ML18036A768
| ML18036A768 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 06/30/1992 |
| From: | Kellogg P, Patterson C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18036A766 | List: |
| References | |
| 50-259-92-21, 50-260-92-21, 50-296-92-21, NUDOCS 9207140102 | |
| Download: ML18036A768 (35) | |
See also: IR 05000259/1992021
Text
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UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION
11
101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323
+>>**~
Report Nos.:
50-259/92-21,
50-260/92-21,
and 50-296/92-21
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 Ferry Site near Decatur,
Inspection
Conducted:
May 16
June
16,
1992
Inspector:
atterso
,
nidor
ent
nspector
4Po
W~
a
e
S gne
l
Accompanied
by:
E. Christnot,
Resident
Inspector
W. Bearden,
Resident
Inspector
Approved by:
e
o
R actor
, Section
4A
Divis
of Reactor Projects
Date
gne
SUMMARY
Scope:
This routine resident
inspection
included maintenance
observation,
operational
safety verification, measuring
and test
equipment
program, Unit 3 restart activities, Unit
1 activities, licensing
activities, reportable
occurrences,
and action
on previous
inspection findings.
One hour of backshift coverage
was routinely worked during the
work week.
Deep backshift inspections
were conducted
on May 30
and June
6.
Results:
Unit:2 operated
at power during this report period
and
was on-line
for 47 days at the
end of the period,
paragraph
three.
The
licensee
met
a commitment to implement Revision Four of the
9207140102
920702
ADOCK 05000259
9
Emergency Operating Instructions
on June
15,
1992.
New control
room furniture for the unit operator
and assistant shift
operations
supervisor workstations
were installed providing ample
space
to use the
new flowcharts.
A temporary waiver of compliance
from technical specifications for
the control
room emergency ventilation system
was granted to
permit
a test necessary
to determine
adequate
capacity for the
system fan, paragraph
three.
All conditions of the waiver were
m'et.
The testing indicated additional capacity is needed.
A violation.was identified by the inspector for failure to
.adequately
disposition nonconforming measuring
and test equipment,
paragraph
four.
Programmatic
problems
were identified with
timely, incomplete,
and
adequate
disposition of nonconformance
evaluations.
There
was
a lack of ownership of the program
and
insufficient management
oversight.
Licensee
management
was
responsive
to these findings
and initiated
a comprehensive
corrective action program.
A non-cited violation was identified for a drawing error in
a
system drawing,
paragraph
three.
Due to the
incorrect disposition of a previous drawing discrepancy
an
unexpected
system isolation occurred
when
a fuse
was pulled.
The
licensee
conducted
a thorough review of this event
and initiated
actions to correct the problem.
An inspector followup item was identified concerning
a scaffold in
place
around the torus,
paragraph
three.
Scaffolding was erected
to the torus
and concrete wall without any clearance,
possibly
restricting
movement of the torus in
a blowdown.
The licensee
is
conducting
an evaluation of the possible
consequences.
A declining trend in complete
and accurate
licensing submittals to
the
NRC was identified, paragraph
seven.
Three licensee
event
reports
and two replies to notice of violations required
resubmittal
due to missing or inaccurate
information.
This
indicated
a lack of attention to detail in preparation
of the
.
submittals.
Unit 3 work activities are proceeding with cooling tower
.
refurbishment,
condenser
retubing, reactor water cleanup
and
recirculation
system piping replacement,
and control
room design
review, paragraph
six.
Unit
1 work activities consisted
of scaffold erection for
walkdowns
and in-vessel
inspections.
Walkdowns
commenced for
information needed
to, support work in Unit
1 during the Unit 2
Cycle
6 refueling outage.
This must
be accomplished
to prevent
a
multi-unit defueling outage
at
a later date.
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. Rupert,
Engineering
and Modifications Manager
- J. Swindell, Restart
Manager
H. Herrell, Operations
Manager
- J. Haddox,
Project Engineer
- H. Bajestani,
Technical
Support
Manager
R. Jones,
Operations
Superintendent
A. Sorrell, Special
Programs
Manager
- C. Crane,
Maintenance
Manager
G. Turner, Site guality Assurance
Manager
R. Baron, Site Licensing Manager
- 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
W. Bearden,
Resident
Inspector
- Attended exit interview
and initialisms used throughout this report are listed in the
last paragraph.
Maintenance.Observation
(62703)
Plant maintenance
activities were observed
and/or 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
(HR,
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 ~
b.
c ~
Unit
1
RHR System
Loop Outage
The inspectors
followed licensee activities associated
with the
scheduled
outage for Loop II of the Unit
1
RHR System.
This loop
is required
by TS to be available for crosstie
operations
to
support Unit 2 operations.
Only Unit
1
and
RHR crosstie
components
were affected
by the outage.
The
RHR loop was
removed
from service
on June
9,
1992,
under hold order 1-92-88.
LCO 2-92-
155-3.5.B. 13 was entered,to
track the
10 day
LCO while the loop
was unavailable.
Various scheduled
preventive
and corrective
action items
on
HOVs and other components
were accomplished
during
this outage.
The loop was returned to service
on June
12,
1992.
Post maintenance
testing in accordance
with 1-SI-4.5.B. 11,
Unit
1 Crosstie for Unit 2 Operability,
was accomplished prior to
declaring the loop operable.
The inspectors
did not identify any
deficiencies
during this scheduled
system outage.
Relay
Room
Fan Vibration
An inspector followed licensee activities associated
with WOs 91-
32000-00
and 92-53881-00.
These
scheduled
work activities were
written to correct various deficiencies
including excessive
fan
vibration for the Relay
Room "A" Air Handling Unit located
on the
3C elevation of the Control
Bay.
