ML18036A471

From kanterella
Jump to navigation Jump to search
Insp Repts 50-259/91-40,50-260/91-40 & 50-296/91-40 on 911017-1115.Violations Noted.Major Areas Inspected:Maint, Surveillance,Operational Safety,Mods,Unit 3 Restart Activities & Cold Weather Preparations
ML18036A471
Person / Time
Site: Browns Ferry  Tennessee Valley Authority icon.png
Issue date: 11/26/1991
From: Kellogg P, Patterson C
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML18036A469 List:
References
50-259-91-40, 50-260-91-40, 50-296-91-40, NUDOCS 9112120116
Download: ML18036A471 (34)


See also: IR 05000259/1991040

Text

gp,fl ASCII

UNITEDSTATES

~ NUCLEAR REGULATORY COMMISSION

REGION II

101 MARIETTASTREET, N.W.

ATLANTA,GEORGIA 30323

Report Nos.:

50-259/91-40,

50-260/91-40,

and 50-296/91-40

Licensee:

Tennessee

Valley Authority

6N 38A Lookout Place

1101 Market Street

Chattanooga,

TN

37402-2801

Docket Nos.:

50-259,

50-260,

and 50-296

License Nos.:

DPR-33,

DPR-52,

and

DPR-68

Facility Name:

Browns Ferry Units 1, 2,

and

3

Inspection at Browns Ferry Site near

Decatur,

Alabama

Inspection

Conducte

October

17 - November 15,

1991

Inspector:

C.

atterson

>or

ide

I

pector

Da e

S gne

Accompanied

by:

E. Christnot, Resident Inspector

W. Bearden,

Resident

Inspector

Approved by:

Pau

J.

Ke

ogg,

ion

f,

In p

TVA Projects

D v'on

rl Z~

Date

S

ne

SUMMARY

Scope:

This routine resident

inspection

included surveillance

observation,

maintenance

observation,

operational

safety

verification,

modifications,

Unit 3 restart activities, cold weather preparation,

and action

on previous inspection findings.

Results:

One violation with three

examples

for failure to follow procedure

for control of electrical

systems

was identified,

paragraph

four.

The first two examples

resulted

in unexpected electrical transients.

Inadequate

identification of electrical

components

attributed to one

of the transients

and

was the reason for the third example.

The first example

occurred

when

an

operator

failed to follow

procedure

to

open

the

generator field excitation

breaker

after

opening

the generator

output breaker.

This resulted

in actuation

9112120116

911127

PDR

ADOCK 05000259

8

PDR

0

of the reverse

power relay causing

an electrical transient.

Plant

operators

tripped

the

reactor

due

to

the

number of unexpected

equipment

responses.

The second

example occurred

when auxiliary plant operators

pulled the

wrong fuses

during

a routine tagout of a diesel

generator.

The hold

order clearance

was not followed to specific unique identification or

physical

location of the fuses.

Plant operators

were unaware of the

fuse tabulation drawings

and fuse unique identifiers

on configuration

control drawings.,

The fuse control

program

was established

in part

under

the Nuclear

Performance

Plan.

A contributing'factor to this

was the use of less

experienced

auxiliary plant operators

instead of

licensed operators

to pull fuses.

The third example

was for failure to maintain labeling of a drywell

blower

power

supply

following

a modification.

The

inspector

identified the breaker

power supply labeled

on two different power

sources.

An unresolved

item

was identified

concerning

the

control

of

a

telecommunications

sub-contractor,

paragraph five.

A stop work order

was issued

by the licensee's

equality Assurance

department

because

the

sub-contractor

work activities

were

being

performed without work

packages.

The licensee

is conducting

an incident investigation of

this problem.

The licensee

conducted

a thorough, timely, self-critical evaluation

of the manual trip that occurred

on October

18, 1991,

paragraph four.

However,

the

number of items

needing correction

on the simulator and

operator

awareness

indicated

a

weakness

in conducting

a

plant

shutdown evolution.

A contractor

work release

program

and associated

pilot programs

has

been

established

for Unit 3 construction

contractors,

paragraph

6.

Initial discussion

with Unit 3 managers

indicated

a general

lack of

understanding

of these

programs.

