

in

Section

Y of the

NRC

Enforcement

Policy for not

issuing

a Notice of Violation and was not cited.

2)

DCN H1239, Revision

A

The

above

DCN modificat,ion

package

was

prepared

to revise

the

design

output drawings

showing design verified TOL relay sizes,

trip 'urrent

settings,

and bill of material.

This

DCN

superseded

all

DCAs

contained

in

ECN modification

package

E-2-P 7010.

Pursuant

to discussions

with licensee

management

and

review of selected

samples

of

DCAs contained

in the

DCN,

the inspector verified that the design

scope of

DCN

H 1239

was

identical

to that of

ECN E-2-P 7010.

Also, the

DCN drawings

showed

numerous

changes

in heater

sizes

and settings

from those

shown

on drawings contained in

P 7010.

The

transitional

design

controls

under

which

DCN

H 1239

was

prepared

and

evaluated

were

reviewed

by

the

inspector.

Procedure

PI 86-03,

paragraph

4.2,

"Processing

Changes

to ECNs,"

did not permit the

use of

a

DCN to correct

ECNs for which the

initial screening

and/or

10 CFR 50.59,

Safety Evaluation

was

no

longer valid.

Because

the

P 7010,

10 CFR 50.59

screening

review

and

Safety

Evaluation

were

based

on inputs

from

TOL

calculations

that contain errors,

the inspector

concluded that

the result of this review was incorrect.

Discussions

with licensee

management

concerning the reason

why a

DCN was prepared

in lieu of revising

P 7010 were

conducted.

The inspector

determined

that the

DCN process

was

used

because

it was

the

most

expeditious

way to

implement field changes

required

to support Unit

2 fuel load.

This failure to comply

with the transitional

design

controls

was identified

as

the

first

example

of

Violation

50-259,50-260,50-296/89-17-02,

Failure to Properly Implement Procedures

As Required

By TS

~

Material Selection

Review

The

inspector

reviewed

the

process

used

to specify

and

procure

materials

for

an

ECN.

The

inspector

reviewed the parts that the

design

engineer

had specified for ECN P-7032

and the parts that

had

actually

been

used for the

ECN.

The design

engineer

had specified

the material

to

be

used

as

required

by SDSP-16.2;

"Procurement

of

Material,

Components,

Spare

Parts,,

and Services",

Revision

0.

The

inspector

reviewed

the

gA levels specified

by the engineer for the

different

components

and

found

them

in

line with the

safety

requirements

of

the

components

and

systems

involved.

All

the

components

drawn from'ower Stores

met or exceeded

the requirements

of the design engineer.

No problems with the specification

and

use

of materials

were identified.

0

.f.

Interface Control

Review

The inspector

reviewed

a sampling of recent modifications to evaluate

engineering

discipline

interface

controls.

These

modifications

involved

ECN P-7032,

which dealt with the upgrading of certain

Reactor

Water

Cleanup

System

cables

to

meet

10 CFR 50.49

requirements.

During the

pre-implementation

review of the modification, it was

determined

that there would be four modifications being performed in

the area at the

same time.

These modifications were being

developed

and

coordinated

by different design

groups.

Even

though it was

recognized

before implementation that interference

would exist due to

the other modifications, work proceeded.

These

interferences

created

by the other modifications resulted

in numerous field revisions

to

the

ECN, including the rerouting of the cable conduit, splicing the

repulled

cables

when

they

were

too

short

to follow the

rerouted

conduit,

and multiple cases

where conduit supports

would have to be

relocated.

The lack of coordination

among the various

design

groups

resulted

in the

task

becoming

more complicated

and requiring

many

field revisions.

The

licensee

has

since

terminated

the

use

of

several

of the various

design

organizations,

a

move which

has

the

potential for reducing the

number of interferences

and required field

revisions

on the modification process.

The inspector also reviewed the process

used to develop workplans for

approved modifications.

Licensee

procedure

SDSP-8.2,

"Modification

Workplans",

Revision

13,

included

an

attachment

which

provided

general

requirements

for all workplans. All safety-related

workplans

were

required

to

have

a

review

by

a

technical

reviewer,

the

post-modification test

manager,

and the site quality organization.

Changes

to

a workplan were

implemented

as either

an intent change or

a non-intent change.

An intent change

was defined

on

Form SDSP-122

as:

Removal of an item installed

by

some other work document.

Change to acceptance

criteria.

