ML18033B404

power

supply concerns,

and nuclear safety review board.

Results:

One Technical

Specification violation was identified for failure to

perform independent verification during cable determination

due to a

programmatic

problem

,

paragraph

5.

There

was

a

lack of

understanding

of the differences

between

independent

verification

and

second

party

checks.

The

signature

blocks

used

in

the

modifications, work package

only contained

a single signature

block,

although

two signatures

by craft personnel

were required.

POC>62".OOVb

50CIb.i 4

I

0

A second violation with two examples

was identified for failure to

implement

procedures

and drawings.

The first example

was for the

unauthorized

bypassing

of two pull points

for

a

sump

pump

cable pull, paragraph

5.

NCVs had

been identified in IR 90-01 for

failure to follow procedures

during

cable pulling.

The

second

example

was for failure to have

an

adequate

drawing,

paragraph

5,

which later resulted in an inadvertent

DG start.

An unresolved

item for returning

a radiation monitor to service

without completing all of the SI steps

was identified, paragraph

2.

An

unresolved

item

concerning

relay

connection

problems

was

identified, paragraph

2.

This

URI has

two examples.

One connection

error involved

a

step

which

had

been

independently

verified.

A

second

example

involved

an

step

that.

had

been

previously

identified during the SI validation process

but had not been

acted

upon.

Overall,

the

monthly inspection

was

highly reactive.

Several

incident investigations

were initiated by the licensee for problems

that occurred

during the high potential testing of conductors.

The

investigations

were 'thorough

and self critical, but the

number of

problems

was of concern

since

the licensee

has

been

in

a recovery

program for

a

number of years.

A programmatic

problem

in IV was

identified.

The licensee

was

slow to respond to corrective actions.

Continuing problems existed during the performance of SIs.

Turnover of site

personnel

continues

to

be high.

Since

the last

full participation, exercise

several

key site

managers

have

changed.

A successful

full participation

graded

EP drill should

be completed

before

Unit 2 restart

using all

the

permanently

assigned

event

responders.

Eleven

LERs, five IFIs, two URIs and five violations were closed.

0'

REPORT DETAILS

1.

Persons

Contacted

Licensee

Employees:

0. Zeringue, Site Director

L. Myers, Plant Manager

M. Herrell, Plant Operations

Manager

J. Hutson, Project Engineer

J. Hutton, Operations

Superintendent

A. Sorrell, Maintenance

Superintendent

G. Turner, Site guality Assurance

Manager

P. Carier, Site Licensing Manager

P. Salas,

Compliance Supervisor

J.

Corey, Site Radiological Control Superintendent

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 Personnel

D. Carpenter,

Site Manager

C. Patterson,

Restart Coordinator

K. Ivey, Resident

Inspector

Attended exit interview

Acronyms used throughout this report are listed in the last paragraph.

2.

Surveillance

Observation '(61726)

The inspectors

followed the licensee's

surveillance

testing

schedule

and

reviewed

completed

results

during this

reporting

period.

The

inspections

consisted

of reviews of the

SIs for technical

adequacy

and

conformance

to TS, confirmation of proper removal

from service

and return

to service of systems,

and reviews of test data.

The inspectors

verified

that

LCOs were met,

and that SIs were completed at the required frequency.

Problems

Related to Inadequate

Surveillance

Instructions

On

May 12,

1990, Unit

1 received

a

PCIS Group

6 Isolation during the

performance

of

O-SI-4.2.G-2,

Control

Room

Isolation

and

Pressurization

Functional

Test.

During the SI,, a fuse blew causing

a Unit

1 reactor

zone isolation,

a refuel

zone isolation

on all

units,

and

the autostart

of control

room pressurization

train A.

SBGT train

A

was

tagged

out of service

and train

C

was

already

running.

The licensee

made

a 4-hour non-emergency

ENS report of an

unplanned

ESF actuation

for this event.

The licensee

determined

that the fuse

blew because

incorrect contacts

were jumpered

during

the

performance

of the SI.

Personnel

performing the

SI jumpered

relay contacts

nine

and

10 instead

of contacts

five and six

as

called

for in

the

SI.

The

licensee

initiated

an

incident

investigation to determine the'root cause of this event.

Preliminary

results

indicated that this event

was

caused

by personnel

errors

and

an

inadequate

procedure.

These

problems

apparently

had

been

identified during the SI validation process,

but no action

was taken

to

correct

the

problems, before

the

was

performed

again.

Contributing to the

event

was

the fact that

contacts

were

not

numbered

on the relay

and are in a configuration where contacts

nine

and

10 are in the place where five and six would logically be.

This

event

is identified

as

example

I of URI 259,

260,

296/90-14-01,

Problems

With Surveillance

Instructions

and will

be

reviewed

following completion of the licensee's

investigation.

During the performance of I-POI-200.4,

Defeating

RPS/PCIS Logic-Unit

One,

on April 25,

1990,

technicians

discovered

that jumpers

placed

between

relay contacts

were not landed

on the correct contacts

as

required

by the

procedure.

This condition

was discdvered

on six

relays.

The contacts

on

each of these

relays

were

sequenced

such

that contacts

nine

and

10 were located

where five and six should

'ave

logically been.

The

odd

sequence

was

not noticed

by the

technicians

performing

the

work nor

was it identified

in

the

procedure.

This

procedure

step

was

also

independently

verified.

Upon identifying these

deficiencies,

WOs were initiated to return

the wiring to the actual

configuration required for the

procedure

and the procedure

was continued.

There were

no equipment or system

actuations

caused

by this incident since all

power

was

removed

as

part of previous

procedure

steps.

The

licensee

completed

an

incident investigation

which determined

the root cause of this event

was

an

inadequate

procedure.

The

procedure

did not specify

the

relay terminal configuration

and did not identify wire numbers.

This

is considered

a

second

example

of URI 259,

260,

296/90-14-01

and

will be addressed

by the followup of the URI.

Failure to Follow Surveillance Instruction

On May 15,

1990,

the licensee

identified that'urbine building vent

exhaust

radiation

monitor

3-RM-90-249

had

been

declared

without full completion

of required

surveillance

testing.

The

radiation monitor was

declared

on May 11,

1990.

However,

during

review of 3-SI-4.2.K.3A,

Turbine

Sui lding

Vent

Exhaust

Monitor

(3-RM-90-249)

Calibration,

TVA discovered

that certain

steps

had not

been

performed,

and the radiation monitor should not

have

been

considered

operable.

The

SOS

declared

the

monitor

inoperable

and notified the chemistry

group to begin

compensatory

sampling

as

required

by

TS Table 3.2.K.

This event

was determined

'I

0

not to be reportable

in accordance

with 10 CFR 50.72;

however,

a

LER

was

to

be

submitted.

The

licensee

initiated

an

incident

investigation

to

determine

the

root

cause

of the

event.

The

investigation

was ongoing at the

end of this reporting period.

This

item is identified as

URI 259,

260, 296/90-14-02,

Failure to Follow

SI,

and will be

reviewed following completion of the licensee's

investigation.

No violations

or

deviations

,were

identified

in

the

Surveillance

Observation area..

Maintenance

Observation

(62703)

Plant

maintenance

activjties

on

selected

.safety-related

systems

and

components

were

inspected

to ascertain

that

they

were

conducted

in

accordance

with requirements'.

The following items were considered

during

this review:

LCOs were met, activities were accomplished

using

approved

procedures,

functional testing and/or calibrations

were performed prior to

returning

components

to service, quality control records

were maintained,

activities

were accomplished

by qualified personnel,

parts

and materials

used

were properly certified,

proper

tagout

clearance

procedures

were

adhered

to,

and radiological

controls

were

implemented

as required.

In

addition,

MRs and

WOs were reviewed to determine

the status of outstanding

jobs

and to assure

that priority was assigned

to safety-related

equipment

maintenance

which might affect plant safety.

Maintenance

activities

reviewed were as follows:

RHR Pump Impeller Wear Ring Replacement

HPCI Maintenance

No

violations

or

deviations

were

identified

in

the

maintenance

observation

area.

Operational

Safety Verification (71707)

The

inspectors

followed the overall plant status

and

any significant

safety matters

Daily discussions

were held

with plant management

and various

members of the plant operating staff.

The

inspectors

made

routine visits to the control

rooms.

Inspection

observations

included

instrument

readings,

setpoints

and

recordings,

status

of operating

systems,

status

and alignments

of emergency

standby

systems,

onsite

and offsite

emergency

power

sources

available

for

a'utomatic

operation,

purpose of temporary

tags

on equipment controls

and

switches,

annunciator

alarm status,

adherence

to procedures,

adherence

to

limiting conditions

for operations,

nuclear

instruments

operability,

temporary alterations

in effect, daily journals

and logs, stack monitor

recorder traces,

and control

room manning.

Thi's inspection activity also

included

numerous

informal discussions

with operators

and supervisors.

General

plant tours

were

conducted.

Portions of the turbine buildings,

each

reactor

building,

and

general

plant

areas

were

visited.

Observations

included

valve positions

and

system

alignment,

snubber

and

~

W

~

e

hanger conditions;

containment isolation alignments,

instrument readings,

housekeeping,

proper

power supply

and breaker alignments,

radiation

area

controls,

tag controls

on equipment,

work activities in progress,

and

radiation

protection

controls.