The inspector
observed
selected
activities including installation of a
new shaft coupling
and
reassembly
of other components.
The inspector
reviewed the two
uncompleted
work packages
and determined that each provided
adequate
instructions
and guidance to support the intended
work
activity.
The inspector did not identify any deficiencies
during
observation of the work activity.
Drywell Pressure
Transmitter
An inspector
observed
portions of licensee activities
on May 19,
1992,
associated
with
WO 91-29039-00,
which replaced
Drywell
Pressure
Transmitter,
2-PT-64-0160A, with a refurbished
transmitter.
The inspector
observed
portions of the actual
transmitter
replacement
and reviewed the uncompleted
work package.
The inspector determined that the
WO provided adequate
instructions
and guidance to support the intended
work activity.
NSI-0-000-PR0001;
Cleanliness
of Fluid Systems,
and SII-0-XX-00-
3014, Troubleshooting
and Configuration Control of
Instrumentation,
were also in use
by the maintenance
personnel
during the work.
Post maintenance
test
was specified to be
performed in accordance
with 2-SI-4.2.F-21(A), Drywell Pressure
Wide Range
(Div. I).
The inspector did not identify any
deficiencies
during observation of the work activity.
No violations or deviations
were identified in the Haintenance
Observation
area.
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,
annunc'iator
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
numerou's
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 wi'th selected
plant personnel
in their functional
areas
during these tours.
Unit Status
During this
IR period the unit operated
at power.
At the
end of
the report period the unit had
been
on line for 47 days.
New
control
room furniture was installed in Unit 2. 'he licensee
met
a commitment to implement revision four of the
on June
15,
1992.
b.
Temporary Waiver of Compliance
On Hay 22,
1992,
the licensee
was granted
a temporary waiver of
compliance
from the requirements
of TS 3.7.E. 1,
CREV system.
The
waiver permitted relief from TS 3.7.E. 1 for a total of 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />
between
Saturday,
Hay 23,
1992,
and Honday,
Hay 25,
1992, to
perform testing necessary
to determine
adequate
capacity for the
CREV units.
The test
was required to support the long lead time
for procurement to support
any future activities for additional
CREVs capacity if necessary.
During the test,
the system
was not
since several
manual
actions
were required in place of
the normal automatic actuation.
0
Compensatory
measures
in effect for the duration of the waiver
were dedicated test personnel
trained
on procedures
for manual
actions
necessary
to initiate the
The inspector verified
the conditions of the waiver were specified in special test
procedure
O-ST-91-07,
Control
Bay Habitability Zone Leakage
Rate.
The procedure
contained
a list o'f dedicated
tested
personnel,
required training,
and detailed actions.
CREVs was
made
at 1:20 a.m.,
on Hay 23,
1992,
and the test
and
equipment restoration to normal
completed
at 8:30 a.m.,
on May 23,
1992.
All conditions of the waiver were followed during the test.
The
inspector
reviewed the completed test procedure.
The capacity
necessary
to obtain
one eighth inch positive water pressure
in the
control
bay was around
1900 cfm and
2370 cfm at one quarter
inch
pressure.
This testing indicated additional capacity
was needed.
The exact size will be evaluated.
The electrical
load will have
to be
added to the
DGs.
The inspector will continue to review the
licensee
actions until the
CREVs is restored
to
a fully operable
basis.
RWCU Isolation
A unanticipated
automatic isolation of the Unit 2
RWCU system
occurred
on April 24,
1992, during placement of an equipment
clearance
associated
with
WO 91-43482-00.
This
WO had -been
written to allow replacement
of RWCU pressure
switch,
2-PS-69-15B.
The isolation occurred
when fuse FUI-69-15A was pulled.
Work
associated
with this pressure
switch replacement
was immediately
stopped,
the fuse replaced,
and the
RWCU system restored
to
operation.
After troubleshooting
the licensee
determined that
RWCU nonregenerative
heat exchanger outlet temperature
indicating
switch, 2-TIS-69-11,
also would become
deenergized
whenever this
fuse
was pulled.
This had caused
an isolation of the
RWCU system
as designed to prevent overheating
protection for the
demineralized resin.
Elementary diagrams,
2-730E922-2,
for the
RWCU system
and 2-730E927,
sheet
13, for the
PCIS system did not
show this fuse in the power supply circuit for 2-TIS-69-11.
The inspector
reviewed incident investigation report,
II-B-92-028,
which documented
the licensee's
investigation into this event.
In
that report the licensee attributed the event to
a failure by
licensee
personnel
to properly disposition drawing discrepancy,
2-
87-1225,
during performance of ECN P7082 which was completed
in
1988.
That
ECN moved instruments
2-TIS-69-4A and
4B and revised
the
power feed
and panel location
on drawing 2-730E922-2,
figure
3.
When these
instruments
were relocated
from panel
2-25-2 to
panel
2-25-5-1, figure
3 was changed to reflect this,
but
a
new
figure was not developed
to show the power feed for .panel 25-2,
which contains
2-TIS-69-11.
DD 2-87-1225
had previously
been
added to the drawing to document that 2-TIS-69-11
was
powered
from
the panel
2-25-2 power supply,
but that
DD was removed
when the
ECN changed
the panel
number.
Without this change
there
was
no
ready method of identifying the power feed from fuse FUI-69-15A to
2-TIS-69-11, without doing extensive
research
on the connection
diagrams.
Connection
diagrams
are secondary
drawings that are not
available in the control
room.
The inspector reviewed the details
associated
with this drawing error and determined that the error
appeared
to be
an isolated
case with no safety significance.
The
licensee
had taken
immediate corrective actions to investigate
the
problem
and the drawing error was corrected prior to performing
additional
work in the affected panels.
This violation will not be cited because it meets
the criteria of
Section VII.B of the Enforcement Policy.
