ML18036B178

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Insp Repts 50-259/93-02,50-260/93-02 & 50-296/93-02 on 930116-0217.Violations Noted.Major Areas Inspected:Maint & Surveillance Observation,Operational Safety Verification, Mods,Refueling & Restart Activities & Site Organization
ML18036B178
Person / Time
Site: Browns Ferry  
Issue date: 02/25/1993
From: Kellogg P, Patterson C
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML18036B176 List:
References
50-259-93-02, 50-259-93-2, 50-260-93-02, 50-260-93-2, 50-296-93-02, 50-296-93-2, NUDOCS 9303080045
Download: ML18036B178 (30)


See also: IR 05000259/1993002

Text

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UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION II

101 MARIETTASTREET, N.W.

ATLANTA,GEORGIA 30323

Report Nos.:

50-259/93-02,

50-260/93-02,

and 50-296/93-02

Licensee:

Tennessee

Valley Authority

6N 38A Lookout Place

1101 Market Street

Chattanooga,

TN

37402-2801

Docket Nos.:

50-259,

50-260,.

and 50-296

License Nos.:

DPR-33,

DPR-52,

and

DPR-68

Facility Name:

Browns Ferry Units 1,

2,

and

3

Inspection at Browns Ferry Site near Decatur,

Alabama

Inspection

Conducted:

January

16 - February

17,

1993

Inspector:

atters

n,, Senlo

esI ent

nspector

ate

Soigne

Accompanied

by:

.J.

Munday, Resident

Inspector

R. Musser,

Resident

Inspector

Approved by:

au

e

ogg,

C se

,

Reactor Projects,

Section

4A

Division of Reactor Projects

SUMMARY

ate

cygne

Scope:

This routine resident

inspection

included surveillance

observation,

maintenance

observation,

operational

safety

verification, modifications, refueling activities, Unit 3 restart

activities, site organization,

and self assessment.

One hour of backshift coverage

was routinely worked during the

work week.

Deep backshift inspections

were conducted

on January

25, January

30,

and February 7,

1993.

9303080045

930225

PDR

ADOCK 05000259

6

PDR

Results:

Unit 2 be

an

a

119 da

refu

9

y

cling outage, on January

29,

1993,

paragraph

four.

The unit was shutdown

and fuel off-loaded in a

controlled manner.

The licensee

implemented

the

NUHARC guidelines

for shutdown risk for the outage.

An unresolved

item was identified concerning mislabeling of fuses,

paragraph

four.

As plant equipment

has

been

tagge'd out during the

outage,

plant operators

have discovered that plant drawings

identifying fuse

numbers did not match the labeling in the plant.

Apparently, during the last year over

a thousand

drawing changes

have

been

made

as administrative

changes

to assign

unique fuse

identification numbers to fuses,

but this evolution was not

coordinated with plant operations.

One violation with three

examples

was identified concerning

failure to perform surveillance testing

and properly control work

activities,

paragraphs

two and three.

The first two examples

were

identified by the licensee

but collectively these

examples

indicate additional attention is needed

to ensure

compliance with

technical specifications

and procedures.

,The first example

was

for failure to conduct

a required surveillance test of the reactor

building crane prior to new fuel movement.

This step

was signed

as complete

based

on verbal

communication

but

an adequate

verification was not performed.

The second

example

was for

failure to perform

an adequate

post maintenance

test to ensure

system operability following maintenance.

The work order required

calibration of a temperature

switch, but the physical

work

required

removal of charcoal

trays which was outside of the scope

of the work plan instructions.

The third example identified by an

NRC inspector while observing work on the high pressure

coolant

injection system.

A procedure

step to verify the job

prerequisites

were complete

was not signed.

i

REPORT DETAILS

Persons

Contacted

Licensee

Employees:

  • 0. Zeringue,

Vice Pr'esident

  • J. Scalice,

Plant Manager

J. Rupert,

Engineering

and Modifications Manager

D. Nye, Recovery

Manager

  • H. Herrell, Operations

Manager

  • J. Haddox,

Engineering

Manager

  • H. Bajestani,

Technical

Support

Manager

A. Sorrell, Special

Programs

Manager

C. Crane,

Maintenance

Hanager

  • G. Pierce,

Acting Licensing Manager

  • R. Baron, Site guality Manager
  • 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

  • J. Munday, Resident

Inspector

  • R. Husser,

Resident

Inspector

  • Attended exit interview

Acronyms

and initialisms used throughout this report

ar'e listed in the

last paragraph.

Surveillance

Observation

(61726)

The inspectors

observed

and/or 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,

observa-

tions 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.

The following SIs were reviewed during this reporting

period:

a.

SI 4.2.J. I-IA, Seismic Monitoring Triaxial Time History

Accelerographs

(SHA-2) Channel

Check

0

On January

26,

1993 the inspector

observed

the performance of

portions of SI 4.2.J. 1-1A, Seismic Honitoring Triaxial Time

History Accelerographs

(SHA-2) Channel

Check.

