ML18036A500
| ML18036A500 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 01/09/1992 |
| From: | Kellogg P, Patterson C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18036A497 | List: |
| References | |
| 50-259-91-41, 50-260-91-41, 50-296-91-41, NUDOCS 9201270181 | |
| Download: ML18036A500 (34) | |
See also: IR 05000259/1991041
Text
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UNITEO STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323
Licensee:
Valley Authority
6N 38A Lookout Place
1101 Market Street
Chattanooga,
TN
37402-2801
Docket Nos.:
50-259,
50-260,
and 50-296
License Nos.:
and
Facility Name:
Browns Ferry Units 1, 2,
and
3
Inspection at Browns
Fe. ry Site near Decatur,
Inspection
Conducted:
November
16 - December
15,
1991
Inspector:
C. A.
P
Inspector
Accompanied
by:
E. Christnot, Resident
Inspector
W. Bearden,
Resident
Inspector
R.
Ber hard, Project Engineer
Report Nos.:
50-259/91-41;
50-260/91-41,
and 50-296/91-41
(
z
Dat
S gned
Approved by:
Paul J.
ogg;
>e
Rea tor
'
ion 4A
Division of Re ctor Projects
Da
e S'gned
SUMMARY
Scope:
This routine resident
inspection
included surveillance
observation,
maintenance
observation,
operational
safety verification,
power
ascension
test
report
review, corrective
action
program,
Unit
3
restart
activities,
contractor
control,
reportable
occurrences,
action
on previous
inspection
findings,
and nuclear safety
review
board.
Results:
A violation and deviation, were identified concerning
the control of
contractor
work activities.
The violation was for failure to have
adequate
design
control- of a site telecommunications
subcontractor,
paragraph
eight.
A site
procedure
to control
these activities
was
not utilized.
Significant quantities
of missing
doc'umentation
for
work performed
to implement
a design
change
was identified
by the
site quality organization.
A stop work order was issued.
(y 10f 70j8i 92010~
pDR
@DOCK
8
The deviation
was from a reply to
a previous violation concerning
the
removal of fire wrap,
paragraph
seven.
To better control contractor
activities,
walkdowns
were to
be
resumed
using
a
phased
approach.
The construction contractor
performed safety re1ated
work but was not
authorized
to perform
the
work.
The contractor
had
only
been
authorized
to perform
non safety related
work such
as scaffolding.
This
was
identified
by
the site quality organization.
Work
activities were stopped
to correct the problem.
All remaining operational
readiness
assessment
team
open items,
the
power
ascension
test
report,
one
licensee
event
report,
one
unresolved
item,
one
inspector
followup item,
and five violations
were closed.
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
N. Herrell, Operations
Manager
- J. Rupert, Project Engineer
- N. Bajestani,
Technical
Support Manager
R. Jones,
Operations
Superintendent
A. Sorrell, Maintenance
Manager
'~G. Turner, Site (}uality Assurance
Manager
R. Baron, Site Licensing Manager
"J. McCarthy, Unit 3 Licensing
- P. Salas,
Compliance Supervisor
- J. Corey, Site Radiological Control Manager
A. Brittain, Site Security Manager
Other
licensee
employees
or contractors
contacted
included
licensed
reactor
operators,
auxiliary operators,
craftsmen,
technicians,
and
public safety officers;
and quality assurance,
design,
and engineering
personnel.
NRC Personnel:
P. Kellogg, Section Chief
- C. Patterson,
Senior Resident
Inspector
- E. Christnot,
Resident
Inspector
- M. Bearden,
Resident
Inspector
R.,Bernhard,
Project Engineer
"Attended exit interview
and initialisms
used
throughout this report
are listed in the
last paragraph.
Surveillance Observation
(61726)
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
by qualified personnel,
and
the SIs
were
completed within the required
frequency.
A review of the
TS surveillance
requirements
and the plant's
progr'am for
ensuring
implementation
of the
requirements
was
performed.
SSP-8.2,
Surveillance
Program,
Revision 0,
dated
September
13,
1991
and 2-SI-1,
Surveillance
Program,
Revision 7, dated
August 23,
1991 were
compared
to
the
requirements
of the Unit
2
TS with an effective
page list dated
November
5,
1991.
Over 700 requirements
were
compared to 2-SI-1 to insure
the
TS
were
implemented
in the
program.
From the review,
over
30
questions
were generated
for further inspection.
The
30 questions
were
discussed
with individuals in work control
who implement the program
and
the
engineer
responsible
for maintaining
2-SI-1.
The questions
were
resolved or action initiated to address
them.
From the review the following observations
were made.
~The
high on-time completion
rate of SIs at
BFNP
seems
to be the
result of manpower
loading of SIs before other work items,
the high
visibility the Sls
have at the
Plan of the
Day meetings,
and
the
planning of SI work activities;
2-SI-l, which lists the'SI requirements,
is 'updated
every six months.
Changes
to the SI are
made through submission of a Form SSP-158,
SI-1
Surveillance
Program
Change
Form.
The
system
engineer
uses
the
normal procedure for plant procedure
changes
to implement the SSP-158
changes
at the SI-1 update interval.
It was
noted that
a tracking
system
to insure
SSP-'158
incorporation
does
not exist.
SI-1 is
current only when all outstanding
SSP'-158s
are also considered.
It
is not currently possible
to determine
SI-1 status
due to lack of
tracking of SSP-158s.
The current revision of SI-1 reflects
the
former practice of using
PMI-35 forms from the superseded
PMI-17.12.
SSP-8.2
indicates
SSP-158s
are
gA records
with lifetime retention,
but does
not indicate
how to track them.
In addi tion, SSP-2.3,
Administration of Site Procedures,
Form SSP-23,
Procedure
Verification Review Checklist,
Step
33 is not specific
enough to ensure
SI changes
that impact frequency,
scope
changes
or
name
changes
generate
an SSP-158.