0

0

REPORT

DETAILS

Persons

Contacted

Licensee

Employees:

  • 0. Zeringue,

Vice President,

Browns Ferry Operations

  • H. McCluskey, Vice President,

Browns Ferry Restart

  • J. Scalice,

Plant Manager

J. Swindell, Restart

Manager

M. Herrell, Operations

Manager

J. Rupert, Project Engineer

  • M. Bajestani,

Technical

Support Manager

  • R. Jones,

Operations

Superintendent

A. Sorrell, Maintenance

Manager

G. Turner, Site guality Assurance

Manager

  • R. Baron, Site Licensing Manager
  • J. McCarthy, Unit 3 Licensing

P. Salas,

Compliance Supervisor

  • J. Corey, Site Radiological Control Manager

Other

licensee

employees

or contractors

contacted

included

licensed

reactor

operators,

auxiliary operators,

craftsmen,

technicians,

public

safety officers, quality assurance,

design,

and engineering

personnel.

NRC Personnel:

P. Kellogg, Section Chief

  • C. Patterson,

Senior Resident

Inspector

  • E. Christnot, Resident

Inspector

W. Bearden,

Resident

Inspector

  • Attended exit interview

Acronyms

and initialisms used

throughout this report are listed in the

last paragraph.

Surveillance Observation

(61726,

61700)

The inspectors

observed

and reviewed the performance of required SIs.

The

inspections

included

reviews

of the

SIs for technical

adequacy

and

conformance

to

TS,

verification of test

instrument

calibration,

observations

of the conduct of testing,

confirmation of proper

removal

from service

and return to service of systems,

and reviews of test data.

The inspectors

also verified that

LCOs were met, testing

was accomplished

0

0

by qualified personnel,

and the SIs

were

completed within the required

frequency.

The following SIs were reviewed during this reporting period:

a

~

O-SI-4.7.B.l.b-2,

Standby

Gas

Treatment Filter Train

B Humidity

Control Heater Test.

b.

C.

This testing is performed

to determine

the operability of the

SBGT

Filter Train

8 Humidity Control circuitry per ANSI N510-l975

and to

verify that the heaters

have

an actual

output of at least

40

KW in

compliance with the

requirements of'S 4.7.B.l.b.

The inspector

reviewed

the

documentation

associated

with

the

most

recently

completed

performance

for this

surveillance

requirement.

The

activity has

an annual periodicity and was performed last on January

17,

1991.

The inspector did not identify any deficiencies

with the

completed surveillance test.

2-SI-4.4.A.2,

Standby Liquid Control Functional Test.

This testing is performed

to determine

the operability of the

SLC

System in compliance with the requirements

of TS 4.4.A.2 and 4.6.G.l

The inspector

reviewed

the

documentation

associated

with the most

recently

completed

performance

for this surveillance

requirement.

The activity is performed

once per operating cycle and was performed

last

on

December

3,

1990.

The inspector

did not identify any

deficiencies with the completed surveillance test.

2-SI-4.7.A.5.c, Control Air/Drywe11 Air Isolation Verification.

This test verifies that the control air supply valve to the Drywell

Control Air System is closed to satisfy the requirements

specified in

TS 4.7.A.5.c.

The inspector

reviewed

the documentation

associated

with

the

two

most

recently

completed

performances

for this

surveillance

requirement.

The activity is performed

once

per month

and

was performed last

on October 6,

1991

and November 3,

1991.

The

inspector

did not identify any deficiencies

with the

completed

surveillance tests.

d.

2-SI-4.2.B-21FT,

Core Spray

Pump Discharge

Pressure

Functional Test.

This test is performed to determine operability of Core Spray

Pump

Discharge

Pressure

Channels,

2-PS-75-7,

2-PS-75-16,

2-PS-75-35,

and

2-PS-75-44,

in order

to satisfy

requirements

of

TS 4.2.B.

The

inspector

observed

portions

of the

ongoing testing

performed

on

November

7,

1991.

The inspector did not identify any deficiencies

wi.th conduct of the surveillance test.

No violations

or

deviations

were

identified

in

the

Surveillance

Observation

area.

~

~

~

~

~

3.

Maintenance

Observation

(62703)

Plant

maintenance

activities

were

observed

and

reviewed

for selected

safety-related

systems

and

components

to ascertain

that

they

were

0

conducted

in accordance

with requirements.

The following items

were

considered

during

these

reviews:

LCOs maintained,

use of approved

procedures,

functional testing and/or calibrations

were performed prior to

returning

components

or

systems

to service,

gC

records

maintained,

activities accomplished

by qualified personnel,

use of properly certified

parts

and

materials,

proper

use

of

clearance

procedures,

and

implementation of radiological controls

as required.

Work documentation

(MR,

WR, and

WO) 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.

The

inspectors

observed

the following maintenance

activities

during this

reporting period:

a.

