ML18033B035

as well

as

other

safety related

equipment inoperable.

The licensee notified the

NRC of this event

by

a

10 CFR 50.72 4-hour

non-emergency

ENS report

on August 24,

1989.

This event

was reported in LER 259/89-23.

The

EECM pumps

are required to automatically start to supply cooling

water to the

DGs and other safety related

equipment.

The failure to

maintain automatic

EECW

pump initiation operable

made all eight

inoperable.

TS 3.9.C.l requires

that at least

two Unit 1 and

2

and their associated

4

kV shutdown

boards

be operable

whenever the

reactor is in a cold shutdown condition with irradiated fuel in the

reactor.

The fai lure to maintain the minimum number of operable

is

an apparent

violation of TS 3.9.C. 1 (VIO 259,

260, 296/89-43-01,

Failure

to Maintain the

Minimum Number of

DGs Operable

Due to

an

Inadequate

SI).

The licensee initiated an investigation

into this event

(RCA 89-66)

which determined that the SI was revised in 1976 to add jumpering of

the

EECW auto-start capability to reduce the

number of pump starts.

The investigation

also identified that the SI was reviewed

by

GE in

October,

1985,

as part of the Surveillance

Instruction

Review for

Unit Startup

(SIRUS) project; that the

was

reviewed

on several

occasions

since the

NPP SI upgrade

program began;

and that validation

walkdowns

were performed for the

SI in June,

1988,

and

May, 1989.

This SI

was validated in accordance

with SDSP 7.4, Procedure

Review,

on

May 16,

1989.

During power operation

since

1976 this

SI would

have resulted in other systems

such

as core spray being inoperable.

Another concern identified during the performance of this SI was the

adequacy

of the valve lineup

used in the SI.

This lineup connected

the discharge

of all 12 of the

EECW/RHRSW pumps to both

EECW service

and

RHRSW service.

Licensee

personnel

questioned

whether

the

resulting

flow would

meet

the

requirements

of

TS 3.5.C.7

which

requires

2

RHRSW pumps,

associated

with the selected

RHR pumps, to be

aligned for

RHR heat

exchanger

service

for each

reactor

vessel

containing

irradiated

fuel.

The licensee

was performing

a safety

evaluation

on this

question

at the

end of this inspection.

This

issue

is identified

as

Unresolved

Item 259,

260,

296/89-43-02,

Adequacy

of

RHRSW Flow During 0-SI-4. 2. B-67,

and will remain

open

pending

NRC review of the

safety evaluation.

This item must

be

resolved prior to Unit 2 restart.

On September

12,

1989,

the licensee initiated a

LRED to. address

the

acceptability of the frequency

used in sampling

DG fuel oil quality

at BFN,

Diesel fuel oil is supplied from an individual day tank (one

day supply)

and

a seven-day

tank for each of the eight

DGs.

TS 4.9,A. l.e requires

that

a

sample

of diesel

fuel

be

checked for

quality once

a month.

The

TS does

not specifically state that the

tank supplying

each

DG shall

be

sampled.

The licensee

interpreted

this to be monthly for each set of DGs, with the four DGs assigned

to

Units 1 and

2 (1A, 1B,

1C,

8 1D) as

one set

and the four DGs assigned

to Unit 3 (3A,

3B,

3C,

8

3D)

as the other set.

In accordance

with

this interpretation,

the licensee

was sampling

each set of seven-day

storage

tanks

on

a staggered

basis (i.e.

sampling

one seven-day

tank

for a Unit 1/2

DG and

one for'

Unit 3

DG each month).

Following

this sampling

frequency, it would take four months to complete

one

cycle of sampling for all of the

DGs.

This interpretation

does

not

meet the intent of the TS.

This event

was reported in

LER 259/89-26.

Procedure

0-SI-4.9.A. l.e,

Diesel

Generator

Fuel

Oil Analysis,

implements

the licensee's

interpreted

frequency for sampling

DG fuel

oil.

This SI has

been

reviewed

and

was validated

on June

6, 1989, in

accordance

with

SDSP 7.4.

The

scope of the SI states

that "Because

the

sets

(DG sets)

are

not considered

common,

a fuel oil quality

determination

must be performed independently for each set."