This surveillance

provides

a channel

check of the strong motion accelerographs

which

satisfies

the channel

check requirements

of TS Tables 3.2.J

and

4.2.J.

This procedure verifies proper operation of the batteries.

It also perturbates

the seismic

sensor

and verifies the proper

response

is received.

The inspector

noted

no deficiencies with

this evolution.

O-SI-4.7.C-1,

Three

Zone Secondary

Containment Integrity Test

On January

30,

1993,

the inspectors

observed

portions of Surveil-

lance Instruction O-SI-4.7.C-1,

Three

Zone Secondary

Containment

Integrity. Test.

The purpose of the test is to verify secondary

containment integrity in accordance

with TS 4.7.c. 1.'a

and 4.7.c.2

when the three reactor building zones

and the refueling floor zone

are interconnected.

During the test,

normal

second'ary

containment

ventilation is secured

and the standby

gas treatment

system is

started.

The test verifies the capability to maintain -.25 inches

of water pressure

with inleakage

less

than

12,000 scfm.

During

the surveillance,

the inspectors verified that each

zone

was able

to maintain at least

a -.25 inches of water dp with the areas

outside the building.

Total flow required to achieve the dp was

approximately

10,000 scfm, leaving

a margin of approximately

2,000

scfm.

No discrepancies

were identified.

SI-4.10.D,

Reactor Building Crane

On January

27,

1993, while performing

an annual

audit of

operations activities, quality assurance

identified that SI

4. 10.D, Reactor Building Crane,

had not been 'performed prior to

the crane

being

used to move

new fuel.

Verification of the

surveillance

being performed is accomplished

by performance of

step 4.3. 1 in O-GOI-100-2,

New Fuel Operations.

This step

was

signed

as completed

by the refuel floor .shift manager following

confirmation from the mechanical

foreman.

New fuel'andling

activities were then

commenced.

Upon discovering the surveillance

had not been

performed

crane activities were suspended

and the

surveillance

was performed satisfactorily.

Incident Investigation

93-006

was initiated to determine

the root cause

and corrective

action.

TS 4. 10.D requires

the Reactor Building crane operability

surveillance

be performed prior to the handling of new or spent

fuel

and quarterly thereafter.

TS 6.8. l.l.c requires that

procedures

shall

be established

covering surveillance 'activities

of safety related

equipment;

This is verified by the satisfactory

performance of SI-4. 10.D.

Contrary to this requirement,

the

reactor building crane

was used to move

new fuel between

January

10,

1993

and January

18,

1993 without first satisfactorily

performing SI-4. 10.D.

This is identified as the first example of

~

s.

VIO 259,

260,

296/93-02-01,

Missed Surveillance

Test

and

Procedural

Step.

d.

Local

Leak Rate Test,

LLRT, on the

RCIC Exhaust

Vacuum Breaker

check valve,

2-71-598

On February 9,

1993 the inspector

observed

portions of a LLRT, on

the

RCIC exhaust

vacuum breaker

check valve,

2-71-598,

bonnet

and

packing.

The controlling procedure

was 2-SI-4.7.A.2.g-'2/PBa,

Primary Containment

Local

Leak Rate Test Rotameter

Method:

HPCI

and

RCIC Turbine Exhaust

Vacuum Breaker

Check Valves

and is

performed to satisfy the requirements

of TS 4.7.A.2.g.

The

inspector verified the calibration equipment

was current

and set

up properly.

Conversation with the operator indicated

he was

knowledgeable

about the operation of the equipment.

A test

box

encapsulates

the valve being tested .and is then pressurized

with

,air or nitrogen.

During this test the seal for the test

box

leaked but after replacement

the test

was completed

satisfactorily.

The inspector

had

no concerns with the

performance of this surveillance.

One example of a violation was identified in the Surveillance

Observation

area.

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

{MR, WR,

and

WO) were reviewed to determine

the

status of outstanding

jobs

and to assure

that priority was assigned

to

safety-related

equipment

maintenance

which might affect plant safety.

The inspectors

observed

the following maintenance activities during this

reporting period:

a

~

Fuel

Pool Cooling Piping

On January 20,'993,

the inspector

observed

maintenance

being

performed

on the

1A fuel pool cooling suction piping.

The piping

drain valve BFN-1-DRV-078-0584 was being refurbished

because it

could not be operated.

The system is needed

to support the unit

2

outage

and other repairs

were needed that required draining this

section of piping.

The repairs

were controlled under work order

92-49785-00.

The inspector

noted quality control personnel

monitored the work.

Radiological

procedures

were followed

satisfactorily.

No defi'ciencies

were

noted.'ontrol

Room Emergency Ventilation

On November 28,

1992

an access

panel

and charcoal

tray was

removed'rom

CREV, Unit B, to access'he

sensing

bulb for a temperature

switch requiring calibration.