Unit 2 Preferred

Motor Generator

WO 91-42556-00

was

used

to troubleshoot

the Unit 2 Unit Preferred

Motor Generator battery to armature voltage fluctuations.

The

WO had

originated

on October

25,

1991,

when

the fluctuations

were first

observed

but

the majority of the

work activities

occurred after

the unit experienced

a loss of

120

VAC Unit Preferred

Power

on

November 3, 1991.

The inspectors

followed the ongoing work activities

and

observed

work in progress

in the field.

Work performed

under

this

WO included

replacement

of the

tachometer

which

was

found

grounded,

replacement

of the

SK circuit card

which

had

a

blown

capacitor,

removal

and calibration of the

OVR and

2UFR, overvoltage

and underfrequency

relays.

The inspector also reviewed documentation

associated

with this

WO and determined

that the work instructions

were

adequate

to support

the

ongoing

work activities.

Trouble-

shooting

was

performed in accordance

with EMI-106, Troubleshooting

and

Configuration

Control of Electr ical

Equipment.

Controls

and

independent

verification for wire determination

and retermination

associated

with the card

and relay replacements

was provided

by the

appropriate

attachment

in accordance

with EMI-106.

Although

no

deficiencies

were identified with the observed

work activities,

the

inspectors

are concerned that the actual

cause of the problem may not

have

been found.'he

inspectors

plan to closely monitor licensee

activities in this area during the next reporting period.

b.

Recirculation

Loop Flow Gain Adjustments

The inspector

reviewed portions of the completed work package for WO

91-42570-00

which controlled performance

of gain adjustments

on the

flow summer for recirculation loop, 2-Fg-68-5.

Under this

WO the

applicable

portions

of 2-SI-4.2.C-7(A-1),

Power

Range

Neutron

Monitoring System

Loop

A Flow Bias Instrumentation

Calibration

and

Functional Test,

were performed.

2-SI-4.2.C-7FT,

Power

Range

Neutron

Monitoring System

Flow Bias

Instrumentation

Functional

Test,

was

performed

on the entire

loop following the completion of the gain

0

0

e

readjustments.

No deficiencies

were identified with the performance

of this

WO.

c.

Spent

Fuel

Pools

The inspector

monitored the licensee's

activities involved with the

three

spent fuel pools.

This activity included

removal of non-fuel

material,

vacuum cleaning

the spent fuel pools,

and video taping the

pools after vacuum cleaning.

All activities observed

were controlled

and adequate

results

were being achieved.

No violations or deviations

were identified in the Maintenance

Observation

area.

4.

Operational

Safety Verification (71707)

The

NRC inspectors

followed the overall plant status

and

any significant

safety matters

related

to plant operations.

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,

verification of onsite

and offsite

power supplies,

emergency

power sources

available for automatic operation,

the purpose of temporary

tags

on

equipment

controls

and

switches,

annunciator

alarm

status,

adherence

to

procedures,

adherence

to

LCOs,

nuclear

instruments

operability,

temporary alterations

in effect, daily journals

and logs,

stack monitor recorder traces,

and control

room manning.

This 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

position

and

system

alignment,

snubber

and

hanger

conditions,

containment

isolation

alignments,

instrument

readings,

housekeeping,

power

supply

and

breaker

alignments,

radiation

and

contaminated

area controls,

tag controls

on equipment,

work activities in

progress,

and radiological protection controls.

Informal discussions

were

held with selected

plant personnel

in their functional areas

during these

tours.

a ~

Unit Status

During

a controlled

shutdown

to repair

a leak in the drywell,

a

manual scram occurred

on October

18,

1991.

The details of the trip

are in the next paragraph.

The unit returned to service

on October

21,

1991

and remained at power during the rest of the report period.

Q

5

b.

Manual Reactor Trip During Controlled Shutdown

Control

Room Operations

On

October

18,

1991,

at 4:58 a.m.,

the Unit

2 reactor

was

manually scrammed

by plant operators.

The unit was undergoing

a

planned controlled

shutdown for repairs

associated

with a leak

in the drywell

when the

unplanned

manual trip occurred.

The

main

turbine

was

manually

tripped

at

4:47

a.m.,

due

to

increasing

vibration

on

number four bearing.

The operators

performed

the

necessary

steps

in

the

procedure

as

the

generator's

output breaker

was

opened

and the turbine's

steam

control valves closed.

Approximately nine minutes after opening

the

output

breaker

a reverse

power trip was

received

which

opened

two switchyard breakers.

