ML19332F002

Forwards Summary of 891121 Meeting Re Schedule for Insp at Plant Prior to Restart of Unit 2.List of Attendees & Supporting Info Encl

ML19332F002
Person / Time
Site:	Browns Ferry
Issue date:	12/04/1989
From:	Wilson B Office of Nuclear Reactor Regulation
To:	Kingsley O TENNESSEE VALLEY AUTHORITY
References
NUDOCS 8912130263
Download: ML19332F002 (35)

Text

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DEC 8 4'1983 i

Mr. Oliver D. Kingsley, Jr.

Senior Vice President, Nuclear Power Tennessee Valley Authority 6N 38A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801

SUBJECT:

MEETING SUWARY - BROWNS FERRY NUCLEAR PLANT, UNIT 2 DOCKET NO. 50-260-This refers to the management meetir.g conducted at our request, in the NRC Headquarters Office on November 21, 1989.

This meeting was held to discuss the schedule for NRC inspections at Browns Ferry prior to restart of Browns Ferry Unit 2.

A meeting summary, a List of Attendees, and a copy of the Master Inspection Plan are enclosed.

It is our opinion that the meeting was beneficial and has provided a good understanding of the necessity and schedule of the inspections planned prior to restart of Browns Ferry Unit 2.

In accordance with Section 2.790 of NRC's " Rules of Practice," Part 2 Title'10, Code of Federal Regulations, a copy of this letter and its enclosures will be place in the NRC Public Document Room.

Should you have any questions concerning these matters, we will be pleased to discuss them.

Sincerely, originalSca3d U sRUCE A.vnG0F1 i

Bruce A. Wilson, Assistant Director for Inspection Programs TVA Projects Division

Enclosures:

(See page 2) 891'2130263 891204 PDR ADOCK 0500026,0 Q

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s DEC 0 o g Mr. Oliver D. Kingsley, Jr.

2

Enclosures:

1.

Inspection Schedule Meeting Summary 2.

List of Attendees 3.

BFNP Restart Master Inspection Plan, Revision 3 cc w/encls:

F. L. Moreadith, Vice President P. Carier, Site Licensing Manager Nuclear Engineering Browns Ferry Nuclear Plant Tennessee Valley Authority Tennessee Valley Authority 400 West Summit Hill Drive P. O. Box 2000 WT 12A 12A Decatur, AL 35602 Knoxville, TN 37902 G. Campbell, Plant Manager Dr. M. O. Medford Browns Ferry Nuclear Plant Vice President and Nuclear Tennessee Valley Authority Technical Director P. O. Box 2000 Tennessee Valley Authority Decatur, AL 35602 6N 38A Lookout Place Chattanooga, TN 37402-2801 TVA Representative Rockville Office Chairman, Limestone County 11921 Rockville Pike Commission Suite 402 P. O. Box 188 Rockville, MD 20852 Athens, AL 35611 General Counsel Dr. Henry Myers, Science Advisor Tennessee Valley Authority Committee on Interior and 400 West Sunnit Hill Drive Insular Affairs ET 11B 33H U. S. House of Representatives Knoxville, TN 37902 Washington, D. C.

20515 Claude Earl Fox, M.D.

O. J. Zeringue, Site Director State Health Officer Browns Ferry Nuclear Plant State Department of Public Health Tennessee Valley Authority State Office Building P. O. Box 2000 Montgomery, AL 36130 Decatur, AL 35602 State of Alabamu Manager, Nuclear Licensing i

and Regulatory Affairs Tennessee Valley Authority SN 157B Lookout Place Chattanooga, TN 37402-2801 bec w/encls:

(See page 3) i 4

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l Mr. Oliver D. Kingsley, Jr.

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D. M. Crutchfield, NRR B. D. Liaw, NRR t

S. C. Black, NRR R.'C. Pierson, NRR G. E. Gears, NRR D. Moran, NRR W. S. Little, NRR/RII A. H. Johnson, NRR/RIl A. R. Long, NRR/Ril J. Rutberg, OGC l'

M. S. Callahan, GPA/CA NRC Document Control Desk NRC Resident Inspector U.S. Nuclear Regulatory Comission Route 12. Box 637 Athens, AL 35611 RII k

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ENCLOSURE 1 INSPECTION SCHEDULE MEETING S M RRY On October 31, 1989, the NRC completed Revision 2* of the Browns Ferry Master Inspection Plan for the restart of Unit 2 (Enclosure 3).

This Plan was reviewed with representatives from TVA during this meeting.

The review included the proposed schedule, purpose and prerequisites for each inspection.

The importance of TVA being ready for each inspection was stressed by the NRC in order to make the most efficient use of the limited inspection resources.

In order to ensure TVA's understanding of the scope and prerequisites for the planned inspections TVA requested meetings or feedback from the NRC to ensure their understanding of the following inspections:

- Inspection J. 1. Overall Staff Traininn

- Inspection R.1. Procedure Adequacy

- Inspection L.1. Perfomance Based Maintenance Team Inspection TVA requested that they meet with the team leader for the Perfomance Based Maintenance Team to discuss changes in the Maintenance Program that are planned to take place soon.