Deletion or

change

to

a

gC or

ANI holdpoint.

This

may

be

processed

as

a

non-intent

change if gC/ANI preapproval

is

obtained.

Changes

in scope

technique

or sequential

order of instruction

steps that would affect the results or nuclear

safety.

Changes

which would implement

a temporary alteration to

a

CSSC

without a TACF.

Changes

to the authority or responsibility for review and/or

approval

of the

document,

or the results

obtained

from its

implementation.

0

10

This definition of intent

change

provided

a great deal of ambiguity

for the classification

of

a

change

to

a workplan.

The inspector

found

several

examples

where

significant

changes

were

made

to

workplans

and

were classified

as non-intent

changes.

These

changes

did not receive

the level of review and

approval

necessary

for the

original

workplan.

Examples

of these

significant

changes

included

change

number

two to workplan

2317-88,

which

deleted

a

support

drawing

and weld map from the original workplan, multiple 'changes

to

workplan 2069-88 to allow such things

as splicing of short cables,

abandoning

instead of removal of cables,

making as-needed

repairs to

concrete,

and

cutting

out

an

existing

weld

and

rewelding.

AnotheJ~e

ample concerning

the switching of leads at

a breaker

panel

is discussed

in paragr~a

h 3 below.

The failure to properly

change

work plans is identified as

an additional

example of violation 50-259,

50-280~MD-296/89-17-02,

Failure to Properly

Implement Procedures

as

Required

by TS.

3.

Post Modification Testing

The inspector

selected

nine recent modifications for review which required

some

type of post modification test.

Each

was

reviewed to determine

the

adequacy

of testing

to insure that the affected

area

had

been

properly

tested

and met design

requirements.

The

nine

modification

packages

reviewed

by the

inspector

are

listed

below:

Work Plan

ECN/DCN

Descri tion

WP 2600-88

P 7131

WP 0132-88

DCN

W 0113A

WP 2181-88

DCN

WW 044A

Reroute

the

unit

2

reactor

vessel

level

reference

piping from the vessel

penetration

to

the first isolation

valve outside

the drywell penetration.

Replace

GE capacitors

inside

the

250

Volt D.C.

battery

charger,

2A, with

equivalent

Mepco or GE capacitors.

Modify

CSSC

motor

operated

valves

control switch settings

based

on valve

vendor

data

and criteria

established

to

permit

valve

seating/unseating

without

exceeding

the

rating

of the

valves

and

to

prevent

inadvertent

backseating.

WP 2010-88

DCN B 0013C

Rework thermowells

in the

RBCCW system

and

four

temperature

elements

in

system 68.

WP 2134-88

ECN 7013

Replace

ihternal

wiring in Limitorque

Operators.

11

WP 2194-88

DCN-P 7082,

R-6

Replace

exi sting Reactor Water Clean-Up

pump motors,

U-2.

.WP2323"88

DCN

WW 0186AA

Replace

the

starter

coils,

add

an

interposing

relay in

compartment

10C,

and

replace

the

starter

coil

in

compartment

llA of the

480V

Diesel

Auxiliary Board

B.

WP 2340-88

DCN

W 0557A

Provide

control

switch settings

based

on ve'ndor data: criteria established

by

G-50

on motor operated

valves.

WP 1100-88

DCN

H 1238A

Incorporated

design

verified overload

heater

sizes for motor control centers.

Of the

nine

packages

reviewed,

the inspector

determined

that the work

plans contained

the following deficiencies:

WP 2181-88,

which

had

changed

valve limit and torque settings,

had

not specified

a leak rate test for valve 2-FCV-71-34.

As part of the

field

completion

package,

Site

Directors

Standard

Practice

8.4,

Revision

13,

"Modification

Workplans",

required

the

responsible

engineer

to assure

that all documentation

is complete.

This

assurance

was

made

without all

required

post

modification

testing

being

specified

or

completed.

This failure

to

follow

procedure

is

an

additional

example

of violation

50-259,

50-260,

50-296/89-17-02,

Failure to Properly Implement Procedures

as Required

by TS.

WP2194-88

incorporated

the design

necessary

to change

out the Unit 2

reactor

water clean-up

pump motors.

During the inspector's

review

of the post modification testing, it was learned that after the motor

changeout

was

completed,

checked

for rotation,

and the electrical

leads

spliced, it later

became

necessary

to reverse

the electrical

leads.

