ML18033B015
| ML18033B015 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 10/20/1989 |
| From: | Little W, Patterson C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18033B012 | List: |
| References | |
| 50-259-89-47, 50-260-89-47, 50-296-89-47, NUDOCS 8911030133 | |
| Download: ML18033B015 (23) | |
See also: IR 05000259/1989047
Text
1 P,S REOIj
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Cy
A,
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323
Report Nos.:
50-259/89-47
50-260/89-47,
and 50-296/89-47
Licensee:
Valley Authority
6N 38A Lookout Place
1101 Market Street
Chattanooga,
TN
37402-2801
Docket Nos.:
50-,259,
50-260
and 50-296
License Nos.:
and
Facility Name:
Browns Ferry 1, 2,
and
3
Inspection
Conducted:
September
25-29,
1989
Inspecto
C. A.
a
son,
Team Leader
D te Si
ned
Team
mbers:
M. Marini
D. Nelson
Approved by
W.
S. Lit
e, Section Chief
Inspection
Programs
TVA Projects Division
Da
e Signed
SUMMARY
Scope:
This special
announced
inspection of Technical Specification
(TS) was conducted
to review the disposition of a historical list of TS problems,
TVA's task force
audit of TS,
a comparison
of system
design
basis
to
TS surveillance
require-
ments,
and
a corn'parison
of TS to the plant configuration.
Results:
Disposition of a historical list of TS problems
was nearly complete with most
of the restart
TS changes
completed.
Action taken to resolve
these
issues
was
good.
The disposition
of the
TS task
force
recommendations
needed
attention
to
resolve
the restart
TS issues
in
a timely manner.
Review by the
RRB using the
Restart Criteria
had
not
begun
during the week of the inspection.
Thirty-six
items were awaiting
PORC review.
Since the licensee
was still in the
process
9110301.
.S5'1021
PDFl
ADOCK 05I.I00259
9
of resolving
these
issues,
the
inspection
team
could
not confirm that all
restart
TS changes
were identified.
Review of the
TS amendment
concerning
(item
061)
indicate
the
quality
of
reviews
could
be
improved,
paragraph
3.
A violation with three
examples
concerning
document
control of
a technical
specification
amendment
and
updating controlled copies
of TS
was identified.
These
examples
resulted
from inattention
to detail
and were not an indication
of a programmatic
problem.
The examples
are in paragraphs
2 and 4.
Two
IFIs
were
identified:
one
related
to
cross-tie
operability
(paragraph
5),
and the other related to
a failure to implement
a
TS Task Force
recommendation
in making
a
TS change
(paragraph 3.a.).
REPORT DETAILS
1.
Persons
Contacted
Licensee
Employees:
0. Zeringue,
Site Director
G. Campbell,
Plant Manager
"R. Smith, Project Engineer
J. Hutton, Operations
Superintendent
"A. Sorrell, Maintenance
Superintendent
G. Turner, Site Quality Assurance
Manager
- P. Carier, Site Licensing Manager
"P. Salas,
Acting Compliance Supervisor
"J. Corey, Site Radi.ological
Control Superintendent
R. Tuttle, Site Security Manager
Other
licensee
employees
or
contractors
contacted
included
licensed
reactor operators,
auxiliary operators,
craftsmen,
technicians,
and public
safety officers;
and quality assurance,
design,
and engineering
personnel.
NRC Attendees
"M. Little, Section Chief
- D. Carpenter,
Site Manager
"C. Patterson,
Restart
Coordinator
- E. Christnot,
Resident
Inspector
- M. Bearden,
Resident
Inspector
- Attended exit interview
Acronyms used throughout this report are listed in the last paragraph.
2.
Historical List of TS Problems
During the period of time that
BFNP has
been
shut down,
a number of items
have
been identified which necessitated
revisions
or upgrades
to the
TS.
These
items were identified in a variety of ways, including
NRC Inspection
Reports,
LERs, Generic Letters,
and
10 CFR 50, Appendix
R.
As
a result of
several
meetings
and
conversations
between
licensee
personnel
and
NRC
staff,
a list of 54 such items
was compiled in March
1987.
Of these,
31
were determined to require submittal
and approval of the affected
TS prior
to restart of Unit 2.
The
team
reviewed
these
31 restart
items
and
two
nonrestart
items to determine
whether the affected
TS had been
revised
and
whether the revision adequately
addressed
the identified concern.
Below
is
an
item by item description identified by the
item number
from the
March,
1987 list of
TS revisions.