The
TS have
requirements
to verify initiating logic or control logic
in Table 4.2.8.
Many of the logic functions are recognized
in TS as
being functionally verified as part of a channel
check or some other
TS required test.
SI-1 does
address
these functions in its listings,
however the SIs that are
performed to meet the logic function do not
indicate that their function is also to confirm the
system logic.
The inspector
reviewed several
and did not find marked acceptance
criteria indicating system logic function was verified.
In addition,
these
SIs did not indicate
which other SIs, if multiple SIs are
needed
to verify system logic, are'eouired
to complete
the test
requirement.
Some
typographical
errors
were
noted
in SI-1.
In addition, four
entries
in Attachment
2 indicated
"Instrument
Channel"
when the
TS
did not.
The system engineer
was notified of the discrepancies
and
will correct
them on the next procedure revision.
Attachment
2 of 2-SI-I indicated
a frequency of "12 M" for 4.2.F'-2.
A TS
change
made
the frequency
"6 M".
No SSP-158
was found.
No
changes
to the SIs were required
as they were already
performed at
6
month intervals.
TS changes
may result in the
need for SSP-158s
to
be generated if SI-I is impacted,
but no other
SI change is required
that would generate
one via the SSP-23
review.
l
Interviews with gA indicated
a periodic comprehensive
audit comparing
the
TS to SI-I is not performed.
The current
program divides the SI
audits
by responsible
organizations
and
checks that each
groups
at the time of the organization's
audit=.
While verifying, SI-4.7.A.3.b met the
TS requirements,
the inspector
discovered
the
SI manually
cycled
the
vacuum
breakers
prior to
verifying their setpoint.
The
vacuum
breakers
setpoint
should
be
determined
"as found" to give
an indication if they would operate
properly if required.
The system engineer
is processing
a procedure
change to correct this.
No violations
or
deviations
were
identified
in
the
Surveillance
Observation
area.
3.
Yiaintenance
Observation
(62703)
Plant
maintenance
activities
were
observed
and
reviewed for selected
safety-related
systems
and
components
to
ascertain
that
they
were
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
(NR,
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.
Teflon Tape
The inspector
continued
to review the licensee's
program for control
of usage
of teflon tape.
Teflon tape
is
a potential
problem in
applications with stainless
steel
due to breakdown of the teflon into
fluorine with excessive
temperatures
and radiation
exposure.
The
inspector
determined
that at
BFNP teflon tape is controlled
as
a
special-issue
chemical
in accordance
with Site Standard
Practice
13.2,
Chemical Traffic Control
Program.
SSP - 13.2 recently
replaced
SDSP
-
24.2
which
provided
previous
guidance
and
requirements.
SSP - 13.2,
paragraph
3.5. 11 requires
the site
C
8
E
Superintendent
or designee
to sign all requisition form 575Ns for all
special
issue
chemicals
such
as teflon tape.
SSP - 13.2 further
requires
the
C
IW
E
Superintendent
or
designee
to routinely
investigate
usage
of special
issue
chemicals
and provides
special
requirements
for use of chemicals
by contractors
working onsite.
The inspector
requested
the licensee
provide
a listing of all recent
issuance
of teflon
tape
to. craft personnel.
From this
computer
listing (power stores
transaction
history) the inspector
determined
that teflon tape
had
been
issued
on four separate
occasions
during
1991.
Those
issuances
involved
a total of 22 spool's of tape.
The
inspector
then
reviewed
the four Form
575Ns
associated
with these
transactions
and
noted
that
each
had
been
cosigned
by
a
representative
of the chemistry section
and that issuance
of teflon
tape
appeared
appropriate
for these
specific work activities.
The
work performed
under the four referenced
work orders
were performed
on sewage
treatment,
hypochlorite injection or other systems
that did
not connect to the
RPV.
The inspector
concurred with the licensee's
determination
that
these
examples
of teflon tape
issuance
were
authorized
usage.
b.
Unit I/2 A Diesel
Generator
Outage
, The
inspectors
followed licensee
activities
associated
with the
scheduled
outage
on the Unit 1/2
A D/G.
This outage
was planned to
start
on December 8,
1991,
and involved the performance of the annual
and six year
inspection of the diesel
engine
and generator.
The
inspector
noted
that
the
licensee
entered
LCO 2-91-312-3.9.B.3
at
5:35
a.m.
on
December
8,
1991,
which required
that the
D/G
be
.returned
to operable
status within
7 days.
The D/G was
removed from
service
under
Hold Order 0-91-0840.
However the licensee
was unable
to perform any of the planned activities
due to an unplanned
which occurred
on December
9,
1991.
The
D/G was returned to service
and tested
at 3:00 a.m. to demonstrate
operability to support Unit 2
restart following that unplanned trip.
The licensee
rescheduled
the
D/G inspections
to occur shortly after the unit is restarted.
The
inspector
did not identify any problems
associated
with the planned
D/G outage.
No violations or deviations
were identified in the Maintenance
Observation
area.
4.
Operational
Safety Verification (71707,
93702)
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 oper'ating
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,
alarm
status,
adherence
to
procedures,
adherence
to
LCOs,
nuclear
instruments
operability, temporary'lterations
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,
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.
Plant Status
Unit 2 tripped from 80/ power
on
December
8, 1991, ending
48 days nf
continuous
operation.
A 30 'ampere fuse blew in the secondary
side of
.a potential
transformer.
This resulted
in actuation
of the main
generator
protective circuit and
a generator
load reject.
A turbine
trip and reactor trip followed.
The licensee
conducted
an incident
investigation of the event
and restarted
the unit on
December
10,
1991.
No reason
other than
a fatigue failure of the fuse could
be
identified.
There
was
no work in progress
nor were there
any power
system
noted
at
the
time of the
event.
Long
term
corrective
actions
are
continuing
including
a modification to the
protective circuit.
These
actions
wi 11
be followed by the inspector
with the closure of the trip report.
b.