This

time the

leads

were reversed

by changing

them at the

breaker

and this

was

accomplished

by adding

a

step

in the

work

instructions. After the leads

were reversed,

drawing

67

E 2-45N2748-4

was not changed

to reflect the actual. installation which required the

color .coded

leads to be terminated at specific breaker terminals.

Section

6.5 of SDSP-8.4

states

that if problems

are

encountered

during implementation of the workplan the responsible

engineer

shall

determine if a design field change is required.

The reversing of the

leads without a field change

being processed

resulted

in drawing

67E

295

N 2748-4 not being

corrected.

This is an additional

example of

Violation 50-259,

50-260,

50-296/89-17-02.

0

12

4.

Drawing Update

Process

The

NRC inspector

reviewed the drawing/procedure

update

process

to verify

that

adequate

controls

were in place to ensure

changes

to the plant are

incorporated into the drawings

and

procedures

prior to declaring

systems

operable..

The

inspector

sampled

six modifications

and verified that

control

room drawings

and plant procedures

w'ere

changed prior to declaring

the

systems

operable.

The packages

reviewed included:

REN

P 7065

DCN

H 0130A

REN

P 7131

REN

P 7045

REN

P 3098

REN

P 7044

The

inspector

selected

ten

systems

to verify that

a

complete

set

of

Control

Room drawings

existed,

including flow, logic,

schematic;

and

single line electrical,

and to verify that they were clear, legible,

and

reflected

the latest modification to the

system.

The

systems

reviewed

were:

Sys.

82,

D

G Fuel Oil

Sys.

67,

Emergency

Equipment Cooling Water

Sys.

63,

Sys.

30, Heating

and Ventilation

Sys.

65, Standby

Gas Treatment

System

Sys.

85, Control

Rod Drive

Sys.

74,

RHR

Sys.

75,

Core Spray

The inspector

reviewed approximately

50 separate

primary drawings in the

control

room for legibility and inclusion of the latest

modifications.

This

review

included

flow diagrams,

instrument

logics,

and electric

schematics.

All drawings

reviewed

were clear,

legible

and

were

updated

within the required

time

frame to include the most recent-modifications.

Revision

clouds

were limited to the

most recent modifications.

Drawing

deviations still

under

review

by engineering

were

clea,.~ y marked.

The

extensive

backlog

of

drawing

deviations

still

under

review

could

compromise

drawing accuracy.

Several

instances

of deviations

as old as

1985

were

noted

as still requiring evaluation.

The

impact of

these

deviations

were

minor

in

each

case

and

none

had direct operability

implications.

The inspector

reviewed the drawing

and procedure

update

process

to ensure

adequate

controls

were

in

place

for incorporating

changes

prior to

declaring

systems

operable after modifications

are

complete.

Operability

checklists

are

used to ensure that modifications are reflected properly on

drawings prior to declaring

systems

operable.

The process

involved the

Systems

Engineering

group

as

coordinators

of the checklist

packages.

Reviews of checklist

packages

did not reveal

instances

of incomplete

or

inaccurate

operability

determinations.

This

process

appeared

to

be

adequate.

0

13

The Mechanical

Logics series

had

been

removed

from the Primary Drawing

list

and

were

not

being

updated.

This

decision

was

based

on

a

determination that the

Logics

had not

been

properly

updated

in the past

and

had consequently

been allowed to become obsolete

and inaccurate

due to

modifications

performed

since

licensing.

Plant

management

was

considering

whether

the

Logics

should

be

restored

and, if so,

the

appropriate

completion schedule.

The inspector

questioned

several

members

of the Operations

staff concerning

the

removal

of the Mechanical

Logic

(47E-611 series)

Diagrams.

'The use of the Logic diagrams at Brown'

Ferry

by the Operations staff was not extensive.

In fact, several

operators

did

not realize that the

Logics

had

been

removed

from the

Primary

Drawing

file.

Operations

personnel

were not trained

on the Logics, but used flow

diagrams,

schematics

and instrumentation

logics instead.

Therefore,

the

removal

of Mechanical

Logics did not

appear

to

be

an

issue

from the

perspective

of the operators.

The

impact of removing

Mechanic

Logics

on

other

groups

such

as

Design

and

Modifications

personnel

should

be

evaluated

as part of the determination

of whether.

the Mechanical

Logics

will be restored.

The

simulator

update

process

appeared

to

be

adequate.