Following completion of the work,

the charcoal

tray was replaced,

the panel

closed,

and

a smoke test

performed to verify no leaks existed

around the panel

seal.

Work

Order 92-50412-02

was written to perform the maintenance

but

failed to add instructions to remove the access

panel

and the

charcoal filter.

The licensee

stated that the procedure

used to

perform this maintenance

did not state that disassembly

of the

CREV unit was required.

Therefore the planner did not include

this in the work instructions nor the required surveillance.

as

a

post maintenance

test.

The craft performing the maintenance

removed the panel

and charcoal tray to gain access

to the sensing

bulb and performed the work.

On December 30,, 1992, following

completion of identical

work on

CREV Unit A, technical

support

determined that SI 4.7.E.3.A, Control

Room Emergency Ventilation

System Charcoal

Halogenated

Hydrocarbon Test, test

was

needed.

The licensee

then realized the test

was not performed for the

B

unit.

Two root causes

were identified in Incident Investigation II-B-92-

81.

The first was insufficient detail in the work order,

due to

the controlling procedure

not stating that disassembly

was

required.

As

a consequence

the appropriate

post maintenance

test

was not assigned.

The second

was unauthorized

removal of the

charcoal tray,

again

due to an inadequate

procedure

and lack of

attention

by craft personnel,

SSP-6.50,

Post-Maintenance

Testing,

Section 3. 1.2 requires that

post-maintenance

testing shall

be sufficiently comprehensive

to

ensure that corrective and/or preventive maintenance

work does not

adversely affect equipment operability, in this case satisfactory.

performance of the surveillance test.

TS Section 6.8. l.l.c

requires that procedures

shall

be implemented

covering surveil-

lance activities of safety-related

equipment.

Failure to perform

SI O-SI-4.7.E.3.B,

following removal of a charcoal

tray from CREV

Unit

B is

a violation of this requirement

and is identified as the

second

example of VIO 259,

260, 296/93-02-01,

Hissed Surveillance

Tests

and Procedural

Step.

HPCI Turbine Steam Supply Valve

On February ll, 1993 the inspector

observed electrical

maintenance

personnel

reconnecting

the motor power supply for the 2-73-0016,

HPCI Turbine Steam Supply Valve.

The work was being controlled

by

WO 93-00507-1

which was written to provide support to mechanical

maintenance

by disconnecting

and reconnecting

the motor power

5,

supply.

The electrical craft had previously disconnected

the

motor leads

and were in the process

of reconnecting

the leads

following mechanical

maintenance.

The inspector,

upon -reviewing

the

WO noted that the prerequisites

had not yet been

signed off by

the electrical

foreman.

The signature

was required prior to any

work commencing.

The craft were questioned

as to why the

prerequisites

had not been

signed

and they replied that the

foreman just missed it.

Failure to verify that the prerequisites

were satisfied prior to commencing

work is

a violation of SSP-6.2,

Haintenance

Hanagement

System,

and is the third example of VIO

259,260,296/93-02-01,

Hissed Surveillance

Tests

and Procedural

Step.

Two examples of a violation 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,

annunciator

alarm

status,

adherence

to procedures,

adherence

to LCOs, nuclear instruments

operability, temporary alterations

in effect, daily journals

and logs,

stack monitor recorder traces,

and control

room manning.

This

inspection activity also included

numerous

informal discussions

with

operators

and supervisors.

General

plant tours were conducted.

Portions of the turbine buildings,

each reactor building,

and general

plant areas

were visited.

Observations

included valve position

and system alignment,

snubber

and

hanger conditions,

containment isolation alignments,

instrument

readings,

housekeeping,

power supply and breaker alignments,

radiation

and contaminated

area controls,

tag controls

on equipment,

work

activities in progress,

and radiological protection controls.

Informal

discussions

were held with selected

plant personnel

in- their functional

areas

during these tours.

a ~

Unit Status

Unit 2 was shutdown for a scheduled

119 day refueling outage

on

January

29,

1993.

This ended

121 continuous

days of power

operation'.

The generator

was taken off-line at 8:15 a.m.

and a-

manual scram initiated at 9:08 a.m.

Cold shutdown

was achieved

at

10: 15 p.m.

on January

30,

1993.

Fuel offload was completed

on

February

10,

1993.

Danger Tags

Operations

is replacing the old hold order tags with a new larger

style tag.

The old tag

was smaller

and was white with a red

border.

The new tag is red

and

much larger.

This will improve

visibility of the tags

and help to prevent hold order violations.

Operations

has posted large "stop sign" shaped

signs throughout

the plant identifying the

new and old tags

and their purpose.

Use

of the

new tags

should reduce the probability of a person

erroneously

operating

a piece of equipment

removed

from service

by

a hold order.