Unless
otherwise
noted,
the
team's
review found that the licensee's
actions
were appropriate
and acceptable.
~ >
(Note:
When
a series of three
amendment
numbers is listed, they represent
the applicable
amendments
for Unit 1, Unit 2,
and Unit 3, respectively)
ITEM 2)
Amendment
134,
130,
105, (7-17-87) revised
TS Table 3.1.A to
delete
the applicability of alternate
action 1.B. from APRM high
flux and
inoperative trip functions.
This
alternate
'action
could
have
erroneously
allowed the reactor
to
be placed
in
an
operational
condition where trip functions
were required to
be
but were not.
ITEM 3)
ITEM 5)
ITEM 6)
ITEM Ba)
Amendment. 133,
129,
104 (5-13-87) revised
TS
LCO 3.3.B. 3 to
clarify RWM operability
requirements.
Amendment
143,
139,
114 (2-12-88) revised
TS
LCOs 3.7.B.2.b,
3.7.E.2.b,
and
3.7.F.2.b
to
revise
the
methodology
and
acceptance
criteria for laboratory analysis
to verify charcoal
absorption
efficiency for SBGT,
CREV,
and
Purge
systems,
as the previous methodology
was outdated.
Amendment
138,
134,
109 (9-11-87) revised
TS 6.0 to update
and
clarify minimum plant staffing levels
and onsite organizations
Amendment
158,
154,
129 (11-18-88) revised
Note 01 of TS
Definition 1.0
~ M to allow the
mode
switch to
be
temporarily
placed
in any position in order
to perform required tests
or
maintenance
when the reactor is in the
shutdown or refuel
modes.
ITEM 8b)
Amendment
158,
154,
129 (11-18-88) revised
TS Definitions 1.0.S
and
1.0.M to link more directly with mode
switch position
and
make
them applicable
only
when
there is fuel in the reactor
vessel.
ITEM 8c)
Amendment
158,
154,
129 (11-18-88) revised
TS Definition 1.0.J
to more clearly define the term startup.
ITEM 8d)
Amendment
158,
154,
129 (11-18-88) revised
TS Definition 1.0.K
to clarify the
term
COLD
SHUTDOWN
CONDITION to include
both
shutdown
and refuel
modes.
ITEM 9)
Amendment
135,
131,
106 (8-20-87) revised
TS Definition 1.0.C.2
to clarify its applicability during Cold Shutdown or Refueling.
The
team
determined
this clarification to
be
appropriate.
However,
an
additional
concern
was
identified.
Although
this
revision
was
approved
in
1987,
page
1.0-2
currently
located
in controlled
copies
of the
TS did not reflect
the
approved
and
issued
change.
Information
provided
by
the
licensee
revealed
that,
at the time the
change
was
approved,
the correct wording was incorporated into the controlled copies
of the
TS and
had not been
incorporated into the
TS master
copy.
In February
1989,
TS Amendment
158,
157,
129 revised different
information contained
on the
same
page.
Upon approval,
the
new
changes
were
made to the
TS master
copy
and distributed to the
controlled copies
of the
TS.
This resulted
in inadvertent
use
of
outdated
wording
in
TS
Definition
1.0.C.2.
This
is
considered
a failure to maintain
adequate
control of changes
to
approved
documents,
as
required
by
Appendix
B
Criterion VI, Document Control,
as committed to by
NQAH Part I,
Section 2.6,
as
implemented
by
SDSP
2. 12,
and is identified
as
example
one
of Violation
259,
260,
296/89-47-01,
Document
Control of TS.
ITEM 10)
ITEM 12)
This item involved confusing information in TS 3/4.5.C
pertaining to the operability requirements
for RHRSW pumps.
The
licensee
had
submitted
proposed clarification of these require-
ments in TS-242,
which is currently under
review by
NRC staff.
This item involved incorrect information regarding
HPFPS
stations
3.A, 3.B,
and 3.C in
TS Table
3. 11.A.
Amendment
162,
159,
133 (12-12-88)
encompassed
a general
rewrite of TS 3/4.11
to eliminate ambiguity and bring
BFNP into conformance with
and other current industry practices.
ITEM 13)
This item involved the discovery that, although
required
the Safety Engineer to perform
a monthly inspection of
plant fire protection
systems,
TS 6.0 did not provide for
a
Safety
Engineer
in the site organization.
The administrative
and
technical
changes
referenced
in
items
6
and
12,
above,
provide
adequate
clarification
of
this
requirement
and
responsibility.
ITEM 14)
This item involved the observation
that
TS 6.0 did not
accurately
describe
the
current
onsite
organization.