Some

simulator

modifications were being delayed,

and apparently this delay was caused

in

part by recent staff reductions.

The

large

backlog

of

approximately

1500

restart-required

drawing

deviations

and the

low work-off rate

may

have

an

impact

on the

planned

startup date.

ECN/DCN Closeout

Review

This portion of the

inspection

was

to

assess

the

licensee

activities

associated

with closeout

of

ECNs.

A brief description

of identified

'problems

associated

with

ECN/DCN closeout

along

with the

licensee's

closeout

process

is discussed

below.

The

ECN/DCN is the vehicle

used

by TVA Engineering to evaluate

and approve

changes

to the physical plant.

Changes

to the facility are allowed by 10

CFR part 50.59

provided the written safety evaluation for the

proposed

modification determines

that

an

unreviewed

safety condition will not

be

created

by the modification.

Additionally,

10 CFR Part 50,

Appendix B,

Criterion III, Design

Control,

requires

that

design

changes,

including

field changes,

be subject to design

control

measures

commensurate

with

those

applied to the original design.

To implement this design

change

into

a

plant

modification,

additional

programs

and

procedures

are

utilized.

The modification program converts

the design

change into a physical plant

modification.

However, in the past,

procedures

necessary

to feedback

to

the

design

organization

the

actual

modification

versus

the

proposed

modifications

were

ineffective.

This

resulted

in

poor

communication

between

the

design

and

operating

organizations

in the

area

of design

control.

An essential

part of this operations/design

feed

back process

should

be the closure of the

ECN which then establishes

the design basis

for additional modifications.

Currently,

only 746 of the

1758 Cycle

5

e

ECN/DCNs

have

been

closed.

TVA developed

closeout

procedure

PI 88-04,

which engineering

follows to review and close

ECN/DCNs.

In the past this

closeout

review was only a paper review to ensure all elements

associated

with the

ECN/DCN process

were complete.

However,

due to a recent

EA audit

this procedure

was being revised to require

a technical

review as well as

the currently required administrative

review.

The licensee

stated that all Cycle

5 restart

ECN/DCNs will be closed prior

to r'estart. If new ECN/DCNs are

opened

as

a result of the partial closure

of

an existing

ECN/OCN,

they will

be

evaluated

against

the

restart

criteria

and

scheduled

accordingly. If an

ECN/DCN requires

partial

closure,

the current

TVA practice is to redefine

the

scope

to cover

only

the completed work, revise the

USED evaluation,

close the

ECN/DCN and

open

another

one

to

cover "any

unimplemented

work.

The

inspector

found

the

commitment

to completely

close all

Cycle

5 restart

ECN/DCNs prior to

restart

acceptable.

The inspector

could not verify that

TVA was

making

adequate

progress

toward closing the backlog

because

there

was

no schedule

available at the time of the inspection.

FSAR Update

10 CFR 50.71 requires that

an annual

update

be submitted to the

FSAR.

The

inspector

reviewed the licensee's

design

and licensing controls to ensure

the

requirements

of

10 CFR 50.71

were

being

properly

implemented.

TVA

used

procedures

SDSP

15.7

and

NEP 3.2 to update

the

FSAR.

Revisions to

the

FSAR text

and

drawings

were

prepared

as

part

of

the

original

ECN/DCN.

However,

the revisions

were held

and not incorporated into the

FSAR update until the associated

ECN/OCN were closed

by

DNE.

Currently,

ONE does

not review the proposed

FSAR changes

for accuracy

when it closes

ECN/DCNs, only that the update

request

has

been

made.

The

inspector

found that

there

were currently

92

ECN/DCNs

which

were

classified

RTS but not closed

because

of unverified assumptions,

and

65

safety

PMENs which had

been

implemented

on

a safety train basis

but the

ECN/DCN remained

open until all work was completed.

These

ECN/DCNs could

potentially result in

a plant configuration which is not reflected in the

FSAR,

should

these

packages

result in

a

RTS or

PMEN prior to January

22,

1989 (the cut-off date for the

UFSAR process)

whose

ECN closure

occurs

after

that

date.

The

procedures

required

ECN closure

before

a

UFSAR

update is processed.

TVA should ensure that the

updates

to the

FSAR are

incorporated

based

upon return to service of equipment instead of ECN/DCN

closure

which

could

lag

behind.

This

is

identified

as

IFI

50-259,260,296/89-17-04,

Changes

That Require

FSAR Update.