Standby Liquid Control

On February

1,

1993 while on

a plant tour, the inspector

noted the

Standby Liquid Control local discharge

pressure

gauge indicator

needle

was bent

and missing

a hold-down screw.

Because

a

surveillance

which depended

on the accuracy of this gauge

had

been

performed satisfactorily- the day before,

work order 93-01295

was

written to determine .if the accuracy

was affected

by this damage.

Haintenance

determined

the gauge

was out of calibration

and would

indicate high approximately twenty psi throughout its entire

range.

The gauge

could not be repaired

so it was replaced.

The

inspector

questioned

the validity of the surveillance

performed

the day before.

The .ASHE code,

Section XI, Article IWP-4000,

requires

instruments

to have

an accuracy of two percent

and the

inaccuracy of this gauge

was only one percent.

The licensee

stated that for this reason

the surveillance did not need to be

re-performed.

Lube Oil Control

The inspector

reviewed the licensee's

lube oil control

program due

to

a recent industry event where the wrong oil was put in a

component.

HPI-O-OOO-LUB001, Lubrication of Equipment,

provides

guidance

on the handling, disposal,

and the addition of oil to

plant equipment.

.The procedure

provides

a detailed list of plant

components

and the lubricant required for that component.

In

addition, the list provides the plant location,

system designation

and lubrication points for each

component.

When lubricant needs

to be added to

a component,

Haintenance

personnel

submit

a request

to Power Stores for the type designated

in the procedure.

Power

Stores

personnel

then drain the requested

amount of oil from a

fifty-fivegallon drum into a smaller container.

If all the oil

is not used

by maintenance, it is poured into

a waste oil barrel

and later disposed of.

The inspector

noted

no deficiencies.-

Reactor, Recirculation

Pump

On February

11,

1993, while on

a plant tour, the inspector

noted

that Reactor Recirculation

Pump breaker

1452 did not have

clearance

tags or control

power fuses

hanging

from it although it

had

been previously cleared

out and was obviously de-energized.

The inspector later discussed

this with an

SRO

from 'the

Operations

Work Control

Group who determined that the breaker

had

been

under clearance

2-93-0198 since January

31,

1993

and should

have

had clearance

tags

on the control

power fuses.

When the

inspector

and the

SRO went back to the breaker to investigate,

the

control

power fuses

were pulled

and the clearance

tags

were in

place.

The inspector then informed the

SOS of the findings.

Further investigation

by the Operations

Manager indicated that

an

AUO had previously been directed to remove the tags

from this

breaker

because it was believed to be hanging

on the wrong fuses.

After further review by Operations, it was determined that the

tags

were hanging

on the right. fuses

but the fuses

wer e

mislabeled,

so the tags

were rehung.

This confusion over fuse

labelling resulted "in the clearance

tags not being

hung

as

.indicated

on the Clearance

Sheets.

The mislabelling of these

fuses resulted

from drawings

being

changed

through the

DCN process

without changing

the labels in the

field.

Pending further review of the li'censee's

program in this

area this item will tracked

as

URI 259,260,296/93-02-02,

Mislabel-

ling of Fuses.

One Unresolved

Item was identified in the Operational

Safety

Verification area.

5.

Hodifications'(37700,

37828)

.

The inspectors

maintained

cognizance of modification activities to

support the restart of Unit 2.

.This included reviews of scheduling

and

work control, routine meetings,

and observations

of field activities.

Throughout the observation of modifications being performed in the field

gC inspectors

were observed monitoring and documented verification at

work activities.

a 0

DCN W17049A, Installation of Emergency Lighting System in Cabling

Spreading

Rooms

The inspector toured the cable spreading

room on January

12,

1993

and inspected

the installation of the battery racks for .this

modification.

The purpose of the emergency lighting was to allow

for safe exit in the event of a lighting failure and carbon

dioxide release

into the rooms.

The batteries,

as installed,

were

not seismically mounted since there were gaps

between

the

batteries

and the support brackets.

Also; an identification label

on the lighting system cabinets

was marked

as "S/L EXP. 2/07/93."

The apparent shelf life of some

component

would be reached

in one

month.

The system engineer

reviewed this and found that the

battery charger

had

been placed in service to energize

the battery

although the

DCN was not closed.

This addressed

the concern

about

the shelf life.

The inspector

reviewed the

DCN and addressed

in the safety

assessment

was that the battery packs

and conduits

were

seismically supported.

The inspe'ctor reviewed the vendor

certification for the battery racks.

The licensee

analyzed

the

gaps at the ends of the battery

and concluded that in a seismic

event only movement of three to four inches

would occur.

The gaps

were greater

than six inches

and if additional batteries

were ever,

added

then side bars

would be required.

Security Upgrade Project

On January

21,

1993,

the inspector

performed

a walkdown of,

portions of the security upgrade project.

These

areas

included

modifications in the security diesel

generator building and the

new secondary

alarm station.