NCV 260/92-21-01,
Drawing Error, will be issued to document this failure to properly
update
the drawing.
Plant Tours
During
a routine tour on Hay 19,
1992, the inspectors
identified
some
housekeeping
concerns
in the area
around the Unit 2 Torus.
Personnel
were working in the overhead within a contamination
area
established
over the torus.
The following items were found:
Anti-contamination clothing in overhead
Loose pieces of insulation or lagging were
seen
hanging
from
the overhead.
One piece of sheetmetal
used to cover lagging was
seen
in
the overhead
jammed
between
a pipe
and the torus.
There were several
wet areas
along the floor below the
torus.
These observations
were discussed
with plant management.
The
licensee
took immediate action to have the affected
area
cleaned.
Another concern identified was associated
with a section of
scaffolding erected
in the area next to the Unit 2 Torus.
One end
of a horizonal scaffolding restraints
was in direct contact with
the concrete
wall and the other end of that restraint
was in
direct contact with the torus wall.
The specific concern is that
this restraint could possibly interfere with any movement of the
torus that occurs
anytime there is
a large
blowdown to the torus.
The ladder that provided access
to the scaffolding had
a tag which
provides
Radcon concurrence
with working in an overhead
area.
Personnel
are required to check that radcon
surveys
have
been
performed of the affected
overhead
areas within the last
seven
days prior to climbing scaffolding or ladders.
That tag
had not
been
signed
since
March 3,
1992.
The inspector
reviewed O-TI-264, Scaffolds
and Temporary
Platforms,
and determined that although
no specific mention of
clearance
requirements
relating directly to the Torus were
referenced,
Section 3.5 requires that restraints
shall
have
a
minimum clearance
of six inches
from all safety-related
items.
The inspector discussed
this concern with the licensee civil
engineer that
has responsibility for review and approval of
scaffolds
and temporary platforms prior to use
by craft personnel.
The engineer
stated
an evaluation of potential effects
on the
torus would be made
by Nuclear Engineering.
The inspector
noted
that the scaffolding was removed
by the licensee within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />
after the above discussion.
The inspector
was later informed that
the licensee
had determined that, the scaffolding
was
no longer
needed.
This item will remain
open
as IFI 260/92-21-02,
Adequacy
of Scaffolding Review,
pending review of the licensee's
evaluation
of this issue.
e.
Control
Room Design
Review
The inspector
observed
the field activities associated
with the
BFNP
CRDR, Unit's
2 and 3.
Little visible field work has occurred
on Unit 3 during this reporting period.
Two control
room panels
have
had minor work, dealing mostly with switch relocation
and
labeling.
Field work in this control
room is expected
to increase
dramatically in the upcoming weeks.
The bulk of the control
room
activity, relative to
CRDR,
has
been
on Unit 2 associated
with the
installation of new furniture.
The unit operator
and
ASOS desks
were removed
and
new modular style furniture was installed.
The
ASOS desk design
was chosen to facilitate use of the
new
flowcharts.
The negative
impact
on the control
room personnel
has
been limited.
The i'nstallation processes
were conducted
to reduce
the noise,
adhesive
fumes, limited space,
etc..
Discussions
with
various operations staff indicated that while the activities
associated
with this job were disruptive,
they were not distracted
from performing their assigned
duties.
One
NCV was identified in the Operational
Safety Verification area.
4.
Measuring
5 Test
Equipment
Program
The inspector
reviewed the licensee's
METE program, specifically in the
, area of out of tolerance
investigations
as outlined in SSP-6.7,
Control
of Measuring
and Test Equipment, revision
1.
Within this area
several
weaknesses
were identified which collectively resulted in an inadequate
HKTE program with respect
to investigating
and dispositioning
nonconforming
MME.
The licensee
transports
most of its MME to the
CLSD, located in
Chattanooga,
for calibration.
Following calibration the MDE
is returned to
BFNP with a calibration report documenting
items
such
as
"as-found"
and "as-left" data,
procedures
used to perform the
calibrations,
calibration tolerance
requirements,
dates of previous,
present,
and next calibration, etc..
If HKTE is found out of tolerance
or damaged
the licensee
is notified and
a nonconformance
evaluation is
issued
which investigates
the prior uses of the
HKTE back to the
previous calibration.
This nonconformance
package
includes the
7
initiating document that designates
appropriate
signatures
needed,
a
copy of the usage log,
and
a copy of the calibration form from CLSD.
The inspector
noted that
when
M&TE was found out of tolerance,
three to
five weeks would pass
before the licensee
was
made
aware of the
condition.
This untimeliness
resulted
in unnecessary
delay in
performing required investigation.
Each group that used the
H&TE during
the period in question will investigate
the uses to determine
system
impact, if any,
and identify corrective action.
This in turn is
reviewed for technical
adequacy
by
a technical
reviewer.
This process
is to be completed in 30 calendar
days but may be extended
to 40
calendar
days with an approved extension.
The inspector
reviewed fourteen
nonconformance
packages
and rioted the
following discrepancies:
SSP-6.7
states
that investigation shall
be completed
30
calendar
days. from the date of initiation and not exceed
40
calendar
.days with approved extensions.
Six packages
were
greater
than
30 days late without approved
extensions
with
four of these
packages
being later than the
maximum allowed
40 days.
Package
no. 91-00504. 1, generated
due to an out of
tolerance digital multimeter,
was completed
February
10,
1992,
and took 59 days to complete.
2.
SSP-6.7
states
that each
instance of use shall
be
investigated
and dispositioned.
Seven
packages
did not
contain documentation of investigating all previous
uses of
the
M&TE during the period in question.
As an example,
package
no.
