ML18039A253
| ML18039A253 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 02/12/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18039A251 | List: |
| References | |
| 50-259-97-12, 50-260-97-12, 50-296-97-12, NUDOCS 9803040159 | |
| Download: ML18039A253 (68) | |
See also: IR 05000259/1997012
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION II
Docket Nos:
License
Nos:
50-259,
50-260,
50-296
Report Nos:
50-259/97-12,
50-260/97-12,
50-296/97-12
Licensee:
Valley Authority
Facility:
Browns Ferry Nuclear Plant, Units 1, 2,
8 3
Location:
Corner of Shaw and Browns Ferry Roads
Athens,
35611
Dates:
December
7.
1997 - January
17.
1998
Inspectors:
L. Wert, Senior Resident
Inspector
J. Starefos,
Resident
Inspector
E. DiPaolo, Resident
Inspector
W. Bearden,. Reactor
Inspector
(Sections Ml.3. M3)
R.
Chou,
Reactor
Inspector
(Sections
M1.3,
M3)
E. Guthrie, Resident
Inspector,
Brunswick
(Sections
01.2, 01.3.
M1.1)
G. Salyers,
Emergency
Preparedness
Inspector
(Section P2.1,
P2.2,
P3. 1,
P5. 1, P5.2,
P7. 1,
P7.2)
E. Testa.
Health Physics
Inspector
(Sections Rl.1, R2.1,
R2.2)
D. Thompson,
Security Inspector
(Section S1.2)
Approved by:
M. Lesser,
Chief
Reactor Projects
Branch
6
Division of Reactor Projects
Enclosure
2
9'803040159
9202'f2
ADQCK 05000259
6
EXECUTIVE SUMMARY
Browns Ferry Nuclear
Plant, Units 1. 2,
8 3
NRC Inspection
Repor t 50-259/97-12.
50-260/97-12,
50-296/97-12
This integrated inspection included aspects
of licensee operations.
engineering,
maintenance,
and plant support.
The report covers
a six-week
period of resident inspection
and inspection in the areas of Maintenance
and
Plant Support by Region II Division of Reactor
Safety inspectors.
o~ei
Control of important plant equipment
and systems
during the diesel
generator
outage for the
12 year
maintenance
inspection
was good.
The electrical
portion of.the
3C diesel
generator
tagout conser vatively used
redundant
means
to ensure
equipment
was de-energized.
One exception to normal site practices
was identified associated
with tagging of removed potential transformer fuses.
(Section 01.1)
Deficiencies were identified during testing of the Reactor
Core Isolation
Cooling system:
~
Poor attention to detai 1 during
a valve stroke test was identified by
the inspector.
The operator
did not closely read
a procedure
step
and
consequently
misunderstood
the actions
necessary
after
a valve stroke
time was determined to be outside the normal
range.
(Section 01.2)
~
The briefing before
a rated flow test
was not thorough in that it did
not include an overview of the test
and did not address
specific actions
of personnel
involved in the test.
. The operator initially established
a
pump flowrate and due to indicated fluxuations, it was not clear to
the inspector
that the specified
minimum value was met.
This was later
corrected.
(Section 01.3)
The licensee effectively monitored control
room deficiencies.
Aggressive
goals
have been set to reduce the number of control
room deficiencies.
Backup
Control
Panel deficiencies
are not included in the control
room deficiency
list although their importance
may warrant increased
awareness.
(Section 02.2)
A licensee identified and corrected non-cited violation was identified
,involving control rod drive temperature
recorders
in the control
room.
Inadequate
procedural
guidance resulted in some of the alarm points being
inadvertently turned off. (Non-Cited Violation 260/97-12-01,
Inadequate
Procedural
Controls
on
CRD Temperature
Alarms, Section 08.1)
Maintenance:
Calibration of the residual
heat
removal
Loop A discharge
pressure
instrument
was performed satisfactorily
and good worker practices
were used during the
surveillance.
Test equipment
was observed to not have foreign material
exclusion protection.
(Section Ml.l)
Good preparation
and detailed planning for the
12 year maintenance
inspection
on the
3C emergency diesel
generator
was evident.
The training of contract
workers using
a surplus diesel
generator
in the training center
was
a good
initiative.
Minor issues
were identified with the control of contr act workers
from a security aspect
(Section M1.2).
A violation of regulatory requi rements
was identified regarding failure to
'romptly
document
a condition adverse to quality identified by the
NRC.
Previous inspections
have identified other
examples
where the initiation of
problem reports
was prompted
by the
NRC.
(Violation 296/97-12-02,
Failure to
Document Condition Adverse to Quality. Section
M1.2)
Setpoint values
used in the instrument calibration
and functional tests
were
consistent with the allowable values
from the licensee's
setpoint
and scaling
documents
and the Technical Specifications
(Section M1.3).
Completed
Work Order
(WO) packages
reviewed by the inspectors
were generally
adequate.
They
contained sufficient details,
work instructions,
and
requirements
for craftworker implementation.
The work. tests.
and
documentation
completed
met the stated
requirements
(Section
M3. 1).
A licensee identified and corrected non-cited violation was identified for one
example of an inadequate
post- modification test associated
with the Unit 3
Drywell Leak Detection System Outboard Return Isolation Valve (Section H3.2).
Improvement
was noted in the post maintenance testing planning process for
recently completed
maintenance
work activities (Section M3.2).
The licensee's
program for controlling temporary modifications was adequate
(Section H3.3).
Overall, the maintenance
department's
self assessment
program was effective in
that management
has identified and pursued
areas
needing
improvement (Section
H7.1):
Numerous maintenance
proficiency indicators are monitored closely for
detection of areas
needing
improvement.
High expectations
are
established
through the establishment
of challenging goals.
Performance
data
from completed observation checklists is effectively
incorporated into monthly reports.
Implementation of the self
assessment
program was prudently revised
by maintenance
management to
focus
on recognized
weak areas.
Some of the observation checklists
were noted
as not sufficiently
critical during self assessments.
The procedural
guidance for the
administration
of the self assessment
checklists
does not accurately
reflect actual
implementation.
Maintenance
management's
expectations
for feedback to the observed individual, signatures
on completed
checklists.
and degree of self-critism were not being met.
A licensee identified and corrected non-cited violation was identified
involving an inadvertent
engineered
safety feature actuation during post
modification testing.
(NCV 50-260/97-12-03,
Inadequate
Procedure
for
PMT.
Section
M8.1)
En ineerin
The licensee
has
implemented significant modifications to increase
the air
system capacity
and reliability.
Insufficient preventive maintenance
on the
control air dryers resulted in several
recent air system transients.
Problems
with the installation of water trap drain lines has resulted in an operator
work around which the licensee is continuing to resolve.
The licensee
has
adequate
measures
in place to periodically verify control/instrument air
quality.
(Section El. 1)
A licensee identified and corrected non-cited violation was identified
involving different residual
heat
removal service water
pump operability
requirements
in Technical Specifications
and the Updated Final Safety Analysis
Report.
The licensee's
safety assessment
provided in the Licensee
Event
Report was thorough.
(NCV 259,260,296/97-12-04,
Design Basis
Not Translated
Properly for RHRSW Pump Requirements.
Section
E8.1)
The Emergency
Preparedness
program overall continued to be strong.
(Section
P3.1)
The
NRC and licensee
goal for declaration of an emergency classification
within 15 minutes of event recognition was exceeded
by 12 minutes during the
loss of station
power event
on March 5.
1997.
It was not clear to the
inspector that the licensee's
evaluation of this aspect
was self-critical and
that the delay was sufficiently explained.
(Section
P3. 1)
Emergency
Response facilities were satisfactorily maintained.
(Section
P2. 1)
Emergency
Preparedness
audits were organized .and objective and satisfied
requirements of 10 CFR 50.54t (Section
P7. 1)
The licensee
had effectively implemented
a program for shipping radioactive
materials required by NRC and
DOT regulations.
(Section Rl. 1)
Radiological conditions in radioactive waste storage
areas
were observed to be
good.
Material was labeled appropriately,
and areas
were properly posted.
(Section R2.1)
RADCON problem reports
were aggressively
evaluated.
cause analysis
performed
and corrective measures
to prevent recurrence instituted.
(Section
R2.1)
Liquid effluent releases
reviewed during this inspection were found to meet
the regulatory requirements
and the compensatory
analysis permitted by the
Offsite Dose Calculation
Manual during the effluent radiation monitor 0-RM-130
outage were satisfactory.
(Section R2.2)
The inspectors
determined that the licensee
had established
in their
procedures
an appeals
process
and
an adjudication process to ensure that
personnel
who were granted
unescorted
access
were trustworthy, reliable and do
not constitute
an unreasonable
risk to the health
and safety of the public.
(Section S1.2)
Summar
of Plant Status
Re ort Details
Unit 1 remained in a long-term lay-up condition with the reactor defueled.
Unit 2 operated at or near full,power with the exception of routine testing
and scheduled
maintenance
Unit 3 operated at or near full power with the exception of routine testing
and scheduled
maintenance
On December
24.
1997. Unit 3 reduced
power
for about
one hour due to a leak on
a Reactor
Water Cleanup
(RWCU) heat
exchanger
The leak was subsequently
repaired.
At the close of the
report period, the licensee
was pursuing
a more permanent
repair.
While performing the inspections
discussed
in this report. the inspectors
reviewed the applicable portions of the Updated final Safety Analysis Report
(UFSAR) that related to most of the areas
inspected.
No discrepancies
were
identified.
IIOI ll
Ol
Conduct of Operations
01.1
3C Diesel Generator
Removal
from Service
a.
Ins ection Sco
e
71707
The resident inspectors
reviewed activities associated
with removing the
3C emergency diesel
generator
(EDG) from service for the
12 year
maintenance
inspection.
One of the resident
inspector s performed
a
detailed review of the electrical portions of the
3C diesel
generator
tagout.
Another inspector
reviewed licensee
actions taken to ensure
compliance with Technical Specifications
and Operations
Standing Order
OS-0128.
The inspector also reviewed the Probabilistic Safety
Assessment
(PSA) Profile that was developed for the
3C diesel
12-year
maintenance
outage.
b.
Observations
and Findin s
The hold order clearance
used for the
3C DG.outage
was broken into four
separate
tagout groups.
These were electrical.
lube oil and fuel oil,
cooling and instrumentation,
and air starting system.
The inspector
performed
a detailed
check of the electrical portions ot the tagout.
The inspector
reviewed reference
drawings to ensure that protection to
plant equipment
and personnel
was provided by the tagout.
The
electrical portions were adequate.
Redundant
methods of deenergizing
equipment
was used.
For example.
the
DG output breaker
was racked out
and tagged
and also the breaker
control
power fuses
were pulled.
The
inspector
found that the electrical tagout also contained
items that
would prevent engine rotation although this was not necessary
for
electrical protection.
For
example.
the electrical
system tagout
contained tags
on air start system
components to ensure that the engine
was not inadvertently rotated.
The inspector performed
a walkdown of all installed electrical
component
tags.
All components
were in the required positions with the
appropriate
tags in place.
The inspector identified
a minor discrepancy
involving the
3C
DG output breaker
(Breaker
1832) potential transformer
fuses
(3-FU4-3ECAR).
Normally, clearances
on fused circuits (other than
control circuits) have the hold notice tag attached to the fuse
compartment
door after the fuses
have
been
removed from the circuit.
In
this case,
the fuses were removed
and placed in a bag with the tag and
placed
on top of the cabinet.
The licensee initiated
a
PER to
investigate the discrepancy.
The licensee
also performed
a review of
all current
hold orders tags
on non control
power
fuses.
No additional
discrepancies
were noted.
The inspectors verified that the licensee
adequately
implemented the new
license requirements
established
when the Technical Specifications
were
revised for the 12 year diesel
generator
inspection.
The licensee
posted
magenta
operator information cards
and placards for protected
equipment.
On January
11.
1998, the inspectors
reviewed Operations
,Standing
Order OS-0128,
Diesel
Generator
12-Year Outage
Requirements,
Attachment
3C,
3EC
DG Protected
Equipment Requirements.