TVA requested

a

one year

schedule

exemption

from the

requirement

to

update

the

FSAR by July 22,

1989.

The inspector

discussed

the plans for

the

FSAR validation

and

update;

however,

no formal documentation

existed

for the inspector

to review.

0'

Q

15

7.

Inspection

to

Determining

Compliance

With

ATWS Rule,

10 CFR 50.62

(TI

2500/20:

Revision 1).

In order to evaluate

the licensee's

implementation of the

ATWS rule, the

inspection

was

conducted

using

inspection

guidance

contained

in

NRR

Temporary

Instruction

2500/20,

Revision

1

and

included

review of the

licensee

approved

design,

verification

that

modifications

did

not

compromise

the

safety

features

of existing

safety-related

protection

system,

verification that

commitments

made to satisfy

'SER requirements

were

implemented,

and verification that

the

ATWS

system

was designed,

procured,

installed

and

tested

under

an

approved

gA

program

that

satisfies

the requirements

of GL 85-06.

a.

Summary of Implementation

Status

1)

The Standby Liquid Control

System

was installed

and was declared

operational.

The Technical

Specification

had

been

approved

by

NRC.

The operators

were trained

on the

System

emergency

operating

instruction

EOI-1

and

2-0I-63.

Surveillance

Instructions SI-4.4.A. 1,

A2,

C2,

C3,

C4,

5

D had

been

issued.

2)

The

ARI installation

was not complete

and

the

system

had not

been declared

operable.

a)

ARI vent valves

and instrument air tubing were installed.

b)

Local

racks

were

installed,

electrical

conduits

were

installed,

and transmitter

and trip units were installed.

However,

most connecting

cables

had not

been

pulled into

the

conduit.

Relays

and

terminal

blocks

had

not

been

installed in local racks.

c)

Control

room

manual

initiation switches,

indicators,

and

alarm window were not installed.

However, the modification

had

been reflected

on the simulator control panel.

d)

ARI function

had

not

been

implemented

in

a procedure

or

training document.

3)

The

RPT installation

was not complete

and the

system

had

not

been declared

operable')

The recirculation

pump trip related to "end of cycle" trip

function

was available

either automatically

or manually

from the control board.

o

16

b)

Modification related to

ATWS rule requirements

had not been

completed.

It was in the

same status

as the ARI system.

b.

Plant Specific Design Requirement

Inspection

The

plant

specific

design

areas

reviewed

and

the

inspection

results

are discussed

below:

Objective

Examine

vendor

documentation

to

verify

that

adequate

ha~rd are/component

diversity

exists

between

the

ARI/RPT

equipinent

and the,exTstsng

reactor protection

system

equipment.

~"P.h~'ically inspect

the ARI/RPT system

and

RPS cabinet

equipment

to

further

confirm

that

the

required

hardware/component

diversity exists.

Results

2)

Through review of the documentation

in the modification package,

the inspector determined

that the

ARI/RPT systems

used

Agastat

GP series

relays.

The

same

type of relays

were also

used for

the

Analog trip unit actuation

circuits.

The

ARI

vent

valve

used

ASCO solenoid

valves

(Part

No.

ASCO

THC8316E36,

THC8210878).

The

same

type of

ASCO valves

were

used for the

backup

scram

vent valve.

The

Rosemount

ATTU were

used for

both the

and

the

ARI/RPT system.

It appeared

that

some=

components

in the

ARI/RPT system

were not diverse

from the

component.

This item is opens

Objective

Review

support

documentation

(electrical

schematics,

power

distribution drawings,'tc.)

to confirm that the logic power

supplies

selected

for the

ARI/RPT logic circuits

provide

the

required

independence/separation

from that associated

with the

RPS in accordance

with the

ATWS requirements.

Physically

inspect

the

ARI/RPT logic

power

supply

wiring,

including

power

cables

entering

the

associated

cabinets

to

verify the

independent/separate

power

source

to

the

ARI/RPT

system.

Results

Through review of the documentation

of the modification package,

the inspector determined that the

RPS logic and instruments

were

powered

from the

MG set

AC power panel,

while the ARI/RPT

system

logic

and

instruments

were

powered

from the

Class

1E

250V

DC panel.

The

design

satisfied

the

power

independence

requirement.

ne

I

e

3)

Objecti ve

17

'I

Physically inspect

and trace

as appropriate

the

ARI/RPT input

and output wiring to verify the use of the reactor water level

and the reactor

pressure

instrumentation

for input signals

and

the

use of ARI/RPT output signals to actuate

the ARI valves

and

the

RPT breaker circuits.