91-00486. 1, concerning
an out of tolerance
flowmeter transducer
assembly,
listed ten uses of the
instrument to be dispositioned,
all of which were
on
CSSC.
Only one of the uses
could
be verified as dispositioned.
Package
no. 91-00332.1 listed work order 90-23710
on the
usage
log and therefore required investigation to determine
the impact of using out of tolerance
H&TE during its
performance,
however,
work order 90-23718
was investigated
instead.
3.
states
that activities associated
with H&TE found to
be nonconforming shall
be investigated
subsequent
to the
previous calibration.
Package
no. 91-00355.3 did not
investigate
the entire period in question
subsequent
to the
previous calibration.
4.
Eight packages
contained various administrative errors
including missing signatures
and dates.
For example,
package
no. 92-00002.2 did not have the investigators
signature
and package
no. 92-00104.
1 had the investigators
'signature
but it was not dated.
'
It was also noted that the controlling document
advised that
a program
status
report
be generated
each
month documenting the number of
calibrations
performed,
the number of nonconforming conditions,
average
number of days required to complete
nonconformance
evaluations,
and
any
other data which might indicate
M&TE reliability problems
and program
performance.
The inspector requested
a copy of the most recent report
and was informed that the report
has never
been generated.
Discussion
was held with licensee
management
on this subject
and
included highlighting the previous
SALP report,
90-02, which also
identified
a weakness
in this area.
One nonconformance
package,
91-00486. 1, concerning
an out of tolerance
flowmeter transducer
assembly,
was also discussed
with licensee
management
concerning
the
operability of systems
that used this instrument for the performance
of
surveillances
required
by TS.
Subsequent
evaluation
by the licensee
determined that surveillances
for the affected
systems
have
been
satisfactorily
completed
since that time.
The licensee will continue
to evaluate this area
as part of a corrective action plan for M&TE
program deficiencies
the licensee
generated
as result of this
inspection.
Additional objectives of this plan are
as follows:
2.
3.
4.
5.
6.
7.
8,
9.
10.
Ensure
each out of tolerance
H&TE usage
is properly
investigated.
Reduce
out of tolerance
review cycle time..
Establish
an escalation
process.
Consolidate
M&TE responsibility into
a single group.
Establish
an automated
H&TE traceability process.
Create
a centralized
H&TE issue
process.
Establish
goals to eliminate administrative errors, late
reports,
and
H&TE damage
and loss.
Ensure proper/prompt operability determination.
Ensure routine reporting to the Plant Manager.
Increase
the scope of both onsite
H&TE calibration
and post
use checks.
This corrective action plan developed
a short term plan to correct these
and other
known deficiencies
in the existing
M&TE program
and
a long
term plan to enhance
the program to meet or exceed
TVA, regulatory,
and
industry standards.
While there were
many individual root causes
for the discrepancies
noted
by the inspector,
the overall root cause
appears
to be
an inadequate
program
and management
oversight in the area of M&TE nonconformance
investigation.
Management
and leadership of the
METE organization
has
changed
several
times in the last year that resulted
in
a lack of
structure
and ownership
and led to these
program deficiencies.
Failure to have methods established
to adequately disposition
nonconforming
H&TE is
a violation of 10 CFR 50, Appendix B, Criteria XII
delineated
in the
TVA Nuclear Quality Assurance
Plan
(TVA-NQA-PLN89-A)
'section 9.5.2.B.3
and
implemented
by SSP 6.7 Control of Measuring
and
Test Equipment.
This constitutes
Violation 259,
260,
296/92-21-03,
Failure to Adequately Disposition Nonconforming
MLTE.
One violation was identified in the Measuring
and Test Equipment 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 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.
Pilot/Prototypical
Program
The inspector
completed
reviews of the
new proceduralized
SPOC/SPAE
process
as planned for the cooling towers.
Discussions
were held with various
managers for the different departments
at
BFNP.
The inspector
noted that each
department
manager
indicated
an understanding
of the cooling towers
SPOC/SPAE prototypical
program including the
Phase
I and
Phase II approaches.
The
inspector
concluded
from these
reviews
and discussions
-that the
licensee's
management
were
aware of the
new SPOC/SPAE
process
and
were ready to support its implementation.
b.
Design Activities
The inspector continued to monitor and review the design
activities associated
with the pilot/prototypical program involved
with the cooling towers
RTO.
DCN 17771,
Remove
Fan Control
Circuits, Automatic Operation
Function
and Indicating Lights From
Control
Room Panel
9-56/9-57
was field completed to the point
where post modification test procedure
O-PMT-BF-027.005,
Cooling
Towers I, 5,
and
6 Logic Functional
and Lift Pump Bearing
Lube
Water Annunciation Test,
was started.
When the fans were test run
and the spring loaded start switch was actuated,
the fans would
start,
but would stop
as
soon
as the switch was released.
The
test engineers
started
a troubleshooting
process
that indicated
that the implementation'f
a section of DCN 17771,
removal of the
reverse
mode of fans,
also affected the start seal-in function.
The inspector
reviewed
BTRD 2/3-BFN-BTRD-027,
Condenser
027.
The document defined the tests
required to demonstrate
that the
CCW system
027 can meet the
functional requirements
for safe
shutdown
from all abnormal
operational
accidents,
and special
events identified
in the
SSA and the
CCW system
027,
Requirements
Calculation.
The
scope of the document
was to identify all functional tests
required for the
CCW system that will determine its capability to
meet safe
shutdown requirements.
This included
any detailed
10
component testing or partial
system testing to ensure
the
functional ability of the system to meet its intended
design
function to support
shutdown of BFNP Unit 2 and/or Unit 3.
The
scope
was specifically aimed at cooling towers
1, 2, 3, 5,
and 6.