This resulted in isolation of

Unit Station Transformers

2A and

2B.

The

4KV Recirculation

Pump

Boards failed to transfer to the

161

KV supply resulting in a

loss of recirculation flow at approximately

8% reactor

power.

The

manual scram

was

initiated within two minutes

as

a

conservative

step

due to

a large

number of unexpected

equipment

responses

which occurred.

This decision

was

reached

prior to

operations

personnel

recognizing

that the recirculation

pumps

had also tripped

a condition which would require,

by TS,

an

immediate

manual

scram.

2)

The licensee's

subsequent

evaluation

determined

that the next

step in the procedure

OI-47, directed the operators

to open the

generator field excitation breaker after opening the generator

output breaker.

This

was not performed

and

as

a result the

reverse

power relays

actuated.

This is the first example of

three

examples

for failure to follow procedure for control of

electrical

system

as

required

by

TS 6.8.1,

Procedures.

This

violation is identified as

VIO 259,

260, 296/91-40-01,

Failure

to Follow Procedures

for Control of Electrical

Systems.

Technical

Support

Group

The inspector

reviewed

and

observed

the licensee's

Technical

Support group activities following the reverse

power trip on the

main generator.

These activities also involved the failure of

the recirculating

pump switchgear

to transfer

from the

normal

power source to the alternate

source.

The licensee

began

a troubleshooting

action plan which involved

the checking of the various relays

associated

with the reverse

power logic network.

The results

of the

troubleshooting

indicated that all relays

and logic network functioned within

acceptable

parameters

and

responded

to

a

reverse

power

indication.

Additional review by the licensee

indicated that

with the generator

output breaker

open,

the field breaker

closed

and the turbine in

a coast

down, the network would attempt to

maintain voltage

and current

from the exciter.

Under these

conditions

a reverse

power trip could be actuated.

0

0

When

this

occurred,

two

switchyard

breakers

opened

and

disconnected

the Unit 2 main transformer

from the grid.

This

cut off the

normal

power to the

2A and

2B

USSTs

and in turn to

the

2A,

2B,

2C Unit Electrical

Switchboards

and

the Unit 2

Recirculation

Switchboard.

The three unit electrical

boards

transferred

to their respective alternate

power supplies

and the

recirculation electrical

board did not.

This resulted in a loss

of unit recirculation

pumps

and

the

reactor

was

manually

scrammed.

The Unit 2

1E electrical

system

was not affected

because

a loss of power or a degraded

voltage condition did not

exist as

a result of the switchyard breaker actuations.

The

licensee

determined

that the failure to transfer of the

recirculation switchboard

was most likely caused

by the transfer

switch being in the manual position.

This was the only way that

the post trip testing could duplicate the failure.

The inspector

determined

from this review and observations

that

the licensee

performed

an indepth troubleshooting

and testing

process

and achieved

acceptable

results.

3)

Unit 2 Trip Report

The inspector

reviewed

Final

Event Report II-B-91-158, which

documented

the

licensee's

evaluation

of this

event.

The

inspector

noted that the report

was signed

by the Plant Hanager

and Site Vice President within two days after the event.

This

represents

a considerable

improvement

compared to the timeliness

of review for the most recent reactor

scram which occurred

on

September

14,

1991.

Additionally, the inspector

noted that the

Final

Event Report

was self critical in nature

and identified.

several

short

term

and

long term corrective action items.

As

the result

of the

review of this report several

areas

for

corrective action were identified.

The exciter field breaker

does not open automatically after

opening the generator

output breaker.

The simulator

does

not accurately

mimic the operation of

the exciter field breaker following a turbine trip.

The

recirculation

pump

boards

did

not automatically

transfer.

Operations

personnel

had difficulty performing the

RWN SI.

The

SOS

was

concerned

with establishing

plant conditions

for maintenance

too early

and before

the plant

was in a

stable

steady state condition.

0

2-FCV-2-29A flow controller was left in manual

control

by

procedure

but this caused

offgas

and

SJAE problems.

The

RBN received

a spurious

inoperable trip at 25K power.

2-FCV-2-190 would not control in automatic.

Operations

did

not start

adjustments

for reduced

load at the

recommended

points.

Scheduling of plant shutdown

was

done without reference

to

the Operations shift coverage

schedule.

Operations

crew

was

not briefed

on

expected

vibration

changes

on

main

turbine

during

power

reduction

and

feedwater

heater

removal.

The

simulator

scenarios

place

2-FCV-2-29A in the

auto

position

but operators

normally have this valve in the

manual position.