Informal discussions

were

held with

selected

plant personnel

in their functional areas

during these tours.

a.

Phase

Unbalance

in Electrical

Systems

The

radwaste

floor drain

holding

pump

motor

indicated

an

amperage

unbalance

and

was

tripping

on

thermal

overload

after

approximately

75 minutes of operation;

The licensee

determined that

phase

C of the three

phase

motor

was

drawing excessive

current,

resulting

in

the

overloading.

The

system

engineering

group

discovered

that

phase

C of the Unit

1 main transformer

was set at

a

highe'r voltage

than

phase

A and

B.

The Unit I, Unit 2,

and Unit 3

main transformers

each consist of three individual transformers,

one

per

phase,

which

can

be

adjusted

individually.

Additional

information supplied

by the licensee

indicated that, for the three

Unit I individual

phase

transformers,

the

tap for the

phase

C

transformer

was

not adjusted

properly.

The Unit I transformer

supplies

normal

power to the

4KV Shutdown

Boards

A and

B through the

Unit Station Service Transformer

IB.

This item will be reviewed to

determine

the affects

on safety related

systems

and tracked

as IFI

259,

260, 296/90-14-03,

Effects of Phase

Unbalance

on Safety Related

Electrical'ystems.

b.

Unit Status

All three units

remain defueled

and in an extended

outage

as part of

the

BFNP recovery

plans.

Work activities for returning Unit 2 to

service

continued.

The

main activities

were

completion of pipe

support

and restraints,

Eg work, and high potential

cable testing to

determine if cable pull-by damage

was evident.

No violations. or deviations

were identified in the Operational

Safety

Verification area.

5.

Yiodifications (37700,

37828)

a ~

Standby

Gas Treatment

System

An inspector

observed

work activities

on all three trains of the

SBGT

system.

These activities

included

review of the

ECN/DCNs,

review of the work plans,

and observation of field activities.

Train

C activities involved five ECN/DCNs, ten

WPs,

and two MRs/WOs.

Train

A activities were similar to those

documented for Train

C with

the exception that the blower motor for Train

C was being replaced.

Train

B was waiting for a system tagout

so field work could start.

The inspector

observed that field activities were being performed in

accordance

with approved

procedures

and controls for WPs,

MRs,

and

WOs.

The inspector

reviewed

QC inspection

reports for

WPs

0150-90 thru

0153-90.

These

IRs

documented

the installation of cable

and limit

switches

for the motor operated

damper

type

FCVs.

At the time of

this observation,

the licensee

was in the process

of determining if

the

SBGT system

damper type

FCV motors would require replacement.

The inspector

noted that an electrical

motor was lying on the floor

next to train

8 with

a metal

EQ tag

and

an "In .Use" tag attached.

The metal

tag indicated that the motor was for the train,B fan and

the "In Use" tag indicated that it was for

WP 0149-90.

A review of

WP 0149-90

indicated that it was written to implement

DCN-W7946A.

This

DCN requires

the replace'ment of non-EQ electrical

cables with EQ

cables

and

made

no mention of replacing the train

8 fan motor.

The

inspector

discussed

the

observation

with the

licensee

and

the

tagging

was corrected.

The inspector also

noted that the fan motor

on

C train was identified with the correct

EQ tag,

and

ECN tag.

b.

High Potential

Cable'Testing

(51061,

51063)

A wet high potential test

program

was initiated at

BFNP to determine

if significant cable pull-by insulation

damage

existed

at

Browns

Ferry.-

This test

program consisted

of selecting

the ten worst case

conduits for several

voltage

levels

in which cable pull-by's

had

occurred,

determinating

the cables

in these

conduits at both ends,

filling the

conduits

with water,

and

performing

a high potential

test

on the cables

to see if they were

damaged.

The inspectors

followed activities

associated

with the wet conduit

high potential

testing

of electrical

cables.

This testing

was

conducted

in accordance

with ST-90-01,

Special

Test Procedure for DC

High Potential

Testing of Low Voltage Cables.

An inspector

observed

and

reviewed

the results

of the wet conduit

high potential testing.

Major points of interest

were

as follows:

1)

Drawing Deviation

The

licensee

performed

post

high potential

testing activities

which involved and the retermination of electrical

leads lifted

to support

the

high potential

testing

and

post modification

testing.

A discrepancy

was discovered

in the wiring for the

C

Diesel

Generator

degraded

voltage

logic system,

on April 20,

1990.

During the lifting process,

a drawing discrepancy

was

identified when conductors

C272

and

C278 from cable

ES4082-IIC

were

found

reversed

from the

positions

on

the

drawing

on

terminal

block

ZT in compartment

25 of the

4160 volt shutdown

board

C.

Potential

DD 90-051

was initiated to .document

the

finding.

The

DD

was

dispositioned

as if the

drawing

was

correct.

The leads

were reversed

from the

as

found condition.

J+

This resulted

in an unanticipated

start

and loading of the

C

Diesel

Generator.

This is the first example of a violation of

10 CFR 50,

Appendix

B, Criterion V, Instructions,

Procedures

and

Drawings,

in that plant drawings

were not appropriate

to

the circumstances.

This item is identified as

VIO 259,

260,

296/90-14-04,

Failure to Implement Drawings

and Procedures.

The

licensee

temporarily

suspended

the testing

due

to the

wiring change

made to the

C

DG.

The site director established

the

requirements

that all

post

testing activity would

be

identified

and

approved

prior to taking out

an electrical

network for testing,

that all restoration activity would

be

aimed at

each circuit involved with the high pot testing,

and

that

(jA/gC would

be involved in the lifting and relanding of

individual electrical

terminations.

Testing

was

allowed

to

resume.

Independent Verification

Section

3.10 of ST-90-01

states

that wire lifting, relanding

and testing prior to return to service

are not within the scope

of that

procedu're

and

are to

be

performed

in accordance

with

established

plant

procedures.

For

cables

in

conduit

3ES-1676-IB,

the

actual

conductor

determination

and

, retermination

had

been

performed

under

Work Order

WO 90-02259

WO

90-02259

required

that

determination

and

termination

activities

were to

be

performed

in accordance

with MAI-3.3,

Cable

Termination

and Splicing for Cables

Rated

up to

15000

Volts.

During the

review of this

work order

the

inspector

noted

an apparent

discrepancy

in the documentation

of the work

activity.

Independent

verification of the

wire lifting

activities

had

not

been

conducted

prior to

commencement

of

testing.

The

inspector

noted

that for conduit

3ES-1676-IB,

which included

66 separate

conductors,

the actual

determination

activities

were

performed

on April 3-4,

1990,

and

documented

for each

conductor

by a single signature for the date actually

performed

on

each

MAI-3.3 data

sheet.

Although the testing

associated

with these

cables

had started

on April 5, all of the

second

signatures

intended

as denoting

independent verification

were

made

by the

same

individual

and

dated April 7.

Cable

testing

had

been

stopped

on April 5 during testing of the 39th

conductor

due to problems

and failure

to properly determinate

three of the required

conductors prior

to

commencement

of testing.

The issue

concerning failure to

adequately

control testing

is

documented

in greater detail in

Inspection

Report 90-08.

The inspector

discussed

these

findings with members of the Site

guality Organizat'ion

on April 10,

1990.

The licensee initiated

an

investigation

and

conducted

interviews with modifications

personnel

involved in the activities.

As the result of this

licensee

investigation

the

NRC inspector

was

informed of the

following:

The conductor

determinations

had

been

performed

by a crew

of modification electrical

craft personnel.

The first

signature

on

each

of the

data

sheets

were those of the

personnel

that actually performed the determinations.

Although

a crew of several

electricians

were involved in

the

activity

and

second

party

checks

by

another

electrician

probably occurred

at the time, there

was

no

clearly defined requirement

or assigned

responsibility

to

perform

independent

verification of the

cable lifting

activities.

Each

of the

second

signatures

dated

on

April 7

on each of the data

sheets

was that of the general

foreman assigned

to the crew.

The

inspector

noted

that

the

NAI-3.3 data

sheet

does

not

mention

a requirement for independent verification, nor are

two

separate,

signature

blanks

included

as

found

on other similar

documents.

SDSP-3. 11, guality Control Inspection

Program

does

not require

gC inspection of wire lifts where the conductor is

to

be

returned

to the

as

found condition,

and

independent

verification is only specified

for relanding of conductors.

However,

TYA Standard

STD-10. 1.53

and

PNI-8. 1

which

cover

control

of

'temporary

alterations

require

independent

'erification

for both lifting and

relanding

of electrical

wires.

Both

licensee

documents

include wire lifts as

an

example of

a

temporary alteration.

PNI-8.1 allows

temporary

alterations

to be performed

under maintenance

requests

or other

plant instructions

rather

than specifically requiring the

use

of

a

TACF,

but

in all

cases

independent

verification

requirements

for installation

and

removal

are required to

be

adhered

to.

This constitutes

a failure to

implement

the

independent

verification

requirements

of

STD-10. 1.53

and

PMI-8.1

for

a

temporary

alteration

(YIO

259,

260,

296/90-14-05).

As the result of the licensee's

investigation into this event,

CARR

BFP

900124

was

issued

to document

the issue.