The inspector

reviewed various work

documents

at the work sites.

Included in these

documents

were

work plans

0031-93

and 0811-92.

These

work plans dealt with the

~

removal of old conduit

and the installation of new conduit

and

boxes to support the installation of new cardreaders.

During the

review of the work documents,

the inspector

noted that'one of the-

activities were designed

to have site

gC involvement.

The

inspector

brought this to the attention of the licensee's

site

quality organization.

On January

22,

a meeting

was conducted

between

the inspector,

TVA

Site guality and

RUST engineering

personnel

to discuss

the matter

of site quality non-involvement with the workplans specified

above

(RUST is the licensee's

contractor in charge of implementation of

the security upgrade project).

As

a result of the discussion,

the

inspector

was satisfied with the non-involvement of site quality

personnel

with WPs 0031-93

and 0811-92.

However, it was-evident

that

some confusion existed

as to what involvement site quality

would have with the post modification testing of the site security

upgrade.

The meeting

was concluded with the understanding

that

RUST personnel

and

TVA site quality would meet to determine

the

involvement of site quality with the remainder of the

modification.

This meeting

was conducted

on January

26.

On

January

27, the inspector

was briefed

on the results of the

January

26 meeting.

The inspector

was satisfied that the level of

site quality involvement with the remainder of the security

upgrade project would be adequate

and meet the requirements

specified in SSP-3.2

and SSP-8.3.

On February

10,

1993, the inspectors

were informed that

numerous

deficiencies of failure to follow modification and design control

procedures

were identified related to the security upgrade project

and that this matter would be documented

on

SCAR number

BFSCAR930002.

As

a result of these findings, site management

took

the following actions:

l.

A TVA reviewer will review and approve all future

security upgrade

WPs.

2.

RUST Engineering will utilize TVA Modifications and

Addition Instructions

and SSP-9.3 for DCN work

activities.

3.

Prior to performing work activities inside the power

block,. RUST Engineering

must obtain both the

concurrence of the Site equal'ity manager

and

Hodifications manager.

4.

Design Engineering will perform

an evaluation

on- the

conditions identified.

5.

RUST Engineering will review and

TVA will concur with

each individual existing

WP to ensure similar

conditions

do not exist prior to resuming

any work

activities.

The inspectors will continue to monitor the licensee's

actions

as

they relate to the security upgrade project.

Installation of the Hardened

Wetwell Vent

During the inspection period, installation of the hardened

wetwell

vent modification continued.

Work was simultaneously

being

performed

on piping inside

and outside of the unit 2 reactor

building in accordance

with DCNs 17337

and

17491.

The inspectors

routinely toured both work sites to ensure

the modification was

being performed in accordance

with the specified requirements.

On February 8,

1993, while touring the

common header portion of

the

HWWV. outside the reactor building, the inspector

noted that

a

60 foot run of the

14 inch pipe between

two 90 degree

elbows

was

bowed.

The offset of the piping was approximately

6 inches.

The

pipe apparently

b'ecame

bowed when

a horizontal

support block was

removed

from the section of piping in question.

As the block was

removed,

the piping section

downstream

from the area in question,

due to its mass

and elevation difference

(drop in elevation of

approximately

30 feet),

caused

the pipe to shift.

Since the pipe

was located in a trench,

the pipe shifted until pinned against

the

trench wall and'then finally causing

a bowed condition.

The inspector

informed the licensee's

engineering

organization of

the observation.

In response

to the inspectors

observation,

site

engineering

personnel

were to inspect the area in question

and

inform the inspector of their determination of the condition the

following morning.

The next morning the inspector

questioned

engineering

personnel

as to whether they had

come to any

conclusion

on this matter.

Engineering

personnel

involved stated

they hadn't

had

a chance

to observe

and evaluate

the piping.

Following this conversation,

the inspector

proceeded

to the area

in question

and discovered that the piping had

been buried.

Engineering

personnel

were apparently

unaware that the piping was

,

i,

10

scheduled

to be buried and.therefore

did not postpone that action.

Portions of the involved piping were

exhumed

and

some

measurements

taken.

An engineering calculation of the piping bow over the

60

foot length determined that stresses

within the pipe were within

allowable limits for 14 inch schedule

30 piping.

The inspectors

will continue to monitor the modification through'ts

completion.

Refueling Activities (60710)

a 0

b.

Refueling Test

Program

On January

29,

1993, Unit 2 was

shutdown to begin its cycle

6

refueling outage.

The outage is scheduled for 119 days

and

contains

numerous

work activities.

Due to the extensive

modifications

and maintenance

work, the licensee

has determined

that it will be necessary

to perform

a simplified

SPOC

on

some

systems prior to the completion of the outage.

This process,

called the System

Review Checklist, is described

in TI-270,

Refueling Test

Program.

This TI is currently being revised to

clarify the process.

In early February,

the licensee

published

a

list of systems that will undergo this proce'ss.