Leak in Unit 2 Reactor Building Nain Steam Tunnel
The inspector
reviewed
the
circumstances
associated
with an event
which occurred
on the midnight shift on November
26, 1991,'here
a
minor steam
leak
was identified by licensee
personnel
on
a four inch
RWCU line located in the Unit 2 reactor
bui,lding main
steam tunnel.
The g')and packing nut had
become
loose
on 2-FCV-69-580 located
on the
RWCU return line to the feedwater
system.
Licensee
personnel
entered
the
steam
tunnel after
sensors
indicated
increasing
temperatures.
Upon entering
the
steam
tunnel
the
was
able to identify the
location of the leak
and estimate
the size of the leak
as
.25
gpm.
'6
Due to the licensee's
ability to evaluate
the problem quickly, the
leak
was isolated
and repaired prior to conditions
degrading.
The
inspector
determined that operations
personnel
responded
well to this
abnormal
condition and identified and corrected
a problem which could
have led to an automatic
shutdown if allowed to continue.
No violations or deviations
were identified in the Operational
Safety
Verification area.
5.
Power Ascension Test Report
Review (72301,
72532)
The inspectors
reviewed
the licensee's
PATP Start-up Report "dated October
29,
1991.
The
PATP
had
commenced
on
February
20,
1991, with the
commencement
of core
reloading
and
completed
on August 6,
1991.
The
licensee's- Unit 2 Cycle
6 report
was submitted
to the
NRC as required
by
The
PATP was performed in three
phases
and consisted of 21 different power
ascension, tests.
A total of 59 separate. test deficiencies
were identified
during the
PATP.
Phase I, Open
Vessel
Testing,
was completed
on May 21,
1991,
with the
completion of 2-TI-149',
Water
Level
Measurements,
and
initial thermal
expansion
walkdowns.
Phase II, Heat-up
to
55% Power,
commenced
on
May 23,
1991, with plant startup,
and
was complete
on July
16,
1991,
when authorization
was
received
to continue with the
power
ascension
above
55'A power.
Phase III was complete
on August 6,
1991, with
the completion of Turbine Generator
Torsional Testing.
The insp'ectors
had previously reviewed the
PATP as
documented
in IR 91-26.
In this report specific
concerns
had
been
raised
concer'ning
testing
results
associated
with TI-131,
TI-174,
and
TI-189.
The
inspector
reviewed
the test results
associated
with these
three
tests
with the
licensee
and determined
that the original concerns
as described
in the
above
stated
inspection
report
have
been satisfied.
Additionally the
inspector
reviewed
the listing of test deficiencies
and determined
that
the licensee
had dispositioned all but two of the
59 deficiencies.
In
each
case
the deficiencies
had
b'een dispositioned
by reperforming portions
of the test,
adjustments
and/or special
testing
under
a work request,
engineering
evaluation,
or contact with vendor for clarification.
The
inspector
did not disagree
with any of the licensee's
basis
used for
closing these test deficiencies.
Two test deficiencies
associated
with 2-TI-190, System Thermal
Expansion,
remain
open
pending
further action
by the
licensee.
The
inspector
discussed
these
test deficiencies
with
a region
based
inspector.
The
regional
inspector
reviewed
the
licensee's
evaluations
and corrective
actions
completed
to date associated
with these
two test deficiencies
and
determined that the licensee's
actions
were acceptable.
No violations or deviations
were identified in the
Power Ascension
Test
Report Review area.
6.
Corrective Action Program
(30702)
The
inspector
reviewed
recently
issued
licensee
procedures
and
held
meetings
with site
gA organization
personnel
for
the
purpose
of
determining
the status of recent
changes
to the corrective action program
at Browns Ferry.
Based
on this review the inspector
determined
tha't the
new program
does
not represent
a significant change
in the way that the
licensee
does
business
in this area.
The
new program replaces
the use of
a single form used for CAgRs
and
PRDs with two separate
forms for use
as
SCARs, Significant Corrective Action Reports,
and P"Rs,
Problem Evaluation
Reports.
However the 'actual criteria
used
to classify
a significant
condition adverse
to quality has not changed.
Timeliness
requirements
and
requirements
concerning
escalation
of delinquent
action
has
not chang'ed
significantly.
An additional
change is the creation of a third form for
use with FIRs, Finding Identification Reports,
which may only be used
by
NgA organization
personnel
for non-significant
prob')ems identified during
performance of a
gA audit or monitoring activity.
Under the
new program
existing
ACPs, Administrative Control
Programs,
such
as
WOs, IIRs,
COTS,
LERs, etc. will continue to be used similar to as under the old program.
The responsibility for tracking
and trending of items will be transferred
'rom the site
gA organization
to site licensing.
The inspector
reviewed
Site Standard
Practice
SSP-2.3,
Finding Identification Reports,
SSP-3.6,
Problem Evaluation Reports,
and SSP-3.4,
Corrective Action. These
licensee
procedures
superseded
SDSP-3.7
and
SDSP-3.13,
which
covered
the
old
program. Additionally, the inspector monitored training conducted
by the
Browns Ferry Corrective Action Coordinator
on
November
25,
1991.
This
training
was
one of a series
of classes
required of all managers
and
supervisors
prior to implementation
of the
new program.
The
new program
was
implemented
by the
licensee
on
December
2,
1991.
The inspector
determined that the
new program is the
same
as the program that is already
in place at the licensee's
other nuclear facilities.
Implementation of
the
new program at those facilities had already occurred earlier this year
and
had
been
intentionally
delayed
at
Browns
Ferry
as
a
conscious
decision
not to change
the existing
program during the Unit 2 restart.
The inspector
was
informed by licensee
personnel
there
had
been
problems
at the other facilities with the implementation of the
new program which
resulted
in delinquent
action
backlogs.
The
inspector
was further
informed that
those
problems
which
have
been
corrected
at
the other
~ facilities were due to reduced
emphasis
on management
review under the
new
program, i.e.
lack of a
MRC.