The
BTRD listed the required tests
as followed:
Descri tion of Test
Provide
warm water channel
level
indication in the main control
room.
Provide forebay level indication in the
main control
room for manual
actions to
reduce
power or if necessary
initiate
Mode Number
027-01
027-02
Provide cooling tower lift pump discharge
water high temperature
signal to 4-KV power
distribution system
(57-5) for tripping of
the corresponding
cooling tower lift pump.
Provide manual
vacuum breaking capability
to prevent backflow of cooling tower warm
water discharge
into the forebay
upon trip
of the
CCW pumps.
027-03
027-04
Provide forebay/warm water channel differential 027-05
level indication in the main control
room.
Provide cooling tower lift pump trip on
receipt of a condenser circulating water
system
(27) cooling tower lift pump discharge
water high temperature
signal.
57-5-05
Also contained
in the
BTRD as attachments
were the Test Scoping
Document for each
mode number
and
a testing matrix for'ach
The inspector
concluded
from this monitoring and
these
reviews that the design activities for the cooling towers
pilot/prototypical program were being performed in
a controlled
manner
and in accordance
with approved
procedures.
c.
Construction Activities
Secondary
Containment
A specific
WP for the drywell chiller modification was
monitored
and reviewed which involved the opening of a 36"
secondary
containment penetration.
WP 3107-92. was written
to implement the
DCAs of DCN W17695 associated
with the 36"
through the Unit 3 reactor building, south wall,
located at elevation 585'"
and 10'" from R16.
The
I
11
inspector
reviewed
DCAs W17695-009,
010,
060,
and 061,
observed
the craft personnel. in the field and monitored the
, gC inspectors activities.
The
DCAs and the
WP instructions
required that the outside cover of the penetration
be
removed;
the
new plate. with one
14" hole
and four 6" holes
be bolted over the penetration;
and the four capped
6"
pipes
and the capped
14"
OD pipe
be pushed
through the plate
up to the inside penetration
cover; all five pipes to be
secured
using U-clamps; the inside penetration
cover
be
removed;
the five capped
pipes
U-clamps
be relaxed
one at
a
time, the pipes
be pushed further into the Unit reactor
building,
and the U-clamps secured;
and the inside
work than completed.
The craftsmen
performing
the work activities in this manner will maintain secondary
containment
throughout the process.
The inspector will
continue to monitor and review the penetration
work.
Work Plan Library
During the monitoring and review of the construction
activities,
the inspector
noted that the contractor
had not
instituted
a
WP library.
The process
of keeping
WPs
when
not in the field being actively worked in a library is the
method that Unit 2 modifications personnel
use.
This item
was discussed
with Unit 3 management
personnel.
Restart
management
agreed to establish
a Unit 3 Work Plan Library.
Pipe Replacement
On May 18,
1992,
the inspector toured the Unit 3 warehouse
containing the mockups for welding the recirculation
system
piping.
Full size
mockups
are being
used to train and
qualify welders for the pipe replacement
job.
The
recirculation
system safe-end,
risers,
and ring header
are
being replaced.
The licensee
is planning to temporarily
support
and lock into position the various spring cans prior
to draining
and cutting the pipe.
On May 19,
1992,
the inspector toured the Unit 3 drywell to
observe
work activities
and preparations
for the pipe
replacement.
The drywell coordinator briefed the inspector
on activities
and preparations
for pipe cutting.
The
activities in progress
were removing grating
and erection of
personnel
were using
a test block for
calibration of UT equipment
in preparation for conducting
a
UT of the safe-ends
weld area.
Preparations
were
on
schedule for the first pipe cut on June
1,
1992.
On June
1,
1992,
pipe cuts were
made for replacement
of the
piping.
These activities were reviewed
by
a regional
based
inspector during the weeks of June
1 -
5 and June
15 - 19,
1992.
These activities are documented
in IR 92-22.
12
Maintenance Activities
The inspector
monitored
and reviewed the maintenance activities
associated
with the pilot/prototypical program
on the
numbers
1,
5,
and
The specific work activities observed
were those
involved with.the pre-operational
testing.
This
included troubleshooting,
meggaring of motors
and electrical
cables
and replacement
of failed oil seals
on fan gear drive
mechanisms.
The inspector noted that approximately
260
WOs were
generated
to restore
towers
1, 5,
and
6 and that
122 had
been
closed
and
43 were in the closure
process.
The inspector will
continue to monitor and review maintenance activities
and the
closure process.
Pre-Operational
Testing/Return to Service Activities
1.)
Testing
The inspector monitored
and reviewed the pre-operational
testing for the pilot/prototypical program
1,
5,
and 6.
The reviews involved test procedures
0-PMT-BF-
027.001,
1,
5,
and
6 Discharge
Temperature
Trip Logic and
Bypass
Switch Test;
O-PMT-BF-027.005,
Cooling
Towers
1,
5,
and
6 Logic Functional
and Lift Pump Bearing
Lube Water Annunciation Test;
and O-PMT-BF-027.007,
Cooling
Towers
5 and
6
Pump Discharge
Flow Control Valve and
Bypass
Valve Interlock Test.
Test 27.001
was initiated to verify
implementation of ECN
and
DCN 1249, Test 27.005,
was
initiated to verify implementation of DCNs-W17703A and
W17771A;
and test
27.007
was initiated to verify
implementation of ECNs L-1929 and L-1960.
Each procedure
'tated the test objectives,
outlined the prerequisites,
discussed
the precautions,
limitations and actions, listed
the tested
equipment
as necessary,
and clearly indicated the
acceptance
criteria with the applicable
procedure
step's that
satisfied the acceptance
criteria.
The inspector
noted
two concerns.