The inspectors

have reviewed. these

systems

and

have determined

the list to be

adequate.

In addition to providing instructions for performing

a system

review checklist,

TI-270 provides

a method to ensure that all'pen

items affecting plant operability are completed or dispositioned

prior to commencing fuel load

and startup.

Appendix 2, the Fuel

Load Review Checklist,

must

be completed prior to fuel load.

Appendix 3, the Startup

Review Checklist, will be completed, prior

. to unit startup.

Both checklists

are concurred

on by all major

plant department

managers,

the

PORC

and the Plant Hanager.

The TI

also contains

those

SIs which are to be performed during the

initial startup after

a refueling outage.

Th'ese .tests

are

delineated

in Appendix

1 of the TI.

The inspectors will monitor

the licensee's

use of the TI throughout the refueling outage to

ensure that regulatory requirements

are being adhered to.

.Core Off-load

Core off load for the Unit 2 cycle

6 refueling outage

began

on

February 3,

1993,

and

was completed

on February

10.

During this

period, the inspectors

observed defueling operations

on numerous

occasions.

During the initial fuel movement observation,

the

inspector

noted that

no licensed

operators

(SRO or RO) were riding

the refueling bridge during fuel movement.

In lieu of riding the

bridge,

an

SRO was present

in the area of the spent fuel pool

and

was monitoring the defueling evolution.

TS 6.2.2.f states

that

a

SRO shall

be present

during alteration of the core to directly

supervise

the activity.

The inspector consulted

experienced

regional

management

on this matter

and

was informed that the

SRO

did not have to be

on the bridge to directly supervise

the

alteration of the core.

The inspector

observed

defueling operations

from the bridge

on

February

5 and February

9.

Movement of numerous

spent fuel

bundles

from the reactor to the spent fuel pool

as well as

installation of double blade guides

was observed.

Two unlicensed

auxiliary operators

trained in fuel handling were

on the bridge

during all fuel movements.

All fuel movements

were tracked with

fuel movement

sheets

by the bridge operators,

the refueling floor

SRO,

an

AUO maintaining-the refueling floor status

board

and

an

operator in the control

room.

A status

board in the control

room

was also maintained to track fuel movements.

The operators

that

were observed

moving fuel were highly proficient and

knowledgeable.

In the areas

surrounding

the reactor cavity and spent fuel pool,

the licensee

established

a loose object/foreign material

control

zone.

All persons

as well as

any loose tools/objects

were logged

into the area.

An individual was assigned

to control this

process.

All loose objects,

such

as

eye glasses,

were required to

be secured

to the individual with lanyards.

Overall, the foreign

material control associated

with -the defueling operation

appeared

to be

a well controlled process.

LPRM Changeout

The inspector

reviewed the plans to changeout

23

LPRM strings out

of 43 total in the core.

The strings

are being

changed

due to the

high failure rate of a certain type using

a one-sixteenth

inch

conductor that fails due to vibrations."

The

23

new strings all

have one-eighth

'inch diameter conductors.

The remaining '20

strings

are

a type having one-eighth

inch diameter conductors

also

- and have not experienced

the

same type of failures.

The strings will be changed

out during the outage after the vessel

is defueled.

There were

no extra considerations

required for

shutdown risk due to the plant configuration.

The procedure to

changeout

the

LPRM's was SII-O-XX-92-051,

LPRM Maintenance

and

Testing Instruction.

The inspector

reviewed procedure

and

additional testing guidance

provided

by General Electric.

The

inspector will continue to follow these activities

as the

changeout

occurs.

Control Blade Inspections

The inspector

observed

operations

associated

with unlo'ading,

inspecting

and placing

new control blades into the Unit 2 spent

fuel pool.

These activities were controlled by notes

and

precautions

contained in General

Operating Instruction,

O-GOI-100-2,

New Fuel Operations.

Once the shipping crate lid was

removed riggers

used the refuel floor overhead

crane to lift the

12

blade from the crate.

It was then inspected

by certified

inspectors

and placed into the spent fuel pool.

The Refuel Floor

Shift Hanager,

an

SRO, supervised

the entire activity.

The

inspector

noted that

no procedures

were in hand

and being used.

The Refuel Floor Shift Hanager stated that

a prejob briefing

described

the method of lifting the'blade

from the shipping crate

,and was'onsidered

to be skill of the craft.

He also stated that

the inspection criteria were obtained

from a General

Electric

do'cument

and put in the form of a checklist.

He stated that the

checklist

was short

and not required to be in hand during the

inspection

but the information obtained

would be transferred

to

the checklist later.

During the inspection three blades

were

found with bent top handles

and determined to be unacceptable

for

use.

It could'ot

be determined

how the top handles, got bent.

The inspector also questioned

the method for removing the blade

.

from 'the shipping crate.