The
administrative
changes
referenced
in item 6,
above,
adequately
resolve this observation.
ITEM 15)
Amendment
127,
122,
98 (2-26-86) provided for the establishment
of
a
procedure
to limit the
amount
of overtime
worked
by
personnel
performing
safety
related
functions,
in
accordance
with GL 82-12.
ITEM 17)
Amendment
139,
135,
110 (1-25-88) revised
TS 6.8.3.1 to clarify.
the access
requirements
to high radiation
areas
where the
dose
rate is greater
than
100 mr/hr but less
than
or equal to 1000
mr/hr.
ITEM 18)
This item involved the evaluation of TS Table 3.7.A, Primary
Containment
Isolation
Valves,
for
possible
additions
or
corrections.
The
licensee
had
completed
their
review
and'ubmitted
proposed
changes
via
TS-251
(8-2-88)
and
TS-251,
supplement
0'1 (7-13-89).
These
pro'posed
changes
are currently
under review by
NRC staff.
ITEM 22)
Amendment
140,
136, ill (1-19-88) revised
TS Table 3.2.A to
change
the trip level setting for SBGT Relative Humidity Heaters
to 2000 cfm to prevent
damage to the
SBGT filter banks.
ITEM 27)
ITEM 31)
Amendment
145,
141,
116 (2-29-88) revised
TS Definition
1.0.0;3,
TS 3.7.D. 1,
and
TS 3.7.D.2 in order to
make
Primary
Containment Integrity definition, operability requirements,
and
action statement
consistent with each other.
Amendment
150,
146,
121 (7-5-88) revised
TS
SRs 4.7.E. 1,
4.7.E.3,
4.7.F. 1, 4.9.A.2.c,
and
4. 11.A.5 to replace
the words
"not to exceed" with the words "at least
once every" in order to
provide
consistency
with surveillance
interval
requirements
contained in TS Definition 1.0.LL.
4
ITEM 36)'mendment
155,
151,
126 (9-23-88)
added
HPCI and
functions to TS Tables 3.2.B and 4.2.B and to the
notes for TS
Table 3.7.A to complete
the lists of Groups
4 and
5 isolation
functions.
ITEM 37)
Amendment
147,
143,
118 (3-3-88) provided several
corrections
as follows:
Clarified Note 7.d for Table 3.2.C, pertaining to Rod Block
Monitor operability
Revised
TS 2. 1.A. l.d to show
SR 4.5.L as the correct
SR for
Deleted
Note
14
from Table
4.2.A,
as it is
no
longer
applicable to any instruments
in the table
Revised
TS 3.6.H to
show
SI 4.6.H-1
and 4.6 AH-2 as
being
the SIs that list safety related
One additional
concern originally included within the
scope of
this
item
involved
confusing
notes
pertaining
to
Primary
Containment
and
Reactor
Building
Isolation
Instrumentation.
Note ll of Table 3.2.A stated that
an instrument
channel
may be
placed in an inoperable
status for up to four hours for required
surveillance,
while Note
22 of Table 4.2.A stated that certain
RMS channels
may be administratively bypassed for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />
for functional testing
and calibration.
The licensee
did not
feel
a
TS clarification change
was desirable
at this time, since
an
upcoming
equipment modification to these
RMS channels will
ITEM 38)
ITEM 39)
ITEM 43)
ITEM 44)
necessitate
TS
changes
and the confusion
concerning
the
notes
can
be
resolved
at that
time.
This
concern
was originally
identified
by
NRC in
IR 86-05
as
IFI 86-05-07.
Additional
followup information
regarding
this IFI is contained
in
IR
89-19,
which identified this
as
an
issue
requiring resolution
prior to Unit 2 restart.
Amendment
137,
133,
108 (8-26-87) revised the drywell leakage
monitoring
requirements
in
and
TS 3.6.C.2 to reflect the guidance
contained
in GL 84-11.
Unit 2 Amendment
164 (5-16-89) revised
TS 3/4.1.B to add
'urveillance
requirements
and
correct
the
overvoltage,
and underfrequency trip settings for the
RPS power
monitoring system.
Amendment
141,
137,
112 (2-3-88) revised
TS 4.7.A.2 and
TS 4.7.A.4 to correct
containment
leak rate
testing
requirements
and delete the option of'erforming
a reduced
pressure
test,
as
such
a test could yield nonconservative
results.