The inspectors
verified a sample of the attachment to ensure that the magenta
operator
information cards
and placards
were placed
on identified plant
equipment.
The attachment
also specified seven switchyard entrance
placards,
however specific locations were not detailed.
The inspectors
walked down the transformer
yard fence
and noted placards
were placed
on
only two gate entrances.
The inspector questioned
the Shift Manager
(SM) about the locations of the placards.
Subsequently,
the standing
order
was changed to specifically identify the location of 15 placards
to be placed
around the transformer yard, switchyard,
and 161-kV
capacitor
bank.
The inspectors
toured the control
rooms to ensure that
work was not being performed that would make systems
inoperable which
were'equired
during the diesel
generator
outage.
No problems were
identified.
The inspector
reviewed the Probabilistic Safety Assessment
(PSA) profile
and compared it to the SSP-7.1
Dual Unit Maintenance Matrix.
No
problems were found with the profile as
compared to the matrix.
While
reviewing the matrix, the inspector
requested
a copy of the Dual Unit
Maintenance Matrix from the planning supervisor.
The copy that was
provided
(marked
as the current revision)
was
a slightly different
.version of the matrix .than the matrix in the current
SSP-7. 1.
Subsequently,
the licensee
found that the Unit 2 control
room also had
an incorrect revision of the Dual Unit Maintenance Matrix.
The licensee
initiated
PER 980052 to address
the apparent controlled document issues.
0
01.2
, b.
Conclusion
The electrical portion of the
3C
DG system tagout conservatively
used
redundant
means to ensure
equipment
was de-energized.
One exception to
normal site practices
was found with the handling,of removed fuses
and
tags associated
with potential transformer fuses.
Control of important
plant equipment
and systems
during the diesel
generator
outage
was good
Reactor
Core Isolation Coolin
S stem Motor 0 crated Valve
JODbi 1it
7 t
Ins ection Sco
e
71707
The inspector
observed surveillance test 2-SI-4.5.F.l.c,
Reactor
Core
Isolation Cooling (RCIC) System Motor Operated
Valve
(MOV) Operability.
Observations
and Findin s
The inspector
observed
the performance of'he
RCIC system
operability surveillance test
on January
7,
1998.
The purpose of this
test was to determine the operability of the
RCIC system
and to ensure
conformance with Technical Specification (TS) 4.5.F. l.c and 1.0.MM.
TS
. 1.0.MH implements the requirements
for Inservice Testing of the American
Society of Mechanical
Engineers
Code Class 1.2,
and 3 components.
The inspector verified that the procedure
used for the test
was approved
and met the requirements
of the TS.
The inspector
observed that the
prerequisites
for conducting the test were met and the appropriate
TS
Limiting Condition for Operations
were entered.
The inspector verified
that the timing values
recorded
and. the process of obtaining the values
were correct
and within acceptable limits per the procedure.
The measured
stroke time of one valve was less than the maximum
allowable,
but more than the normal range.
The inspector
observed that
the operator
misread the procedure
and thus did not recognize that the
valve needed to be restroked
and timed.
The operator timed valve 2-FCV-
71-6A,
RCIC Steam Line Drain Inboard Isolation valve,
as 2.9 seconds
in
the open direction.
This value was outside the normal
range of 0.8- 2.6
seconds,
but within the maximum allowable value of 3.4 seconds.
The
procedure indicated that the valve should
be stroked again.
The next
three steps in the procedure
described the restroke timing sequence to
be performed
when the conditions were met necessitating
that the valve
be restroked.
The operator misread the guidance
and determined these
steps to be nonapplicable.
The
NRC inspector discussed
the procedure
guidance with the operator.
The operator, after additional
review of
the procedure.
performed the restroke timing and recorded the data
according to the procedure.
The inspector noted that the licensee's
procedures
require
a detailed
review of the surveillance
packages
following testing to identify errors
such
as the one described
above.
01.3
The inspector
observed the completion of the surveillance
and the review
of the surveillance
package
by the Unit Supervisor.
.The inspector
found
no further discrepancies.
Conclusions
Overall conduct of the surveillance test
was adequate.
Poor
attention'o
detail during
a portion. of the test
was identified by the inspector.
The operator did not closely read
a procedure
step
and consequently
misunderstood
the actions necessary
after
a valve stroke time was
determined to be outside the normal
range.
Observation of Reactor
Core Isolation Coolin
Rated
Flow Test
Ins ection Sco
e
71707
The inspector
ob'served the performance of 2-SI-4.5.F.l.d,
RCIC System
Rated Flow at Normal Operating
Pressure
surveillance test.
Observations
and Findin s
.On January
7,
1998. the inspector
observed the performance of
surveillance test 2-SI-4.5.F.1.d,
RCIC System
Rated
Flow at Normal
Operating Pressure.
The purpose of this surveillance test
was to
.determine the operability of the
RCIC system in conformance with the
requirements
in TS 4.5.F. l.d and 4.5.H.3.
This test is also performed
to provide data
used to evaluate the
RCIC pump performance for ASHE
Section
XI requirements,
specified in TS 1.0.HH.
The inspector verified that the procedure
used during the performance of
the test
was
an approved
procedure
and met the TS requirements.
The
inspector
observed that the required
TS Limiting Conditions for
Operation were entered while conducting this surveillance.
The inspector attended the pre-evolution briefing and noted that the
personnel
requi red by the procedure
were present.
The brief was
conducted in the Unit 2 Control
Room.
The briefing discussed
the
precautions
and limitations. radiological controls.
and reminders of
good operating techniques.
The inspector
observed that the briefing did
not address
an overview of the test or each individual's specific
involvement in the test.
The impact of not addressing
these specifics
during the briefing subsequently
became evident.
Personnel
located in
the
RCIC turbine room did not fully understand
the scope of testing
being performed
and consequently
a delay in testing occurred.
The
inspector
noted that the Unit Operator
did not use
a briefing checklist,
such
as the list in Site Standard
Procedures
12.1,
Conduct of
Operations,
section 3.6, entitled Evolution Briefings.
After the
RCIC turbine was started
and the specified
pump discharge
pressure
and flowrate were established,
the inspector
observed that the
indicated
RCIC pump discharge
pressure
was cycling periodically above
and below the specified value.
The procedure stated that the flowrate
02
02.1
be established
at or above the specified value.
The inspector
questioned
the Unit Supervisor whether, the indicated flowrate was
acceptable for the test.
The Unit Supervisor
observed the flowrate and
decided to have the operator establish
a slightly higher flowrate.
These observations
were discussed
with the Operations
Manager
.
Subsequently,
a Problem Event Report
(PER)
was initiated addressing
the
issues
described
above.
Management
indicated that plant policies
and'ractices
regar ding reading these type of indications would be reviewed..
The inspector verified that all acceptance criteria data
was
satisfactory, all equipment
used to perform the test was within the
calibration periodicity, and that the ultrasonic flow detector
was
correctly installed, with the proper test parameters
loaded into the
computer.
The inspector
observed
personnel
in the RCIC turbine
room and
noted that
some copies of the test being used to perform steps in the
procedure
were marked
as information only, while others
were not.
The
master
copy, which was located in the Unit 2 Control
Room,
was not
marked
as
a master
copy.
Conclusions
The surveillance test
was completed satisfactorily.
The briefing before
the test
was not thorough in that it did not include an overview of the
test
and did not address
specific actions of personnel
involved in the
test.
The operator initially established
a pump flowrate
and due to
.indicated fluctuations, it was not clear to the inspector that the
specified
minimum value was met.,
This was later corrected.
Operational
Status of Facilities and Equipment
Hi h Pressure
Coolant In'ection
S s
em Walkdown
Ins ection Sco
e
71707
The inspector
performed
a detailed
system walkdown of the Unit 3 High
Pressure
Coolant Injection (HPCI) system in accordance
with Inspection
Procedure
71707.
Portions of the Unit 2 HPCI system were also reviewed.
Observations
and Findin s
Checks of all accessible
valves
showed
an overall
good material
condition.
System valves
and breakers
were positioned
as required by
system procedures.
No excessive oil leakage
was noted from system
components.
Inspection of the interior of the
HPCI relay cabinets for
Units 2 and 3 showed that no jumpers were present.
Conditions of the
interior of the cabinets
was good.
A piping support for a vent line for the Suppression
Pool Outboard
Suction
(3-FCV-073-27) valve was not properly installed and hanging from
piping.
This deficiency was previously identified by the licensee
and
a
work request to correct the deficiency had been written.
The inspector
questioned
whether the deficient piping support
posed
an operability
concern.
The system engineer
found that
PER 970918 was written to
investigate the. pipe hanger discrepancy.
The
PER determined that the
discrepancy
did not affect oper ability and that the hanger
had not been
reinstall'ed following valve maintenance
on an adjacent
The
work to correct the discrepancy is scheduled
for the next planned
system
outage in February
1998.
While reviewing Unit 2 HPCI system,
the inspector
noted that the Gland
Seal
Exhauster suction coupling was different than the one used
on
Unit 3.
Although it was apparent that Unit 3 couplings were flexible as
discussed
in the
FSAR, it was not clear to the inspector that the Unit 2
coupling was flexible.
The system engineer
was notified of these
differences
and subsequently verified that the coupling was in fact
flexible and was part of the original design.
The coupling used
on
Unit 3 HPCI system
was of a newer design.
A steam packing leak from the turbine inlet steam trap inlet isolation
valve (3-SHV-73-'592) was observed to be blowing steam near
an electrical
junction box for the HPCI system
(3-JBOX-073-3134).
The box appeared
sealed
and contains
a drain hole as required.
The leaking valve had an
open work request.
Discussions with the system engineer indicated that
he was knowledgeable
about the packing leak and was monitoring the
status periodically.
The licensee
subsequently
installed
a temporary
herculite barrier to protect the junction box.
c.
Conclusion
The portions of the Unit 3 HPCI system reviewed were in conformance with
plant instructions.
Overall material condition was good.
The licensee
was adequately identifying and pursuing corrective actions for system
material condition deficiencies
such
as minor leaks.
02.2
Control
Room Deficiencies
Ins ection Sco
e
71707
The resident inspectors
reviewed the licensee's
process
and
implementation of identifying and tracking control
room equipment
deficiencies.
The inspector also performed
a walkdown of control
room
instrumentation
and indications to verify that deficiencies
were
accurately
being tracked.
The inspector
also performed
a walkdown of
the Backup Control Panels.
Observations
and Findin s
The licensee
has not established
a formalized procedure to identify and
track control
room equipment deficiencies.
Discussions with plant
, operators
indicated that previously there
was
a standing
order which
contained
guidance.
The guidance is currently still used
even though
the standing order is no longer in use.
The licensee defines
a control
room deficiency as
a problem with a control or indication in the control
room or remote equipment which fails to operate
from the control
room
7
point of control.
Control
room deficiencies
which have
a work request
(WR) submitted are broken into the following three work categories:
~
Control
room WR's which can be worked at steady state
100K power
~
Control
room WR's which require
a load reduction to work
~
Control
room WR's which require
an outage to work
The control
room
MR list is audited weekly in accordance
with the
guidance
and the operations
department activities schedule.
The
inspector
reviewed the list as contained in the licensee's
work planning
and control data
base.
The inspector
performed
a walkdown of the Unit 2
control panels to compare the list to the actual control
room
conditions.
No additional discrepancies
were noted by the inspector.
Discussions with plant operators
indicated that there were different
interpretations for categorizing
a control
room deficiency.
The
licensee
previou'sly identified this and presently requi res the shift
manager
to approve all control
room deficiencies.
This has
reduced the
number of errors in categorizing control
room deficiencies
and improved
consistency.
Control
room deficiencies
are monitored on
a weekly basis in the plan of
the day meeting.
The plan of the day document includes
a list of WRs
that can be worked at rated power.
Trend reports of control
room
deficiencies
are also included.
The licensee
informed the inspector
that this is performed in order to increase
management's
awareness
of
control
room deficiencies
and to heighten their priority in work
planning.
The inspector
found no recent adverse'rend
in the number of
non outage or power reduction control
room deficiencies
(16 for Unit 2
and
12 for Unit 3 when reviewed by the inspector).