A strap

was attached

to the top handle

and slowly raised

by the overhead

crane while laborers lifted and

supported

the blade to keep the weight off the top handle.

Once

the blade

was in a vertical position the laborers released'he

blade

and allowed it to be supported

by the top handle

and the

crane.

The

GE document required that

a specialized lifting sling

,

be used.

The Refuel Floor Shift Hanager stated that

TVA didn'

have this type sling but that

GE had approved

the method they were

using.

The inspector

noted

no other discrepancies

with this

activity.

No violations or deviations

were identified.

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 person-

nel, skilled craftsmen,

supervisors,

managers

and executives.

a 0

System

SPOC

.The licensee

had

commenced

a

SPOC review of five systems.

The

systems

selected

were

as follows:

¹5

¹8

¹7

¹37

¹53

Extraction Steam

Turbine Drains

and Hisc. Piping

Turbine Extraction Traps

and Drains

Gland Seal

Water

Demineralizer

Backwash Air System

These

systems

were chosen to exercise

the process

and required

only minor work.

Only a

SPOC

Phase

I (system ready for testing)

review is being performed at this time for these

systems.

'

13

Additionally, the licensee

has developed

a listing of sy'stems

requiring

SPOC for Unit 3 restart.

The systems

were grouped into

three categories;

1) systems

which require

a

SPOC that were not

previously reviewed for Unit 2; 2) systems

which require

a minor

system

SPOC and,;

3) systems

which will not require

a

SPOC.

The

inspector

reviewed the list and

no problems

were identified.

Examples of systems

requiring

a minor

SPOC were the five systems

listed above.

Cleanup Demineralizer

On January

27,

1993, during

a routine tour of the refuel floor,

the inspector

observed that

a radiation monitor reading

1000 mr/hr

was not in alarm although indicating above the labeled

alarm

setpoints.

The monitor was located

18 inches

above

a temporary

cleanup demineralizer

skid used to maintain the Unit 3 reactor

cavity water while modifications were performed

on the

RWCU.

The

alarm setpoint

was labeled at alert

700 mr/hr and alarm 950 mr/hr.

This was discussed

with the health physics technician

assigned

to

the refuel floor.

The alarm setpoint

had

been

changed

to 1400

mr/hr but the labeling

had not changed.

This was because

the

. previous

weekend

CRDs were exercised

on Unit 3 causing

some crud

release

resulting in the radiation increases.

The inspector

reviewed the temporary skid for adequacy of labeling

and locking as

a high radiation, area.

TS requir'es that a-high

radiation area

be locked if greater

than

1000 mrem/hr.

The

monitor probe

was hanging

18 inches

above the skid.

The skid was

wrapped in lead blankets to provide shielding.

Temporary barriers

were erected

on each side of the skid with a lock and chain,

However,

in front of the skid were several

valves

and associated

piping not inside the barrier.

Also, there

was

no barrier to

prevent

anyone

from climbing the front of the skid onto the top of .

the skid.

This was discussed

with the radiological control

manager.

The licensee

stated that the barriers

were adequate

since it would require

a malicious intent to go on top of the

skid.

The inspector

contended that there

was

no locked door or

structure

in front of the skid to prevent

a person

from climbing

on top of the skid.

This concern

was reviewed

by Region II health

physics inspectors

during February 8-12,

1993,

and concluded that

the licensee controls were adequate.

Unit Separation

Program

SSP 12.50, Unit Separation

For Recovery Activities, describes

the

controls established

to ensure that Unit 3 recovery work does

not

impact Unit 2 operations..

This was accomplished

by labelling

equipment

and areas

needed to support Unit 2 operation

and then

limiting personnel

access

to these

areas.

Equipment operation

needed to support unit separation

was controlled by clearances.

14

d.

Unit 3 recovery personnel'ere

identified by.a blue hard hat

and

a

picture

badge with a blue dot.

The blue dot prevented

a Unit 3

person

from wearing

someone else's

hard hat

and entering

a Unit 2

space.

These

personnel

could only enter

a Unit

2- operating

space

following authorization

by the Unit 2 SOS/ASOS

and issuance

of a

black and orange'adge

signifying their approval.

During the time

from cold shutdown of Unit 2 for the cycle six refueling outage

until reload of fuel in the reactor vessel

the

use of black and

orange

badges will be suspended.

Unit 3 personnel will continue

to wear blue hard hats but the use of the blue dot on the their

badges will be discontinued indefinitely.

This is being done

because

past mistakes

were not made

as

a result of. the wrong

personnel

being in the wrong place.

Other aspects

of the unit

separation

program will not be modified.

Cooling Tower Phase II SPOC

On January

21,

1993, the inspector participated

in a followup

.walkdown of cooling towers

1, 5,

and

6 as part of Phase II of the

SPOC process.

The inspector

had previously accompanied

licensee

personnel

on the

Phase

I walkdown on December

7,

1992.