Amendment
142,
138,
113 (2-12-88) revised
TS 3.7.A.5 and
SR 4.7.A.5.c to limit the use of air for pneumatic
control inside
containment,
to reflect the guidance
contained
in GL 84-09.
ITEM 45)
Amendment
154,
150,
125 (9-2-88) revised
TS 3/4.4 to meet
shutdown requirements
for future fuel cycles,
and to comply with
ATWS requirements
of 10 CFR 50.62.
ITEM 46)
Amendment
153,
149,
124 (8-19-88) revised
TS 3/4.5, 3/4.9,
and
6.9.7 to improve
DG reliability by decreasing
the
number of fast
diesel starts,
to reflect the guidance
contained
in GL 84-15.
ITEM 47)
ITEM 48)
ITEM 50)
Unit 2 Amendment
162 (1-30-89) revised
TS Tables 3.2.B and
4.2.B to change
the trip setpoint for the existing
ADS timer,
and
add
surveillance
and
setpoint
requirements
for
a
high
drywell
bypass
timer,
in
accordance
with
Item II.K.3.18.
I
This item involved
a proposed
TS change
to demonstrate
that ARI
equipment
can satisfy
the reliability requirements
of the
Rule,
Conversations
with licensee
personnel
and
NRC staff determined that such
a change
is not required at this
time.
NRC staff will provide
guidance
on
a
generic
basis
regarding
TS requirements
for ARI at
a future date.
Unit 2 Amendment
172 (9-13-89)
updated
the Unit 2 TS to reflect
the Reactor
Core Operating Limits for Cycle 6.
ITEM 52)
Amendment
152,
148,
123 (8-8-88) .revised
TS Table 3.7.A to
increase
the stroke time for LPCI injection valves
FCV-74-53 and
-67 from 30
seconds
to
40
seconds
due to valve motor operator
modi ficati on s requi red to meet
10 CFR 50. 49 criteri a.
ITEM 53)
Amendment
160,
157,
131 (11-28-88) revised
TS 1.1.C to delete
all references
to "top of active fuel" when measuring
reactor
water level,
and to describe all involved setpoints
as
"above
vessel
zero".
ITEM 54)
This item involves proposed
TS additions pertaining to testing
requirements
necessary
to
demonstrate
remote
shutdown
capability,
as required
by 10 CFR 50, Appendix
R.
The licensee
has
submitted its proposed
Appendix
R TS enhancements
via TS-.268
(4-14-89).
This
submittal
is currently
under
review
by
NRC
staff.
3.
TS Task Force'udit
To fulfill a commitment
made in
Fuel
Load Without Adequate
Neutron
Monitoring
Due
to
Inadequate
Safety
Review
of
Technical
Specification
Amendments,
an assessment
was 'conducted
of the
BFNP Unit 2
TS.
The
licensee
established
a
TS
assessment
team
consisting
of ten
members with nuclear
work experience
ranging
from
8 to
27 years.
The
final report was issued
March 31,
1989.
The
team
developed
four major objectives
to perform the
assessment.
A
summary of the four objectives
and the licensee's,conclusion
follows:
Objective
A was
an evaluation
of the effectiveness
of the
TS change
control
program.
The task
force
concluded
that
the
process
was
effective in identifying necessary
changes
to
TS
and
implementing
procedures.
Objective
B
was
to
evaluate
the
current
TS
interpretations
to
determine their compatibility with the
intent of
TS
requirements.
The task force concluded that the
TS interpretation
manual
contained
four nonconservative
interpretations
and
nine
outdated
interpreta-
tions.
CAgRs were written to track resolution of these deficiencies.
Objective
C was to provide confidence
that
TS accurately
reflected
plant design
basis criteria.
The task force concluded that the
TS
consistently
reflect
plant
design
criteria.
Of the
18
issues
identified none were determined
to be significant by the task force.
Objective
D
was
to provide confidence that
TS contained
essential
requirements
to
ensure
safe
plant
operation.
The
task
force
concluded
that
BFNP
TS
contained
essential
requirements,
however,
significant issues
were identified which when resolved
would enhance
the ability to safely operate
Unit 2.
Of 99 issues
identified,
two
were
recommended
for Unit
2 restart
TS
changes.
Eighty-three
of
the
issues
were
recommended
for restart
administrative controls
and
evaluation.
The remaining
14 issues
were categorized
as post-restar't
action items.
From the
four objectives the
18 items in
C and
99 items in
D were placed
into several
categories
of action
items.
Each
item was designated
by
a
letter and
number
as Cl, C2, or the appropriate
designation for the item.