However,

this

CARR was

not written until April 24,

two weeks after the

issue

was discussed

with the Site guality Organization.

Based

on the discussions

among

licensee

personnel

during the

NRC meeting

discussed

in paragraph

7, this failure appears

to

have

occurred

due to

a lack of understanding

of the actual

meaning of independent verification on the part of modifications

'ersonnel.

The

term

"second

party" or

"second

person"

is

frequently

used

rather

than

"independent

verification."

The

meaning

of

a

second

person

requirement

as

practiced

by

0

modifications

personnel

may not satisfy

the

requirements

for

independence

by separate

time and

space.

The inspector

also

noted that

SDSP - 3. 15, Section

4 states

that

"second

person"

verification

shall

be

synonymous

with

"independent

verification."

Additionally,

as

procedures

are

routinely

revised

"second

person"

should

be

replaced

with "independent

verification."

The

inspector

noted

that

Revision

2

to

MAI - 1.3,

General

Requirements

for Modifications, which

was

issued

within the last

month, still used .the

term

"second

party."

The inspectors will followup on this issue

again in

future inspections

and

as part of the closure to this violation.

The

inspector

noted

that

the

conductor

relanding

signature

blocks

on

each

of the

MAI - 3.3

data

sheets

included

two

signatures

for each

of the

cables

that

were

relanded

and

appeared

to

conform

to

the

independent

verification

requirements.

3)

Results

a.

Damaged

Cable

ES327-I

Cable

ES327-I

was

damaged

approximately

one inch below the

conduit bushing

on cohduit

ES337-I

in

a junction

box at

column

N-R3 at

elevation

586

in the

Unit I reactor

building.

The cable

was cut by

a sharp object

such

as

a

knife

or

screwdriver

apparently

while

removing

the

internal

condui't seal.

The person

performing the work did

not

pay

adequate

attention

to the existing cables

while

removing the seal

material.

The

damage

was determined

by

the

licensee

to

be

not

cable

pull-by

activities.

'.

Damaged'ables

LS 175,

187,

191

Five conductors

out of the cables

were found damaged.

The

licensee's

evaluation

was continuing at the

end of the

report period but initially the

damage

did not appear

to

be cable pullby related.

Cable Pull Deficiencies

On April 30,

1990,

the

licensee identified'hat

a multiple cable

pull

(gang pull)

made

in the Unit .I reactor

building apparently

exceeded

the

pull

tension

listed

. in

the

workplan.

A

CA(R

(no.

BFP900132)

was written to document this condition.

Disposition

of the

CARR determined

that

the

pull" tension

was

not actually

exceeded

and

no problem

had occurred.

During the

same

cable pull,

it was

noted that

two cable pull boxes

were bypassed

in violation of

the latest

engineering

requirements

for cable installation.

An

incident

investigation

was

initiated

for

cable

installation

practices

including the problems of bypassing

pull boxes.

General

Construction Specification

G-38, Installing Insulated

Cables

Rated

Up

To

15000 Volts, includes

the methods for establishing

and

bypassing

pull points.

Specification

Revision Notice

(SRN) G-38-69,

effective

April

6,

1990,

added

the

following requirement,

"Pullpoints (i.e.,

condulets,

other

than

"C" condulets

used

to

inject lubricant,

manholes)

shall

not

be

bypassed

when pulling

cables

unless

authorized

by NE."

An

inspector

reviewed

the

licensee's

completed

incident

investigation

( II-B-90-054) and determined

the following:

DCN W5547 included five separate

workplans.

The

implementation

of

SRN G-38-69

was

inadequate

in that the

SRN signed

out April 6,

1990,

as "effective immediately" did

not arrive at

BFN document control until April 26,

1990,

and

was

then

given

a

due

date

for site

implementation

of

May 27,

1990.

Cables

ES325-I,

ES350-I,

ES363-I,

K307-1, ES825-I,

and

ES833-I

were

pulled

bypassing

two pull

points

without proper

NE

authorization.

NRC requi,rement

10 CFR 50,

Appendix 8, Criterion

V "Instructions,

Procedures,

and Drawings" requires

that activities affecting quality

be prescribed

by procedures

and accomplished

in accordance

with the

procedures.

.

The

failure

to

implement

the

requirements

of

SRN G-38-69 during the

performance

of cable pulling activities

was

identified

as

another

example

of

a violation of

10 CFR 50,

Appendix

B, Criterion

V

(VIO 259,

260,

296/90-14-04:

Failure to

Implement

Drawings

and

Procedures).

Although this

problem

was

identified

by the

licensee, it does

not meet

the criteria for a

non-cited violation since it is

a further example of cable pulling

deficiencies

as identified in

NCV 90-01-01

and

NCV 90-01-02.

6.

Restart Test Program

(70301,

70400)

The total

number of test procedures

written and

approved for performance

was

43.

Total tests

completed

and results

approved

by the plant manager

numbered

34.

Total

TEs identified as of April 20,

1990 involving hardware

issues

was

216.

Of this

number,

202

were resolved,

and

14 remained

outstanding.

7.

Management

Review Committee

(40700)

An inspector monitored the

MRC meeting

conducted

on April 25,

1990.

The

MRC meets daily, or when necessary

as part of the licensee's

corrective

action

program,

to provide adequate

oversight of corrective action.

Each

newly identified potential

CA( is

presented

to the

MRC which decides

whether the item constitutes

a

CARR or

PRD.

Additionally, determinations

are

made

concerning

generic implications, reportability, disposition;

and

other related

concerns.

One possible

disposition is to invalidate

the

10

item if it is not considered

to

be

a quality concern

or is below the

threshold for

a

CAQR or

PRD.

Neither the Site Director nor the Plant

Manager

were

present

at this

session.

A member of the Site Quality

Organization

acted

as chairman.

Four

new potential

CAQs were presented

during the

MRC meeting.

Two of

these

were delayed until

a later

date

because

the responsible

engineer

was

not available for discussion

of the item.

Another item was discussed

but

delayed

to allow the

responsible

section

supervisor

adequate

time to

review the issue prior to additional discussion,

The

MRC members

agreed

that in each of these

three

cases

that

a failure to take timely action

would not

occur

bacause

of the

delays.

Based

on

the

low safety

significance of these

three

issues,

the inspector did not disagree

with

the MRC's decision to postpone

formal action

on the issues.

The final item discussed

was

BFP 900124,

which concerned

the failure to

perform

independent

verification

on lifted electrical

conductors

discussed

in paragraph

S.b(2)

in this inspection report.

The inspector

reviewed

the potential

CAQ form and noted that it described

the

problem

as

a failure to perform

"second

party" verification of the

"as

found"

cable training radius

rather

than

the failure to perform "independent

verification"'f the corr'ect lifted cable.

This error

was

immediately

noted

by the

MRC and the chairman directed that

an additional

statement

be

added

to correct

the form.

Additionally the

chairman directed that

probable

inadequacies

in MAI - 1.3, General

Requirements for Modifications,

and

MAI - 3.3, Cable Termination

and Splicing for Cables

Rated

up to 15,000

Volts,

be considered

as part of the corrective action plan

and that the

failure

appeared

to

be

a training

problem

rather

than

a

case

of

personnel

error (thus not requiring disciplinary action).

The

inspector

had

several

concerns

relating to the

handling of this

item by the

MRC, which are

as follows:

The modifications representative

to the

MRC stated

that the

second

party verification actually occurred,

since

the general

foreman that

signed

the blocks at

a later date

was

present

during the time and

actually

observed

the

conductors

being lifted.

This implied that

the

only failure

was

one

of failing to

document

properly

the

activity when performed.

The

MRC did not recognize

that

a person

actually present

observing

the conductor lifting activity could not

be

considered

as

an

"independent verifier," nor did they question

whether the activity was ever independently verified.

Throughout

the

meeting

the

term

"second

party"

was

used

almost

exclusively, rather than "independent verification."

Members

did not discuss

that- the lifted conductor constituted

a

temporary alteration,

nor that

STD-10. 1.53,

SDSP-3.15,

and

PMI-8.1

had been violated.

The

CAQR only specified

a

single

cable

as

the

problem

when

approximately

half of the

66

conductors

in that

conduit

were

involved.

0

11

The

item

was

determined

by the

tlRC to

be

a

CAQR with potential

prograomatic

concerns,

and it was

placed

on the calendar for followup

within two weeks.

8.

Reportable

Occurrences

(92?00)

The

LERs listed

below were

reviewed

to determine if the information

provided

met

NRC requirements.

The review included the verification of

compliance

with

TS

and

regulatory

requirements,

and

addressed

the

adequacy

of the

event description,

the corrective

actions

taken,

the

existence

of potential

generic

problems,

compliance

with reporting

requirements,

and

the relative

safety

significance

of each

event.

Additional in-plant

reviews

and

discussions

with plant personnel,

as

appropriate,

were conducted.

a.

(CLOSED)

LER 259/87-05,

Loose

Electrical

Connection

Leads

to

Safety Systems

Actuation.

This

LER was

associated

with erratic voltage

and frequency

on

4KV

Shutdown

Board

A due to

DG

A voltage regulator failure during the

monthly starting

and loading testing.

Investigation

by licensee

electrical

maintenance

personnel

found

that

a loose electrical

connection

between

the

power boost current

transformer

(XCT)

and

the

voltage

regulator

had

created

a

high

resistance.