The latest

walkdown was performed to ensure deficiencies

noted during

previous

walkdowns

had

been corrected.

No major discrepancies

were noted.

8.

Site Organization

On February

16,

1993, the licensee

announced

a reorganization

of the

Site guality, Licensing,

and

ISEG organizations

on plant site.

Under

the

new plan", these

groups will be combined to form a new organization

titled Nuclear Assurance

and Licensing.

The new organization will be

headed

by R;R. Baron,

who previously held the position of Site guality

Manager.

Directly reporting to Hr. Baron will be the guality Control

and Support Hanager,

guality Assurance

Manager,

Independent

Review/Analysis

Manager,

and the Licensing Manager.

Hr. Baron will

report directly to Hr. J. Haciejewski,

Corporate

Nuclear Assurance

General

Hanager,

and indirectly to Hr. O.J.

Zeringue, Site Vice

President.,

Although effective immediately,

the organization will be in

a transition period for approximately four months.

9.

Self Assessment

(40500)

a.

PORC

On February

10,

1993, the inspector

attended

a weekly meeting of

the

PORC.

The meeting

was conducted

in accordance

with, TS 6.5

requirements.

For

13 agenda

items presented,

two items required

additional clarification and

one was disapproved.

The

PORC

members

provided

an effective review for the items questioning

manual

operator action requirements

and unnecessary

cable

replacement.

15

b.

Outage

Risk Hanagement

The inspector

reviewed processes

established

by the licensee for

reducing plant outage risks.

Although plant procedures

have not

yet been revised to include

NUHARC guidance

on shutdown

manage-

ment, the guidance

was incorporated

into the planning of the

current outage.-

In December,

1992,

an evaluation

was conducted

by

site

and corporate

personnel

of the Unit 2 cycle

6 outage

schedule

as

recommended

by NUHARC-91-06, Guidelines for Industry Actions to

Assess

Shutdown

Hanagement.

The team identified

a number of items

to improve the schedule

including such things

as maintaining

HPCI/RCIC available until the reactor

head

was removed,

not

performing tests

which breach the main steam

system until the

steam line plugs were installed,

and delaying reactor

bottom drain

work until the fuel pool gates

were reinstalled.

These

items were

appropriately. dispositioned.

Overall the

t'earn concluded that the

schedule

had adequately,

considered

the. concept of defense

in depth

and

had

been constructed

conservatively with respect

to nuclear

safety issues.

Additionally the licensee

developed

a matrix

which identifies the systems

available for decay heat removal,

fission product barriers, reactivity control

systems,

systems

available for fuel pool cooling, switchyard activities,

AC and

DC

power available,

etc.

This matrix is updated daily and.is

included in the Plan of the Day package.

The inspector

noted that

the= main steam line plugs were sealed

by the use of station

service air, without a backup supply.

This was brought to the

attention of the Haintenance'Hanager,

who stated that the plug has

an air supplied bellows type seal

and

an 0-ring type seal.

This

design

ensures

the plug" does not leak if one of the seals fail.

10:

Exit Interview (30703)

The inspection

scope

and findings were

summarized

on February

19,

1993

with those

persons

indicated

i.n 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

259,

260,

296/93-02-01

259,

260,

296/93-02-02

VIO, Hissed Surveillance Test

and

Procedural

Step,'aragraphs

two and three.

URI, Hislabelling of Fuses,

paragraph

four.

ll.

Acronyms

and Initialisms

ASHE

American Society of Hechanical

Engineers

ASOS

AUO

,

BFN

CFR

CRD

'CRDR

CREV

DCN

'DP

GE'OI

HPCI

HWWV

ISEG

LCO

LLRT

LPRM

MR

NRC

NRR

PORC

QA

QC

RCIC

.RO

RWCU

SCFM

SI

SPOC

SRO

SSP

TI

TS

URI

VIO

WO

WP

WR 16

Assistant Shift Operations

Supervisor

Auxiliary Unit Operator

Browns Ferry Nuclear Plant

Code of Federal

Regulations

Control

Rod Drive System

Control

Room Design

Review

Control

Room Emergency Ventilation

Design

Change Notice

Differential Pressure

'eneral

Electric

General

Operating Instruction

High Pressure

Coolant Injection

Hardened

Wetwell Vent

Independent

Safety Engineering

Group

Limiting Condition for Operation

Local

Leak Rate Test

Local

Power

Range Monitor

Maintenance

Request

Nuclear Regulatory

Commission

Nuclear Reactor Regulation

Plant Operations

Review Committee

Quality Assurance

Quality Control

Reactor

Core Isolation Cooling

Reactor Operator

Reactor

Water Cleanup

Standard

Cubic Feet

Per Minute

Surveillance Instruction

System Pre-Operability Checklist

Senior Reactor Operator

Site Standard

Practice

Technical Instruction

Technical Specification

Unresolved

Item

Violation

Work Order

Work Plan

Work Request

1

'