Browns Ferry intends
to implement the
new
program using
the
MRC somewhat similar to its'tilization under the old
program.
Part
of the training
was
reading
of
a
BFN Operations
Memorandum
dated
October
31,
1991,
which outlined expectations
in this
area.
Specifically
mentioned
in this
memorandum
was
an
expected
timeliness
rate of 98/ with de1inquent
action
backlogs
considered
as
unacceptable
performance.
The inspector
also
reviewed
the most recently
issued
Site guality Trend
Report
dated
November
5,
1991, to determine
the level of timeliness
for
corrective actiors.
That report covered trending of Conditions Adverse to
guality,
quality
assurance
findings,
external
findings,
Inc'ident
Investigation Reports,
and Corrected
on the Spot
items for Unit 2 during
September
1991.
At the
end of the
month there
were ll open significant
CAgRs
one of which had delinquent corrective action.
There also existed
33 non-significant
CAgRs
and
15
PRDs at the
end of the
month.
The
inspector
noted that the overall timeliness
rate
had continued to improve.
The percentage
of delinquent
items for this period
was 8.6l (the rate
has
continued to decrease
from approximately
20% in November 1990).
Many site
organizations
have
not
had
any recent delinquent
items.
However during
the past six months the onsite Nuclear Engineering organization
has
had
an
overall
40%
delinquency
rate.
This
problem
was identified
by the
licensee's
gA organization
as
an adverse
trend
and
documented
under
CARR
BFA910216112.
No other apparent
adverse
trends
were identified in the
licensee
report.
The inspectors will continue to monitor 'the licensee's
implementation of the
new program
and report
on performance
in this area
after adequate
time
has
elapsed
to allow an assessment
of adequacy
and
timeliness of corrective actions
under the
new program at this site.
No violations
or deviations
were identified in the Corrective
Action
Program
Review area.
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; observation
of pre-job field wo'rk,
in-progress field work,
and
gA/gC activities; attendance
at restart craft
level
progress
meetings,
restart
program
meetings,
and
management
meetings;
periodic
discussions
with both
TVA and contractor
personnel,
skilled craftsmen,
supervisors,
m'anagers,
and executives.
'a ~
Contractor'ctivities
The inspector
observed
and
reviewed
the activities of two of TYA's
Unit 3 main contractors,
GE and
SWEC.
The inspector
also
observed
activities
performed
by additional
contractors
such
as Digital and
PCC.
The activities included the following:
1)
Training
The inspector
reviewed
and observed
training given to
SWEC and
technical
personnel.
The specific
items
consisted
of
procedure
MMM No. 2.5,
Maintenance
Training, which establishes
and 'efines
the
requirements
and
responsibilities
for
implementation
of
maintenance
and
modifications
services
training
at
BFNP;
SWTP
004,
Introduction
to
Regulatory
Requirement
- TVA's Nuclear guality Assurance;
SWTP 003, Print
Reading
-
Use
of
TYA Drawings;
informal
training
for'amiliarization
with procedure
MAI-4.3, HVAC Duct Systems,
which
establishes
the
requirements
for fabrication,
installation,
modification, verification,
and
documentation
of
HVAC duct
systems;
and
SWTP-004, Plant Reference
Material
and Control-Work
Control
Process.
The training
was
conducted
in
a classroom
environment,
attendance
sheets
were filled out
and for the
SWTP's
an
examination
was
given
to the participants.
The
inspector
concluded
from these
reviews
and
observations
that
was
conducting
training for personnel
and
using
TVA's
methods.
Reactor
Vessel
Internals
The inspector
continued to monitor the activities performed
by
GE associated
with the reactor
vessel
internals.
The IVVI was
completed
and
involved
an
inspection
of the
Steam
Dryer.
Several
indications
were observed
and actions
were being taken
to address
them.
This
was identified as
an IFI in IR'1-38.
The jet
pump
beam replacement
was completed.
This replacement
included
removal of the eld
beams,
replacement
with new
beams
and tack welding of the
new beams.
Other activities included
placement of the separator
and dryer in the vessel,
drain
down
of the vessel,
removal
of the
steam
plugs,
placement
of the
drywell head,
and installation of shield plugs.
Work Release
The inspector
continued
to monitor the licensee's
and
SWEC's
activities
involved with contractor
work authorization.
The
specific
items
reviewed
were
par t of the pilot program for work
documentation
preparation
and involved
12
WOs.
These
WOs were
prepared
by
SWEC personnel,
reviewed
by
SWEC and
TVA gA and Unit
3 work control.
The inspector
observed
these activities
as the
process
developed.
No significant deficiencies
were identified.
The licensee
approved
SWEC activities for preparation
of work
documents
Boot Incident
On
November
14,
1991,
a licensee
gA person
questioned if work
previously
performed
by
was within the
scope
of the
contractor
work release
program.
It was determined
that
the
work was outside
the scope.
A stop work order was issued.
An
incident investigation
was initiated on the problem.
It was
determined
that
on
November 4,, 1991,
personnel
performed
work order 91-422447-00.
This work involved partial
removal of a boot seal at
a secondary
containment penetration
to
allow data verification of
a
pipe
support.
The
work
was
authorized
by Plant Operations
and conducted
in accordance
with
the procedure.
However,
SWEC personnel
were only authorized to
do scaffolding
work at
the
time
under
the contractor
work
release
program.
The contractor
work release
program
was
outlined in IR 91-4Q,
10
The
licensee
determined
that
the
CWL
program
was
not
communicated
downward to the craft level.
There
was
general
confusion about implementation
and understanding
of the program.
The
licensee
initiated
several
corrective. action
steps
to
correct the problem.
These
included withdrawing all work orders
from construction
until
they
could
be
reviewed
for
scope
definition.
Only scaffolding
WOs were released.
All
supervisors
and
engineers
were to
be retrained
in the
CWL
program.