During attendance
at
a maintenance
department. performance indicator meeting, the inspectors
observed that control
room deficiencies
were addressed
and that
aggressive
goals
have been set.
The maintenance
department
goal is 5
deficiencies
per operating unit control
room.
The inspectors
have also
noted
an emphasis
on resolution of CR deficiencies
during refueling
outages.
The inspector noted that the Backup Control
Panel for Unit 2 had three
items that had work requests.
Two of the deficiencies
were identified
in January
1997
and the other
was identified in June
1997.
These
items
were not tracked
as control
room deficiencies
although the importance of
the Backup Control
Panel
may warrant increased priority over other plant
work requests.
Conclusion
The licensee effectively tracks
and trends control
room deficiencies.
Aggressive goals
have been set to reduce the number of control
room
deficiencies.
The inspector noted that Backup Control
Panel
deficiencies
are not included in the control
room deficiency list
although their importance
may warrant increased
awareness.
0;
08
08.1
Miscellaneous
Operations
Issues
(92901)
0 en
Ins ection Followu
Item 260 296/97-11-01,
Status
Control Issues.
On October 21,
1997, the
icensee identified that all inputs from the
control rod drive
(CRD) temperature
recorders to the
CRD Unit High
Temperature
in the Unit 2 control
room were disabled.
The
licensee's
investigation determined that the alarms for each point would
be turned off if a change, of the range data
was performed for that data
.
point on the recorder.
If an individual was viewing (not making program
changes,
only viewing) the range settings for any or all channels
on the
HR2500E Yokogawa recorder,
and exited the setup
menu by pressing the
"enter" and "end" softkeys rather than "aborting," then the recorder
would still view this action as
a channel
setup
change.
Although the
current range data information would be retained,
the alarm setup would
default to the "off" or disabled
mode.
The licensee indicated that an
individual performing
a scan of the range data could have inadvertently
disabled the points.
The licensee attributed the event to the lack of
clarity in the vendor technical
manual for the recorder
.
The inspectors
reviewed the licensee's
planned corrective actions
associated
with the disabled
CRD alarms.
Corrective actions
included
re-enabling the
CRD high temperature
alarm functions, briefing the
Instrument Maintenance
and Operations
personnel
to heighten the
awareness
associated
with recorder
program response to viewing program
data,
revising Yokogawa controlled vendor manual to clarify the setup
mode operation of HR 2500E
Yokogawa recorders,
evaluating training
course
ICT 103.010L
(Yokogawa Recorder
Programming
Lab Guide)
and
addressing
deficiencies,
and evaluating the availability / use of tamper
indicating devices
on Yokogawa keylock switches.
The Final Safety Analysis Report specifically addresses
that the control
rod drive temperature light is provided in the control
room to allow the
operator to know the condition of the Control
Rod Drive Hydraulic
System.
The
FSAR also specifically addresses
these
recorders
(2-TR-85-7A and 2-TR-85-7B) and the trip settings.
The inspectors
noted
that the Integrated
Computer System provides indications of elevated
temperatures
in the
CR independent of these
recorders.
Temperatures
above the alarm setpoint are printed out on an alarm typer in the
CR.
The inadequate
procedural
guidance for work on this quality related
recorder
caused
the alarms for each point to be turned off.
This is
a
violation of 10 CFR 50 Appendix B, Criterion
VS Instructions,
Procedures,
and Drawings.
This licensee-identified
and corrected
violation is being treated
as
a Non-Cited Violation, consistent with
Section VII.B.1 of the
NRC Enforcement Policy (Non-Cited Violation
260/97-12-01,
Inadequate
Procedural
Controls
on
CRD Temperature Alarms).
The IFI will remain open for additional
review of status control issues.
Conduct of Maintenance
II. Maintenance
Ml.1
Loo
A Residual
Heat
Removal
Dischar
e Pressure
Switch
Calibration.
Ins ection Sco
e
71707
The inspector observed the performance of 3-SI-4.2.B-54,
Core
Standby'ooling
System Residual
Heat
Removal
(RHR) Loop A Calibration
surveillance.
Observations
and Findin s
On January
8,
1998, the inspector observed 3-SI-4.2.B-54.
RHR Loop A
Discharge
Pressure
Calibration surveillance.
This procedure is intended
to satisfy the calibration requi rements specified in TS tables 3.3.B and
4.2.B.
The inspector verified that the procedure
was approved
and that
equipment
used
was within the calibration period.
The inspector
observed that the surveillance
was conducted satisfactorily.
The
workers used
good work practices
employing
a reader-performer
method to
perform each step of the surveillance,
and good communications
were
noted throughout the evolution.
The inspector observed that the workers demonstrated
good ownership by
submitting recommendations f'r procedure
improvements after the
surveillance
was complete.
The workers noted that the sequence
of
steps.
during thk restoration part of the procedure.
should
be changed
to improve the procedure.
The inspector
observed.
during review of the
data
recorded in the procedure,
that no order of magnitude
was provided
for an acceptance criteria value.
The acceptance criteria specified
millivolts but this was not recorded
on the data table.
The worker
appropriately
added this information and submitted
a procedure
change.
During the acquisition of the test equipment.
the inspector
observed
that the equipment did not have foreign material exclusion
(FME)
protective coverings installed.
This condition was also noted
on
equipment located
on storage
racks
and calibrated high accuracy pressure
gages.
The licensee
subsequently
placed
FME covers
on the equipment.
The licensee
discussed
with the inspector that additional evaluation
would be performed regarding implementation of FME protection
on test
equipment.
c.
Conclusions
The
RHR Loop A Discharge
Pressure
Calibration was performed
satisfactorily and good worker practices
were used during the
surveillance.
Some test equipment
was observed to not have foreign
material exclusion protection.
10
Emer enc
Diesel Generator
12-Year Maintenance
Outa
e
Sco
e
62707
The resident inspectors
observed training activities,
maintenance
activities,
and the control of contractors
during the 12-Year
maintenance
outage
on the
(EDG).
Observations
and Findin s
Good preparation
and detailed planning for the scheduled
outage
activities was evident.
The licensee
planned
and implemented
a post-
work lessons
learned.
The inspector
noted good maintenance
practices
were implemented
such
as cutting old 0-rings to prevent inadvertent
reuse.
The inspector
observed that foreign material exclusion covers
were used
when appropriate.
Minor issues
were identified with the
control of contractors
from a security aspect.
The training of contract
workers using
a surplus diesel
generator
in the
training center
was
a good initiative.
The inspectors
also noted that
effective use of mockup training was evident during implementation of
the power range neutron monitoring modification which was installed in
Unit 2 during the Fall
1997 outage.
.On January
13,
1998. while observing the implementation of the Fuel
Transfer Strainer Inspection which 'is proceduralized
by Mechanical
Preventive Instruction,
MPI-0-082-INS005,
Standby Diesel
Engine Twelve
Year Inspection,
the inspector
noted that the inspection
was performed
differently on the two strainers.
It appeared to the inspectors that
the procedural
requirements
were not being met.
The inspector discussed
the observation with the contractor
and brought the issue to the
attention of the TVA mechanical
maintenance
supervisor present at the
diesel.
The following day, the senior resident inspector discussed
the
observation with the Maintenance Superintendent
who had not been
made
aware of the issue.
Subsequently,
the inspector
discussed
the issue
with the Lead Mechanical
Maintenance representative
for. the diesel
outage
who indicated that the implementation of the fuel transfer
strainer
inspection did not meet the licensee's
expectations
and that
the inspection of one of the strainers
had been reperformed.
Technical
concerns with the adequacy of the
3C strainer inspections
were later
resolved through discussions
with the Mechanical
Maintenance staff.
On January
22,
1998, the inspector questioned
the initiation of a
problem evaluation report
(PER)
on this issue.
The licensee
recognized
that
a
PER had not been written and immediately initiated BFPER980095.
The licensee indicated that they believed that an oversight
had occurred
since the diesel
outage maintenance
logbook had indicated their
intention to write a
PER.
The inspectors
were also concerned that the
maintenance
personnel
did not raise the issue to the appropriate levels
of management
prior to
NRC discussion with the Maintenance
Superintendent.
Since
a
PER was not initiated, the Management
Review
Committee did not review the incident prior to the
EDG being returned to
11
service.
The inspectors
have documented
examples
where
PERs
have
requi red prompting in the past
(see
IR 259,260,296/97-11
and
IR
259,260,296/97-07
).
The failure to promptly document the
NRC
identified condition using the licensee's
Corrective Action Program
and
report it to appropriate levels of management
is
a violation of
SSP-3.4,
Corrective Action Program.
(Violation 296/97-12-02.
Failure to
Document Condition Adverse to Quality)
Conclusions
Good preparation
and detailed planning for the scheduled
outage
activities was evident.
The training of contractors
using
a surplus
diesel generator in the training center
was
a good initiative.
Minor
issues
were identified with the control of contractors
from a security
aspect.
A violation of regulatory requirements
was identified regarding fai lure
to document
a condition adverse to quality identified by the
NRC.
Surveillance Testin
Ins ection Sco
e
61726
The inspectors
reviewed completed surveillance instructions for selected
.instruments to verify that the surveillance instructions satisfied the
Technical Specification calibration and functional testing requirements.
Observations
and Findin s
The inspectors
reviewed completed surveillance instructions for the most
recent performance of instrument calibration
and functional testing for
the Unit 2 Drywell "A" Channel
High Pressure
and Unit 2 "A"
Channel
Scram Discharge
Tank High Water Level. Scram.
The inspectors
also reviewed documentation
associated
with those
sur vei llances
performed prior to the Unit 2 restart in 1991.
Completed licensee
surveillance instructions
reviewed included the following:
2-SI-4.1.B-5(A)
Reactor Protection
Isolation System High Drywell Pressure
Instrument
Channel Al Calibration.
2-SI-4. 1.A-ATU(A) Reactor
Protection
Isolation System Analog Trip Unit Channel Al
Functional Test.
2-SI-4.1.B-8(A)
RPS High Water Level in Scram Discharge
Tank
Calibration.
2-SI-4.1.A-8(A)
RPS High Water Level in Scram Discharge
Tank
Functional Test.
C.
H3
H3.1
12
Instrumentation calibrations were required
by TS to be performed every
18 months while channel
functional tests
were required monthly.
The
inspectors
also reviewed
TVA Engineering Calculations,
NESSD 2L-085-
0045A, Setpoint
and Scaling
Document,
2-LE-85-45A and 2-LS-85-45A,
Discharge
Tank High Water
Level Scram,
and
NEESD 2P-064-0056A-00-01,
Setpoint
and Scaling
Document,
2-PT-64-56A and 2-PIS-64-56A.
High
Drywell Pressure
which provided the engineering
basis for the
licensee's. setpoint scaling methodology.
Additionally. the inspectors
reviewed the applicable instrument calibration data sheets
from
Instrument Maintenance
Procedures.
2-SIMI-85A, Scram Discharge
Tank
Setpoint
and Scaling
Document,
and 2-SIMI-64A, Primary Containment
Setpoint
and Scaling
Document.
These instrument calibration data sheets
were used
by the licensee's
maintenance
organization to provide the
instrumentation technicians with reference
data for use during
instrument calibrations.
No deficiencies
were identified during this
review.
The inspectors
noted that setpoint values
used in the
instrument calibration and functional tests
were consistent with the
allowable values
from the licensee's
setpoint
and scaling
documents
and
the Technical Specifications.
Conclusions
No deficiencies
were identified during the review of selected
completed
instrument calibration and functional testing documentation.
The
.inspectors
concluded that setpoint values
used in the licensee's
instrument calibration and functional tests
were consistent with the
. allowable values
from the licensee's
setpoint
and scaling
documents
and
the Technical Specifications.
Maintenance
Procedures
and Documentation
Review of Work Order Packa
es
Ins ection Sco
e
62700
The inspectors
reviewed Work Order
(WO) packages to determine the
adequacy of the licensee's
process for planning,
accomplishing. testing,
and -documenting the work activities
and to verify that the documentation
satisfied the requi rements
from Licensee
Procedures
SSP-6.2,
Maintenance
Management
System,
and SSP-7.1,
Work Control.