After the
TS
task
force
performed
the audit
a
group of
BFNP plant
personnel
were
assembled
consisting
of
licensing
engineers,
system
engineers,
and operations
personnel
and others
to answer
the
items
and
prepare
the action item.
The .action in
some
cases
was the preparation
of
procedure
revision for submittal to
PORC.
Several
more restart
TS changes
were identified by the plant group.
The inspector
questioned
whether
the Restart Criteria in Volume
3 of the
NPP were
being
used
to evaluate
whether
an
item was
a restart
TS change
or post restart
change.
At the
end of the inspection
none of the
items
had
been
reviewed
by the
RRB.
Additionally, 'the
RRB review would
come
after
a
PORC review of
some
items.
There
were
an
estimated
35
items
awaiting
approval.
Included
in this
were
10 items designated
as
post restart
TS changes.
The inspector
concluded that the licensee
was still in the decision
making
stage
for determination
of whether
items were restart
or not.
This
was
also supported
by the
TS task force recommendation
of 2 restart
TS changes
compared
to
a total of
6 after
the plant staff review.
Considerable
variation
of the
numbers
could result
following
review
and
RRB
review, with new items designated
as post restart
TS changes.
The inspector
determined this portion of the inspection
could not
be
a
confirmatory one
since
the actions
to address
the task force
items
were
still being reviewed.
The inspection
could only be
somewhat of a quality
check
on the items in progress.
The inspector briefly reviewed
the entire list of findings.
In general,
the
inspector
thought
the
task
force
items
were well thought out
and
conservative reflecting the experience
level of the task force.
Accordingly the
inspector
reviewed
in detail
a
sampling
of the
items
identified by the
TS task force.
The first two items
(D8 and
D61) were
identified by the
TS task force
as restart
items.
A discussion
of the
inspection of these
items
and other items follows:
a.
Audit Item
D 61
The task force
recommend
a
TS change prior to restart for TS 3.7.F,
Purge
Vent and
Exhaust.
The present
TS states
that primary containment
shall
be normally vented
and purged through
the
primary
purge
system.
The
may
be
used
when the primary
containment
purge
system is inoperable.
The task force concern
was
that for normal venting,
during
power operating conditions the
was the
preferred
path
and
the technical
specification'hould
be
amended
accordingly.
The inspector. reviewed
the
BFNP
TS submittal
dated
August 4,
1989,
and
concluded
that
the
submittal
did not
address
the
task
force
concern.
No statement
was
added to allow the preferred
vent path.
The
second
sentence
of 3.7.F. 1 concerning
using
when
primary
containment
purge
is
was
eliminated
from
the
LCO
statement.
This part of the
LCO statement
was
moved to the
BASES.
This represents
a fundamental
mi sunderstanding
of
LCO statements
and
TS BASES.
10 .CFR 50.36 states
the
BASES are not part of TS.
The
statement
added
to the
BASES would
have better
described
the
operation
of the
purge
system.
The
statement
was that the primary
containment
purge
and ventilation system
may be
used
as part of the
inerting/deinerting
process
for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following placing the
mode
switch in the
RUN position or 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior to shutdown.
This is
the
purpose
of the
purge
system.
During
power
operation,
the
primary containment is isolated
by two isolation valves in series.
The licensee
decided
to revise
the submittal.
Inspector
Follow-up
Item
259,
260,
296/89-47-03
is
designated
to follow-up
on this
action.
b.
Audit Item
D8
The
task
force
recommended
a
TS
change
prior to restart
for
TS 3.2.A-1.0,
concerning
isolation of shutdown cooling.
BFNP TS action
1.0 in Tables 3.2.A notes that for inoperable isolation function that
shutdown. cooling
should
be
isolated.
The
task
force felt that
shutdown cooling should
be allowed to remain
in service
even if the
automatic
isolation capability
becomes
Other 'compensa-
ting action
could
be acceptable
and at
a
minimum
a" time should
be
allowed to establish alternate
decay
heat
removal capability prior to
isolation.
'I
The inspector
concurs with a
TS change
for establishing
an alternate
decay
heat
removal
prior to isolation.
In discussion
with the
licensee
consideration
was
being given to allowing six hours.
The
inspector
noted
that
requires
the
affected
system
isolation
valves
be closed
and locked within one hour and declare
the affected
system
The
one
hour time period
seemed
adequate
for
establishing
an alternate
cooling
method.
Any deviation
from
regarding this matter should
be fully explained
in TVA's submittal.
The licensee
stated
the time difference would be reviewed.