The fuel

used for immediate

operation of an individual

DG is contained in the

day tank

and

seven-day

tank assigned

to that

DG.

Each

DG should

be

considered

separately

since

sampling

one seven-day

tank verifies the

fuel quality only for its assigned

DG.

The frequency of sampling the

fuel oil supply of only two DGs per month does not meet the require-

ments of the

TS.

The failure to meet surveillance

requirements

for

sampling

the

quality of

DG fuel is

an

apparent

violation of

TS 4. 9.A. 1. e

(VIO 259,

260,

296/89-43-03;

Failure to Sample

DG Fuel

Oil per

TS Frequency).

C.

On

September

19,

1989,

the

licensee

identified that

compensatory

measures

for fire protection

which were taken

on June

28,

1989,

had

been

discontinued.

On June

28,

due to

a fire protection line leak

and problems with an isolation valve,

hose stations

on Unit 2 Reactor

Building elevations

565

U-R13 (2-26-878)

and

541

P-R14

(2-26-877)

were isolated.

A gated

wye connection

and additional fire hose were

installed

on

a

hose

station

on elevation

565

U-R9 (2-26-861) to

satisfy

TS

LCO 3. 11.E. l.a for compensatory

measures.

In accordance

with procedure

FPP-2,

Fire Protection-Attachments,

a Fire Protection

Equipment

and

Barrier

Penetration

Removal

From

Service

Permit

(Attachment

F no.89-553)

was processed

to implement these

measures.

Item

6

on the Attachment

F indicated that

a roving fire watch was

required

and

was

already

in place

per

a

separate

Attachment

F.

FPP-2,

Attachment

F,

step 6.4.3 requires

that

a fire watch

have

a

copy of the

Attachment

F form authorizing the fire watch in his

possession

while performing

those

duties.

However,

the required

roving fire watch did not identify that the compensatory

measures

had

been

removed.

On

September

9,

1989,

a equality

Monitoring

inspector identified that the gated

wye and

hose

were missing and,

therefore,

compensatory

measures

were

no longer in effect.

TS 3. 11.E. l,a requires

that when a required fire hose station is not

operable,

a

gated

wye

be

connected

to the nearest

operable

hose

station with sufficient hose to provide coverage for both areas.

The

failure to maintain

TS

LCO required

compensatory

measures

is

an

apparent violation (VIO 259,

260,

296/89-43-04,

Failure to Maintain

TS

LCO Compensatory

Measures for Inoperable Fire Hose Stations).

Three violations

were identified in this area.

These violations were

identified by the licensee

but they are not being issued

as

a

NCV because

of similar violations which have occurred in the the surveillance

program

during the past two years

(see

paragraph

6).

3.

Surveillance Observation

(61726)

During this inspection

period,

an

NRC inspector

observed

the performance

of procedure

1/2-SI-4.9.A. l.d(B), Diesel

Generator

B Annual

Inspection.

Licensee

personnel

were

knowledgeable

in the

requirements

of the

procedure.

During the performance,

nine non-intent procedure

changes

were

required

in order

to

complete

the

SI.

Several

of the

NICs involved

changing

the order of steps

in the procedure.

One section called for an

annunciator

check prior to closing the

DC control

power breaker for the

DG; however, with the breaker

open

and

no control

power to the annunciator

panel,

the steps

were meaningless.

This SI was being performed to satisfy the surveillance

requirements

of TS 4.9.A. 1.d

and

was also

used to validate

the

SI in accordance

with SDSP

7.4.

The

NRC inspector

considers

the large

number of NICs

needed

to

complete

the

as

excessive

since

the

had already

been through the

verification review.

Some of the

NICs would have

been identified if a

walkdown of the

had

been

performed prior to approval of the SI.

The

lack of a preliminary walkdown is

a weakness

in the

SI upgrade

program

which results in unnecessary

problems during the first run of an SI.

The

number of NICs being experienced

and the proper

use of NICs are of

concern

and will be reviewed further.

This is identified

as

Inspector

'ollow-up

Item 259,

260, 296/89-43-06,

Non-intent Changes

to Surveillance

Instructions.

No

violations

or

deviations

were

identified

in

the

Surveillance

Observation

area.

4.

Followup on Previous

Inspection

Items (92701)

(CLOSED)

URI 260/88-35-01:

Surveillance Testing Concerns.