Observations
and Findin s
The inspectors
reviewed various
WOs, completed
and closed during 1991,
1993,
and during the period of July
1 - December
31,
1997, for WO
adequacy
and implementation.
The inspectors
reviewed documentation
for
the following completed maintenance activities:
WO 90-00071-00,
Replace 'diaphragm in CRD Scram Inlet Valve, 2-FCV-
085-39A/1035
WO 90-00055-00,
Replace
diaphragm in CRD Scram Inlet Valve, 2-FCV-
085-39A/0235
P2.2
26
The inspector
used
EPIP 17.
Emergency
Equipment
and Supplies.
Revision 21, to evaluate the inventories of emergency cabinets
and
lockers in the
TSC and
OSC.
The equipment tested
by the inspectors
operated satisfactorily
and the emergency
lockers inventories
were
complete.
The inspector
reviewed documentation of completed inventories
from
December
1996 through
December
1997.
The inspectors
found the
documentation
complete.
In the event of a complete loss of communications to the site, the
licensee
had added
a satellite phone in the TSC.
The equipment
supporting the satellite
phone was placed in an independent,
secure
cabinet
and provided an independent
power supply.
Conclusion
The inspector
concluded that the licensee satisfactorily maintained the
Emergency
Response Facilities and equipment.
Equipment tested
by the
inspector
performed satisfactorily. Audits of equipment
and supplies
were completed at the required frequencies.
Communication capabilities
were enhanced
by the addition of a satellite
phone.
Public Alertin
S stem
a.
Ins ection Sco
e
82701
This area
was inspected to review the licensee's
method of notifying the
public in the event of an emergency.
and the Public Alerting System test
frequency
and test data.
Requirements
applicable to this area
are found
Sections
IV.D of Appendix
E to 10 CFR Part 50,
and the licensee's
Emergency
Plan.
Observations
and Findin s
The licensee
maintained
100 sirens within the Emergency
Preparedness
Zone for their public alert and notification system.
The inspectors
reviewed documentation
from December
1996, through
December
1997, for
the bi-weekly si lent tests,
monthly sounding
and an annual
sounding of
the sirens.
The inspectors
determined that the sirens
had been tested
at the requi red frequencies.
The 1996 Browns Ferry Nuclear Plant siren
availability report summary indicated
a siren availability of 98.9
percent
compared to the Federal
Emergency
Hanagement
Agency's acceptance
criterion of 90 percent.
The inspector
met with the individual responsible
for maintaining Browns
Ferry sirens.
The inspector
reviewed documentation
and discussed
the
quarterly and annual
maintenance of the sirens.
The documentation
indicated that as
a system,
the sirens
needed
minimal repairs.
The
licensee
maintained
a matrix which gave
a quick, visual indication of
individual si ren performance for trending purposes.
The matrix was
a
positive TVA initiative.
27
In addition to the sirens,. the licensee maintained tone alert
radios for area
schools
and day care centers.
Documentation
reviewed by the inspectors
indicated that the licensee
satisfactorily distributed
and maintained the tone alert radios.
Conclusion
The inspector
concluded that the siren system
and tone alert radios were
being satisfactorily tested
and maintained.
The licensee
was
effectively trending siren operability.
EP Procedures
and Documentation
Emer enc
Plan
Im lementin
Procedures
Ins ection Sco
e
82701
The inspector
reviewed the changes to the Emergency Plan.
selected
and evaluated
whether changes to the EPIPs were in agreement with
and implemented the Emergency
Plan.
Requirements
applicable to this area
are found in 10 CFR 50.47(b)(16).
Appendix
E to 10 CFR Part 50,
and the licensee's
Emergency
Plan.
Observations
and Findin s
The inspector
reviewed
EPIP 14, Radiological Control Procedures,
Revision 13, effective date of November 17,
1997.
The procedure
was used
by on shift personnel
to perform a manual offsite dose
assessment
in the
event of a radiological
emergency.
The inspectors specifically focused
on EPIP 14. Attachment
E.
"Manual Methodology For Projecting Total
Effective Dose Equivalent
(TEDE)" a computer
method
and
a manual
method.
If the computer
was not available,
then the manual
method
was to be
used.
It was the licensee's
expectation that both methods
should give
the user the same result.
The inspector
requested
and observed the
licensee
use the same input data
and perform an offsite dose calculation
using both the manual
and computer
methods.
The inspector 's review of
the calculations
noted that results
compared favorably.
The inspector
reviewed Revisions
32, 33, 34, 35,
and 36 to the
licensee's
Emergency
Plan.
The inspectors
noted that the changes
were mainly clerical or organizational
changes
which did not
decrease
the effectiveness
of the Emergency
Plan.
The inspector verified that all letters of agreement identified in
the Emergency
Plan were current.
The inspector verified by reviewing
a letter dated July 11,
1997,
that the State
had performed thei r required
annual
review of the
Emergency Action Levels.
The inspector
reviewed the licensee's
March 5,
1997, Notification Of
Unusual
Event
(NOUE) emergency declaration
based
on Unit 3 loss of
28
station
power during
a refueling outage.
In evaluating the licensee's
response
to the event, the inspectors
reviewed the licensee's:
EPIP-1,
Emergency
Plan Classification Matrix.
EPPOS 2, Timeliness of Classification of Emergency
Conditions
Post
Event Review,
Problem Evaluation Report:
BFPER970486
Unit Status
(Refueling)
normal
"day shift" Control
Room staffing and
Operations
Department
document,
"Conduct Of
Operations" which included duties
and responsibilities
of key personnel
during abnormal
and emergency
conditions.
The loss of power occurred at 10:40 a.m.
The notification of
Unusual
Event
(NOUE) was based
on the Emergency Action Level
(EAL)
5.1-U: "loss of off-site power for greater than
15 minutes".
Therefore, station power was lost for 15 minutes before the
conditions for the
EAL were met.
The event was declared at ll:22
a.m.,
27 minutes after meeting the conditions for the
EAL or 42
minutes after loosing station power.
NRC guidance provided to the
industry in EPPOS-2,
"Timeliness of Classification of Emergency
Conditions" indicates
15 minutes
as reasonable
period of time for
.assessing
and classifying
an emergency
once indications are
available to control
room operators that an
EAL has
been
exceeded
and the licensee's
Emergency
Plan Implementing Procedure
(EPIP)-l,
Emergency
Plan Classification Matrix, states that
a declaration
needs to be made within 15 minutes of'vailable indication (10:40
event/10:55
EAL was met).
The inspectors'eview
of the documents
listed above determined that:
Unit 3 was. shut
down (refueling).
Sufficient operations
personnel
were available to
effectively respond to the event
and implement the
actions of the licensee's
Emergency
Plan.
The licensee's
"Conduct of Operations"
document
clearly delineates
control
room staff action and
responsibilities
during abnormal
and emergency
conditions.
The licensee
concluded that the event declaration
was timely,
although it exceeded
the guidance in EPPOS-2
and EPIP-1.
The
licensee's
basis f'r not meeting the 15 minute guidance
included
the need to: notify key management:
dispatch
personnel
considerable
distances to the cooling tower switchgear
and
161
KV
switchyard; wait for feed back from dispatched
personnel:
and
respond to the notification of a tornado watch.
The licensee's
review did not address
why the condition could not be adequately
identified from the control
room instrumentation,
without the need
for feedback
from the switchyards.
The
was objective and
unambiguously written, and established
the criteria for
p5
P5. 1
29
classification.
The licensee's
review did not evaluate the
relative priority of'ey management notification to the inherent
need to rapidly communicate
emergency conditions.
and whether the
shift staffing was most efficiently utilized.
The licensee
did
not identity any lessons
learned
on timeliness.
It was not clear
to the inspector
that the licensee's
evaluation
was self-critical
and that
a
sufficient explanation for the delay was provided.
Conclusion
Dose assessment
results
from the manual
procedure
used
by on shift
personnel
compared favorably to the computer
method for dose
assessment.
Revisions
32.
33. 34, 35.
and 36 of the Emergency
Plan were made
in accordance
with requirements.
The
NRC and licensee
goal for declaration of an emergency classification
within 15 minutes of event recognition was exceeded
by 12 minutes during
the loss of station
power event
on Narch 5,
1997.
It was not clear to
the inspector that the licensee's
evaluation
was self-critical and that
a sufficient explanation for the delay was provided.
Staff Training and Qualification in EP
Trainin
of Emer enc
Res
onse Personnel
Ins ection Sco
e
82701
The inspector
reviewed the Emergency
Response
Training Program to
evaluate the current qualification of the emergency
response
personnel
and their training.
Requirements
applicable to this area
are contained
and (15), Section
IV.F of Appendix
E to 10 CFR Part 50.
and the licensee's
Emergency
Plan.
b.
Observations
and Findin s
The licensee
continued to maintain classroom training of the Emergency
Response
Organization
(ERO) in accordance
with Section
15 of the
Emergency
Plan and
EPIP 19, "Radiological
Emergency
Preparedness
Training and Drills."
The inspector
reviewed three lesson
plans
and their associated
exams
identified in the matrix.
The inspectors
determined that the lesson
plans were well organized
and the subject matter'ontent
was
commensurate
with the position being taught.
The exams were generally
well written and adequately
challenging for the position.
The status of ERO training was reviewed by selecting approximately
twenty individuals from the
ERO roster
and verifying their
training was current based
on the licensee's
computer system.
The
inspectors
compared the training dates
indicated
on the computer
against the class
attendance
roster
.
No discrepancies
were found.
Conclusion
30
P5.2
P7
P7.1
The
ERO training program was satisfactory.
ERO lesson
plans were good,
and exams were adequately challenging.
Emer enc
Plannin
Drills
Ins ection Sco
e 82701
The inspector
reviewed the licensee's drill documentation to
evaluate'hether
they were conducting the types
and number of drills identified
in Section
14, "Drills and Exercises," of the licensee's
Requirements
applicable to this area
are contained in 10 CFR 50.47(b)(14),
Section IV.F(1) of Appendix
E to 10 CFR Part 50.
Observations
and Findin s
The inspector
reviewed
1996 and
1997 documentation of Browns Ferry
quarterly TSC/OSC staffing drill with each of the three teams;
Drills; and Medical Drills with Huntsville Hospital
and Athens-Limestone
Hospital.
Each of the three teams;
Red.
Blue.
and Green, participated
in an equal
number of drills.
The 'inspector verified that in 1996 and
1997 the licensee
had conducted
~ the required drills in accordance
with Section
14, "Drills and
Exercises," of their Plan.
The licensee
used the training simulator to conduct
ERO drills.
Since
the last inspection,
the licensee started
conducting
"Post Drill
Critique Table Top" drills with the. team that had just participated in
the simulator controlled drill.
The licensee training philosophy was
that, if the team were briefed on the critique findings and the same
teams
re-,enacted
the scenario in a table top walkthrough, the ensuing
dialog within the team. of actual
response
and expected
response,
could
enhance their performance.
The inspectors
considered
the table top
drills a program strength.
The inspectors
noted that "Post Drill
Critique Table Top" drills were not
a requirement in the Emergency
Plan
or EPIPs.
Conclusion
The licensee satisfied the drill commitments in their Emergency
Plan.
Post simulator drill table top scenario walkthroughs were
a program
strength.
equality Assurance in EP Activities
Re uired
Audit of Emer enc
Pre aredness
Pro
ram
The inspector
reviewed this area to assess
the quality of the required
audit and evaluate
whether
the audit met the requirements of
and the licensee's
Emergency
Plan.
Observations
and Findin s
31
P7.2
Audit SSA9703
was
a combined audit for Browns Ferry.
Sequoyah,
Watts Bar
Nuclear Plants,
and Corporate Offices in Chattanooga
and Knoxville,
conducted
between
June
16 and August 1,
1997.
The audit team consisted
of a Lead Auditor and eleven
team members
from the TVA nuclear, sites,
TVA corporate,
and
a member from another utility.
The audit did not
identify any weaknesses
or
PERs in the Emergency
Preparedness
Program at
Browns Ferry.