One involved the cooling
tower
1 fan testing
when test
personnel
attached
a lanyard
to each
fan to ensure that each fan, fan gear box,
and fan
motor would not rotate
due to wind action prior to testing.
Due to lack of communication
and
second party verification
a
fan was inadvertently started with the fan blades
secured
with the lanyard.
This resulted
in a broken fan blade,
The
inspector discussed
this item with licensee
management
concerning test control.
The second
problem involved the test procedures.
While
reviewing the procedure it was noted that
a signature
was
required of the Modification Representative.
Throughout the
test procedures
the steps
are signed
by the Test Director.
The qualifications
and designations
for a Test Director are
0
13
clearly stated
in the licensee's
program.
The inspector
could. not determine
who the modifications representatives
were,
what their job titles were, or what their
qualifications were.
The inspector discussed
this concern
with licensee
personnel.
The inspector
observed
the performance of Section 5.3,
6 Fan Control Functional Test, of procedure
0-
PMT-BF-027.005.
All steps
were performed
as directed
by the
test,
communications
were adequately
established
and
controlled,
and all independent verification requirements
were met.
The inspector
concluded
from the field observations
and
reviews that the licensee
started
a pre-operational
type
testing
program for the cooling towers
1, 5,
and 6, using
approved
procedures
and were conducting the tests
in a
controlled manner.
Testing Neetings
The inspector
attended
the Unit 3, 7:00 a.m. testing
program
meetings.
This meeting
was being held on
a daily basis.
and
was patterned after the Unit 2 testing
program meeting.
The
personnel
discussed
the status
of various tests
involving
1, 5,
and 6, the expected testing for that
day,
any problems affecting test completion or delaying the
start of testing,
any specific group that stated
a subsystem
and/or system
was ready for test
when in fact it was not,
and
any group that did not support testing in an adequate
manner.
The inspector
noted
one difference
between
the Unit
2 testing
program meetings
and the Unit 3 meeting.
The .Unit
2 meetings
were attended
by representatives,
usually
supervisors,
from various organizations
on site,
such
as
operations,
maintenance,
technical
support, testing
program,
TVA gA, design engineering,, work planning
and scheduling,
and customer services.
The Unit 3 meetings,
were attended
by representatives
from system engineering,
testing
program,
TVA gA,
and scheduling:
The meeting did not have
a
conference
room and
was poorly attended.
The inspector
discussed
this meeting with various group supervisors
and
managers.
Several
were not aware. that the meeting
was being
held.
One significant item was discussed
and it involved
a
stop testing, similar to
a stop work situation in
construction,
on the cooling towers.
This occurred
when
during testing, wiring problems,
due to original
construction
and recently installed modifications,
were
identified.
Testing
was stopped
on June
12,
1992,
and
had
not resumed
as of June
16,
1992.
In
a previous inspection report,
the inspector
documented
several
ineffective meetings
and discussed
this occurrence
0
14
with licensee
personnel.
The inspector will continue to
attend
and monitor the pre-operational
testing meetings.
Unit-3 Safe
Shutdown Analysis
The inspector
reviewed the Unit 3 SSA.
This was issued
as
calculation
ND-(0999-910033,
dated
February
28,
1992.
The
provides
a systematic
analysis of the requirements for safe
shutdown 'for transients,
accidents,
and special
events.
The
analysis
was developed
from revision six of the Unit 2
SSA and
incorporated
open= items from the licensee's
commitment tracking
system.
It assumes
operation of Units
2 and/or
3 with Unit
1 shut
down and defueled.
Key differences
were noted
between
the Unit 3
First, the Unit 3
SSA did not use
a phased
approach.
There
was
no
distinction between
equipment required for restart of the unit and
equipment that could be modified after restart.
Next, unit
interactions
were considered
with respect
to the required actions
that the shared
or common systems
take to support the event..
The list of assumptions
was reviewed
and found to be reasonable.
The Unit
1 and shared
equipment interactions
were reviewed.
The
SSA assumed
that the Unit
1 inter-unit
LOCA accident
signals
are
blocked.
This modification has already
been
performed
on Units
1
and
3 to support Unit 2 operation.
Other modifications required
on Unit 3 such
as
ATWS and
PASS are already being tracked
by other
regulatory requirements
and will not require special
tracking.
The
SSA is
a two volume document containing the analysis for
several
events.
For example,
Appendix 28, contains
the review for
shutdown
from outside the control
room,
The unit interactions
section discusses
that this special
event could affect the site
as
a whole since the loss of habitability of the control
room may
require
shutdown of all units from outside their control
rooms.
The shared
systems
were fuel oil,
starting air,
and
4K VAC distribution.
This list was consistent
with the systems
required to bring the unit of a safe hot shutdown
condition.
The inspector
concluded that the licensee
had performed
a detailed
SSA similar to Unit 2 with the differences
discussed.
From an
analytical viewpoint this provides the basis for Unit 3 to safely
be shutdown for transients,
accidents,
and special
events,
The inspector discussed
with the plant licensing staff the
need to
docket the
SSA.
The Unit 2
SSA was not placed
on the docket
and
it was concluded
a similar approach
would be used for Unit 3.
0
15
6.
Unit
1 Activities
The inspector
reviewed
and observed
the licensee's
activities involved
'ith the Unit
1 reactor vessel.
This included reviews of procedures
and
records;
observations
of field work,
QA/QC, operations
and contractor
personnel
activities;
and discussions
with licensee
and contractor
supervisors,
engineers,
and skilled craft personnel.
The IVVI of the
reactor vessel
and
steam dryer was completed.
Additional activities
included: reactor pressure
vessel
inspectability study,
and retrieval of
loose material.
The inspector will continue to monitor the Unit
1
reactor vessel activities.
a
~
Unit
1 Construction
0
On Hay 27,
1992,
the inspector toured the Unit
1 reactor building
and observed significant scaffolding erection in progress.