This

URI involved four events

which resulted in inadvertent actuations

of

safety related

equipment

due to inadequate

SI procedures

and the failure

to follow SI procedures.

These

events

are

summarized

as follows:

1)

On

December

9,

1988,

while operators

were

performing

procedure

2-SI-4.2.8-45A (I),

RHR Logic System

Functional Test,

a step in the

procedure

required that the local

manual

stop button

be depressed.

However,

the operator

depressed

the

pump start button.

The

2D

pump started

and

ran for approximately five seconds.

This event

was

reported in LER 260/88-16.

2)

On

December

17,

1988,

during

the

performance

of procedure

O-SI-4.9.A. l.b-l, Unit 1/2

DG A Load Acceptance

Test,

a start of the

2D

pump occurred.

This occurred

because

of incorrect sequencing

of steps

in the procedure.

Steps

which initiate the logic to start

the

pump were performed prior to steps

to preclude

a start of the

pump.

This event

was reported in LER 259/88-49.

3)

On 'December

18,

1988,

during

the

performance

of procedure

O-SI-4.9.A. l.b-2, Unit 1/2

DG

8 Emergency

Load Acceptance

Test,

the

2C

Core

Spray

pump started.

During the test,

the wrong keylock

switch

was placed

in the test position contrary to steps

in the SI.

When the next procedure

step

was taken,

the

2C pump received

a start

signal

because

the logic was not inhibited by its test switch.

This

event

was reported in

LER 260/88-17.

4)

On

December

18,

1988,

during

the

performance

of

procedure

2-SI-4.2.C-3(G),

IRM Channel

C Calibration,

a technician installing a

SI required

jumper inadvertently grounded

the jumper'nd shorted out

a fuse

supplying

power to the

RPS

channel

2B

IRM detectors.

This

resulted

in a trip of RPS channel

2B (a half scram actuation).

This

event

was reported in

LER 260/88-18.

From discussions

with the licensee,

and further review of this item and

the associated

LERs,

the inspector

concluded that the event

summarized

in

item 4 above

was not caused

by inadequacies

in the SI or failure to follow

the SI.

The events

summarized

in items 1, 2,

and 3, however,

are

examples

of

an

apparent

violation of TS 6.8. l. 1.c for failure to maintain

and

implement

SI procedures

(VIO 260/89-43-05:

Failure

to Follow SIs

and

Inadequate

SIs).

URI 260/88-35-01 is closed.

One violation was identified during the

Followup of Previous

Inspection

Items.

Surveillance

Upgrade

Program

On

September

17,

1985,

the

NRC

issued

a request,

pursuant

to

10 CFR 50.54(f), that

TVA submit information including plans for correcting the

problems

at

BFN.

In response

to this

request,

TYA prepared

Nuclear

Performance

Plans

including

NPP Volume 3 which identified the root causes

of problems specifically related

to

BFN and defined plans for correcting

them.

One

of the

problems

at

BFN

concerned

surveillance

program

deficiences

which

had

resulted

in

numerous

NRC violations.

The root

causes

of the deficiencies

were attributed to unclear SIs and failure to

follow SIs.

The

NPP

Volume

3 committed to give management

attention to

the surveillance

program

and

implement

a

process

to verify procedure

adequacy prior to SI performance

for Unit 2 startup.

The SI review and

upgrade

process

was

implemented

to ensure that

TS requirements

are fully

met in SIs; that

are technically correct;

and that

can

be

performed

as written.

SDSP

7.4,

Procedure

Review,

establishes

the

methods

for the

review,

verification,

and validation of procedures,

including SIs, to ensure that

they

are technically

adequate

and

incorporate

appropriate

acceptance

criteria and quality requirements prior to approval.

Procedures

are given

a verification review

by

a qualified reviewer prior to approval

and

validated

after

approval

during

the first-time

performance

of the

procedure,

by simulation,

or by

a walk-through of the procedure

steps.

SDSP

7.4 was revised

on April 25,

1989,

to include

a procedure

review

checklist;

incorporate

industry

standards

for procedure

review;

and

combine all procedure

reviews into one comprehensive

procedure.

6.