Audit Item C8
The task
force identified the
requirements
of 3. 1.A.
do not
require
the
IRM inoperative tr ip or the
APRM inoperative tr ip while
in shutdown.
These functions should
be required
OPERABLE anytime the
high flux trip is required.
The table
also
does
not require
high in shutdown,
however,
note
7 applied to the
REFUEL heading
seems
to indicate it should
be applicable.
The task force
recommended
that
controls
be established
prior to restart followed by TS changes.
The
plant staff
determined
this
item
as
acceptable
and correct
with no administrative
controls
needed
or
TS changes
required.
The
basis for this was stated that the exi sti ng plant design
and hardware
interlocks
make it impossible
for any control
rod to
be
at
any
position
other
than fully inserted
when
the
mode
switch is
in
shutdown.
Note
7 applied to
REFUEL only.
The inspector
reviewed
note
7,
and the table.
Note
7 was beside
the
column heading of the Table 3. 1
~ A for REFUEL only.
However,
Note
7
states
the following:
When
the
reactor
is
subcritical
and
the
reactor
water
temperature
is
less
212
degrees
F,
only the
following trip
functions
need to be operable:
A.
Mode switch in
SHUTDOWN
B.
C.
High flux IRM
D.
Scram discharge
volume level
E.
APRM 15 percent
F.
low pressure
The
inspector
reviewed
and
found that the
RPS trip functions
were
required
for operating
mode
5
which is
both
Shutdown
or
Refuel.
Furthermore
in
BFNP
TS Section 1.0 for definitions it was
noted that definition M.,
Mode of Operation,
for
shutdown
mode
and
refuel
mode
has
a footnote
(1).
This footnote
allows
the
mode
switch to
be placed
in any position to
perform required
tests
or
maintenance
authorized
by the shift operations
supervisor,
provided
that the control
rods
are verified to remain fully inserted
by
a
second
licensed
operator
or other technically qualified
member
of
the unit technical staff.
Since
the
function of
is
to protect
the
core,
these trip
functions
might
be
applicable
in
the
shutdown
mode
also.
The
inspector
has
concern
with the
task
force finding
and
should
be
reviewed further prior to restart.
10
Also,
the
inspector
was
concerned
that
the
plant staff did not
evaluate
the difference
between
from
a
standpoint
that
more
protection
might be
needed for. the reactor.
The evaluation
was .only
from the standpoint that the existing controls were justified.
The licensee
stated this item would receive further review.
d. 'udit Item D39
The task force identified that the value of "tau" which is
a factor
to account for scram
response
time in the calculation of the minimum
critical power ratio
should
be administratively controlled
as
equal
to
one until
time
measurements
and
"tau" calculations
are
completed
at the beginning of each cycle.
TS 4.3.C requires
time testing
be
completed prior to exceeding
40K. power after
each
refueling outage.
A TS change is to be submitted after restart.
TVA agreed
to the administrative
controls prior to restart
and to
.
keep the controls in effect until
a
TS
a change
was
made.
BFNP, TS 4.5.k.2.a
requires "tau" equal
to 0.0 prior to initial scram
time measurements
for the cycle.
in surveillance
requirement
4.2.3 states
"tau" should
be
equal
to 1.0.
If BFNP implements
the
administrative controls,
they will be in violation of BFNP T.S.
The
inspector
concluded
that
as
a conservative
approach,
and to
be in
compliance with TS, the value of "tau" should
be changed.
The
licensee
agreed
that
to get "tau"
equal
to
1.0
would
be
a
noncompliance
item and that the surveillance
requirement
would remain
at
0.0 until the
TS
was
changed.
Administrative controls
would
review
a calculation
using 1.0 until the
TS was updated.
e.
Comparison of BFNP to Standard
TS
The licensee's
audit included
a comparison
of BFN TS to
STS for BMRs.
Recognizing
numerous
minor differences,
the
licensee
established
an
undefined
level
of significance
for
documenting
differences.
The
inspector
selected
one
system,
SLC,
and
conducted
an
independent
comparison
between
BFNP TS and
STS in order to determine
the depth of
comparison
conducted
by the
licensee.
The
following differences
noted
by the inspector
were not documented
by the licensee.
Also,
only differences
where the
BFN TS are less conservative
than
STS are
identified:
Pump Operability:
Verified by BFN TS 4.4.A. 1 quarterly
vs
STS 4. 1.5.b. 1 monthly.
System Valve Lineup:
Not verified by
BFN /TS vs
4. 1. 5.b. 4 monthly.