A question

was raised

on timeliness of the crew recognition

that recirculation

pump trips require

an immediate

scram.

The operations

crew was unable to close various

feedwater

valves from the control

room.

Pressure

indicator 2-PI-2-46

was broken.

Operators

had

no

indication

of

condensate

pressure

downstream

of the

demineralizers.

Plant

management

determined

the

crew

involved in the

incident needed additional training before assuming shift.

The operations

crew was not able to obtain

a controlled SI

copy in a timely manner to return the recirculation

pumps

to service.

Each of the

items

were

given either

short

or

long

term

corrective actions

to

be completed.

Although the trip report

was very thorough

and self-critical, the number of items needing

correcting indicated

a weakness

in controll.ing a plant shutdown.

b.

Incorrect

Fuses

Pulled

1)

Equipment Clearance Violation

UNR

259,

260,

296/91-38-03,

concerning

fuse

labeling

and

identification was identified after plant operators

pulled the

incorrect fuses while tagging the

1B

DG for routine maintenance.

This

caused

the

4160 volt shutdown

board to transfer

from the

0

normal

power

supply to the alternate

supply.

The inspector

concluded

that

hold

order

0-91-657,

was

not

prepared

in

accordance

with plant procedure

SDSP 14.9,

Equipment Clearance

Procedure,

Section 6.3. Establishing

a Clearance

requires that,

for components

that

are

not uniquely identified,

tags will

identify as specifically as possible

the location of the tagged

component.

For

example,

"one

inch valve three

feet

from

1-HCV-2-36".

In the preparation of tag

number 16, fuse unique identification

was not used nor was the physical location adequately

described.

Tag

number

16 read

"BKR 1822 Line Side

PT Fuse

4

Kv S/D Bd

B

Compt 3".

PT fuses

are

located

in a front and rear

panel of

breaker

compartment

3.

The line side

fuses

are in the front

panel.

The only labeling

on the front panel

is "auxiliary

panel".

On the

back

panel

the fuses

are

labeled

by

a fuse

unique identification label

and

a caution sign stating,

"CAUTION

PT

COMPARTMENT AUTOMATIC ACTIONS MAY RESULT

UPON OPENING,

OBTAIN

SHIFT

ENGINEERS

APPROVAL PRIOR

TO OPENING".

The logical choice

for a person pulling the fuses

would be the rear panel

since the

caution signs

discusses

PT compartment.

The hold order tag did

not state

the location or use

the fuse

unique identification

indicated

on the fuse label

and drawing.

Accordingly, this is

a violation of

SDSP

14.9,

Equipment

Clearance

Procedure.

TS 6.8. 1.1

requires

that

written

procedures

shall

be established,

implemented,

and

maintained

covering those

recommended

in Appendix A of RG 1.33, Revision 2,

February

1978.

Listed

in administrative

procedures

are

procedures

for equipment control.

This is the second

example of

VIO 259,

260, 296/91-40-01,

Failure to Follow Plant Procedures

for Control of Electrical Systems.

Incident Investigation

In discussion

with plant personnel

and review of the licensee's

incident investigation II-B-91-151, it was identified that plant

operators

were

not

using

UNIDS.

Inaccuracies

in the plant

drawings

was the stated

reason.

Also, in this particular

case

the

UNIDS were

reversed

for the line

and

load fuses.

The

licensee

corrected

this

using

a

PDD form.

The

inspector

discussed

with licensee

management

that the drawings listing the

fuses

were

CCDs

and

a confidence

question

should not exist.

Any

drawing

problem

should

be identified

and

promptly corrected.

Licensee

management

stated

the

UNIDS would be used for the many

drawings having

UNIDS for fuses.

0

3)

NPP Commitment for Fuse Identification

The

inspector

reviewed

the

licensee

commitments for the fuse

program.

The licensee

committed in the

NPP that prior to Unit 2

restart all class

1E fuses

would

be identified

by the

fuse

tabulation.

The fuse tabulation lists

each

fuse

by

a unique

identifier.

Also, temporary

fuse labels

have

been

placed

on

electrical

cabinets

throughout

the plant.

Remaining

to

be

completed

is

placing

the

fuse

unique identifier

on plant

electrical

drawings.

Although

many

drawings

have

been

completed,

some drawings are not complete.

In a letter titled, Status

and Schedule for Completion of Unit 2

Post-Restart

Issues,

dated

September

20,

1991,

the

licensee

identified the

commitments

made in this area.