The loose'onnection

subsequently

burned

open

under

load.

The

damaged

electrical

connection

was

repaired

and

the

voltage regulator'as

replaced.

All components

and connections

of

the

A

DG control

system

were

inspected

with

no further

damage.

identified.

Subsequent

inspections

on

the

remaining

7

DGs

were

performed

and

no other

problems

identified.

The

licensee

has

revised

the

annual

DG inspection

surveillance

instruction

(SI)

4.9.A. 1.d,

to require

removal of insulation from bolted connections

to allow inspections.

The

inspector

reviewed

documentation

provided

by the

licensee

to

verify the

completeness

of the

above

corrective

action.

The

inspector

determined

that

the

licensee's

corrective

actions

have

been

adequate

to prevent

recurrence

of this event.

This

item is

closed.

b.

(CLOSED)

LER 260/88-06,

Revision

2,

480

Volt Shutdown

Board

Voltage Transient Initiates Engineered

Safeguards

Features.

This

LER involved

two

RPS circuit protector trip events

which

occurred

in Unit 2 in 1988.

An inspector

reviewed this

LER in IR

89-40

and

determined

that it met

the reporting

requirements

of

10 CFR 50.73,

and

that corrective

actions

had

been

completed.

However,

this

LER

was left open

pendino

completion of circuit

protector modifications planned

by the licensee.

12

From the time that these

events

occurred

in 1988 until the current

reporting

period,

there

have

been

several

RPS circuit protector

trips for all three units.

The licensee 'issued

a

LER for each of

the events

and

each

event

was

reviewed

by the resident

inspectors

when

they occurred.

To reduce

the

number

of items tracking the

status

of the

RPS circuit protector modifications,

LER 296/90-01

will be kept open

as

a Unit 2 restart

item until completion of the

modifications

and

resolution

of

power

supply

concerns.

Therefore, this

LER is closed.

(CLOSED)

LER 260/89-004,

Technical

Specification

Violation

Due

to Missed Surveillance.

On

February

22,

1989,

the

licensee

identified that

the

due

February

14,

1989,

had not been

performed

on the

C

and

D 250 Volt Shutdown Batteries.

The next required

surveillance

had

been

performed

on, February

21,

1989, resulting=in

exceeding

the. time

period

specified

in

T.S.

3.9.C

between

February

15 and February 21,

1989.

The licensee

determined

during the subsequent

investigation that the

missed surveillance

occurred

due to inadequate

controls

and tracking

of surveillances

and failure

by maintenance

supervision

to ensure

that the surveill'ance

was performed.

Licensee

management

conducted

training with maintenance

supervisory

personnel

to emphasize

the importance of reviewing SI schedules

and

proper

communications

between

foreman

and

the

SI scheduling

group.

Additionally, the licensee

created

a task force for evaluating

the

existing

SI scheduling. program

and identifying any recommendations

for improvement.

The

inspector

reviewed

documentation

to verify that

the

above

training

was

performed.

The

inspectors

have

noted

a

gradual

improvement in this area largely resulting from increased

manag'ement

attention.

The inspector

agrees

that

adequate

corrective

actions

have occurred that should prevent recurrence.

This item is closed.

(CLOSED)

LER 296/89-004,

Personnel

Error

Results

in

an

Unplanned Start of a Diesel Generator.

On

September

6,

1989,

Unit 3 experienced

an

unplanned

automatic

start of the

3D

DG during

the

performance

of post

maintenance

testing following replacement

of the start failure relay,

SFD1.

The

licensee

immediately stopped all related testing until the

cause of

the event could

be determined

and the diesel

generator

secured.

The

licensee

determined

during

the

subsequent

investigation that the

event occurred

due to an inadequate

maintenance

request,

YiR 919735,

which did not r'equire that the start failure relay

be reset prior to

closing

the start circuit breaker

in order to preclude

automatic

starting of the diesel

generator.

0

13

The inspector

reviewed

LRED, 89-3-151,

and

Incident Investigation

Report 89-70,

which covered this event.

As corrective actions

the

licensee

counseled

the maintenance

planner that

had

performed

the

planning

on

MR 919735

and

conducted

training concerning

the event

with all maintenance

planning

personnel.

The inspector

reviewed

documentation

provided

by the licensee

to verify performance

of the

above corrective

actions

and

concu'rs

that the completed corrective

actions

should

be

adequate

to prevent

recurrence.

This

item is

closed.

(CLOSED)

LER 260/89-006,

Unplanned

ESF

Actuations

Due

to

the

Loss of Reactor

Protection

System

Motor Generator

Output Caused

by

Personnel

Standing

on Breaker Cabinet.

On March 31,

1989, Unit 2 experienced

an unplanned

ESF actuation

due

to the deenergization

of the

2B

RPS Bus.

After an investigation,

the

l,icensee

determined

the

event

had

occurred

due to modifications

personnel

climbing onto the associated

RPS output breaker cabinet.

The

2B

Bus

was, placed

on the alternate

power supply and affected

systems

returned to normal.

The

licensee

later

determined

that .scaffolding

provided for the

personnel

to

use

which

was

located

above

the cabinet

was

not

constructed

with

a ladder

to provide direct access.

The breaker

overvoltage

relay

was identified as

being sensitive to direct, small

magnitude

mechanical

shock.

The licensee

evaluated

this condition

(vibration sensitivity)

as

being

an

acceptable

condition

under

normal plant operating conditions.

As corrective actions

the licensee

performed

the following:

SDSP

14.32,

Scaffold

Construction

Procedure

was

revised

to

include

as part of the -final checks,

a survey of the area to

identify any plant equipment

that

may

be inappropriately

used

during the planned

work activity.

A critique of the event

was provided to modifications personnel

along

with

a

management

memorandum

urging

increased

care

in

preparation of workplans

and their implementation.

The related

breaker

cabinet

was

marked with a pepaanent

label

to

warn of sensitive

plant

equipment.

A team of licensee

personnel

was assigned

to tour the plant for identifying other

similar equipment that might require labeling.

The

inspector

reviewed

Incident Investigation

Report

89-28,

and

Modifications Manager

Memorandum

dated April 17,

1989 which covered

this

event.

A list of potentially sensitive

components

that

received

warning labels

was also

reviewed.

The inspector

concurs

with the

licensee's

evaluation

of the

above

event

and resulting

corrective action.

This item is closed.

14

'(CLOSED)

LER 260/89-21,

Technical

Specification

Violation Caused

by Personnel

Error.

On July

10,

1989,

the licensee

determined

that

a 4-hour

TS

LCO for

neutron

monitoring

system testing

had

been

exceeded

by

2 minutes.

Surveillance test 2-SI-4.2.C-1.2,

"Instrumentation that Initiates

Rod

Blocks/Scrams,

APRN

Functional

Test,"

includes

jumpering

relay

contacts

to

remove

APRN

2F

and

IRN 2F inputs to the

RPS,

making

~these

instruments

inoperable.

IRN 2H was inoperable at the time of

the test

due to other conditions.

TS 3. 1, Table 3. 1.A requires

that=

a minimum of three

IRN channels

be operable for each

RPS trip system

during the shutdown

mode except during required surveillance testing.

Table 3. 1.A, note 23, allows

a channel

to be placed in an inoperable

status

for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />

provided at least

one operable

channel

in

the

same trip system is monitoring that parameter.

Due to problems

encountered

during

the

performance

of the SI,

personnel

errors

in

monitoring

the

LCO time,

and failure to notify the

SOS of the

impending time limit, the 4-hour

LCO limit was exceeded.

Additional licensee

reviews

determined

that applicab'le

TS actions

were

.in place at the time of this event

and

no violation of TS

had

occurred.

Table 3. 1;A, Action 1.A requires

that the trip system

be

tripped

within

one

hour;

or, all

operations

involving core

alterations

be

suspended

and all

control

rods

inserted

within one

hour.

During this event,

Unit 2

was in cold

shutdown'ith

all control

rods inserted

and

no core alterations

in progress.

Under

these

plant

conditions,

compliance

with Action

1.A

was

'aintained

throughout

the

event

and

no violation of TS occurred.

The licensee

submitted revision

1 of the

LER on February

12,

1990,

to change

the report to a voluntary LER.

The inspector

reviewed Revision

0 of the

LER, dated

August 9, 1989,

Revision

1 of the

LER,

and the Unit 2 TS.

The inspector

concluded

that

no

TS violation had o'ccurred

and this event

was not reportable

per

10 CFR 50.73.

This item is closed.

In addition,

the

inspector

reviewed

the

licensee's

corrective

actions,

proposed

i'n revision

0 of the

LER, to prevent recurrence

of

the event.

The

proposed

actions

included revising the

SI writers

guide to require notification of the

SOS prior to exceeding

a

LCO

time limit when it becomes

apparent

that the

time limit cannot

be

met

and revising the

conduct of testing

procedure

to specifically

assign

responsibility for monitoring

LCO time limits created

and

controlled

by testing.

The inspector verified that the conduct of

testing

procedure

had

been

revised,

but noted that the

SI writers

guide

had

not

been

revised.

Discussions

with licensee

personnel

revealed

that

SDSP 7.4,

Procedure

Review,

had

been revised

instead

of the

SI writers guide.