Surveillance

Program

Review

NRC inspections

conducted

since

January,

1988, identified 15 violations,

including 22 examples,

related to deficiencies

in surveillance testing

and

implementation

of

TS

LCO compensatory

measures.

There

were

12

LERs

submitted

concerning

events

cited

in the violations.

There

were

17

additional

LERs submitted,

including

27 examples.

The

examples

include

those in the four apparent violations detailed in the above paragraphs

and

their associated

LERs.

The violations and additional

LERs included 11 examples of inadequate

SIs;

12 examples

of failure to follow SIs

by licensed operators,

maintenance

craftsmen,

and chemistry technicians;

3 examples

of the failure to meet

scheduled

TS surveillance

frequencies;

2

examples

of the failure to

perform

implemented

as

compensatory

actions;

and

21

examples

of

failure to

implement or maintain

compensatory

measures

required

by

TS

LCOs.

The violations and

LERs are

summarized

as follows:

a ~

Surveillance Instructions

And Requirements

1)

VIO 88-05-03:

Two Examples of Failure to Follow Procedures

and

a

Lack of Attention to Detail.

- This involved two examples of

failure to follow a SI.

2)

VIO 88-32-01:

Two Examples of Failure to Follow Procedures.

This included

one example of failure to follow a SI.

This event

was reported in LER 260/88-11.

3)

VIO 89-06-01:

Nine Examples of Failure to Follow Procedures

and

Four

Examples

of Inadequate

Procedures.

This

included four

examples

of failure to follow SIs

and

one

example

of

an

inadequate

SI.

4)

VIO 89-08-01:

Failure to Follow Procedure

by Not Removing

a

Jumper Installed

During an

IRM Surveillance.

This involved one

example of failure to follow a SI.

This event

was reported in

LER 260/89-03.

5)

VIO 89-08-02:

Failure

to

Perform

Meekly Surveillance

on

Shutdown

Board Batteries.

This involved one example

where

a SI

frequency

was

exceeded.

This

event

was

reported

in

LER 260/89-04.

6)

VIO 89-11-05:

Failure to Satisfy

TS 4.6.B. l.c.

This involved

one example of failure to perform compensatory

sampling required

by

TS surveillance

'requirement

4.6.B. 1.c for an

inoperable

continuous conductivity monitor.

This event was reported in LER

296/89"02.

7)

VIO 89-27-02:

Failure to Meet TS Requirements

for Operable

Loops.

This

involved

one

example

where

a SI frequency

was

exceeded.

This event

was reported in

LER 260/89-19.

VIO 89-33-03:

Failure

To Follow SI Procedure.

This involved

one example of failure to follow a SI.

NCV 89-35-03:

Missed

Results

in

a

TS Violation.

This

involved

one

example

where

a SI frequency

was

exceeded.

This

event

was reported in LER 260/88-19.

VIO 89-43-01:

Failure to Satisfy

TS Due to Inadequate

SI.

This

involved

one

example of an inadequate

SI (see

paragraph

2.a of

this report).

This event

was reported in

LER 259/89-23.

VIO 89-43-03:

Failure to Sample

DG Fuel Oil Per

TS Frequency.

This involved one example of an inadequate

SI (see

paragraph

2.b

of this report).

This event

was reported in LER 259/89-26.

VIO 89-43-05:

Failure to Follow SIs

and Inadequate

SIs.

This

included

two examples

of failure to follow SIs

and

one example

of an

inadequate

(see

par agraph

4 of this report).

These

events

were

reported

in

LERs

259/88-49,

260/88-16,

and

260/88-,17.

LER 259/88-08:

SGTS Relative

Humidity Heaters

Have

Not Been

Tested in Accordance

With TS Due to Inadequate

Procedures.

This

involved one example of an inadequate

SI.

LER 259/88-10:

Inadequate

Procedures

Cause

Two Cases

of Missed

Samples

That Were Required to Compensate

For Inoperable Effluent

Radiation Monitors.

This included

one example of an inadequate

SI.

LER 259/88-14:

Surveillance Testing of Liquid Radioactive

Waste

Discharge

Isolation

Valves

Incomplete

Due

to

Inadequate

Procedures.

This involved one example of an inadequate

SI.

LER 259/88-15:

Failure to Monitor Off-Gas Stack Effluents

Due

to Procedural

Inadequacy

and Personnel

Error.