The
inspecto'r
reviewed
the
licensee
reply to
NOV 91-26-02
concerning
removal of fire wrap from operable
equipment.
In
this reply it was
stated
that actions
taken
to
improve
the
'control of inspection requests
of contractor walkdown activities
would be resumption of these activities using
a phased
approach.
This
was
not
done for the construction contractors.
SWfC was
not scheduled
to
be released
to perform safety related
work
activities until December
9,
1991.
This is
a deviation from the
NOV reply to
91-26-02.
This
item is identified
as
DEV
296/91-41-01,
Control
of
Construction
Contractor
Work
Activities.
5)
On
December
9,
1991,
the licensee initiated
a plan of the
day
meeting for Unit 3 restart activities.
The inspector
attended
several
of the meetings.
The meetings
are attended
by senior
licensee
and contractor personnel.
b.
Operations Activities
The inspector
reviewed
and observed
the Unit 3 operations activities
involved with the reactor
vessel
drain
down.
This activity was
performed
in accordance
to procedure
3-SOI-31A, Drain
Down of U-3
Reactor
Vessel
and
Cavity to
Condensate
Storage
System.
The
operations
group
and
various
support
groups
held
several
pre-job
.planning
meetings
and briefings.
The
inspector
noted
that
a
scheduling fragnet
was developed
to indicate to personnel
the various
times at which certain activities
were to occur.
These activities
included
system line
ups
to drain
the water to 85 storage
tank,
placement of the
steam
separator
and dryer into the reactor vessel,
and
removal of the
main steam line plugs.
The inspector
concluded
that
these activities
were controlled
by approved
procedures
and
performed
by qualified individuals.
One deviation
was identified in the Unit 3 Restart Activities.
8.
Contractor
Control
(37702)
The inspector
continued
to review the activities of the sub-contractor,
Key Communications,
and
the resulting incident investigation.
The review
involved field work
and
design
change activities
associated
with
W9276A,
W9277A,
and
W9279A.
The review indicated that
DCN
W9276A was
issued to replace existing
phone switch and
make associated
changes
in the
Plant
Communications
Room,
located
on the
1C level of the Contro'l
Bay.
DCN W9277A was
issued
to delete wires and cables
in order to allow switch
replacement
and
DCN
W9279A was
issued
to install cables,
splices,
and
terminations
in the yard area
outside
the
power block and in the turbine
building.
The fol lowup indicated that
'a
WP for DCN W9276A was required to
be written to implement the
DCN and
none
was written although
the
new
switch was
made operable.
WP-0087-91
was written to implement
DCN W9277A
and
the
WP
was
never
signed
into
work status
although it was
a
prerequisite for DCN 9276A.
WP-2045-91
was written to implement
DCN 9279A
and
was
signed into work and never utilized.
This resulted
in the work
associated
with
WP
2045-91
being
near
to completion
and
with
no
documentation.
Appendix
B, Criterion III, Des.ign Control,
requires
that
measures
shall
be established
for the identification and control of design
interfaces
and for coordination
among participating design organizations.
The
licensee
uses
SDSP
16. 17 to control contractor activities.
These
requirements
were not met or followed for the subcontractor.
Work plans
were
not utilized
and
on October
13,
1991, electrical
cables
were cut
servicing the
PREAS.
In Inspection
Report 91-40, this item was identified
as
a
URI.
This
item is
changed
to
a
VIO 259,
260,
296/91-41-02,
. Inadequate
Design Controls for Sub-Contractor.
One violation was identified in the area of Contractor Control;
Reportable
Occurrences
(92700)
The
LERs listed
below
were
reviewed
to determine if the
information
provided
met
NRC
requirements.
The
determinations
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.
(CLOSED)
T.S.
Violation Following
Loss
of Primary
Containment
Caused
by Personnel
Error.
This
LER had
been
submitted
by the licensee
due to the
same
breach of
event
described
in VIO 91-23-01
closed
in this
IR.
The inspector
reviewed
the licensee's
corrective actions
associated
with
this
LER as part of the followup review of corrective actions
associated
with the violations issued for this event.
0
12
10.
Action on Previous
Inspection
Findings
(92701,
92702)
a
~
b.
C.
d.
(CLOSED) IFI 259, 260, 296/91-38-04,
Procurement
Stop Work
This
item. was originally identified when the inspector
was
informed
gA had issued
SWOs concerning
BNA activities.
The inspector
reviewed
two
SWOs identified
as
BFSW-001
and
BFSW-002.
The inspector
noted
that
both
SWOs clearly indicated
the activities that
were to
be
stopped,
the
reasons
for the
and the corrective actions
needed
to lift the
SWOs.
The inspector
concluded
from this review that gA
reviewed
BNAs activities
and
had taken appr'opriate
action
as
needed.
(CLOSED)
URI 259,
260,
296/91-40-02,
Adequacy of Design
Controls
During Sub-Contractor Activities.
The
item
was originally identified
when
on
October
13,
1991,
information
was
received
that
indicated
a
sub-contractor,
Keys
Communication,
was
disconnecting
PREAS
readers.
These
PREAS
terminals
are
used
as part of the personnel
accountability
system
during
a radiological
event.
As
a result of review and followup,
this item was
changed
into
a VIO 259,
260, 296/91-41-02,
Inadequate
Design Controls for Sub-Contractor.
(CLOSED) VIO 259, 260, 296/91-10-03,
Inadequate
Test Controls
This
VIO was
issued for two examples
of failure to implement test
control
measures
for returning
components
to service.
The first
example
was identified when
on March 18,
1991, during integrated
leak
rate test,
the reactor
building torus
vacuum breakers'opened
when the
torus pressure
was greater
than the reactor building pressure.
The
second
example
was identified when
on October 4,
1990,
during the
performance of a SI, the
A3
RHRSW pump did not start.
The inspector
reviewed the licensee's
response
to the VIO, dated
June
21,
1991.