This
was
a concern
because
no unit separation
program exists for Unit
1
construction activities.
This program is defined in Site Standard
Practice,
SSP-12.50,
Unit Separation for Recovery Activities.
This procedure
states
Unit
1 is in layup.
Further, it explains
that the procedure will require, revision
when it becomes
necessary
to support Unit
1 recovery activities.
This concern
was discussed
with the Restart
V.P.
on Hay 28,
1992.
The work activities in Unit
1 were stated
as within the scope of
Unit 3 work.
This was explained
as all work required to support
multi-unit operation.
The physical
work was being planned for the
Unit 2 Cycle
6 outage,
since this was the last scheduled
three
unit defueling outage.
An example of this work was electrical
distribution work such
as deferred Unit
1
EQ cables
necessary
to.
support
both Unit
1
and Unit 2 operations.
The inspector
concluded that the work in Unit
1 was for Unit
1 recovery.
The
activities were being driven by schedule
convenience.
If Unit
1
were not to operate
then the work was not necessary
for Unit 2 or
Unit 3 operation.
The inspector discussed
that by controlling Unit
1 construction
work as part of Unit 2 operating
space this was in effect
integrating the operating unit and construction unit.
The
inspector stated that
some Unit 2 modifications were being worked
in advance for the Unit 2 outage to reduce
the scope of the Unit 2
outage
work.
.The Unit 3 construction activities
had sharply
increased
since
some design
change
DCNs had
been
issued.
These
coupled with construction activities
on Unit
1 would increase
the
chance for construction activities to affect the operating unit.
The Restart
VS P. stated that the Unit
1 activities would be
stopped until the issue
was reviewed.
This was also discussed
with the V.P. of Operations.
A meeting
was held in the Region II office in Atlanta,
on
June
11,
1992 to discuss
these
issues.
As discussed
at this
16
meeting,
the activities
on Unit
1 would be limited to walkdown
activities required to prevent
a three unit defueling outage in
the future.
The walkdowns would be performed
by a dedicated
crew
of 30 people with the activities treated
as
a Unit 2 operating
space
work.
The activities will be listed in the plan of the day
handout.
Any departure
from the activities discussed
would be
reviewed with the
NRC.
Additional Activities
The licensee. provided the inspector with a list of modifications
resulting from multiple unit operation
mechanical
studies,
multiple unit operation electrical studies,
and evaluation of
future multiple unit outages.
Some of the modifications involved
the following:
DCN W17792,
Shutdown
Board
Room HVAC.
This modification is similar to the Ellis & Watts air
conditioners installed
on top of electrical
board
room 2A.
The
new
HVAC units will be located
in Unit
1 reactor
building,
and will provide qualified
HVAC to 4160V Shutdown
Boards
A and
B,
480 volt shutdown
boards
IA and
1B,
480V
RNOV Boards
1A and
1B,
and
250V
RMOV board
1A and
1B.
DCN W18230,
EECW/RCW Valve Actuator Change.
This modification will change
out water actuated
valves
1-
FCV-67-50 and
51
and replace
them with pneumatic
operated
valves.
These
valves provide
EECW cooling to the two Unit
1
RBCCW heat exchangers
and the spare
heat exchanger
in case
of a loss of RCW.
The valves
are located in the Unit
1
reactor building.
Unit
1 Equipment
Impacting Unit 2 and
3 Operations.
These
items involve equipment,
electrical
cables,
and
end
devices,
that are located in Unit
1 spaces
and could impact
operation of Unit 2 and/or 3.
The latest information
received
from the licensee
indicated that
19 cables
could
impact Unit 3.
No information had
been received
as to the
identified impact
on Unit 2 operations.
DCN W17725, Unit
1 Non-1E Battery Addition - Unit Battery
and Battery Board 5.
This modification will install
a new battery room, battery,
battery charger,
DC electrical
switch board
and associated
ventilation system in the Unit
1 turbine building.
DCN W17721,
Replacement
of 4KV/480V Transformers
TSIA and
TS1B.
17
This modification will replace
two 750
KVA transformers
located in the Unit
1 reactor building, with two 1000
KVA EQ
transformers.
DCNs W17620
and
WXXXX, Reinstall Unit
1
RHRSW to
RHR Heat
Exchangers.
The second
DCN had not been
numbered
as of this reporting
period.
These
two modifications will reinstall
the. present-
ly cut and capped
RHRSW piping,
make the piping seismically
qualified and possibly rework or remove dresser
The piping is located in the Unit
1 reactor building and
RHRSW tunnels.
Additional modifications involved the control air system,
Unit 1/2 control
bay
HVAC ductwork,
CREVS, Unit
1
HWWV,
off-gas
and standby
gas stack,
load tap changers
for the
and
USSTs, Unit
1 turbine building crane,
NFPA upgrade
for the cable spreading
A, and Unit
1 generator rotor
rebuild.
C.
Reactor
Vessel
The inspector
reviewed
and observed
the licensee's
activities
involved with the Unit
1 reactor vessel.
This included reviews of
procedures
and records;
observations
of field work,
QA/QC,
operations
and contractor
personnel
activities;
and discussions
with licensee
and contractor supervisors,
engineers,
and skilled
craft personnel.
The followup reviews of indicators identified by
UT of the in-vessel
manways
were discussed.
This involved
unexpected
indications
on one of the
manways that will require
additional
inspection
and evaluations.
The licensee
discussed
these indications with Region II senior
management.
The inspector
will continue to monitor the Unit
1 vessel activities.
Licensing Activities
The inspector
noted
a declining trend in complete
and accurate
licensing
submittals to the
NRC.
First, several
LERs had to be resubmitted.