In IR 89-59 and

in NPP two post-restart

commitments

were identified.

One was to

remove

the reference

to amperage

from the drawings

and replace

them with the

unique identifier from the

fuse

tabulation

controlled

document prior to startup

from the next refueling

outage

(cycle 6).

The

second

commitment

was

to install

permanent

fuse labeling prior to startup

from the next refueling

outage

(cycle 6).

In addition

a long term post restart

commitment

was to include

non-restart

fuses into the fuse tabulation

and drawing revision.

A submittal

would be forwarded to the

NRC providing

a plan for

these actions

by January

15,

1992.

c.

Labeling and Indication

In IR 91-38,

the inspector identified

a

URI involving the labeling

and identification of the Unit 2 Drywell Blowers.

Additional reviews

of

DCN W6839B, Modification for Cable Reroute/Replace/Retag,

and

CCD

Drawings

1-45E751-4,

2-45E751-4,

3-45E751-4,

2-453E751-1

and

2-45E75-2,

Wiring Diagram 480V Reactor

MOV Boards, indicated that the

labelling for the installation of modifications

was adequate.

The

inspector

noted that for items that were deleted

by modifications,

the

removal of outdated

labels

was not adequate.

The end result of

this activity was that the plant labeling did not reflect the

CCDs

and

various

equipments

indicated

as

having

more

than

one

power

source.

SSP

12.53,

Component

Labeling

Signs

and

Operator

Aids,

requires

that operations

be responsible

for preparing

and

hanging

labels

as modifications are

completed.

This is considered

the third

example of VIO 259,

260,

296/91-40-01,

Failure to Follow Procedure

for Control of Electrical

Systems.

One violation was identified in the Operational

Safety Verification area.

1

0

I

10

5.

Modifications (37700,

37828)

The inspectors

maintained

cognizance

of modification activities to support

the operation of Unit 2.

This included

reviews of scheduling

and work

control, routine meetings,

and observations

of field activities.

a.

Work Activities by Sub-Contractor

The inspector

was informed by TVA gA management

that

a sub-contractor

was

performing

work in

spaces

important to safety without task

management

from site modifications or on site design support from NE.

The inspector

informed

TVA representatives

that information had also

been

received

that

the

sub-contractor,

Key

Services,

was

disconnecting

some

PREAS

card

readers.

Plant

Maintenance

was

receiving

WRs to repair the card readers

and were concerned that this

could have

an impact on the upcoming

EP drill.

After further review by the inspector plus information received that

the

work being

performed

by

Key Communications

was in the

cable

spreading

rooms

and various locations

on the

1C level of the control

bay the inspector

determined that adequate

design controls

were not

followed.

This item is identified

as

UNR 259,

260,

296/91-40-02,

Adequacy of Design Controls

During Sub-Contractor Activities.

The

licensee's

gA group issued

a stop work order

on the sub-contractor.

The licensee

is also

conducting

an incident investigation of the

problem.

The inspector will review this further after completion of

the investigation.

A walkdown was

conducted

by the inspector

along

with the licensee's

gA and modifications organization.

All cable

penetrations

were sealed into the cable spreading

room.

No immediate

safety concerns

were identified.

b.

Unit 1 and

2 Cable Spreading

Room

The inspector identified

some

temporary telecommunication

equipment

on the wall in the cable

spreading

room.

There were disconnected

wires, wires in cable trays,

and equipment

covers

on the floor.

The

licensee

did not think this

was part of the sub-contractor

work but

is reviewing this area.

The inspector

stated

the structure

may not

be securely

mounted

on the wall or in the cable trays.

The licensee

is performing

a calculation for the seismic

adequacy.

This will be

considered

part of UNR 90-40-02 until resolved.,

6.

Unit 3 Restart Activities

(30702)

The inspector

reviewed

and

observed

the licensee's

activities involved

with the Unit 3 restart.

This included reviews of procedures,

post-job

activities,

and completed field work; observa'tion of pre-job field work,

in-progress field work, and gA/gC activities; attendance

at restart craft

level,

progress

meetings,

restart

program

meetings,

and

management

meetings;

and periodic discussions

with both TVA and contractor personnel,

skilled craftsmen,

supervisors,

managers

and executives.

0

a.

Contractor Activities

1.)

Inplant Craft Work

During this reporting period

SWEC

commenced inplant craft work.

This involved installation of scaffolding in the Unit 3 Drywell

and

was performed

by carpenters.'WEC

provided the supervision

of the craft and

BFN TVA exercised

overview and management.