The licensee
indicated that for the first example
an
adequate
review was not performed for a
FCR
.
The
design for the
pressure differential switches for the vacuum breakers
was controlled
by
ECN P3051
and the installation of the switches
was controlled
by
WP 2036-84.
During the installation
a
FCR was not reviewed for PNT.
The licensee
indicated that for the
second
example
personnel
failed
to
adhere
to
PNI
17.1,
Conduct of Testing,
which requires
that
equipment
awaiting
be
adequately
tagged.
Had the
PMT been
performed
the failure of A3
RMRSW to start would have
been detected.
The inspector
reviewed .the licensee's
corrective which included the
requirement
in
SDSP
12.4 that
FCRs,
now referred
to as
FDChs,
be
reviewed for
and that all licensed
and non-licensed
operator
review incident investigation
number
II-B-91-074.
The
inspector
determined that the corrective action
had
been completed.
(CLOSED)
VIO 259,
260,
296/91-24-02,
Failure
to Follow Clearance
Procedures.
13
This
VIO had
been
issued
due to the 'licensee's
failure to follow
applicable
procedures
which resulted
in an event where the
1D D/G was
motorized.
On July 9,
1991, while releasing
Hold Notice 0-91-0501
following maintenance
on the
1D D/G the
.25
amp position indication
fuse
was incorrectly installed in the control
power circuit.
The
actual
control
power fuses
are
required
to
be
15
amp fuses..
The
individual that reinstalled
the
fuses
had transposed
the position
indication fuses
and control
power fuses..
The individual then racked
in the breaker
but failed to trip check the breaker.
Had that step
been
performed
the
.25
amp fuses
would have
blown at that point.
Independent
verification
was
later
performed
on
the
fuse
reinstallation
which failed to identify'he error.
Later following
two hours of operation
performed
as
PNT, the
D/G the generator
output
breaker
could not
be tripped from the control
panel
in the control
room.
The breaker
remained
closed for approximately
seven
minutes
before it was tripped locally.
Following to the event the licensee
removed
the
D/G from service to
perform engine
and
generator
tests
to determine if any equipment
damage
had
occurred.
No
damage
was identi'fied, and
the
D/G was
returned to operable status
on July 10,
1991.
The
inspector
reviewed
the licensee's
response
to the
VIO dated
September
5,
1991.
In that
response
the licensee
attributed
the
failure to personnel
error
by the individual that reinstalled
the
fuses
and
the
second
individual required
to perform
independent
verification of the activity.
As corrective actions
the licensee
took personnel
action against
the individuals involved and committed
to conduct additional, training
on procedural
requirements
associated
with racking
in breakers
and
independent
verification for all
operations
personnel.
The inspector
reviewed Final
Event Report,
II-B-91-135, which documented
the licensee's
investigation of this
event.
Additionally, the
inspector
examined
training
attendance
records
related to this event for operations
personnel.
The training
sessions
included
specific
training
on
Final
Event
Report,
II-B-91-135,
SDSP
3.15,
Independent
Verification,
and
breaker
operations'ased
on this review the inspector
determined
that the
completed
corrective
actions
should
be
adequate
to
prevent
reoccurrence.
(CLOSED)
VIO 259,
260,
296/91-23-01,
Breach of Primary Containment
when Reactor
was Critical
(CLOSED)
VIO 259,
260, 296/91-23-02,
Failure to Follow Work Control
Procedures
(CLOSED)
VIO 259,
260, 296/91-23-03,
Inadequate
Procedures
to Control
Drywell Entry when Containment Integrity is Required.
These
three
VIOs were categorized
in the
aggregate
as
a Severity
Level III problem
and
involved escalated
enforcement
with
a civil
0
penalty for licensee
actions
which led to an event that occurred
on
June
5,
1991,
when primary containment
was .not maintained
during
a
time while the reactor
was critical
and at
150 psig
and
365 degrees
F.
This event
occurred
as
the result of both drywell personnel
access
doors
being
open while licensee
personnel
were in the Unit 2-
drywell
performing
thermal
expansion
walkdowns
duri'ng
the
PATP.
Interlocks for both drywell doors
were defeated at 2:45 a.m.
on June
5,
1991,
to facilitate frequent entry by personnel
performing the
walkdowns.
This occurred without the approval
and notification of
the
SOS.
The failure
was
identified
by appropriate
'licensee
personnel
at 6:30'.m.
and primary containment integrity immediately
restored.
Licensee
management
decided
to place
the plant in cold
shutdown
at 10:00
a.m.
The unit was
not re'started
until June
10
after the
licensee
had
conducted
a detailed investigation into the
event
and initiated
a planned
corrective action
program associated
with the event.
The
inspector
reviewed
the licensee's
response
to the violations
dated
September
6,
1991.
In that response
the licensee
attributes
the failure to
an unauthorized
action
by a'echanical
maintenance
craftsman.
Contributing
factors
in this failure were
lack of
attention
by those
personnel
in the direct area
during the event,
inadequate
procedures
which failed to control containment
entry and
the method
used
to defeat
the door interlocks which resulted
in an
erroneous
door position indication in the control
room.
The response
also provided
the details
of the licensee's
corrective action plan
which included the following:
Those
personnel
directly involved in de'feating
the drywell door
interlocks
received disciplinary action.
Personnel
that were
shown
to
have
observed
the
drywell
doors
open
but did not
question
the condition were counseled.
Employee
training
sessions
were
conducted
to outline
a
new
improved
operating
plant
philosophy.
The training sessions
included
a
description
of
the
event,
plant
personnel
responsibilities,
and
SOS
authority
and
responsibility.
Additional training
was
provided
to
maintenance
craft
and
supervisory
personnel
on expected
performance
and documentation
of assigned
work.
Existing plant procedures
that were considered
inadequate
were
revised
to more clearly describe
requirements
for drywell entry
when primary containment integrity is required.