This

was

done to ensure that existing SIs

would

be revised

to include

these

requirements

as well

as

newly

written SIs,

The

inspector

verified that

SDSP

7.4,

Form

171

"Procedure

Verification

Review

Checklist"

had

been

revised

to

require notification of the

SOS

when it becomes

apparent

that

a

LCO

time limit can

not

be

met.

The

inspector

also verified that

2-SI-4.2.C-1.2

had

been revised to include these

requirements.

0

15

(CLOSED)

LER 259/89-23,

Performance

of Surveillance

Testing

-Results

in Inoperable

Eme'rgency

Equipment

Cooling Water

System

and

Diesel

Generators

Which is

an Unanalyzed Condition.

On August

15,

1989,

the licensee

identified that all

12

EECW pumps

and all

8

DGs were

made

inoperable

in violation of TS requirements

during

the

performance

of surveillance

testing.

Procedure

O-SI-4.2.B-67,

Residual

Heat

Removal

Service

Water Initiation Logic,

included disabling

the automatic start'ogic of the

EECW system

to

perform the test.

The

EECW system

is required

to automatically

provide cooling water to essential

equipment,

including the

DGs, in

the event of an accident.

The

cause of the event

was

a deficient

test procedure.

The inspector

reviewed the licensee's

closure

package for this item

'nd

the incident investigation

RCA 89-66

which

was

performed for

this event.

The incident investigation

determined

that the SI was

revised

in 1976 to include disabling

the

EECW automatic start logic

to

reduce

the

number of, pump starts.

The licensee's

immediate

corrective action

was to place an, administrative

hold on the SI

so

it could

not

be

used

again.

'Other

immediate

actions

included

screening

the

schedule

of SIs to

be performed

in the following two

weeks

for similar deficiencies.

One

was

identified

which

required

revision prior to its performance.

Long term corrective

actions, included

the establishing

of

a

procedure

review group to

review scheduled

SIs for problems.

The inspector verified that the

LER met the reporting requirements

of

10 CFR 50.73

and verified that

the corrective

actions

were

complete.

This event

was

included

as

an example of a Severity Level

III violation (VIO 89-43-01)

issued for a programmatic

breakdown of

the surveillance

testing

program.

The long term corrective actions

committed

to for the overall surveillance

testing

program will be

verified during the followup of VIO 89-43-01.

This item is closed.

(CLOSED)

LER 259/89-24

and

LER 259/89-27,

Deenergization

of

Bus

by Motor Generator

Circuit Protector

Operations

Caused

by

Inadequate

Design of Protector Setpoints.

These

LERs

involved

three

events

between

August

26

and

October

16,

1989,

where the Unit

1

bus

1B was deenergized

due to

RPS circuit protector trips.

Each event resulted

in

ESF actuations

which occurred

as

designed.

The root

cause

in each

event

was

determined

to

be

an

inadequate

design

of the setpoints

for the

circuit protectors.

The

inspector

reviewed

the

LERs

and verified that .they met the

reporting

requirements

of

10 CFR 50.73.

Following each

event

the

licensee

returned all systems

to the normal status

and corrected

the

cause

of the

power supply fluctuations.

The corrective actions

given for both

LERs and the inspectors

findings were

as follows:

0

16

(1)

The

licensee

performed

an

evaluation

to

determine if the

existing

MG set voltage adjustment

potentiometers

should

be

replaced with ones of a different type.

From this evaluation,

the

licensee

decided

to

replace

the existing

open-design

potentiometers

with ones

having

an enclosed

design

that would

be

less

susceptible

to dust disposition.

Three

DCNs

were

approved

by the

PORC

on October

14,

1989, for replacement

in

all three units.

(2)

The licensee

performed

an evaluation of the design

basis for

the

MG set circuit protection

setpoints

and initiated

design

changes.

From this evaluation,

the licensee initiated

design

changes

for modification of the circuit protector

setpoints.

These

LERs

are

closed.

Completion of the

RPS circuit protector

design

changes

and modifications will be resolved

by the followup of

LER 296/90-01.

(CLOSED)

LER 259/89-26,

Failure to

Sample All Seven-Day

Fuel Oil

Storage

Tanks for the Diesel

Generators

Resulting in a Violation of

Technical Specifications.

This item involved the failure to sample

DG fuel oil for'quality on

a monthly basis

as

required

by

TS 4.9.A.l.e'.

The licensee

had

interpreted

the

TS to mean that the

DG seven-day

fuel oil storage

tanks

were to be sampled

once

a month

on

a staggered

basis

and the

was written to reflect this interpretation.

On September

12,

1989,

the licensee

determined

that the staggered

sampling

frequency

was in violation of the TS.

The inspector

reviewed

the

LER, dated

October

11,

1989,

and

the

licensee's

closure

package for'his item.

The licensee

implemented

immediate

corrective

action

by sampling all of the

DG seven-day

tanks

on

a monthly frequency.

The licensee

then revised

procedure

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

Diesel

Generator

Fuel

Oil Analysis,

to

implement

monthly sampling

of all

DG seven-day

tanks.

Subsequent

licensee

review of this

issue

identified that

a monthly sampling

frequency

was excessive

relative to the standardized

technical specifications.

A TS change

request

was,submitted

to the

NRC to request

a quarterly

sampling frequency for each

DG seven-day

tank.

The inspector verified that the

LER met the reporting requirements

of

10 CFR 50.73

and verified that

the corrective

actions

were

complete.

The

TS change will be resolved

between

the licensee

and

NRR in accordance

with

NRC procedures

governing

TS amendments.

This

event

was

included

as

an example of a Severity Level III violation

(VIO 89-43-01)

issued for

a

breakdown of the surveillance

testing

program.

The

long

term corrective

actions

committed

to for the

overall

surveillance

testing

program will be verified during

the

followup of VIO 89-43-01.

This item is closed.

17

(CLOSED)

LER 260/89-28,

Failed

Solder

Connecti'on

on

Scram Pilot

Air Header During Instrument Calibration Results

in

RPS Actuation.

This item involved

a

RPS actuation

on

a low scram pilot air pressure

signal

which occurred

during the calibration of a pressure

indicator

(2-PI-'85-67A) .on

December

6,

1989.

The

cause

of the trip was the

failure of

a soldered

connection

which caused

the instrument

tap

piping to disconnect

from the air header

piping.

The resultant air

leak

reduced

the

header

pressure

to the trip setpoint.

Licensee

investigation

and

examination

of the failed connection

did not

uncover sufficient evidence

to determine

the root

cause

of the

failure.

The

connection

had

been

in service for

14 years

and

2-PI-85-67A

had

been

removed

several

times for calibrations.

The

licensee

indicated

that

stresses

added

from the

removal

and

reinstallation of the

pressure

indicator for each calibration

may

have contributed to the failure.

The

inspector

reviewed

the

LER,

dated

January

5,

1989,

and

the

licensee's

closure

package for this

item and verified that the

LER

met

the reporting

requirements

of

10 CFR 50.73.

The

licensee

repaired

the solder connection

and replaced

the pressure

indicator.

The

licensee

also

performed

leak testing

of the other

soldered

connections

in the

scram pilot air header

and identified three

more

air

leaks

These

leaks

were

repaired

also.

As

a

long

term

corrective action,

the licensee

planned to perform

an evaluation of

the present

system piping to determine if additional

actions

should

be

taken

to

increase

system reliability.

However,

the current

system

meets

design

requirements

and

provides

a fail safe

actuation

on loss of air.

This item is closed.

9.

Action on Previous

Inspection

Findings

(92701,

92702)

(CLOSED)

IFI 259,

260,

296/86-28-03,

Failure

to Specify

Overload

Element Ratings

on Drawings.

This item involved

a licensee

finding that design

documents

did not

reflect the overload

element ratings for HCC starters.

It could not

be established

whether

the overloads

were properly specified

by the=

designers.

The

licensee

initiated

a

SCR

and

established

a

corrective action

plan to resolve

the issue.

This IFI was

opened

to

record

the

progress

of the licensee's

corrective

actions

and to

follow any adverse

findings.

During this reporting'period,

an inspector

reviewed

the licensee's

closure

package

for this

item

and

held discussions

with licensee

personnel

concerning

the

status

of the corrective

actions.

The

resolution of this issue

was

committed to by the licensee

in Section

13.4 of the

NPP,

Volume 3.

The commitment was to inspect

and modify

Unit 2 safety related

NCC thermal

overloads

and Units I and

3 safety

overloads

required for Unit 2 safe

shutdown prior to

18

restart.

At the

time

of this

report,

they

had

completed

modifications for all committed overloads

except for one

DCN.

This

DCN included

changing

out

3 sets

of overloads

and revising

the

setpoints

on

several

others.

This

DCN will be

completed

and

implemented prior to Unit 2 restart.

The

inspector

verified that

the

resolution

of this

issue

was

included

in the licensee's

system

to track

NPP comoitments.

The

inspector

concluded

that, the

purpose

of this IFI was

adequately

resolved

by the

licensee's

'NPP

commitment.

The resolution

and

closure of

NPP

commitments will be

addressed

by the

NRC for the

restart of Unit 2.

This item is closed.

(CLOSED) IFI 259, 260, 296/87-02-06,

System

Walkdowns.