This included

one

example of an inadequate

SI.

LER

259/88-35:

Procedural

Inadequacy

Causes

Unplanned

Initiation of Control

Room Emergency Ventilation.

This involved

two examples of inadequate

SIs.

LER 259/89-14:

Unplanned

DG Starts,

an

ESF Actuation,

Caused

by

Personnel

Error and Procedural

Inadequacy.

This included

one

example of an inadequate

SI.

LER 260/88-15:

A Missed Chemistry

Sample

Due to Personnel

Error

Results

in

a Violation of Technical

Specifications.

This

involved

one

example of the failure to maintain

compensatory

actions

required

by

TS surveillance

requirement

4. 10.C.2.b

when

the fuel pool cleanup

system

was inoperable.

20)

LER

260/89-21:

Technical

Speci ficati on Violation Caused

By

Personnel

Error.

This involved one example of failure to follow

an SI.

b.

TS

LCO Compensatory

Measures

VIO 89-11-01:

Failure to Satisfy

TS 3.2.A.

This involved one

example of failure to take compensatory

measures

required

by TS

LCO 3.2.A,

Table 3.2.A,

note

1.G for an inoperable ventilation

exhaust

radiation

monitor.

This

event

was

reported

in

LER 259/89-06.

2)

VIO 89-33-04:

Breach of Fire-Rated

Door.

This involved one

example of failure to implement

compensatory

measures

required

by TS

LCO 3. 11.G. l.a for inoperable fire rated assemblies.

3)

4)

5)

6)

7)

VIO 89-43-04:

Failure to Maintain TS Compensatory

Measures for

Inoperable

Fire

Hose Stations.

This involved one

example of

failure to maintain

compensatory

measures

required

by

TS

LCO

3. 11. E. 1. a for inoperable fire hose stations

(see

paragraph

2. c

of this report).

This will be reported in a future

LER.

LER 259/88-10:

Inadequate

Procedures

Cause

Two Cases of Missed

Samples

That Were Required to Compensate

for Inoperable Effluent

Radiation Monitors.

This included one example of the failure to

maintain compensatory

measures

required

by TS LC0,3.2.D.2 for an

inoperable

RCW effluent radiation monitor.

The other

example

involved an inadequate

SI (see

paragraph

6.a. 14).

LER 259/88-15:

Failure to Monitor Off-Gas Stack Effluents

Due

to Procedural

Inadequacy

and Personnel

Error.

This included one

example

of the failure

to

implement

compensatory

measures

required

by

TS

LCO

3. 2. K. 2 for inoperable

off-gas

stack

radiation monitors.

The other example involved an inadequate

(see

paragraph

6.a. 16).

LER 259/88-16:

Personnel

Error Resulting

in a Violation of

Technical

Specifications.

This

involved two examples

of the

failure to implement

compensatory

measures

required

by

TS

LCO 3.2. K.2 for an inoperable off-gas stack flow monitor.

LER

259/88-26:

Violation of Fire

Protection

Technical

Specification

Due

to

Personnel

Error.

This

involved four

examples

of failure to implement compensatory

measures

required

by

TS

LCO 3. 11.G for blocked

open fire doors without operable

fire detection

systems

on either side of the doors.

8)

LER 259/88-41:

Failure to Comply With Technical Specifications

Caused

by Personnel

Error.

This involved one

example of the

failure to implement

compensatory

measures

required

by

TS

LCO 3.2.D.2 for inoperable

RCW effluent radiation monitors.

9)

LER 259/88-46:

Medical

Emergency

Causes

Failure to Comply Mith

Technical

Specifications.

This involved one example of failure

to implement

compensatory

measures

required

by TS

LCO 3. 11.A.2

for inoperable fire protection panels

and detectors.

10)

LER 259/88-51:

Failure to Meet Technical Specifications

Because

of Personnel

Error.

This involved one example of the fai lure to

maintain

compensatory

measures

required

by

TS

LCO 3.2.0 for

inoperable

RCW effluent radiation monitors.

ll)

LER

259/89-05:

Plant

Technical

Specifications

Surveillance

Requirement

Exceeded

Due to

a Misinterpretation

by Supervision

Responsible

for Patrolling

Firewatches.