11
Explosive Charge:
Continuity not verified by BFN TS vs
4. 1.5.b.2
monthly.
Replacement
required to be
no older than
5 years
by
TS 4.4.A.2.c
vs
STS 4.1.5.c.l
required
to
be
from
same
manufactured
batch
as
one tested.
Infrequent Surveillances:
Once per cycle,
no operational
condi tion
speci fi ed
by
TS vs
4. 1.5.c
once per
18 months,
shutdown.
These difference
were discussed
with the licensee
as observations
and
do
not represent
a concern
about
the quality of the task force audit which
was good.
4.
TS Comparison to Plant Configuration
a
~
TS Tables
The
inspector
compared
selected
TS tables
of instrumentation
and
components
to actual plant configuration.
The tables
selected
were:
3.2.F
Surveillance
Instrumentation
3.7.A
Primary Containment Isolation Valves
3. 11.A
Fire Detection Instrumentation
3. 11.B
Spray/Sprinkler
Systems
3. 11.C
Hose Stations
Information
contained
in the
tables
was verified,
on
a
sampling
basis,
to
be consistent
with actual
plant configuration.
Included
was verification of nomenclature,
location, function,
and in the case
of instrumentation,
the parameter
measured
and type of indication and
range.
A typographical
error
was
identified
in
Table
3.2.F,
Surveillance
Instrumentation.
Drywell
Temperature
Indicator
TI-64-52AB
was
listed
with
other
instrumentation
for
Drywell
Pressure.
The licensee
acknowledged
this error
and stated
that it
would be corrected
in a future
TS amendment.
No safety significance
is connected
with this error.
Also
in
Table
3.2.F,
The
wide
range
Gaseous
Effluent Radiation
Monitor and Recorder
was incorrectly identified as Instrument
Number
RR-90-322A.
The correct identification is
RM-90-306
and
RR-90-360,
respectively
for
the
monitor
and
recorder.
The
licensee
had
previously identified this
discrepancy
and
produced
a
copy of
an
12
intended
TS revision to,correct the error.
This is
new instrumenta-
tion and is still in the, process of being installed.
b.
TS Comparison to
The- inspector verified that all references
to the
FSAR contained
in
TS Section 5.0, Major Design Features,
were consistent with the
FSAR.
No discrepancies
were identified.
C.
TS Controlled
Copy Review
The inspector
reviewed
two copies
of Unit 2
TS to ensure
that all
pages
were present
and
were of the appropriate
amendment.
The
two
copies
reviewed were
numbers
52 and
40 assigned
NRC Resident
Inspector's office and the Unit 2 control
room, respectively.
Pages
1. 1/2. 1-2 through
1. 1/2. 1-4 of copy
52 were of the incorrect
amendment.
The
pages
present
were considered
"Original", having
an
effective
date
of 3-19-87.
According
to
the
TS Effective
Page
Listing,
these
pages
should
have
an
Effective
Revision
Date
of
3-3-88,
reflecting
Amendment
No.
143.
This indicates
that these
pages
were not -properly revised
upon
Issuance
of Amendment
No.
143.
Numerous, other
pages
also affected
by Amendment
143 were properly
revised.
The
presence
of
superseded
pages
in copy
52
represents
example
two of the violation 259,
260,, 296/89-47-01,
discussed
in
paragraph
2 above.
Two copies of pages
3.7/4.7-15
and
16 (front and back of one sheet)
were present
in
TS copy
40 located in the Unit 2 control
room.
One
of these
pages
(3.7/4.7-16)
contained
a
licensee
added
annotation
adjacent
to
paragraph
4.7.c. l.a,
a
surveillance
requi rement
for
secondary
containment.
The
annotation
referred
to
CM-88-64-2-007.
This
CM identifies
a
known
in-leakage
source
from temporary air
compressors
that accounts for
a portion of the allowable
in-leakage
of 12,000 cfm.
Since
two copies of page 3/7/4 '-16 were present,
the
CM would not have
been identified if the non-annotated
page
had
been
used.
SDSP
12. 11,
"Special
Requirements
and
Compensatory
Measures,"
requires
that
when
TS
are
annotated
with
SRs
on
CMs,
that
the
annotated
pages
replace
the
existing
pages.
This
precludes
duplicated
pages,
and thus eliminates
the possibility of missing
a
or
SR.
The inspector verified that all other
pages
annotated
with
SRs or
CMs (two existed) in the control
room copy of Unit 2
TS were
not duplicated.
The inspector also verified that
no other
SRs or
existed ,that
should
be
annotated
in Unit
2
TS according
to the
requirements
in
SDSP
12. 11.