One weakness
was identified for Browns Ferry in the area of
Meteorological
Programs
regarding the calibration acceptance
criterion for the meteorological
wind speed
sensors.
Conclusion
The inspector's
review concluded that the Emergency
Preparedness
audit
was organized
and objective and satisfied the requirements
in
Licensee's
Corrective Action Pro ram For Drill Comments
and Issues
Ins ection Sco
e
82701
This area
was reviewed to evaluate the licensee's
corrective actions to
comments
and issues identified in their drills. Requirements
applicable
to this area
are contained in 10 CFR 50.47(b)(14).
b. Observations
and Findin s
The inspector
reviewed findings from the licensee's drill critiques
and
verified that drill comments
were being tracked
on Problem Evaluation
Reports
(PERs), the plant wide tracking system,
and Activities
Management
Oversight System
(AMOS),
a local
PC based tracking system
used
by the Emergency
Preparedness
groups.
From the tracking lists, the
inspector selected
four items that had been closed.
and reviewed the
documentation to evaluate the licensee's
timeliness of closure
and
quality of thei r resolution.
The closed
items reviewed by the inspector
were satisfactorily resolved
and closed in a timely manner.
Conclusion
The inspector concluded that the licensee
was satisfactorily
tracking and resolving drill comments.
32
'adiological
Protection
and Chemistry Controls
Tr ans ortation of Radioactive
Hater ials
Ins ection Sco
e
86750
and TI2515/133
The inspectors
evaluated
the licensee's
transportation of
radioactive'aterials
program for implementing the revised Department of
Transportation
(DOT) and Nuclear Regulatory Commission
(NRC)
transportation
regulations for shipment of radioactive materials.
The
regulations
are published in 10 Code of Federal
Regulations
(CFR) 71.5
and 49 CFR Parts
100 through 177.
Observations
and Findin s
The inspectors
reviewed procedures
and determined that they adequately
addressed
the following: assuring that the receiver
has
a license to
receive the material
being shipped;
assigning the form, quantity type,
and proper shipping
name of the material to be shipped; classifying
waste destined for burial; selecting the type of package
required;
assuring that the radiation
and contamination limits are met:
and
preparing shipping papers.
The inspectors
reviewed the Certificate of Compliance
(CoC) No.5805 for
~the Model
No.
CNS 3-55 package
and
CoC No.
9168 for the Model
No.
8-120B package
and found that the licensee
was
an authorized
user.
The
inspector
reviewed the receipt surveys for the incoming package
and
found that they followed their procedural
requirements.
The inspectors
verified that prior to the shipment
made
on December
10.
1997, the
silicone 0-ring seals
were inspected,
by the licensee,
for defects
(there were none),
and the 0-rings had been replaced within six months
as required
by the
CoC No. 5805.
The inspectors
observed the cask decon
and witnessed the final surveys for this package
and the shipping papers
that were presented to the shipper
(TRI-STATE MOTOR TRANSIT) and found
no items of non-compliance.
Shipment
number
1297-7852
contained
approximately
13,000
Ci of irradiated
hardware.
The inspectors
also
reviewed the shipping paperwork for shipment
1197-7801
made
on
November 25,
1997 that consisted of approximately 10.000
Ci of
irradiated hardware
and found no items of non-compliance for either
shipment.
The inspectors
reviewed the lesson plan for the Radioactive
Waste
ackaging
and Loading Inspector Training, Revision
2 and judged them to
e adequate.
The inspectors
also reviewed the Radioactive
Waste
Packaging,
Transportation.
and Disposal training requi re by 49
CFR Part
172, Subpart
H and IE 79-19 and determined that the training met the
requirements
and there were three individuals onsite who had received
a
Certificate of Completion for the training July 8-11,
1997.
Conclusions
33
R2
R2.1
Based
on the above reviews, the inspectors
determined that the licensee
had effectively implemented
a program for shipping radioactive materials
required
by NRC and
DOT regulations.
Status of Radiation Protection
(RP) Facilities and Equipment
Occu ational Radiation
Ex osure Control
Pro ram
I
Ins ection Sco
e
83750
The inspectors
reviewed implementation of selected
elements of the
licensee's
radiation protection program.
The review included
observation of radiological protection activities including radiological
postings; verification of posted radiation dose rates
and contamination
controls within the Radiologically Controlled Area
(RCA).
The
inspectors
also reviewed selected
Problem Evaluation Reports
(BFPER).
Observations
and Findin s
The inspectors
toured the reactor building including the refueling
floor, radwaste facilities, and outside yard areas
including radioactive
material storage
areas.
At the time of the inspection,
radiological
housekeeping
was observed to be good. Radiologically controlled areas
observed
were appropriately posted
and radioactive material
observed
was
appropriately stored
and labeled.
The inspectors
independently verified
dose rates of posted
boundary
ropes
on the refueling floor and found the
dose rates
as noted
on the surveys
and as posted.
The inspectors
reviewed
BFPER971425,
dated
September
11,
1997, involving
a slightly contaminated scaffold jack found on the bottom floor of the
Intake Building.
The jack was discovered
by the licensee
during
a
routine monthly survey of the area.
As a result'of the identification
of this jack
~
an aggressive
search of the scaffolding and scaffolding
hardware located outside the plant was initiated by the licensee.
Two
other items were identified as having
a small but detectable
quantity of
contamination during this search.
The licensee
performed
a cause
analysis to determine
how the material got outside the radiological
control area
(RCA) and determined that improper removal
was the apparent
cause.
The licensee instituted
an eight step corrective action program
to prevent recurrence.
The inspectors selectively toured the site and
did not find any additional instance of similar material.
The
inspectors
observed that.
as stated in the corrective actions, scaffold
material
used
or stored outside of an
RCA was in the process of being
painted green to fulfillthe commitment
"GREEN is CLEAN".
The
inspectors
reviewed the licensee's
summary of events in the last two
years that was attached to the
PER and found two additional
PERs,
BFPER
970717
and
BFPER 971340, that addressed
particles
found inside the plant
but outside the
RCA.
The first had
a count rate so low that the
licensee
was unable to detect the particle in several
locations in the
PCN-1B.
The second particle most likely came from a worker going to a
I
decon
shower
and was not found in the backtrack survey.
The licensee
added guidance to procedure
RCI-1 on precautions for transport of
contaminated
material through clean areas.
Contamination results
from
counts of selected
swipes,
by the inspectors,
from "clean areas"
were
found acceptable.
Conclusions
Radiological conditions in radioactive waste storage
areas
were observed
to be good.
Material
was labeled appropriately
and areas
were properly
posted.
In addition,
RADCON PER(s) were aggressively
evaluated,
cause
analysis
performed
and corrective measures
to prevent recurrence
instituted.
Li uid Effluent Radiation Monitors and Li uid Waste Treatment
S stem
Ins ection Sco e'4750
The inspectors
reviewed selected
licensee
procedures
and records for the
operation of the liquid radiation effluent monitor
and the start-up
and
operation of the liquid radwaste treatment
system
(THERMEX').
Observations
and Findin s
The inspectors
toured the radwaste facility to observe the physical
layout and operation of the process
and radiation monitors in use.
The
inspectors
reviewed the effluent liquid radiation monitor operational
history and repair work orders
and observed that monitor 0-RM-130 had
recent occurrences
of spiking during plant releases.
Resolution of work
order
WO 97-007660-00
was reviewed
and the spiking was attributed to
electrical spikes.
During the inspection the licensee also discussed
that
a leaking drain valve had lowered the liquid level in the tank that
was monitored by the detector
and thus altered the background
(higher
than normal) so that when effluent liquid filled the monitored chamber
the count rate was lowered because of the higher density of the liquid
vs. the air density when the chamber
had
a reduced liquid volume.
The
drain valve was replaced to correct the altered background settings.
Additional
NRC review of this issue is documented in Inspection Report
97-11.
The licensee
made one of two total liquid releases
in November to
verify monitor operabi lity.
During the period of investigation
compensatory
measurements
as permitted
by the Offsite Dose Calculation
Manual
(ODCM) were in place to ensure that no unmonitored
releases
were
made.
The inspectors
reviewed the liquid release
data for the period
January
1997 thru December
1997 and observed that the peak
number of
releases
occurred in March (32) and the least
number of release
occurred
in November (2).
One of the November releases
was
a release to verify
the operabi lity of the liquid effluent monitor.
The Total Effective
Dose Equivalent for liquid release for the year to date
was calculated
to be approximately 0. 15 mrem or about 4.9X of the
ODCM annual limit of
3.0 mrem.
The inspectors
reviewed logsheets
564. 1.
EPA DATA LOGSHEET,
for the period June
1997 thru November
1997
and the Turbidity Work Sheet
683-1 for the same period to ensure that no liquid effluents
exceeded
35
release limits.
There were no anomalous turbidity samples
from a
radwaste liquid effluent batch release
containing particulates.
Turbidity was found to be less than the 1.0
NTU for those tanks
released.
The inspectors
reviewed the physical layout of the
THERMEX'system
and
reviewed the start-up
and operational
data for the system.
Several
improvements
had been
made, as
a result of lessons
learned during start-
up and were being tested for effectiveness.
One of the improvement
items was the use of available spent resin exchange capacity in High
.
Integrity Containers
HIC(s) to treat brine from the liquid system
and
the other was the addition of coagulant-aid
media to help improve the
phase separator
operation
and reduce resin fines carryover into the
Reverse
Osmosis
elements
(RO).
Some indication of resin fines had been
observed in the second
RO stage.
The inspectors
review of the
analytical results for the discharges
did not find any evidence of the
resin fines getting through the treatment
system for subsequent
release
into the environment.
Conclusions
Liquid effluent releases
reviewed during this inspection were found to
meet the regulatory requirements
and the compensatory
analysis permitted
by the
ODCM during the effluent radiation monitor 0-RM-130 outage were,
satisfactory.
Conduct of Security and Safeguards Activities
Access Authorization
Ins ection Sco
e
81700
To verify that the licensee
had an adequate
procedure
for review, if
requested
by an individual who is denied
access
or their access
is
suspended
or revoked'n
accordance with the Access Authorization (AA)
Program.
Observation
and Findin s
The inspectors
reviewed
AA records of selected
individuals to determine
that the licensee
had adequately
implemented the AA requirements
which
are to ensure that individuals who are granted unescorted
access
are
trustworthy, reliable and do not constitute .an unreasonable
risk to the
health
and safety of the public.
The inspectors
reviewed the licensee's
AA Procedure.
TVA Nuclear
Standard,
STD-11. 1, Providing Access
Clearance for Nuclear Plants
and
Safeguards
Information,
and determined that the procedure clearly
defined the AA regulatory requirements.
Appendix
B of STD-11.1
established
the criteria for denying,
suspending.
or revoking
a
clearance.
Appendix D, of STD-11. 1, established
the process
for appeal
and defined the requirements of the screening
review board.
\\
c.
Conclusi on
36
The inspectors
determined,
through AA procedures
and records
review,
that the licensee
had established
in thei r procedures
an appeals
process
and
an adjudication process to ensure that personnel
who were granted
unescorted
access
were trustworthy, reliable and do not constitute
an
unreasonable
risk to the health
and safety of the public.
There were 'no
violations of regulatory requirements
noted in this area.
V. Mana ement Heetin
s
X1
Exit Heeting Summary
The resident inspectors
presented
inspection findings and results to
licensee
management
on January
23,
1998.
Other meetings to discuss
report issues
were conducted during the report period including formal
meetings with plant management
on December
12,
1997,
and January
16,
1998.
The characterization
of an Emergency
Preparedness
issue described
in Section
P3. 1 was discussed
in a telephone
conversation
January
14,
1998.
The licensee
acknowledged the other findings presented.
Proprietary information is not 'included in this inspection report.
Licensee
PARTIAL LIST OF
PERSONS
CONTACTED
T. Abney. Licensing Manager
J. Brazell, Site Security Manager
R. Casey,
Manager,
Access Authorization/Fitness for Duty
R. Coleman, Acting Radiological Control
Manager
J.