This

involved

one

example of continuous failure to implement compensatory

measures

required

by

TS

LCO 3. 11.A. l.b for fire protected

zones

or areas

with inoperable detectors.

12)

LER 259/89-21:

Failure to Establish

Correct Fire Match Due to

Personnel

Error Results

in Condition Prohibited

by Technical

Specifications.

This

involved

two

examples

of failure to

implement

compensatory

measures

required

by

TS

3. 11.G for

blocked

open fire doors without operable fire detection

systems

on either side of the doors.

13)

LER 296/88-06:

Procedural

Deficiency

Caused

Failure to Comply

With Technical

Specifications.

This involved two examples

of

failure to maintain

compensatory

measures

required

by

TS

LCO 3.2.D.2 for inoperable

RCM effluent radiation monitors.

14)

LER 296/89-01:

Failure to Provide

Required

Continuous

Fire

Match

on Inoperable

Fire Doors

Caused

by Personnel

Error Due to

Insufficient Training.

This

involved

two

examples

of the

failure to implement

compensatory

measures

required

by

TS

LCO

3. 11.G. l.a for

blocked

open fire doors without operable fire

detection

systems

on either side.

In addition,

the following events

were

associated

with surveillance

testing:

VIO 88-28-01:

Failure

to

Control

and

Correct

Known

Drawing

Discrepancies.

A

known

EECW drawing

discrepancy

resulted

in the

development

of an

inadequate

SI for EECM hydrostatic testing.

This

error resulted

in

an

event

during which the

3C

DG was

operated

without

EECW flow for cooling during a performance of the monthly

DG

operability SI.

This

should

have

been

identified during the

upgrade

review process.

This event was reported in LER 296/88-07.

VIO 89-20-01:

Failure

to

Meet

TS

Requirements

for Operable

Pumps.

This violation involved

a condition where the

2C

pump

cooler fan motor was found to be rotating backwards.

This condition

made the associated

pump inoperable

and

reduced

the

number of

10

operable

pumps

below the

minimum required

by

TS 3.5.8.9.

This

condition

was

not

identified

during

the

performance

of the

operability SI for the return to service

of the

2C

RHR pump cooler

fan

motor

following maintenance

activities.

The condition

was

discovered

during

a

subsequent,

scheduled

performance

of the SI.

This event would have

been identified if the post maintenance

test

which consisted

of the

had

been properly performed.

This event

was reported in 'LER 260/89-15.

The extent of violations

and events listed above indicate that significant

problems still exist in the

area of surveillance

testing.

Mhile the

licensee

has

implemented

numerous

corrective

actions,

none

have

been

effective

in

accomplishing

the

necessary

program

improvements.

Of

particular

note

is

the

NRC instrument

adequacy

inspection

(IR 89-06)

which was

conducted

in January

and February,

1989.

The results of this

inspection

included

one violation involving 13

examples

of deficiencies

in the performance

of SIs

and calibration instructions,

and

a deviation

(DEV 89-06-03) for the failure to fully implement the

NPP commitment for

a

surveillance

upgrade

program.

The report

also

questioned

whether

sufficient management

attention

had

been directed to fully implement the

NPP

commitment.

The

basis

for this conclusion

included the

examples

referenced

in the violation

and similar findings

from

IR 88-35

(see

paragraph

4 of this report).

The licensee

responded

to the findings of IR 89-06 by letter

on July 7,

1989.

The

licensee

admitted

the

violations

and

the deviation

and

committed

to

implement corrective

actions

to prevent their recurrence.

These corrective actions

included the following:

Establishing

an

SI task force to review and to make

recommendations

on training,

on the conduct of testing,

procedure

reviews,

scheduling

and personnel

accountability.

Revising procedures

to establish

a formal

process

to validate SIs,

incorporate

evaluation

checklists,

provide

qualifications

for

reviewers

and

validators,

and

consolidate

SI verification

and

validation requirements

into one procedure.

Providing training to operations

and I 8

C personnel

to prevent the

reoccurrence

of adverse activities.

The

licensee

concluded

that

these

actions

and

increased

management

attention

would ensure

compliance with the intent of the commitments in

NPP

Volume 3.

However, there were

12 examples of deficiencies

related to