This
is discussed
in 'the paragraph
on reportable
occurrences
in this IR.
Second,
the response
to
a violation in IR 92-03 contained
inaccurate
information and
a revised
response
was requested.
Third, the response
to'
violation in 'IR 92-12 did not address
the management
controls
specifically requested
in the IR.
Collectively, these
examples
represent
a negative trend in adequate
licensing submittals.
Each of
these
items
was discussed
with licensee
management
and the revised or
supplemental
responses.
1 8
8.
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.
Several
discrepancies
were noted
by the inspector that indicated
a lack
of attention to detail
by the writer'.
This was discussed
with the
compliance
manager;
.and
he indicated that the
LER's would be corrected
and resubmitted
to the
NRC.
1.
259/92002,
Unplanned
Engineered
Safety Features
Actuation Because
of an Unexpected
Reactor Protection
System Failure.
The event date
was incorrect in several
blocks throughout
the report.
The
LER sequential
number located in block 6 was incorrect
on several
pages.
This
LER stated
there were
no previous
LER's on similar.
events.
2.
260/92003,
Inadvertent
Group
4 Isolation During Performance
of the
High Pressure
Coolant High Temperature
Functional Test.
The report date in block 7 was blank.
The description of the event indicated the isolation
occurred at 0400 instead of the correct time of 0440.
0
9.
3.
260/92004,
on
Low Reactor
Water Level
Due
to Failure of the Feedwater
Level Control
System.
Block 8 did not list Unit's
1
and
3 as other facilities
involved even though the control
room emergency ventilation
and standby
gas treatment
system
are
common to all unit's.
Action on Previous
Inspection
Findings
(92701,
92702)
(CLOSED)
URI 259,260,296/92-11-02,-Hissing
Independent Verification
Steps.
During the performance of 0-SI-4. 11.B.2.a,
Diesel Fire
Pump Operability
Test,
the inspectors
noted
two steps that did not require
independent
verification.
Step 7.3.8.9. placed the Diesel
Driven Fire
Pump Strainer
Backwash Control Switch to Auto but did not independently verify its
position.
The licensee
stated
the independent verification was not
required,
based
on satisfactory
performance of a test conducted
in June
1989,
which operated
the
pump for two hours without allowing the
19
strainer to backwash.
The licensee further stated
the strainer is
backwashed
weekly during the performance of the SI and that
based
on
previous experience,
the strainers
are not likely to clog in such
a
manner
as to affect the operability of the
pump or prevent the system
from performing its design function.
Step 7.3.12.5
placed the Diesel
Fire
Pump Controller Selector
Switch to Auto following performance of
the SI, but did not independently verify its position.
The licensee
stated that independent verification of this step
was not required in
that step 7.3. 12.8 verifies correct positioning of this switch by
observing that annunciator
I-XA-'5-8E, Window 44,
DIESEL
PUMP
LOCAL CONT
IN MNL OR OFF, is not in alarm.
Regional Office Notice
2201,
dated
August 18,
1983 maintains this method of independent verification is
acceptable.
Based
on the above information this item is considered
closed.
Exit Interview (30703)
The inspection
scope
and findings were summarized
on June
19,
1992 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
Descri tion and Reference
260/92-21-01
260/92-21-02
259,
260,
296/92-21-03
NCV,
RWCU Drawing Error, paragraph
three.
IFI, Adequacy of Scaffolding Review, para-
graph three.
VIO, Failure to Adequately Disposition
Nonconforming MME, paragraph
four.
Licensee
management
was informed that
1
URI was closed.
and Initialisms
ASOS
BFNP
BTRD
CFR
CLSD
CRDR
CSSC
Assistant Shift Operations
Supervisor
Anticipated Transient Without Scram
Auxiliary Unit Operators
Browns Ferry Nuclear
Power Plant
Baseline
Test Requirements
Document
Condenser
Cooling Water
Cubic Feet
Per Minute
Code of Federal
Regulations
Central
Laboratories
Services
Department
Control
Room Design
Review
Control
Room Emergency Ventilation System
Critical Structures,
Systems,
and
Components
Common Station Transformers
Drawing Change Authorization
DCN
HWWV
IFI
IR
KV
LCO
LER
LOP/LOCA
NQA
NRC
Radcon
RCW
RMOV
RTO
SPAE
USST
WP
Design
Change Notice
Drawing Discrepancy
Diesel
Generator
Engineering
Change Notice
Emergency
Equipment Cooling Water
Emergency Operating Instruction
Environmental Qualification
Flow Control Valve
Heating, Ventilation,
& Air Conditioning
Hardened
Wet Well Vent
Inspector
Followup Item
Inspection
Report
In Vessel
Visual Inspection
Kilo-volt
Limiting Condition for Operation
Licensee
Event Report
Loss of Power/Loss of Coolant Accident.
Motor Operated
Valve
Maintenance
Request
Measuring
and Test Equipment
Non-Cited Violation
National Fire Protection Association
Nuclear Quality Assurance
Nuclear Regulatory
Commission
Primary Containment Isolation System
Post Maintenance/Modification
Test
Plant Operating Instruction
Quality Assurance
Quality Control
Radiological
Controls
Reactor Building Closed Cooling Water
Raw Cooling Water
Residual
Heat
Removal
Residual
Heat
Removal
Service
Water
Reactor Motor Operated
Valve
Return to Operation
Reactor
Water Cleanup
Systematic
Assessment
of Licensee
Performance
Surveillance Instruction
System Plant Acceptance
Evaluation
System Pre-Operation
Checklist
Safe
Shutdown Analysis
Site Standard
Practice
Unresolved
Item
Unit Service Station Transformer
Violation
Vice President
Work Order
Work Plan
Work Request
0
0