The presence
of two conflicting pages
in
the Unit 2 copy of TS represents
example three of Violation 259,
260,
296/89-47-01
discussed
in paragraph
2.
The inspector discussed
with
the licensee
the practice of annotating official copies
of
TS with
13
non-NRC
revi ewed
informati on,
whi ch presents
the
opportuni ty for
unauthorized
changes
to TS.
5.
System Design'asis
Comparison to TS Surveillance
Requirements
In order
to verify that
TS surveillance
requirements
accurately verify
system operability,
the inspector
compared
surveillance
requirement
flow
rates
for the
RHR system to the design basis flow rate requirements.
Table 6.4-1 lists minimum
RHR pump flow of 10,800
gpm
and
20,000
gpm for
one
and
two
pump operation,
respectively,
at
0 psid
between
the reactor
and drywell for adequate
ECCS response.
TS surveillance
4.5.B. 1 .requires
that
each
(RHR)
pump deliver 9000
gpm at
125 psig
and two pumps in
the
same
loop deliver
12,000
gpm at
250
psig.
The
licensee
provided
calculations that demonstrated
the surveillance
requi rement flow rates
are
conservative
in verifying
RHR operability with respect
to design
basis
flow rate requirements.
TS 3.5.B. 11
requires
that
the
RHR unit to unit
cross
connect
capability be operable
whenever irradiated fuel is in the reactor
and when
pressure
is
greater
than
atmospheric.
When
questioned
about
this
requirement
pertaining
to Unit
2 restart,
the licensee
stated
that the
Unit
1
RHR cross
connect would be utilized to meet the requirement.
It is
unclear what licensee
intentions are regarding Unit
1
RHR operability for
seismic,
environmental
qualification,
and fire protection
requirements.
Additionally,
the
NRC
has
questions
with
regard
to
satisfying
TS
surveillance
requirements
for Unit
1
RHR and control
room staffing for
Unit
1 with Unit
1
RHR required for Unit 2 operation.
These
concerns will
be tracked
as IFI 259,260,296/89-47-02,
Unit 1
RHR Cross-Tie Operability.
6.
- Exit Interview (30703)
The inspection
scope
and findings were
summarized
on
September
29,
1989
with
those
persons
indicated
in
paragraph
1 'above.
The
. inspectors
described
the
areas
inspected
and
discussed
in detail
the
inspection
findings listed below.
The licensee
did not identify as proprietary
any
of the material
provided
to or reviewed
by the inspectors
during this
inspection.
Dissenting
comments
were not received
from the licensee.
Item
259,
260, 296/89-47-01
Descri tion
VIO, Document Control of TS,
example
1 in
paragraph
2,
and
examples
2
and
3
in
paragraph
4.
259,
260,
296/89-47-02
IFI, Unit
1
RHR Cross-Tie Operability,
paragraph
5.
259,
260, 296/89-47-03
IFI, Failure of TS
Change
to
implement
Task Force
Recommendation,
paragraph
3.a.
14
7.
Acr onyms
BFNP
CAQR
CFR
GL
GPM
HPFPS
IFI
IR
LER
LCO
MR/HR
NRC
RRB
SDSP
,SLC
SR
SRs
TS
Automati c Depr essui izati on System
Average
Power
Range Monitor
Alternate
Rod Insertion
Anticipated Transient Without Scram
Browns Ferry Nuclear Plant
Boiling Water Reactor
Condition Adverse to Quality Report
Cubic Feet
Per Minute
Code of Federal
Regulations
Compensatory
Measure
Control
Room Emergency Ventilation
Diesel Generator
Final Safety Analysis
Repor t
Generic Letter
Gallon Per Minute
High Pressure
Coolant Injection
High Pressure
Fire Protection
System
Inspector
Followup Item
Inspection
Report
Intermediate
Range Monitor
Licensee
Event Report
Limiting Condition for Operation
Low Pressure
Coolant Injection
Millirems Per Hour
Nuclear Performance
Plan
Nuclear Regulatory
Commission
Nuclear Safety
Review Board
Plant Operations
Review Committee
Reactor
Core Isolation Cooling
Residual
Heat
Removal
Residual
Heat
Removal
Radiation Monitoring System
Reactor Protection
System
Restart
Review Board
Standby
Gas Treatment
System
Site Directors Standard
Practice
Surveillance Instruction
System
Surveillance
Requirements
Special
Requirements
Standard
Technical Specification
. Technical Specification
Valley Authority
Violation