TYA has
developed
various
programs
intended
to
enhance
job
performance
of maintenance
craftsman
and ,supervision.
These
include
a
screening
and
evaluation
program
to
assess
job
performance of maintenance
foreman.
This program is intended to
include
screening
and evaluation
of both current
foreman
and
future
candidates
to ensure
they
possess
adequate
skills to
perform their supervisory
duties.
Additionally the licensee's
15
general
employee training program will be enhanced
to emphasize
the importance of the plant's safety barriers
and responsibility
to follow procedures.
The inspector verified current revisions of licensee
procedures
to
verify that corrective
actions
had
been
completed
in this area.
2-0I-64,
Primary
Containment
System
. Operating
Instruction,
was
revised to require that all door manipulations will be performed
by
operations
personnel
and that at least
one of the
two airlock doors
be closed
always
when primary containment
is required.
SDSP
14.15,
Entry and
Work in'he Primary Containment,
was revised
to require
that drywell entries
be performed in accordance
with 2-0I-64 while
-primary containment
is required
and that entries
be
performed
in
accordance
'with MNI-129, Opening
and Closing of Drywell Personnel
'Airlock Doors, while primary containment
is not required.
MMI-129
was
revised
to
change
the
method of defeating
the interlocks
so
control
room indication of door position
was not affected,
to allow
defeating
interlocks only when primary containment
is not required
and to require
SOS notification prior to defeating
interlocks.'ased
on conversations
held with selected
licensee
personnel
the
inspector
determined
that personnel
were
knowledgeable
of the event
and
that
adequate
training
on sensitivity
to operating
plant
requirements
had
occurred.
The inspector
also
noted that special
training
on drywell
door operation,
TS,
and
correct
method of defeating
interlocks
had
been
conducted
during the
period 'directly prior to the decision to restart
the unit on June
10,
1991.
Two sessions
of this training had
been monitored. by
NRC shift
inspectors
as
part of the 'continuous
shift coverage
that
was
occurring
during that
time period.
Additionally the
inspector
determined
that the licensee's
new program for craft supervision
had
been
implemented.
The first class
of maintenance
foreman
which
includes
elements
of the proposed
screening
and evaluation
process
is
currently ongoing
and
scheduled
for completion prior to the
end of
this reporting period.
ORAT Open
Item Closure
An
ORAT inspection
was
conducted
prior to restart
of Unit 2.
Thirteen
open
items
were identified in IR 50-260/91-201.
A followup
was performed
and
documented
in IR 50-260/91-202.
In IR 91-202
open
items
1,
2,
4,
6,
7, 8,
and
11
wer e cl osed.
One
new itern
was
identified in
IR 91-202
which
was
closed
in IR 91-26.
The
team
verified that all corrective actions
to address
the restart
concerns
had
been
implemented
except
review
of
the
final
incident
investigation report concerning
the fuel handling event.
Closure of
the remaining items follows:
16
1.)
(CLOSED)
Open
Item 260/91-201-03,
Fuel
Handling
Event
Final
Incident Investigation Report.
The
inspector
reviewed
the
licensee's
final
incident
investigation report.
The report was revised to include
a
human
performance
evaluation
system.
This evaluation
provided
more
comprehensive
recurrence
controls
and identified problem areas
related to the event.
a.)
Inadequate
verbal
communication
-
adequate
information
transfer
did not occur
between
personnel
involved in the
event.
b.)
Inadequate
written communication - procedural
guidance
was
not provided
on signal
spikes related to noise.
c.)
Poor
work practices
-
incomplete
troubleshooting
was
performed to resolve
the case of the unusual
spikes.
d.)
Poor
managerial
methods
- high standards
for resolving
problems
before
continuing activities
not effectively
communicated.
The results
of the incident investigation report were discussed
in
a
TVA/NRC management
meeting
held at the site
on
Nay 13,
1991.
Several
incident
investigation
improvements
were
discussed
in
the
meeting
including 'n
overall
program
effectiveness
review.
The inspector
concluded that
a thorough
self-critical
review of the
event
was
conducted.
This
was
essential
for effective
problem resolution after
the plant
restart.
2.)
(CLOSED)
Open
Item
260/91-201-05,
Correction
of Procedure
Deficiencies
Including Procedure
Style
Guide
Terminology
and
Definitions
The
inspector
reviewed
the
licensee's
response
and
closure
package
for this
item.
Site
Standard
Practice
2.2, Writing
Procedures
was
issued
on
October
8,
1991.
The
procedure
combines
the style
guide for writing instructions
and site
writers guides into one
document.
Guidance
is provided in the
on
logic
terms,
referencing
and
branching,
emphasis
techniques,
and definition of terms..
Procedural
discrepancies
were identified in 2-0I-71, O-OI-57D,
and
2-01-74.
Procedure
changes
were
made
or
addressed
to
correct
the discrepancies.
Additionally,
a
memorandum
was
issued
by Operations
management
to remind personnel
of their
responsibilities
and
the
importance
of taking
time
when
verifying procedure
revisions.
The
inspector
reviewed
the
licensee
response
procedure
revisions
and operations
memorandum.
This item was. resolved
by these actions.
0
17
(CLOSED) Open Item 260/91-201-09,
Locked Valve Program Training
The
inspector
reviewed
the
licensee's
response
and
closure
package.
Live-time training
was
conducted
for the operating
crews.
The lessons
plans
and attendance
sheets
were reviewed.
Items
addressed
were
the
locked-valve
program,
independent
verification, versus
second party verification, and surveillance
and procedural
adherence.
These actions
resolved
the concern.
(CLOSED)
Open
Item
260/91-201-10,
Independent
Verification
Training
The
inspector
reviewed
the licensee's
response
and
closure
package for this item.
Several
weaknesses
were noted during
a
walkdown of 1-SI-4.5.8.11,
Unit
1 X-tie for Unit
2
Operation.
The weaknesses
were addressed
or
a SI revision made.