The

inspector

also

noted craft work being

performed

under

SWEC

management

outside

the plant.

This activity involved moving of

trailers

and hookup of electrical services.

As of this reporting

period

SWEC

had not completed

the training and certification of

the work plan writers.

This training is expected

to be completed

by December 9, 1991.

2.)

Walkdowns

Walkdown activities associated

with Unit 3 can

be put into three

groupings.

These

are

integrated

walkdown activities,

design

scoping,

and RFIs.

'a ~

Integrated

walkdown activities are

90% complete

in civil

and mechanical

areas,

except for the Unit 3 torus.

These

are

scheduled

to

be

completed

on

November

22,

1991.

Electrical

walkdowns are

90% completed,

excluding vertical

drop

cable

calculations,

Eg cable

walkdowns,

and

CCRS

validation walkdowns,

which are

scheduled

to be completed

in January

1992.

b.

Design

scoping

walkdowns

are

increasing

due

to

the

establishment

of requirements

to schedule

these activities

through the daily work schedule.

c ~

RFI's

are

used

as

BNA internal

tracking

and

control

document for information requests

between

the various

BNA

site organizations.

RFI's are screened

to determine if the

informa'tion is already available

from another

source prior

to performing

a walkdown.

A total of 391 RFI's

have

been

issued with 173 completed.

b.

Contractor

Work Release

Program

The licensee

has

established

a

CWR program to improve control of

contractors.

This is to ensure

the

necessary

prerequisites

are

completed

before the contractor is released

to perform work.

Key

attributes

of the

program

are

organizational

interface,

quality

assurance

oversight,

and authorization

from plant operations prior to

performing physical plant work.

t

0

12

This

program

has

been initiated for contractor

work associated

with

Unit 3 restart.

Included with the

CWR are

several pilot program.

The table below lists the programs.

Contractor

Work Release

1.

SWEC

Complete

Scaffolding, fire watches

and nonsafety

related

work outside the Power Block

2.

SWEC

11/12/91

Nonsafety-related

work inside the

Power

Block

3.

SWEC

11/18/91

Receipt,

storage,

handling,

and issuance

of material

4.

SWEC

11/20/91

Work document preparation,

(work plans,

work orders,

and work requests)

5.

SWEC

12/09/91

6.

BNA

TBD

7.

Pacific Nuclear

TBD

Safety-rel ated

work

and

acceptance

inspection

Integrated

design

changes

Plant decontamination

Pilot Programs

1.

BNA

2.

SWEC

3.

SWEC

4.

SWEC/BNA

Complete

Walkdown

11/17/91

Work Document Preparation

12/02/91

guality Control Inspection Certification

TBD

Design

Change

processing -

A/E to

constructor

5.

BNA

TBD

Integrated

design

change

The inspector discussed

with various Unit 3 managers

the

NRC interface

expected

with the pilot programs

in a meeting

on November

12,

1991.

There

was

a general

lack of under standing of the pilot programs

by

Unit 3 managers.

This was discussed

with the Vice President for Unit

3.

Jet

Pump

Beam Exchange Activity

The inspector

reviewed

and monitored the Unit 3 jet pump

beam exchange

activities.

This was performed

by

GE under

BFN TVA oversight.

Part

of the activity involved the

use of

a cutting wheel

to cut the

retaining ring from the attachment.

During this time frame

a cutting

wheel

broke

and approximately

75 percent of the wheel

was recovered

I

0

13

d.

from the Unit 3 reactor vessel.

The licensee

commented

that the

remaining

25 percent would not pose

a problem because

of the size

and

the material

that the cutting wheel

was

made of.

Also during this

time frame

a jet

pump

beam

was

dropped

and successfully

recovered.

The inspector will continue to monitor this activity.

Pilot Programs

The inspector

reviewed

and discussed

the

BFN pilot programs

approach

to starting

up contractor

work activities inside the

power

block.

This program applies

to both units.

The approach

involves

a close

step

by step monitoring of the initial work activities to verify the

adequacy of the process.

This program was established

to help ensure

that problems

would

be identified prior to

a significant amount of

actual

work being completed in the field.

The pilot program reviewed

involved

the

work plan writing for

DCN

P0623

which

exchanged

Temperature

Recorder

1-TR-74-80 with a new type recorder.

7.

Action on Previous

Inspection

Findings

(92701,

92702)

a ~

b.

(CLOSED)

URI 260/91-38-02,

Dual Labeling of Drywell Blower Supply.