Examine electrical

schematics

'to confirm this portion of the

design.

Results

The

and the ARI/RPT system

used

separate

sensors.

The logic

circuit for the

and

the logic for the

ARI/RPT system

were

located

in

separate

cabinets.

All the

cables

were

in

conduits.

The ARI/RPT circuits were in separate

conduits.

The

ARI/RPT system

was physically separated

from the

RPS.

Objective

Verify that the existing

RPS separation criteria continues

to be

met subsequent

to the

implementation

of the

ARI/RPT equipment.

This

should

include

a

description

of

the

existing

plant

separation criteria and

an inspection

of the

ARI/RPT wiring to

verify consistency.

Results

5)

The

inspector

reviewed

the existing plant separation

criteria

and

the

ARI/RPT

modification

package.

It

appeared

the

modification for the

ARI/RPT

system

wi 11

not violate

the

separation criteria.

Objecti ve

Review

how maintenance

will be performed with the reactor at

power

for

the

ARI/RPT

system.

Confirm that

maintenance

procedures

are

in

place.

Inspection

the

hardware

(control

switches,

alarms,

indication) in place which will allow for the

performance

of maintenance

while at

power.

Verify that

the

hardware

implemented

for maintenance

is consistent

with the

human-factors

guidelines

in effect at the plant.

Inspect

the

bypass

controls

and verify that

no

jumpers

or lifting lead

methods

are being utilized for bypassing.

Resul ts

The

ARI/RPT modification

had not

been

completed.

No procedure

was available for review.

This issue is open.

18

Objective

Inspect

the existing

manual

control

room controls

associated

with the

ARI/RPT system.

Review the

emergency

procedures for-

an

ATWS event.

Results

The

hardware

had

not

been installed.

No emergency

procedure

was available for an

ATWS related event.

This issue is open.

Objecti ve

Verify that

preoperational

testing

was

accomplished

for the

ARI/RPT prior to plant startup

subsequent

to the ARI/RPT system

implementation.

Review the planned at-power testing;:procedures,

and

the

hardware

design

(with supporting

schematics)

with

respect

to the capability to test

ARI/RPT

system

during

both

power operation

and while the plant is shut

down.

Examine the

restriction for allowed out-of-service times, during testing

and

for

an

inoperable

ARI/RPT.

Inspect

the

hardware

permanently

installed

as part of ARI/RPT to

accomplish

testing

including

control

room annunciation,

indication, controls,

and

bypasses.

Review the administrative test procedures

to verify that ARI/RPT

will

be

returned

to service

upon test

completion.

Observe

representative

test.

Results

The

ARI/RPT system

had not performed preoperational

test.

This

issue is open.

Objective

Review

the

circuitry

schematics

which

alloHs

for

the

completion of mitigating action

once

the

ARI/RPT function is

actuated.

Review electrical

schematics

as

necessary

to verify

this

phase

of the

design.

Examine

the

requRed

deliberate

operator

action

that

must

take

place

to

return

the

final

actuation

devices

to

normal

status

upon

completion

of the

required action.

Results

Once

the

ARI/RPT system initiated, it will go to completion of

mitigative action.

Oeliberate

operator

action

must take

place

to return the final actuation

devices

to normal status.

Objective

Verify that appropriate

operating

and maintenance

procedures

are

in place

and that personnel

had

been

sufficiently trained

to

assure

satisfactory

performance of-the installed ARI/RPT system.

19

Resul ts

No procedures

were available't

this time.'o training

was

provided to the operator

on the

ARI/RPT system.

This issue is

open.

10)

Objective

Verify that the actual

ARI function time test

was performed,

and

the test results

met the design

requirement that the control rod

motion will begin less

than

15 seconds after ARI initiation and

will be completed within 25 seconds.

Results

The

ARI function

time testing

had

not

been

performed.

This

issue is open.

11)

Objective

Examine

documentation

(plant

procedures,

calculation

data

sheets)

to verify sufficient

Boron to achieve

Hot

Shutdown.

Verify that

operators

are

trained

tn

apply

standby

liquid

control

system.

Results

The

SLCS has

been declared operational.

The Boron concentration

calculation

method

was

verified.

The

operators

had

been

trained to apply

SLCS by emergency

operating instructions

EOI-1

and

2-01-63.