Corey. Radiological Controls
and Chemistry Manager
T. Cornelius,
Emergency
Preparedness
and Planning
C. Crane, Site Vice President.
Browns Ferry
T. Feltman,
Emergency
Preparedness
R. Greenman,
Training Manager
J.
Johnson,
Site Quality Assurance
Manage
R. Jones.
Assistant Plant Manager
S.
Kane. Acting Site Licensing Supervisor
C. Kelly, Corporate Security Manager
R. Kitts, Manager,
Emergency
Preparedness,
Corporate
R. Moll. System Engineering
Manager
G. Little, Operations
Manager
B. Marks,
Emergency
Preparedness,
Corporate
D. Nye, Site Engineering
Manager
D. Olive, Acting Operations
Superintendent
J.
Shaw,
Design Engineering
Manager
K. Singer,
Plant Manager
J. Schlessel.
Maintenance
Manager
IP 37551:
IP 40500:
IP 62700:
IP 62707:
IP 62706:
IP 61726:
IP 71707:
IP 71750:
, IP 73756:
IP 81502:
IP 82701:
IP 83750:
IP 84750'P
86750:
IP 92901:
IP 92902:
IP 92903:
37
INSPECTION
PROCEDURES
USED
Onsite Engineer ing
Licensee Self-Assessments
Maintenance
Implementation
Maintenance
Observations
Maintenance
Program
Surveillance
Observations
Plant Operations
Plant Support Activities
Inservice Testing of Pumps
and Valves
Fitness
For Duty Program
Operational
Status of the Emergency
Preparedness
Program
Occupational
Radiation
Exposure
Radioactive
Waste Treatment.
and Effluent and Environmental
Monitoring
Solid Radioactive
Waste
Management
and Transportation
Of
Radioactive Materials
Followup-Plant Operations
Followup-Maintenance
Followup-Engineering
ITEMS OPENED
DISCUSSED
AND CLOSED
OPENED
~T
e
Item Number
260/97-12-01
296/97-12-02
Status
Closed
Open
Descri tion and Reference
Inadequate
Procedural
Controls
on
CRD Temperature
Alarms (Section
.08.1)
Failure to Document Condition
Adverse to Quality (Section Ml.2)
260/97-12-03
Closed
259,260,296/97-12-04
Closed
Inadequate
Procedure for PHT
(Section H8.1)
Design Basis
Not Translated
Properly
for RHRSW Pump Requirements
(Section
E8.1)
296/97-12-05
Closed
Inadequate
Post Modification Test
(Section H3.2)
DISCUSSED
~T
e
Item Number
.IFI
260,296/97-11-01
Status
Open
Descr i tion and Reference
Status
Control Issues
(Section 08.1)
CLOSED
T~e
Item Number
LER
260/96-005-00
260/96-199-01013
260/96-199-02014
IFI
.260,296/95-064-10
IFI
260/97-05-04
Status
Closed
Closed
Closed
Closed
Closed
Closed
Closed
Closed
38
Descri tion and Reference
ESF Components
Were Actuated
as
a
Result of an Inadequate
Procedure
(Section H8.1)
Unit 2 Scrammed
on Low Reactor
Wat'er
Level
Due to the Digital Feedwater
System Reinitializing its Feed
Pump
Demand Output Signal to Zero and the
Subsequent
Trip of the Reactor
Core
Isolation Cooling on High Exhaust
Pressure. (Section H8.2)
RCIC Inoperability (Section H8.3)
Failure to Comply with IST
Requirements
(Section H8.4)
Residual
Heat
Removal Service Water
Pump Limiting Condition for
Operation is Non-Conservative
(Section E8.1)
Secondary
Containment Ventilation
Damper Failures
(Section
E8.2)
Spurious
HSIV Closures
on Reactor
Scram (Section E8.3)
Unit 2 Scram on Turbine Control
Valve Fast Closure
Due to Loss of
Excitation to Main Generator
(Section E8.4)
~y
13
WO 91-42376-01,
Troubleshoot Controller 2-FC-2-190 which would not
operate in automatic
WO 91-35689-01,
Repair valve 1-HCV-90-133A
WO 91-44533-01,
Troubleshoot noise located inside Motor 3-MTR-030-
0239
WO 91-41927-00,
Relug wires on
EDG Control Cabinet
WO 91-33796-00,
Open
and inspect wireways
and covers for Reactor
NOV Board 3A Panel
3A
WO 91-44048-00.
Clean
Fan 0-FAN-030-0186 due to low flow rate
WO 91-41654-01,
Remove
and inspect Valve, 0-CKV-067-539
'O
91-31161-00,
EDG starting air compressor
high pressure
gasket bolts
WO 91-24427-00,
Exercise various
EDG air start relief valves
WO 93-01197-01,
Install temporary
RPV level instrument
on refuel
floor
WO 97-02594-01,
Disconnect/Remove/Reinstall/Reconnect
B3
Pump Motor 0-NTR-023-0088
WO 97-04404-00.
Perform Inspection
and Maintenance
on
Operator
for Isolation Valve 2-FCV-071-0002
WO 97-04414-01,
Repair
Damaged
Motor Lead for 2-NTR-071-0003
WO 97-06387-49,
Repair Packing
Leak for Valve 2-FCV-071-0002
WO 97-07577-00,
Replace
Valve 2-LSV-071-0005
WO 97-08654-00,
Replace Relief Valve 0-RFV-002-3105
WO 97-08659-00,
Troubleshooting
Valve 0-NVOP-067-0049 for Failure
of Indication Light
WO 97-09218-00,
Perform Adjustments to 0-PMP-023-0088
Pump
Impeller to Achieve Proper Flow
WO 97-09807-00.
Replace
Valve 3-FSV-076-00948
WO 97-10735-01,
Replace Relief Valve 3-RFV-086-0552A
WO 97-10916-00,
Replace Relief Valve 3-RFV-086-0522D
WO 97-11249-01,
Troubleshoot failure of valve 3-FSV-090-0257A
position indication
All the
WOs reviewed contained workorder summaries,
pre-job references
and requirements,
work instructions.
material requisition forms,
descriptions of actual
work performed,
work closure documents,
and
attachments.
The work order summaries
included component
identification. problem and work descriptions,
and requirements for
post-maintenance
testing.
The required
procedures
for the tests
were
also listed in the work order summary.
Post-maintenance
testing is
further discussed
in Section M3.2.
The work instructions listed the
step by step
sequence
of the work to be performed,
depending
upon the
complexity of the work.
WO attachments
were used for recording data
and
in some instances
contained additional
procedures
used during the work
activity.
Based
on the review of the completed documentation,
the
inspectors
concluded that the licensee's
WO packages
were generally
adequate.
The planning
and work instructions
were thorough
and complete
and provided sufficient details for the craftworkers to implement the
work activity.
Additionally, the
WOs included documentation to show
that required
post-maintenance
tests
were performed
and that all
required
QC inspection holdpoints
had been completed.
c
0
14
During the review of completed
WOs the inspectors
concluded that current
and previous
programs for control of temporary jumpers
and lifted leads
associated
with maintenance
work activities was adequate.
During the review the inspectors identified several
WO documentation
deficiencies.
These deficiencies
included
a missing checkmark
and
missing step completion signatures
by craft personnel
and
a missing
cable inspection attachment.
The inspectors
concluded that the
deficiencies
were minor
and that the affected workorder packages
were
adequate.
The inspectors
discussed
the deficiencies with members of
'icensee
management.
The inspectors
were informed that the deficiencies
had not met licensee
management's
expectations.
Additionally. the
inspectors
noted that the licensee
issued
Problem Evaluation Reports
(PER)
BFPER 980071
and
BFPER 980076 to address
these deficiencies.
Conclusions
WO packages
reviewed by the inspectors
were generally adequate.
They
contained sufficient details,
work instructions.
and requirements
for
craftworker
implementation.
The work, tests,
and documentation
completed
met the stated
requirements.
Review of Post Maintenance Testin
Pro
ram
Ins ection Sco
e
62700
The licensee's
post-maintenance
test
(PMT) program was reviewed to
determine the adequacy of the licensee's
process for planning and
accomplishment of testing prior to return of equipment to service
and to
verify that the testing
had satisfied the requirements
from SSP-6.50,
Post-Maintenance
Testing.
Additionally, the inspectors
reviewed the
details associated
with a previous fai lure to perform adequate
post-
modification testing.
Observations
and Findin s
During a previous review of the licensee's
PMT process
documented
in
Section
M3.1 of Inspection
Report 50-259.260,296/97-10
the inspectors
identified a weakness.
This review identified that
PMT requirements
specified in WOs were not consistent with respect to the level of detail
and
some
WOs included descriptions of PMT requi rements
which lacked
detail.
In some cases.
additional interpretation
by maintenance
personnel
was required prior to performing the work activity.
During the review of recently completed
WOs documented in Section
M3. 1
the inspectors
reviewed the adequacy of post-maintenance
testing that
had been performed before equipment
was returned to service.
During
this more recent
review,
improvement in the
PMT planning process
was
noted.
PMT requirements
specified in these
WOs were more consistent
with respect to the level of detail
and no examples of required
additional interpretation
were noted during the review.
M3.3
15
During review of WO 97-11249-001.
the inspectors
determined that the
licensee
had recently identified an example of a previous failure to
adequately test primary isolation valve position indication following
implementation of a plant design
change.
WO 97-11249-001
had been
issued to troubleshoot position indication problems for the Unit 3
Drywell- Leak Detection Return Outboard Isolation Valve, 3-FSV-090-0257A.
This condition had been recently discovered during
a fai lure of the
valve to indicate closed during containment isolation valve operability
testing.
During troubleshooting,
licensee
personnel
determined that
valve position indication wiring was
swapped
between
3-FSV-90-255
and 3-
FSV-90-257A.
These valves are the outboard supply and return isolation
valves for the Unit 3 drywell continuous air monitor
(CAM) and are
controlled from a
common handswitch in the Unit 3 Control
Room.
The
licensee
had documented this problem in PER BFPER971786.
The inspectors
reviewed this
PER and noted that the incorrect wiring configuration
had
existed since both valves
had been installed
as part of a design
change
performed during the Unit 3 recovery in 1995.
The apparent
causes
identified in PER BFPER971786 were improper installation
and inadequate
post-modification testing which had not individually tested the valves
and detected
the problem.
The inspectors
concluded that corrective
actions specified in the
PER were adequate
and that required
TS actions
had occurred since the licensee's
actions for 3-FSV-90-257A had been
Also satisfied were
TS requirements
for 3-FSV-90-255
as
being inoperable.
This licensee-identified
and corrected violation is
.being treated
as
a Non-Cited Violation, consistent with Section VII.B.1
of the
NRC Enforcement Policy (Non-Cited Violation 296/97-12-05,
Inadequate
Post Modification Testing).
Conclusion
An NCV was identified for
a previous
example of inadequate
post-
modification testing.
No recent
examples of inadequate
post-
modification testing or post-maintenance
testing were identified.
Improvement
was noted in the licensee's
PMT planning process
on recent
WOs.
Review of Tem orar
Modifications
a.
Ins ection Sco
e
62700
The inspectors
reviewed the licensee's
program for controlling temporary
modifications to permanent plant equipment to determine the adequacy .of
the licensee's
process for review and approval of temporary
modifications
and to verify that any temporary modifications satisfied
requi rements
from Licensee
Procedures
SPP-9.5.
Temporary Alterations,
and SII-O-XX-00-3014, Troubleshooting
and Configuration Control of
Instrumentation.
Observations
and Findin s
The inspectors
reviewed the licensee's
program for control of temporary
modifications to permanent
plant equipment
and determined that these
~
~
16
were controlled through several different methods.
Temporary
modifications of short dur ation were usually controlled in accordance
with
approved plant procedures
such
as testing procedures
or
maintenance
work instructions.
Temporary modifications of longer
duration were controlled in accordance
with SPP-9.5.
Temporary
modifications performed during planned maintenance activities such
as
lifted electrical
leads or installation of temporary jumpers were
controlled in accordance
with SII-O-XX-00-3014.