This item was

opened

when the inspector,

during

a plant tour, noted

that Drywell Blower 2B-3

was

labeled

as

being

supplied

from two

different electrical

sources.

After additional

revi'ews of CCDs, the

inspector

determined that this was

a violation and was identified as

the third example of VIO 259,

260, 296/91-40-01,

Failure to Follow

Procedures

for Control of Electrical

Systems.

(CLOSED)

URI

259,

260,

296/91-38-03,

Fuse

Labelling

and

Identification.

This

item

was

opened

when

the

inspector

reviewed

the

licensee

activities

involved with the pulling of the

wrong

fuses

while

performing

an

equipment

tag

out for the

B

DG.

The

inspector

determined

after further

review of the

licensee's

method for

controlling fuse pulling that this was

a violation and was identified

as

the

second

example of VIO 259,

260,

296/91-40-01,

Failure to

Follow Procedures

for Control of Electrical

Systems.

8.

Cold Weather Preparations

(71714)

The inspector

reviewed the licensee's

program to protect plant systems

and

equipment

important to safety

from cold weather conditions.

The

BFNP

areas

subject to cold weather

include the intake structure

which houses

the

RHRSW pumps,

the ultimate heat sink, the

CCW pumps

and the fire pumps,

the reactor building roof which supports

the condensate

transfer

system

head

tank,

the

condensate

storage

tanks

located

near the Unit 3 turbine

C

I ~

0

0

14

building, the

two

DG buildings located

on the east

and west sides of the

reactor building, the fire protection

system valve pits, the five cooling

water towers,

and the diesel

driven fire pump buildings.

The inspector

reviewed procedures

O-GOI-200-1,

Freeze Protection Inspection,

and

EMI-46, Freeze

Protection

Program.

The inspector also observed

the

licensee's

field activities.

The inspector

noted that portable

heaters

were pre-staged

in the intake building, the Unit 3

DG carbon dioxide room

and various other plant areas.

The inspector

observed

that

a tarpaulin

was being used to cover, the grating over the

RHRSW intake structure.

This

and additional observations

were discussed

with the licensee.

Exit Interview (30703)

The inspection

scope

and findings were

summarized

on

November

15,

1991

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 Number

Description

and Reference

259, 260, 296/91-40-01

VIO, Failure to Follow Plant Procedures

For

Control of Electrical Systems,

paragraph

4.

259,

2600 296/91-40-02

URI,

Adequacy

of

Design

Control

During

Subcontractor Activities, paragraph

5.

Licensee

management

was informed that

2 URIs were closed.

Acronyms and Initialisms

ANSI

BFNP

BNA

CCD

CCRS

CCW

.CFR

CWR

DCN

DG

'MI

EP

Eg

FCV

American National Standards

Institute

Browns Ferry Nuclear Power Plant

Bechtel

North American

Configuration Control Drawing

Consolidated

Cable Rating System

Component

Cooling Water

Code of Federal

Regulations

Contractor

Work Release

Design

Change Notice

Diesel Generator

Electrical Maintenance Instruction

Emergency

Preparedness

Environmental gualification

Flow Control Valve

0

15

GE

GOI

IR

KV

KW

LCO

MOV

MR

NE

NOV

NPP

NRC

NRR

OI

PDD

PREAS

PT

QA

QC

RBM

RFI

RG

RHRSW

RWM

SBGT

SDSP

SI

SJAE

SLC

SOS

SSP

SWEC

TBD

TS

TVA

UNIDS

URI

USST

VIO

WO

WP

WR

General Electric

General

Operating Instructions

Inspection

Report

Kilovolt

Kilowatt

Limiting Condition for Operation

Motor Operated

Valve

Maintenance

Request

Nuclear Engineering

Notice of Violation

Nuclear Performance

Plan

Nuclear Regulatory

Commission

Nuclear Reactor Regulation

Operating Instruction

Potential

Drawing Discrepancy

Personnel

Radiological Accountability System

Potential

Transformer

Quality Assurance

Quality Control

Rod Block Monitor

Request for Information

Regulatory

Guide

Residual

Heat

Removal Service Water

Rod Worth Minimizer

Standby

Gas Treatment

System

Site Director Standard

Practice

Surveillance Instruction

Steam Jet Air Ejector

Standby Liquid Control

Shift Operations

Supervisor

Site Standard

Practice

Stone Webster Engineering Corporation

To Be Determined

Technical Specifications

Tennessee

Valley Authority

Unique Identifiers

Unresolved

Item

Unit Service Station Transformer

Violati on

Work Order

Work Plan

Work Request