Surveillance

Instructions

had

been

i ssued

for

quarterly

system functional test

and

18 months

operating

cycle

functional test.

c.

Conclusion

Since

the electrical

installation

had

not

been

completed

for the

ARI/RPT system,

this

inspection

did not

accomplish

the

original

objective.

A follow-up inspection

is .required after the

licensee

declares

the

ARI/RPT

system

operational.

This

is

. identified

as

IFI 50-259,

50-260,

50-296/89-17-05,

Followup on

ATMS Modifications.

The following items

need re-inspection:

1)

Component Diversity"

5)

Maintenance

Procedure

6)

Manual Control in the Control

Room

7)

Preoperational

Test

9)

Procedure/Training

10)

ARI Function

Time Test

A Generic Letter is being prepared

by the

NRR to require the licensee

to

certify

that

the

ARI/RPT

system

satisfies

the

diversity

requirements.

20

8.

Review of EA Audit BFT 89901 - Design

Change

Control

Prior to this

NRC inspection,

TVA's Engineering

Assurance

group performed

a technical

audit of the transitional

design

change

process.

This audit

resulted

in

seven

CAQRs

which

documented

specific deficiencies

in the

implementation

of

the

transitional

program.

As

a result

of

these

deficiencies

the

Browns

Ferry Site Director

suspended

the

issuance

of

modification packages

until temporary corrective action

and

a review plan

to determine

extent of the condition could 'be developed.

The inspector

will review the

licensee's

corrective

action

in

a future

inspection.

This item is identified as unresolved

item 259,260,296/89-17-06,

Followup

of Licensee's

Corrective Action for EA Audit, BFT 89901.

9.

Exit Interview

The inspector

scope

and findings were

summarized

on

May 26,

1989, with

those

persons

indicated

in paragraph

1.

The

inspectors

described

the

areas

inspected

and

discussed

in detail

the

inspection

results

listed

below.

The licensee

did not identify as proprietary" any of the material

provided ,to

or

reviewed

by

the

inspectors

during this

inspection.

Dissenting

comments

were not received

from the licensee.

Item Number

Descri tion and Reference

259,260,296/89-17-01

Violation

-

Failure

to

Comply

With

the

Requirements

10 CFR 50.59,

Paragraph

2.b

259,260,296/89-17-02

Violation

"

Failure

to

Properly

Implement

Procedures

as

Required

by TS,

Paragraphs

2

and

3

259,260,296/89-17-03

Licensee

identified

violation

-

Inadequate

Thermal Overload Calculations,

Paragraph

2.d

259,260,296/89-17-04

259,260,296/89-17-05

259,260,296/89-17-06

IFI

Changes

That

Require

FSAR

Update,

Paragraph

6

IFI

-

Fol 1 owup

on

ATWS

Modificati ons,

Paragraph

7

URI -

Followup of Licensee's

Corrective Action

for

EA Audit, BFT 89901,

Paragraph

8

10.

Acronyms and Initialisms

ANI

ANSI

ARI

ATTY

Authorized Nuclear Inspector

American National

Standards

Institute

Alternate

Rod Injection

Analog Transmitter Trip Unit

21

ATWS

BFN

CAQR

CFR

DCN

DBVP

FCR

F-DCN

FSAR

GE

H-DCN

HPCI

IFI

ISEG

NE

NEP

PMEN

SDSP

TACF

TSD

USQD

W-DCN

WP

Anticipated Transient Without Scram

Browns Ferry Nuclear

Condition Adverse to Quality Report

. Code of Federal

Regulations

Design

Change Authorization

Design

Change

Document

Design

Change Notice

Design

Change

Request

Division Nuclear Engineering

Design Baseline Verification Program

Engineering

Assurance

Engineering

Change Notice

Field Change

Request

Field Initiated - Design

Change Notice

Final Safety Analysis Report

General Electric

Plant Initiated Design

Change

Notice

High Pressure

Coolant Injection

Inspection

Followup Item

Independent

Safety Engineering

Group

Nuclear Engineering

Procedure

Notice of Violation

Nuclear Performance

Plan

Project

Change Notice

Project Instruction

Partial Modification Evaluation Notice

Quality Assurance

Quality Control

Reactor

Core Isolation Cooling

Residual

Heat

Removal

Recirculation

Pump Trip

Reactive Protection

System

Return to Service

Safety Evaluation

Report