The inspectors
noted that the licensee's
program required that any
required
10 CFR 50.59 safety assessments
associated
with any temporary
modifications controlled by approved plant procedures
or approved work
instructions would have been satisfied during the procedure or work
instruction review and approval
process.
The inspectors
noted that
temporary modifications to equipment,
which remained out-of- service for
maintenance,
did not requi re performance of a
10 CFR 50.59 safety
assessment.
An'assessment
would have been required for any maintenance
activity that would have required that equipment to have
been placed
back in service with a temporary modification installed.
The inspectors
were informed by licensee
management that this practice
had rarely been
performed
and that for any occurrence
documentation
for the appropriate
10 CFR 50.59 reviews would have been included with the completed work
documentation.
The inspectors
had identified only two examples of
temporary modifications left in place following completion of
maintenance activities during recent
reviews of completed work orders
documented in Section H3.1.
Documentation for both
WOs included the
required
10 CFR 50.59 safety assessments.
The inspectors
also reviewed the licensee's listing of existing
The inspectors
concluded that none would
adversely affect the safe operation of Units 2 or 3.
The inspectors
noted that only six active temporary modifications existed for the two
operating units.
The inspectors
determined that licensee controls in each of the above
cases
were adequate to require the appropriate level of review and
approval
and to ensure the completion of
required verification steps for proper component
removal
and
reinstallation.
c.
Conclusions
The inspectors
determined that licensee controls were adequate to
requi re the appropriate
level of review and approval for temporary
modifications
and to ensure the completion of requi red verification
steps for proper
component
removal
and reinstallation.
No examples of inadequate
controls of temporary modifications to
ermanent
equipment were identified.
The inspector concluded that the
icensee's
program for controlling temporary modifications was adequate.
17
H7
guality Assur ance in Maintenance Activities
M7. 1
Maintenance/Modifications
De artment Self Assessment
Pro ram
a.
Ins ection Sco
e
62707 92902
One of the resident
inspector s reviewed the Maintenance/Modification
Department self assessment.
program.
The inspector
reviewed Maintenance
Section Instruction Letter HSIL-1. Maintenance Self Assessment
Process,
selected
monthly performance
reports
(September
to December
1997),
and
completed observation checklists.
The inspector discussed
the program
with the Maintenance
Program Coordinator
and the Maintenance
Manager.
The inspector attended
a maintenance
performance evaluation meeting
and
a working level discussion for the Level
1 trend report.
b.
Observations
and Findin s
MSIL-1 provides guidance for the administration of the self assessment
e
rogram.
The program was established
in August 1996.
Table
1 of HSIL-1
ists performance indicators which are used to analyze trends.
The
performance indicators are obtained
or developed
from quality indicators
(such
as
management
reports,
audits,
or
Problem Evaluation Reports)
and
completed observation checklists.
Six checklists
are contained in
HSIL-1 for observation of key maintenance activities.
Table
2 of MSIL-1
assigns
responsibilities
for the checklists
and
a schedule
for
completion.
The following observations
were noted through review of
selected
completed checklists:
The checklists contained in HSIL-1 are highly detailed
and clearly
convey management
expectations
for performance in key areas.
The guidance in Table 2 of HSIL-1 for checklist completions
was
not always being met..
For example.
no MA-1, Management
Overview
checklist was completed for the months of September
and October
1997.
The guidance indicated that at least nine MA-1 checklists
would be completed
each
month.
This checklist is used
by
maintenance
management to assess
observations.
This checklist
appeared to be important regarding maintenance
management
evaluation
and feedback
on the quality of the self assessment
checklists.
The inspector noted that the Maintenance
Manager
completed several of the MA-1 checklists late in December.
1997.
Many of the checklists
completed in September
1997 did not contain
critical comments.
With the exception of several
MA-4.3
checklists which evaluated
planning of work packages,
the
inspector
noted that no checklist items were marked "red"
,(unsatisfactory
performance).
Of a sampling of 25 checklists,
the
inspector
noted only 5 items were marked
as "yellow" (improvement
needed).
~
~
18
~
The inspector
noted that the maintenance
department
as
a group
was initiating less than fifty percent of the.
PERs attributed to
maintenance.
The percentage
was
as high as
80 percent in some
shops but was lower in the Modifications group.
Several
recent
NRC findings in the maintenance
area also are indicative of some
workers not being self critical.
~
The "actions assigned"
section of the checklists
was not being
used.
It appeared that issues
which warranted corrective actions
would be handled through the
PER process.
A significant fraction
of the completed checklists did not contain signatures
for the
individual being observed.
Section 4.3 of MSIL-1 describes
how the
checklist is to be reviewed with the individual immediately after
completion.
Step 4.3.7 indicates that the signature
should be
obtained
acknowledging that feedback
was provided.
~
Maintenance
management
has
been flexible in application of the
self assessment
program.
Area of emphasis
are directed
by
management
as concerns
or problems are identified.
The inspector
noted several
prudent actions
by maintenance
management to address
recognized
weak areas.
For example,
47 checklists
(MA-3, Review of
Work Package)
were completed in September
1997 to address
deficiencies in the area of planning.
The inspector noted that
several of these checklists contained constructive critical
comments.
~
Section 4.2 of MSIL-1 indicates that general
foremen are
responsible for ensuring that the checklists
are completed at the
recommended
frequency.
Discussion with management
indicated that
this responsibility has
been shifted to the maintenance
shop
Additionally, Section 4.5 indicates that each observation
checklist has
an assigned
owner who is tasked with evaluating
overall performance
and implementing corrective actions.
This
function is actually performed
by the Maintenance
Program
Coordinator.
At the weekly performance evaluation meeting,
the inspector
noted that
performance indicators associated
with areas
recognized
as needing
improvement were emphasized.
The inspector
also observed that the
maintenance
department
was monitoring numerous
performance indicators of
maintenance
proficiency including work efficiency issues.
Using the completed checklists
and the other. quality indicators listed
in MSIL-1, maintenance
management
develops
Monthly Performance
Reports.
MSIL-1 indicates that the Monthly Performance
Reports are used to
develop
a separate
quarterly report.
The actual practice is to use the
monthly reports to develop the. Maintenance
Department input to the
quarterly site Level
1 Trend Report.
The inspector's
review of several
monthly reports indicated that the
monthly reports accurately
summarized the results of completed
checklists.
The monthly reports contained
useful information regarding
19
analysis of the other quality indicators
as well. For example,
the
September
1997 report contained
a detailed review of Problem Evaluation
Reports in the Maintenance/Modifications
area.
The Top Ten
Maintenance/Modifications
Manager's
Issues List addressed
the major
problem areas
noted through the analyses
of the monthly reports.
The
status
and effectiveness
of actions in progress to address
the issues
are specifically addressed
in each monthly report.
The inspector noted that information from the monthly reports
was
effectively incorporated into the June
1997 site Level
1 Trend report:
The trend reports
and the Maintenance/Modification
Manager
Top Ten
Issues appropriately
addressed
regulatory issues
as well as self
identified items.
Review of the open issues
indicates that management
is setting high standards.
For example,
one issue is reduction of
preventive maintenance activities performed within the late band.
Specific items are listed in the action plans to address
each issue.
The licensee
has
been successful
in improving performance in some of'he
areas
noted
as needing
improvement.
For example,
emphasis
on pre-
briefings-and post briefings has increased
the overall quality of
briefings.
The number of significant human performance deficiencies
has
been
reduced in recent
months.
Improvement
has
been noted in some
planning areas.
All of these
issues
have open action plans since
management
is not fully satisfied with performance in those areas.
.The inspector
observed portions of a working group meeting where the
maintenance
department
presented its proposed
input to the January
1998
Level
1 trend report.
The inspector
noted that deficiencies
regarding
scaffolding controls which were the subject of a
NRC violation were not
addressed
during discussion of maintenance
department
procedural
issues.
The representatives
of the other departments
did not question this.
The
inspector observed that the representatives
of the other
departments
were appropriately critical regarding the proposed characterization
of
performance in each area.
c.
Conclusions
Overall, the maintenance
department's self assessment
program has
been
effective in that management
has identified and pursued
areas
needing
improvement.
Numerous maintenance
proficiency indicators are monitored
closely for detection of areas
needing
improvement.
High expectations
are established
through the establishment
of challenging goals.
Performance
data
from completed observation checklists is effectively
incorporated
into monthly reports.
Implementation of the self
assessment
program was prudently revised
by maintenance
management to
focus on recognized
weak areas.
Some of the observation checklists
were noted
as not sufficiently
critical during self assessments.
Several
recent
NRC findings also
indicate that
some maintenance
workers are not being self critical.
H8
H8.1
20
The procedural
guidance for the administration of the self assessment
checklists
does not accurately reflect actual
implementation.
Maintenance
management's
expectations
for feedback to the observed
individual. signatures
on completed checklists,
and degree of self-
critism were not being met.
Enhancement
of the self assessment
program
is included as the first issue
on the Top Ten Maintenance/Modifications
Manager's
Issues
Top Ten Issues list.
Miscellaneous
Maintenance
Issues
(62707,
92902)
Closed
Licensee
Event
Re ort
LER
Com onents
Were Actuated
as
a Result of an Inade uate Procedure.
On October
12,
1997,
an inadvertent
engineered
safety features
(ESF) actuation occurred
during post-maintenance
testing of a main steam relief valve
modification during the Unit 2 outage.
Shorting of the circuit, while
jumpers were being placed.
caused
an invalid low level signal which
started all eight emergency diesel
generators,
generated
a Unit 2 full
reactor
and caused
one loop of core spray to inject into the Unit
2 vessel.=
The inspector's
review of this event is documented
in
inspection report 259,260.296/97-10.
The licensee
documented the root
cause of this event
as
an inadequate
procedure
associated
with the
modification test program.
The procedure did not require
a
performing'nd
support organization
review in the post maintenance test approval
process.
A more conservative test method of jumper installation at
terminal strips rather than at the relay terminal blocks was identified
following the event
and implemented with a change to the test procedure.
The inspector
reviewed the revised Site Standard
Practice
(SSP)
SSP-8.3,
Modification Test Program,
Revision 8, steps
3.4. 1.A. 11 and 3.4.2.A.7,
which included
an independent
review by the support organizations to
ensure that the most appropriate test
methods
are utilized to minimize
the risk of inadvertent
impact on the plant.
Additional corrective
actions included discontinuation of the use of alligator clips on
installed plant equipment without the approval of'he
Maintenance/Modification
Manager.
The inspector
concluded that the
corrective actions adequately
addressed
the apparent
root cause of the
event.
The inspector
reviewed
a previous similar event. that occur red in April
1996, during which all eight
EDGs started.
The inspector
reviewed
inspection report 50-259,260,296/97-09.
which dispositioned the event
as
a Non-Cited Violation for failure to follow a procedure
which required
that revisions to work plans
be sent to planning for review.
Revisions
were made to the work plan to delete the requirement for a
clear ance/isolation
and
a note was added to perform the work "hot".
(energized)
The work plan was never sent
back to planning for review.
The test methodology selected for use in the most recent post
maintenance test was not adequate to preclude
an inadvertent
engineered
safety features
actuation.
The inspector concluded this was not
a
violation that could reasonably
have been prevented
by the licensee's
'orrective actions for the discussed
previous violation. This non-
'
21
repetitive licensee identified and corrected violation is being treated
as
a Non-Cited Violation (NCV), consistent with Section VII.B.1 of the
(NCV 50-260/97-12-03.
Inadequate
Procedure for
PMT)
Closed
Licensee
Event
Re ort
Unit 2 Scrammed
on
Low Reactor
Water
Level
Due to the Digital Feedwater
System
Reinitializing its Feed
Pump
Demand Output Signal to Zero and the
Subsequent
Trip of the Reactor
Core Isolation Cooling on High Exhaust
Pressure.
Inspection
Report 259,260.296/96-05
addressed
details of the
Unit 2 scram
and subsequent
reactor
core isolation cooling
(RCIC) system
trip following initiation.
Related
enforcement
actions are documented
in a subsequent
letter and Notice of Violation issued August 1,
1996.