This item was originally identified when the inspector

reviewed the

licensee's

configuration control

program.

The IFI contained

three

specific

areas

with

the

majority of

the

emphasis

on

the

Configuration Control Drawings.

All items with the exception of the

item dealing

the

FSAR updating

were closed

in IR 87-42

and 89-35.

The

remaining

item involved the correcting'f

FSAR figure 8.5-2.

The

licensee

is

currently

updating

the

FSAR

including all

modifications

and

design

issues.

This process

includes

reviews

by

technical

personnel

including the

system

engineers.

Based

on this

method

and the total updating of the

FSAR, this item was adequately

addressed.

This item is closed.

(CLOSED)

IFI

259,

260,

296/88-33-01,

Lack of

Locked

Valve

Criteria.

This item concerned

the 'criteria for and

use of locking chains

on

plant valves.

Two specific

valves

were

used

as

examples.

The

'licensee

formalized

the criteria

by issuing

procedure

GOI-300-3,

General

Valve Operations,

on

December

7,

1989.

This procedure

not

only listed the locked valve criteria, but Attachment

1 is

a 58 page

list of all locked valves

by valve number,

valve description,

and

required position for normal plant operation.

Procedure

GOI-300-3

is

now

the

"Yiaster"

procedure

for locked

valve criteria

and

performing

locked

valve verification.

The

system

operating

instruction checklists

have

been

revised

to the

requirements

of

GOI-300-3

and verification is

complete.

The

valve

verification will be

performed

by using

GOI-300-3

instead of the

various

system

OIs.

The inspectors

have reviewed

the procedure

and

its implementation,

including the

two examples

cited

and

have

found

the licensee

response

acceptable.

This item is closed.

(OPEN)

IFI

259,

260,

296/89-27-03,

Verification That

DG Output

Breakers

Recharge

in 2.5 Seconds

or Less.

This

item

addressed

the

steps

being

taken

to

ensure

that this

significant modification was adequately

addressed

by the appropriate

plant procedures.

19

The licensee

indicated

that

the timing of the

DG breakers

would

occur

only during

the

performance

of procedure

EMI 7.9, Initial

Installation,

Test,

and

Checkout

of

4KV Circuit Breakers

and

Procedures

for Alignment of Circuit Breakers

to Cubicle.

The

inspector

reviewed

the procedure.

It indicated that the recharge

time of the

DG breakers

would be tested

only for a

new breaker or if

a rebuilt breaker

was being placed'in

the

DG output breaker cubicle

of the

shutdown

board

and it had not been

in that specific cubicle

before.

That

would mean,a

DG breakers'echarging

time would

be

tested

every five years

and only if a different rebuilt breaker

was

going -to

be used.

Therefore,

the

DG output breakers

do not have

a

testing interval for verifying that the recharge

time is 2.5 seconds

or less.

During the

a

LOP/LOCA situation

where

the

.DG output breakers

take

longer than

2.5

seconds

to recharge,

a possibility exists that the

DG output

breakers

would fail to reclose

due

to the

antipump

circuity of

each

breaker.

Additional

discussions

with the

licensee's

system engineering

group indicated

they have

an excellent

understanding

of this issues.

They informed the inspector

of the

following:

The

3

second

time delay relays

are calibrated

in accordance

with SI-4.9.A.4.c,

4160V

Shutdown

Board Under/Degraded

Voltage

Time Delay Relay Calibration.

The verification that the

8

DG output breakers will recharge

in

2.5

seconds

or less will be

made

a yearly requirement

as part

of the SI

~

The

inspector

reviewed

SI-4.9.A.4.c

and

noted

that section

1.2,

frequency,

stated:

This

SI is to

be

performed

annually

and

when

required

by

maintenance

performed

on

the relays.

Degraded

Voltage

and

Diesel

Breaker

timing relays will be calibrated

every six

months.

Additional

changes

to the surveillance

program instructions

for

the

4160Y. shutdown- boards

involving the eight

DGs output breakers

are

needed.

This

item will remain

open

pending

review of these

changes.

(CLOSED)

IFI

259,

260,

296/89-43-06,

Non-Intent

Changes

to

Surveillance Instructions.

This

item involved

a

concern

over

the

abnormal

number

(nine) of

non-intent

procedure

changes

(NICs) which were

issued

during the

validation

performance

of

procedure

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

Diesel

Generator

B Annual Inspection.

The inspector

considered

the large

number of changes

to

be

excessive

since

the

had already

been

through

the verification review process.

The inspector

also

noted

20

'that

some of the

NICs were required to complete

the SI.

This item

was

opened

pending further review of the licensee's

usage of NICs.

The inspector

reviewed

the licensee's

closure

package for this item.

Procedure

SDSP-2. 11,

Implementation

and

Change of Site

Procedures,

covers

the generation

and

usage of NICs. 'n response

to the large

numbers

of NICs generated

for many site

procedures,

including the

subject SI, the licensee

revised

SDSP-2. 11 to restrict the

scope of

NICs and simplify the wording of the criteria for determination of a

NIC.

These

revisions

should

ensure

that

NICs are

used for minor

changes

and will not

change

the

scope

of procedure

steps.

The

inspector

reviewed

a compilation of NICs for the period of August

1989,

through

March

1990,

and

noted that

the

number

of NICs

had

decreased

significantly

since

the

revisions

to

SDSP-2. 11

were

implemented.

This

reduction

can be'ttributed

to the

SDSP-2.11

'evisions

and

improvements

made

to the

procedure verification

and

validation program.

This item is closed.

(CLOSED)

IFI

259,

260,

296/89-47-02,

Unit

1

Cross-Tie

Operability.

TS 3.5.B. 11

requires

that

two

pumps

and

associated

heat

exchangers

from an adjacent

unit

be

whenever

irradiated

fuel is in the reactor

and

when pressure

is greater

than atmospheric.

The licensee

plans to use

the Unit

1

RHR System II to provide backup

to Unit 2 and to meet these

requirement.

This IFI was

opened

since

it was unclear

what the licensee's

intentions

were regarding Unit

1

RHR operability for seismic,

Eg, fire protection,

and

system

operation.

The

licensee

conducted

a

systematic

review of the

various

Unit

2 programs

to determine their need for the Unit

1

backup.

No requirements

were identified for Eg and fire protection.

The inspector

discussed

this with the applicable

NRR reviewers

and

likewise

no

issues

were identified.

The Unit .1

RHR System

I to

System II crosstie

line is not seismically qualified.

To provide

a

seismically qualified

backup

to Unit 2

a

seismically

qualified

blind flange will be installed.

This work will be accomplished

under

DCN W9364A.

The inspector

reviewed

the

DCN

and drawings.

This

design

change

fixes the seismic

boundary

and avoids significant pipe

support

modification

required

to

seismically

qualify existing

pressure

boundaries.

The

inspector

concluded

that this

design

change

provided

a seismically qualified

RHR backup to Unit 2.

Unit

2 OI-74,

Residual

Heat

Removal

Opera'ting

Instruction,

was

reviewed.

Section

8=..18 of Revision

14,

dated April 5,

1990,

contains

instructions for initiation of shutdown cooling using the

RHR Unit

1 backup.

The

issues

concerning

the

RHR unit to unit cross

connect

are

resolved.

This IFI is closed.

(CLOSED)

URI

259,

260,

296/89-43-02,

Adequacy

of

Flow

During O-SI-4.2.8-67.

21

This

item involved

a concern

on the

adequacy

of the valve lineup

used

during the performance of procedure

O-SI-4.2.8-67,

RHR Service

Water -Initiation Logic.

The lineup utilized in the SI connected

the

discharge

of all of the

pumps to both

EECW and

RHRSW service.

The licensee

was in the process

of performing

a safety evaluation at

the

end of the inspection

period to determine

whether the resulting

flow would meet

TS requirements

for

RHRSW flow through the

RHR heat

exchangers

during accident conditions.

This iteq was

opened

pending

NRC review of the completed safety evaluation.

The inspector

reviewed the licensee's

closure

package for this item,

including the

completed

safety evaluation.

The

RHRSW system is

a

standby

system

that

must

be

manually initiated

and

aligned

to

perform its safety functions.

Chapter

10.9 of the

FSAR allows

1

hour to provide six

pumps to supply cooling water to the

heat

exchangers

and three

EECW

pumps for the design basis

LOCA.

The

valve lineup used

in the SI did not affect

RHRSW system flow since

licensed

operators

were available

to place

the system into service

in the event of an accident. 'he

valve lineup did not affect

EECW

system

flow since

four

pumps

are

dedicated

to

EECW service.

The

inspector

concluded that the valve lineup for the

SI was acceptable

and

no violation occurred.

This item is 'closed.

(CLOSED)

URI

259,

260,

296/89-52-01,

Adequate

Inventory

Controls of Special

Nuclear Materials.

During

a routine radiation

protection

inspection,

the

inspectors

were

made

aware of special

nuclear material accountability problems.

Since this

URI was

opened,

a special

SNM inspection

was

conducted.

A notice of violation and

proposed

imposition of civil penalty

was

issued for IR 259,

260,

296/89-55

on May 2,

1990.

The issuance

of

the

NOY closes

the URI.

TVA's response

to the

NOV will be evaluated

in future inspections.