Training was
conducted with item 260/91-201-09.
These
actions
resolve the concerns.
(CLOSED) 260/91-201-12,
Weaknesses
in Training Program
The inspector
reviewed
the licensee's
closure
package
and reply
for this item.
.The
ORAT identified that adverse
trend control
limits for several
indicators
were
too high.
When
no audits
were
performed
during
a period
a reject
rate of zero
was'ntered.
Some trend data
was not being forward to site
gA as
required.
The licensee
eliminated
the control limits.
Each
item trended is
now analyzed
on its
own significance, merit, or
impact.
Nore discussion
and analyses
of the item was required
from line organizations
for the trend report.
When
no audit is
performed
the trend indicates
no data instead of zero.
Site
gA
contacted
the various line organizations
.to insure all required
data
is forwarded to site gA.
The inspector
reviewed
some
gA
trend reports
and the reports
provide detailed
explanations
of
the indicators.
Where
no audit
was
performed
no
data
is
indicated.
These actions
resolve
the concern.
(CLOSED) 260/91-201-13,
Improvements
in Incident Investigation
Reports
The
inspector
reviewed
the
licensee's
closure
package
and
response
for this item.
Changes
were
made to the final event
report
package
to identify team
members
trained in root cause
analysis.
Other specific
items
were addressed
in the
response
of closure
package.
In
a TVA/NRC management
meeting
on May 13,
1991, the improvements to incident investigations
were outlined.
These
are
as follows:
training - basic root cause
analysis
techniques
human performance
enhancement
system methodology
increase
number of'ualified investigators
18
plant manager
approval of team composition for category
1
events
category
1 events
reviewed
by multidiscipline management
committee
freezing of event
scene
and immediate conduct of interviews
improved trending system
overall program effectiveness
review
A new Site Standard
Practice
12.9,
Incident Investigation
and
Root Cause Analysis,
was
issued
on September
4, 1991.
This was
a
new procedure
to implement Corporate
Standard
12.9.
In general
since
the
plant restart
on
Nay
24,
1991,
the
inspector
has
noted
a general
improvement in the effectiveness
of incident reports.
They have
been
thorough
and self-critical.
These actions
resolve
the concern.
In summary all
ORAT open items are closed.
Item
260/91-201-01
260/91-201-02
260/91-201-03
260/91-201-04
260/91-201-05
260/91-201-06
260/91-201-07
260/91-201-08
260/91-201-09
260/91-201-10
260/91-201-11
260/91-201-12
260/91-201-13
Inspection
Report Closed
91-202
91-202
91-41
91-202
91-41
91-202
91-202
91-202
91-41
91-41
91-202
91-41
91-41
260/91-202-01
91-16
ll.
Nuclear Safety Review Board
The inspector
attended
selected. activities of the
NSRB conducted
December
12,
1991.
Plant
management
discussed
items of interest.
Areas
covered
included
both Unit
2
and Unit 3 activities.
Haj or
items of
interest
were
foreign
material
exclusion,
the
management
review
committee's
function with resp'ect to the
CARR process,
Unit 3 progress
and
0
19
schedule,
incorporation of Unit 2 lessons
learned into the Unit 3 program
and
a report
on Unit 3 fuel inspection results.
The
members
were interactive
with the
management
on the
issues
discussed.
Several
items for plant ac'tion were identified.
Results of
NSRB directed audits
were discussed.
For those activities reviewed
by the
inspector,
the
NSRB's activities were consistent with the requirements
of
the TS.
Exit Interview {30703)
The inspection
scope
and findings were
summarized
on
December
16, .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
296/91-41-01
259, 260, 296/91-41-02
Description
and Reference
DEV, Control of Construction Contractor
Work Activities, paragraph
7.
VIO, Inadequate
Design Controls for Sub-
Contractor,
paragraph
8.
Licensee
management
was
informed that
6
ORAT items,
1
LER,
1 IFI,
1 URI,
and
5 VIOs were closed.
Acronyms and
BFNP
BNA
CAQR
CSE
CFR
COTS
CWL
DCN
DEV
D/G
FCR
FDCN
GPH
IFI
IIR
Initia 1 i sms
Adminstrative Control
Program
Browns Ferry Nuclear Plant
Bechtel
North America
Condition Adverse to Quality Report
Chemistry
8 Environmental
Code of Federal
Regulation
Corrected
on the spot
Contractor
Work Release
Desi,gn
Change Notice
Deviation
Diesel
Generator
Engineering
Change
Notice
Field'Change
Request
Field Design
Change Notice
Gallons
Per Minute
Heating, Ventilation,
5 Air Conditioning
Inspector
Followup Item
Incident Investigation
Report
20
IR
LCO
MAI
NQA
NRC
PATP
PCC
PER
PMI
PREAS
SDSP
SOI
SWTP
TS
WP
Inspection
Report
In Vessel
Visual Inspection
Limiting Condition for Operation
Modification Alteration Instruction
~ Maintenance
Management
Manual
'aintenance
Request
Management
Review Committee
Nuclear Quality Assurance
Nuclear Regulatory
Commission
Nuclear'Safety
Review Board
Operating Instruction
Operational
Readiness
Assessment
Team
Power Ascension Test Program
Project Cost and Control
Problem Evaluation Report
Plant Manager Instruction
Post Maintenance/Modification
Test
. Problem Reporting
Document
Personnel
Radiological Accountability System
Quality Assurance
Quality Control
Residual
Heat Removal
Residual
Heat Removal
Service
Water
Reactor
Pressure
Vessel
Reactor
Water Cleanup
Site Director Standard
Practice
Surveillance
Instruction
Special
Operating Instruction
Senior Reactor Operator
Site Standard
Practice
Stone Webster Engineering
Company
Stop
Work Order
Stone
Webster Training Program
Technical Specification
Valley Authority
Unresolved
Item
Violation
Work Order
Work Plan
Work Request
D'