The licensee
documented
a specific commitment in the
LER to strengthen
procedural
requi rements for the inservice testing program with regard to
control of testing activities.
The inspector verified that Site
Standard
Practice
SSP-8.3,
Modification Test Program,
Revision 8,
included enhancements
to the Retest
Control
Form to state the basis for
specifying the test.
This
LER is closed.
Cl osed
Violati on 260/96-199-01013
RCIC Inoperabi
1 ity.
Thi s violati on
is addressed
in the Notice of Violation transmitted
by a letter dated
August 1,
1996,
from the
NRC to TVA.
This violation involved the
inoperability of the Unit 2 RCIC system for a period greater
than that
allowed by Technical Specifications
(TS).
RCIC was returned to a fully
operable status
by implementing
a design
change which raised the
exhaust
pressure trip setpoint from 25 psig to 50 psig.
This change
was
previously reviewed by the resident inspectors
and documented in NRC
IR 259.260,296/96-05.
Corrective actions
were inspected in conjunction
with those described in Section M8.2.
The inspector additionally
verified that Quality Assurance
performed the independent
assessment
of
the corrective actions within six months of the licensee's
submittal
as
discussed
in the licensee's
response.
This violation is closed.
Closed
Violation 260/96-199-02014
Failure to Comply with IST
Requirements.
This violation involved two examples of failure to
perform required American Society of Mechanical
Engineers
(ASME)
Section
XI in-service testing (IST).
Both the
RCIC system turbine
exhaust
check valve and the
HPCI system turbine exhaust
check valve were
returned to service after having undergone
maintenance
(replacement)
without adequate
IST being performed
on the valves.
Quality Assurance
evaluated
the effectiveness
of the licensee's
corrective actions
and
concluded that the corrective actions
were effectively implemented.
The
inspector
reviewed the
QA evaluation
and noted that the licensee
included the use of techniques
such
as interviews
and database
searches
to acquire data to support their conclusion.
The inspector verified
that
ASME Section
XI training was performed for Technical
Support
Engineers in September
1996.
as documented
in BFPER960710.
This
violation is closed.
El
Conduct of Engineering
22
III. En ineerin
E1.1
Control Air S stem Transients
and Air ualit
Ins ection Sco
e
37551
The inspector
reviewed the licensee's
corrective actions to address
several
incidents in which control air system pressure
decreased
significantly below the normal operating pressure.
The inspector
also
verified that measures
were in place to ensure that air quality
requi rements
are periodically tested.
b.
Observations
and Findin s
The control,air system supplies air pressure to various control systems
and to the control rod drive hydraulic system.
An automatic reactor scram will occur if control air pressure
lowers to a predetermined
level.
Small reductions in control air pressure
were experienced
on
several
instances
in the November
1997 time frame on Unit 2.
The
were determined to be caused
by actuation of the excess
flow
check valve on the inlet of the control air dryers supplying air at that
time (Unit 2 or Standby).
This valve actuates
to shut off flow to the
.dryer,
and therefore the control air system,
when excess
flow to the
dryer is
experienced.'nitial
troubleshooting efforts focused
on system leakage
downstream of
the dryers
and improper operation the excess
flow check valves.
Later,
the licensee
determined that the excess
flow check valves were actuating
due to degraded
conditions of the control air dryers.
Solenoid
and
check valves which transfer flow through the two dryer desiccant
towers
(one on line and one in a dessicant
regenerative
mode) were found to be
excessively
worn.
The results of these
degraded
conditions resulted in
increased
flow to the control air dryer which actuated
the excess
flow
The licensee
determined that the root cause of the degraded
conditions
of the dryers
was due to a lack of preventive maintenance.
Corrective
actions included performing preventive maintenance
on flow transfer
components
on
a regular schedule.
Increased
moisture
has also been observed
on the Units 2 and 3 control
dryer inlet prefi lters.
The system engineer indicated that this was due
to the installation of a higher capacity control air compressor
which
has
a lower capability of moisture
removal than the original
compressors/moisture
separators.
This resulted in an operator
work
around which required the blowdown of the control air dryer prefilter
on
a regular basis.
A design
change
has
been partially completed which
installed water traps
on the control air dryer prefilters.
However,
problems with the installation of the drain lines (insufficient line
slope)
has delayed their being put into operation
and has resulted in
V
E8
23
continued operator
work arounds to regularly blow down the water traps.
The licensee is currently reviewing options to the drain line slope
problems.
The inspector verified that the licensee
had measures
in place to verify
control air/instrument air quality.
The inspector
found that O-TI-34,
Monthly Control Air System Dryer Dewpoint Test and Purge Control,
performs moisture content .checks
on control air dryer and drywell
control air systems.
0-TI-173. Control Air Sampling, periodically
(every
6 months) performs air particulate
and hydrocarbon
checks
on
these
systems.
These preventive maintenance
items are performed based
on the licensee's
commitments
made in response to
Conclusion
The licensee
has
implemented significant modifications to increase
the
air system capacity
and reliability.
Insufficient preventive
maintenance
on the control air dryers resulted in several
air system
Problems with the installation of water trap drain lines
has resulted in operator work around which the licensee is continuing to
resolve.
The licensee is periodically monitoring control/instrument air
quality as documented in the response to Generic Letter 88-14.
.Miscellaneous
Engineering
Issues
(92903)
E8. 1,
Closed
Licensee
Event
Re ort
Residual
Heat
Removal Service Water
Pum
Limitin Condition for 0 eration is Non-
Conservative.
The
LER documented
an inconsistency
between
statements
in
the Updated Final Safety Analysis Report
(UFSAR) and Technical Specification 3.5.C,
regarding the number of Residual
Heat
Removal
(RHRSW) pumps required to remove heat from a unit
following a design basis accident.
The
UFSAR states that within one
hour following a design basis accident, six RHRSW pumps will be required
to supply cooling water to the
RHR heat exchangers.
The licensee
has
determined that two RHRSW pumps
per unit are required to serve the core
and containment cooling function following a design basis accident.
The
current
TS requires
seven, five, or four pumps to be operable
and
assigned to
RHRSW service with three,
two,
and one units fueled,
respectively.
Since two RHRSW pumps are supplied from emergency diesel
generator
A and two are supplied from emergency diesel
generator
B, then
the potential existed for
a single failure of diesel
generator
A or
B to
reduce the number of available
pumps to less than the number of pumps
described in the
UFSAR for the case of two or three unit operation.
The licensee
completed
an analysis to determine the suppression
pool
temperature
response
for the non-accident unit-following a loss of
coolant accident or other design basis accident in the opposite unit.
considering
a complete loss of offsite power and the worst case single
failure.
The analysis
supported the licensee's
conclusion,
as presented
in the
LER. that more than two hours is available to the operators
for
either restoring another
RHRSW pump to service or for establishing
't e~
gpss
24
alternate
power to the two RHRSW pumps lost as
a result of the single
failure.
The inspectors
reviewed the Emergency Operating Instructions
and verified that procedures
prompted the operators to 'initiate
suppression
pool cooling.
The inspector discussed this issue with
control
room
Senior Reactor Operators
who indicated that actions would
be taken to restore
power to the 4kV shutdown board through the crosstie
to the appropriate
EDG on the other unit.
The inspector
reviewed
O-AOI-57-1A, Loss of Offsite Power
(161 and 500 kV) / Station Blackout,
to verify that instructions were provided to 'operators to energize
a
Unit 1/2 4kV shutdown board using
a Unit 3 diesel generator.
The
licensee
concluded that the condition described
by this event would not
degrade
the
RHRSW safety function to an extent that would prevent
a unit
shutdown.
The inspectors
noted that the licensee
event report
assessment
of safety consequences
sufficiently detailed the licensee's
analysis
and conclusions.
The assessment
was improved from previous
examples
documented
by the inspectors.
The licensee's
corrective actions
included administrative controls to
ensure that the four RHRSW pumps would be available after
a single
failure during two unit operation.
The inspector verified that
Operating Instruction O-OI-23, Residual
Heat
Removal Service Water
System,
was changed to require that either six RHRSW pumps are required
for two fueled units or if only five RHRSW pumps are available,
they
shall
be powered from five separate
4kV Shutdown Boards.
The licensee
also submitted
a Technical Specification
(TS) change to the
NRC on
December
30,
1997, to correct the non-conservative
TS.
This issue represents
a failure to assure that the design basis
was
correctly translated into specifications.
drawings,
procedures
and
instructions.
The licensee identified this issue,
performed
a thorough
assessment
of the safety implications,
and initiated corrective actions.
The licensee's
evaluation adequately
supported the conclusion that this
deficiency would not have prevented
a safety system from performing its
function under
design basis accident conditions.
This licensee-
identified and corrected violation is being treated
as
a Non-Cited
Violation. consistent with Section VII.B.1 of the
NRC Enforcement
Policy.
(NCV 259.260,296/97-12-04,
Design Basis
Not Translated
Properly
for RHRSW Pump Requirements)
Closed
Ins ection Followu
Item
IFI
260 296/95-064-10
Secondar
Containment Ventilation Dam er Failures.
This issue
was previously
discussed
in NRC inspection reports 259.260,296/95-64
and
259,260,296/96-08.
The issue involved secondary
containment ventilation
damper failures due to sticking solenoid valves.
The solenoid valve
sticking was suspected
to be occurring at the core-plugnut interface.
The inspector attended
the Maintenance
Rule
(MR) Expert Panel
meeting
on
January
8,
1998. which reclassified the Secondary
Containment Isolation
System from MR a(l) status to
MR a(2) status.
The members
discussed
that all the associated
had been replaced
by February
1997 and no associated
solenoid valve problems
have occurred since the
replacement.
The discussion
indicated that in July 1997, the licensee
ended weekly swapping of the fans, currently the fans are
swapped
every
E8.3
E8.4
25
six weeks.
The licensee
had approximately six months of "typical
operation" data without an associated
solenoid valve failure.
The
system engineer
considered that the problem was resolved with the
changeout of solenoid valves.
As discussed
in Section El. 1 of this
report, the resident
inspectors
also verified that control air quality
is being monitored.
The lack of failures
on the secondary
containment
ventilation
indicates that the specific system problem
resolution
was adequate.
This IFI is closed.
Closed
Ins ection Follow-U
IFI
260/97-05-04.
Spurious
Isolation Valve (MSIV) Closure
on Reactor
Sections
E1.2 and Ml. 1
of NRC Inspection Report 97-10 describe detailed review of modification
activities completed to reduce the probability that the MSIVs would shut
unnecessarily
following a reactor
A minor problem with the
capacitor
calculation
was identified.
Overall implementation
and design
was adequate to address
the problem.
The IFI is closed.
Closed
Licensee
Event
Re ort
Unit 2 Scram
on Turbine
Control Valve Fast Closure
Due to Loss of Excitation to Main Generator.
NRC Inspection Report 96-12 describes
NRC review of the event.
The
event was attributed to an incorrectly revised maintenance
procedure for
main generator
exciter bush replacement.
The corrective actions listed
in the
LER were completed.
The resident
inspectors verified that the
event
had been correctly characterized
as
a preventable failure in the
.maintenance
rule program.
The
LER is closed.
P2
P2.1
IV. Plant
Su
ort
Status of Emergency Preparedness
(EP) Facilities,
Equipment,
and
Resources
Ins ection Sco
e
82701
This area
was inspected to determine whether the licensee's
Emergency
Response Facilities
(ERFs)
and equipment
were adequately
maintained in
accordance
with the Emergency
Plan.
Requirements
applicable to this area
are found in 10 CFR 50.47(b)(8)
and (9),
Sections
IV.E
and VI of Appendix
E to 10 CFR Part 50,
and the licensee's
Emergency
Plan.
Observations
and Findin s
The inspector toured the Technical
Support Center
(TSC) and Operational
Support Center
(OSC)
and tested telephones.
fax machines,
and
Emergency
Response Facility Information System monitors
and Computers.
All
equipment tested satisfactorily.
The inspector
reviewed several
controlled volumes of the Emergency
Plan Implementing Procedures
(EPIPs) in the
ERFs for being
maintained
up to date.
All of the EPIPs
reviewed were up-to-date.