(CLOSED)

VIO 259,

260,

296/86-25-06,

Failure

to Maintain

Records

of Facility Changes,

Including the

10 CFR 50.59 Safety Evaluation.

This violation resulted

from

a

change

to plant flood protection

features.

Originally, flood doors

to the

reactor

building

and

radwaste

building were maintained

closed

except for personnel

and

equipment

access

as

stated

in the

FSAR.

In

1981,

the

licensee

changed

this practice

to maintain

the

doors

normally open.

When

questioned

by

a

NRC inspector

in

1986, no'0

CFR 50.59 safety

evaluation

could

be

retrieved

to

document

acceptability

of the

change.

The

licensee's

corrective

actions

consisted

of reevaluating

the

existing conditions

and performing

a

new safety evaluation.

A

NRC

inspector

reviewed

the

new safety

evaluation

and

documented

the

findings in IR 88-32.

The evaluation

adequately justified revising

the

FSAR to reflect leaving the doors

open

and the revision was

made

in

Amendment

5 to

the

FSAR in August

1987.

The evaluation

recommended

that

the

Bases for Section

3.2 of the

TS

be

changed

to

,22

delete

the statement,

"Plant flood protection is always in place

and

does

not depend

in any way on advanced

warning."

This statement

was

not

accurate

under

the

circumstances

since

operator

action

was

required

to close

the flood doors.

As of October

18,

1988, this

change

had not

been

made.

The evaluation additionally recommended

that

an

administrative

instruction

be

developed

to ensure

that

operators

close

the

flood

doors

whenever

the

Wheeler

Reservoir

elevation

reaches

558 feet.

The plant

responded

by adding

the

necessary

operator

action, to procedure

ARP 1-BFARP9-20,

Panel 9-20.

The

inspector

considered

this

to

be

inappropriate

since

the

entry condition into the procedure

was

the actuation of the

"Lake

Elevation High" alarm which occurs at 564 feet.

This alarm point is

6 feet above that at which operator action is required

by the safety

evaluation.

This item was left open

pending licensee

resolution of

the above

two outstanding

issues.

The inspector

reviewed the licensee's

closure

package for this item

and determined

the following:

(1)

The

licensee

had

a

commitment

to revise

the

TS

Bases

for

Section

3.2

by

October

31,

1990,

and

was

tracking

the

completion of this item on the commitment tracking system

under

item number

NC0860334008.

(2)

Steps

were

added

to GOI-300-1,

Operations

Routine

Sheets,

to

require verification that

the reservoir

level

is less

than

558 ft.,

or if flood water

enters

the

service

building

corridor, the

doors

and

hatches

listed in Attachments

1 and

2

of O-AOI-100-3, Flood Above Elevation

565 ft., must

be closed.

The

inspector verified that Attachment

1 contained

the flood

doors for the reactor

building

and

radwaste

building.

The

inspector verified that the approved

procedures

were in place.

Based

on the requirements

contained

in the

GOI, AOI, and

ARP,

and

the commitment to revised

the

TS Bases,

this item is closed.

(CLOSED)

259,

260,

296/88-05-03,

Failure

to

Follow

Procedures

-

2 Examples.

This violation was

issued for two examples

of the'ailure

to follow

procedures.

The first example

involved surveillance testing

on the

SGTS.

This example

was

reviewed

and. closed in IR 88-34.

The second

example

involved the failure to initiate a,LRED for a reportability

determination

when rust

was

found in the containment

spray

header.

A

LRED was

subsequently

initiated following discussions

with

NRC

inspectors.

The

inspector

reviewed

the, licensee's

response

to

second

example

of the violation.

A -CARR

was initiated

as

the result of

an

inspection

which revealed

clogged containment

spray

header

nozzles.

As part of the

CARR review,

a determination

was

made that

the

finding was

not reportable.

The

CARR was

taken to the

SOS

on duty

23

who

incorrectly

decided

that'

'LRED

was

not

required

since

reportability had already

been

addressed

on the

CARR.

This was not

in accordance

with

PMI 15.4,

Unique Reporting

Requirements,-

which

governs

the initiation of LREDs.

As corrective

actions,"

a

LRED

was

subsequently

issued

and

an

informational

LER was submitted to the

NRC.

A critique of the event

was also

prepared

and reviewed

by the

SOSs,

STAs,

and reportability

engineers.

The critique emphasized

the requirements

of PMI 15.4.

The inspector

concluded

that this event

was

an isolated

occurrence

and

adequate

corrective

actions

were

implemented.

The inspector

noted that

LREDs are

used conservatively

by the current operations

staff.

This item is closed.

k.

(CLOSED)

259,

260,

296/89-08-02,

Failure

to

Perform

Surveillance

on Shutdown

Board Batteries.

During

a

the

licensee

informed

the

NRC

inspectors

that 2-SI-4.9.A.2.a-2,

Meekly Check for Shutdown

Boards

C

and

D Batteries,

was not performed within its

TS required frequency.

This violation was

issued for a failure to meet

TS requirements

for

the performance of surveillance testing.

The

licensee

responded

to

the

violation

by letter

dated

May 12,

1989.

The inspector

reviewed

the

response

and

noted that

the

licensee

admitted

the violation

and attributed

the

cause

to

inadequate

control

and

tracking of survei llances

and

personnel

error.

The licensee

performed

the following corrective actions

and

the inspector verified that they were complete.

The

missed

was

successfully

performed

on

the

C

and

D

shutdown

board batteries.

I

The surveillance

scheduling

and tracking program

was evaluated

as

part of

a

task

force

reviewing

the entire surveillance

program.

A SI task

force

recommendation

was

implemented

requiring

the

work control unit to ensure

positive verification that

a SI

has

been

completed

on

the

due

date.

This

requirement

was

proceduralized

in PMI 17.1, Conduct of Testing.

This item is closed.

This example

was included

as part of a special

inspection

on SI program deficiencies

(IR 89-43) which resulted

in a

severity

level III violation.

Review of the overall

program

upgrades will be conducted

during the followup of VIO 89-43-01.

l.

(CLOSED)

259,

260,

296/89-33-03:

Failure

to

Follow

Procedure.

0

24

This violation involved two examples

of failure to follow procedures

during the performance of

EECW pump surveillance testing.

The first

example

was

the failure to take complete vibration data.

The second,

example

was

the failure to complete

the analysis

of the

SI data

within the

4 working day time frame required

by the SI.

The data

analysis

was

not completed until six days following performance of

the SI.

The

inspector

reviewed

the licensee's

response

to this violation

dated

September

25,

1989.

The licensee

admitted the first example

of the violation.

The reason for the violation was

personnel

error

in that

an operator initialed the step which noted that displacement

vibration

amplitude

was

within the

limits of the

acceptance

criteria.

This

was

due to misinformation provided to the operator

from

a

mechanical

test

technician

who didn't clearly

know the

vibration baseline

status

for the

pump being tested.

In May 1989,

the

licensee

received

relief from

the

NRC

changing

vibration

requirements

from the displacement

vibration amplitude to a velocity

vibration

amplitude

method.

Because

of this

change,

velocity

vibration data

was

recorded

instead of displacement

vibration data

during the SI; however,

the velocity vibration baseline

had not been

established

at the

t'ime .of the test.

The deficiency

was

noted

by

the licensee

during

a technical

review of the completed SI.

At that

time,

the

pump

was

declared

inoperable

and

a retest

was

performed.

The retest

confirmed that the

pump met the displacement

vibration

acceptance

criteria.

The operator

involved was counseled

on signing

off steps without complete information.

This example is closed.

The licensee

denied

the

second

example of the violation.

The reason

for the denial

was that the six day analysis

included Saturday

and

Sunday

which are

not

normal

working days for the Mechanical

Test

Section-.

Therefore,

only four working

days

were

required

to

complete

the analysis.

This denial

was

accepted

by the

NRC in an

acknowledgement

letter

dated

October

16,

1989.

This

example

is

closed.

(CLOSED)

259,

260,

296/89-47-01,

Document

Control

of

Technical Specifications.

This violation concerned

three

examples

of where

BFN TSs

were not

maintained

in accordance

with SDSP 2.2, Controlling Documents.

The

first example

was

where

TS Amendment

135,

131,

106

had

been entered

into the controlled

copies

but not into the plant licensing master

copy.

Subsequently,

TS Amendment

158,

157,

129 revised different

information

on

the

same

page

resulting

in inadvertent

use

of

outdated

wording that

had

been

changed

by

TS

Amendment

135,

131,

106.

The

licensee

has

corrected

the

mix

up

and

submitted

the

correct

TS

page

to the

NRC.

The inspectors

have verified that the

TS amendments

are correct.

25

The

second

example

was

that- TS controlled copy 52 was not properly

maintained with the latest

amendment

to TS.

Example three

was that

Unit 2 Control

Room

TS Copy 40 was not properly maintained

in that

two copies

of page

3.7/4.7-16

existed

but only one

was

annotated

with information pertaining

to

compensatory

measures

88-64-2-007

which was in effect at the time.

These

two examples

were resolved

by

a

1005 audit of all

TS controlled

copies.

Further,

Document

Control

procedure

DCRM 302.2

was

issued

to describe

and control

audits

of various controlled

documents.

Section

2.2.A requires

a

100% annual

audit

on manuals

contained

in the Technical

Information

Center

and

Key Distribution Points.

As

a result of the initial

audits,

only a few minor additional discrepancies

were identified by

the

licensee

which

have

been

corrected;

The

NRC inspector

has

reviewed

DCRM 302.2

and

the audit

schedule

and

determined

the

licensees

action

on this violation is acceptable.

This violation is

closed.

No violations or deviations

were identified during the Followup of Open

Inspection

Items.

10.

Power Supply Concerns

An inspector

reviewed

Condition Adverse to Quality

power supply events

as part of IR 90-01.

The

inspector

noted that

numerous

RPS trips

had occurred

due to power supply

difficulties.

In addition,

the

inspector

expanded

IFI 88-28-03

to

include all three

BFN units

due

to- the potential effects of having

an

ESF

actuation

in Units

1

and

3 during Unit

2 operation.

However,

IFI

88-28-03

was previously closed

by inspection

in IR 89-.35.

This IFI will

remain

closed

and

the followup of all

RPS circuit protector

and

power

supply concerns will be tracked

by LER 296/90-01.

11.

Site Management

and Organization

(36301,

36800,

40700)

During this

inspection

period,

two senior

site

management

changes

occurred.

The Plant Manager

and the Project

Engineer

have

been replaced

with individuals

from within TVA.

The

new Plant

Manger

was recently

hired

from

INPO

and

was working

on Unit 3 restart

plan.

The Project

Engineer

has

been

at

BFNP

working in Nuclear

Engineering.

Both

individuals appear

to be fully qualified for this position.

One area of

concern

exists

in the

area

of Emergency

Preparedness.

Since

the last

full participation

EP exercise

several

key site individuals

have

changed

and their experience

in

BWRs is limited.

The

new Plant Manager is from

INPO and

a

CE plant.

The Operations

Manager is from a

BSW plant.

The

Technical

Support

Manager

is from a Westinghouse

plant.

All three of

these

individuals are

key players

in an event.

Due to their inexperience

at

BFNP or even

a

BWR plant alternates

must

be- used.

With the

new Plant

Manager, it is not clear

who will be the Site

Emergency Director or when

the

new managers will be fully qualified to assume their leadership

roles

during

an event.

A successful

full participation

graded

EP drill should

be

completed

before

Unit

2 restart

using all the

permanently

assigned

event responders.

26

In general,

turnover

of site

personnel

continues

to

be

high.

The

licensee

needs

to strive for staff stability which will lead to

a

"BFNP

team" that

can

function in unison

to support

the Unit

2 restart

and

testing

program.

Nuclear Safety Review Board

This inspection

concerned

mainly the activities of the Nuclear Safety

Review

Board

(NSRB).

The

requirements

of the

NSRB are specified

in

TS 6.5.2.

The

two upper tier corporate

documents

that provide guidance

on

the activities of the

NSRB are

NP Standard

STD 1.1. 1. Revision 0,

Nuclear

Safety

Oversight,

Section

2.2.;

NSRB

Requirements;

and

NP

Directive

DIR 1.1.

Revision

0, Nuclear Safety Oversight,

Section 3.2.1

NSRB.

These

two

procedures

were

reviewed

to

determine if the

requirements

of

TS 6.5.2

were fully implemented.

DIR 1. 1

provided

basically

the

same list of review

and audit activities

as

TS 6.5.2.1

except it added

non-destructive

testing

and did not clearly identify

Quality Assurance

Practices.

The only potential

problem

was that under

the qualification sections

(TS 6.5.2.3)

the

members

are required to have

a minimum of five years

experience

in 'at least

one of the technical

areas

of TS 6.5.2. 1.

A situation could exist where under

DIR 1.1

a person with

only NDT background could'be

on the

NSRB and counted for a quorum,

when in

fact

he is not even eligible for participation

on the

NSRB per the

TS.

Procedure

DIR 1. 1.

as written has the potential

to delete

the requirement

of the

TS.

This was discussed

with the

NSRB Chairman

and

he immediatel'y

issued

DCN-2,

an interim change

to DIR 1. 1 to make the procedure

exactly

match the TS.

No member

or alternate

on the

BFN NSRB fit this situation

in qualification for the board.

In DIR l. 1 mention is

made of the

use of subcommittees

which may not be

made

up of

NSRB

members

to conduct the business

of the

NSRB.

Also the

use

of teleconferencing

for

NSRB meetings

is outlined.

Both of the

practices

are

neither

allowed or prohibited

by the

TS.

Both of the

practices

are

used

throughout

the industry but they must

be carefully

controlled

by the

NSRB to ensure

that the

NSRB function does

not

become

diluted.

The

inspector

reviewed

the

resumes

of ten full board

members

and five

expert advisor

board

members

(non-TVA).

These

resumes

were

accompanied

with the

appointment letter to the

NSRB signed

by the

TVA Senior

Vice

President,

Nuclear

Power,

dated

January

10,

1990.

No discrepancies

were

identified with either the experience

levels of the

NSRB or the letter of

appointment.

The mix of areas

of expertise

was'road

enough to ensure

the requirements

of TS 6.5.2.1

were met.

The inspector also reviewed the charter for the following subcommittees:

USQD Subcommittee

Quality Assurance

and Safety Oversight Subcommittee

Chemistry,

Waste

Management,

Radiological

Control Subcommittee

Engineering

Subcommittee

Operations,

Maintenance,

and.Modifications

Subcommittee

0

27

These

charters

were all

concise,

provided clear

purpose

as

well

as

function/scope

sections,

and

were fully acceptable.

The inspector also

reviewed

four selected

NSRB implementing

procedures.

These

procedures

were clear

and accurate

to provide guidance

in the applicable

areas.-

The

NSRB meetings

are generally

held at

BFN on approximately

a one month

frequency.

Generally,. but not always,

there is senior TVA'anagement in

attendance

for at least part of the meetings.

The meeting usually lasts

two days.

The first day is overview and subcommittee

work.

The

second

day is

a full board meeting,

subcommittee

presentations

and

an executive

meeting.

A resident

generally

attends

all or part of these

regular

meeting

when held at

BFN.

The presentations

are

good

and the board

asks

thorough questions.

Action items are assigned

and old action

items are

discussed

for closure.

For example,

during the

NSRB meeting

number

245

held

on March 27-28,

1990,

there

were nine

new action

items

added to the

list of eleven

existing

items.

The backlog is adequate

with no long

overdue

item.

The oldest

was about

seven

months.

The

NSRB action item

tracking system is good.

The inspector

reviewed

the

gA audit schedule

and concluded that the audit

matrix is correct

in scheduling

audits

required

by

TS 6.5.2.8 at the

required frequency.

'

brief review of selected

audits indicates

they are

of

good quality

and

have

appropriate

findings.

A review of the

transmittal files indicate that the submittal

requirements

of TS 6.5.2. 10

are

being met in all examples

reviewed.

The

NSRB Chairman

and Techni'cal

Secretary

were

very helpful

and responsive

to the inspectors

questions

and requests.

No open items were identified.

Exit Interview (30703)

The iyspection

scope

and findings were

summarized

on

May 18,

1990 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, 296/90-14-01

259, 260, 296/90-14-02

259, 260, 296/90-14-03

259,

260, 296/90-14-04

259,

260, 296/90-14-05

URI, Problems with Surveillance

Instructions,

paragraph

2.

URI, Failure to Follow SI, paragraph

2.

IFI, Effects of Phase

Unbalance

on Safety

Related Electrical

Systems,

paragraph

4.

VIO, Failure to Implement Drawings

and

Procedures,

paragraph

5.

VIO, Failure to Implement IV, paragraph

5.

28

AOI

BFNP

BSW

CAQR

CFR

DCN

GOI

IFI

INPO

IR

IRM

IV

KV

LCO

LER

LOP/LOCA

LRED

MAI

fiG

NE

NI C

NRC

OSIL

PMI

Abnormal Operating Instruction

Average

Power

Range Monitor

Annunciator Response

Procedure

Browns Ferry Nuclear Plant

Boiling Water Reactor

Babcock

5 Wilcox

Condition Adverse to Quality Report

Combustion Engineering

Code of Federal

Regulations

Design

Change Notice

Diesel Generator

Engineering

Change Notice

. Emergency

Equipment Cooling Water

Electrical Maintenance

Instruction

Emergency Notification System

Emergency

Preparedness

Environmental Qualification

Engineered

Safety Feature

Flow Control Valve

Final Safety Analysis Report

General

Operating Instructions

Inspector

Followup Item

Institute of Nuclear

Power Operations

Inspection

Report

Intermediate

Range Monitor

Independent Verification

Ki 1 ovolt

Limiting Condition for Operation

Licensee

Event Report

Loss of Power/Loess

of Coolant Accident

Licensee

Reportable

Event Determination

Modification Addition Instruction

Motor Control Center

Motor Generator

Management

Review Committee

Maintenance

Request

Non-Cited Violation

Nuclear Engineering

Non-intent Procedure

Change

Nuclear Performance

Plan

Nuclear Regulatory Commission

Nuclear Reactor Regulation

Nuclear Safety Review Board

Operating Instruction

Operations

Section Instruction Letter

Primary Containment Isolation System

Plant Manager Instruction

Plant Operations

Review Committee

Problem Reporting

Document

Quality Assurance

0

29

SDSP

~