It was tentatively agreed that the Plant Manager and Maintenance Superintendent would meet with the team leader during the team's on-site preparation during the week of December 10, 1989. The NRC told TVA that they should submit a letter to the NRC stuting their readiness for the inspection 30 days prior to the inspection scheduled to begin on January 8, 1990.

Mr. Little stated that he would provide Mr. Campbell requested feedback on the scope of the three inspections.

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• Revision 2 of the MIP was discussed in the meeting. Minor changes made during the meeting are incorporated into Revision 3 which is enclosed.

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ENCLOSURE 2 LIST OF ATTENDEES i

1.

TVA J. Bynum. Vice President Nuclear Production O. Zeringue. Site Director Browns Ferry G. Campbell. Plant Manager, Browns Ferry P. Carier, Site Licensing Manager. Browns Ferry P. Salas, Compliance Supervisor, Browns Ferry 2.

NCR i

B. Liaw. Director. TVA Projects Division. ADSP S. Black. Assistant Director for TVA Projects. TVAPD B. Wilson. Assistant Director for TVA Inspection Programs TVAPD E. Goodwin. Technical Assistant TVAPD G. Gears. Senior Project Manager TVAPD W. Little Section Chief. TVAPD K. Ivey, Jr., Resident Inspector TVAPD

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ENCLOSURE 3 BfNP RESTART MASTER INSPECTION PLAN i

REVISION 3 9

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2 BFNP RESTART INSPECTION PLAN INDEX I. INSPECTIONS PLANNEO A.

SITE MANAGEMENT AND ORGANIZATION l

B.

QUALITY ASSURANCE C.

. SEISMIC ISSUES D,

FIRE PROTECTION E.-

ENVIRONMENTAL QUALIFICATION F.

TECHNICAL SPECIFICATIONS G.

PROCUREMENT AND PIECE PARTS H.

RESTART TEST PROGRAM I.

OPCRAT10NAL READINESS FOR RESTART J.

OPERATOR TRAINING K.

(NotAssigned)

L.

MAINTENANCE M.

ELECTRICAL DESIGN ISSUES N.

ROUTINE ONSITE INSPECTIONS 0.

VERTICAL SLICE TEAM INSPECTION P.

REGION 11 SUPPORT INSPECTIONS Q.

ALLEGATION /0 PEN ITEM REVIEW FOR RESTART R.

PROCEDURE UPGRADES S.

ANTICIPATED TRANSIENTS WITHOUT SCRAM II. INSPECTIONS COMPLETED A.

DESIGN BASELINE VERFICATION PROGRAM AND DESIGN dALCULATION REVIEWS B.

FUEL LOAD C.

WELDING D.

INTERGRANNULAR STRESS CORPOSION CRACKING E.

EMPLOYEE CONCERNS PROGRAM 4

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3 I. INSPECTIONS PLANNED i

A.

SITE MANAGEMENT AND ORGANIZATION 1

Issue The NRC's 50.54(f) letter of September 17, 1985, requested specific information regarding actions taken or planned by TVA to improve management oversight, direction, and support of BFN activities.

In response to the 50.54(f) letter, TVA submitted the Browns Ferry Nuclear Performance Plan (NPP, Volume 3). In Sections II and IV of this plan, TVA described corrective actions to strengthen management and organization such at: 1) restructuring the BFN site organization to be compatible with changes to the corporate structure; 2) preparing position descriptions which delineate areas of responsibility and authority for site management, including reporting channels and interfaces; 3) defining training activities, such as shif t technical advisor (STA) training or senior reactor operator (SRO) license training for managers; and 4) establishing specific site improvements, such as a site licensing group.

Inspections Conducted and Status The following inspections have been conducted:

Organizational changes: 85-36 Management qualifications:

87-33

" War Room" activities: 87-46 PORC:

85-28, 87-02, 88-05, 88-21 Management training:

89-12 Important management changes continued to be made which could have a significant impact on the plant as it transitions from a 4 year outage to an operating plant. Due to the outage and the staff reorganizations that were required, the NRC must review the current staff organization and its preparedness for restart.

Inspections Planned 1.

Assess Site Management and Organization Effectiveness l

RI staff Prerequisites:

None Scheduled:

Ongoing (Weekly assessment, reported in monthly resident report through restart) a.

Ability to plan, schedule and successfully carry out major activities required for restart without significant delay, and I

with a minimum of problems I

b.

Performance based review of ability to provide integrated team effort-

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On site review committees effectivaness (MC 40700) d.

Plant activity meeting effectiveness e.

Coordination and timeliness of problem resolution f.

LER review with emphasis on root cause analysis g.

Effectiveness of information flow up the management chain h.

Feedbt.ek of causal events to lower staff levels 1.

Effectiveness of feedback of operating experience J.

Effectiveness of standing orders and night orders L.

Site functional interface with corporate activities 1.

Operational and management staffing / qualifications from MC 36301/ ANSI 18.1 m.

Operational processes

__ tagouts, logs, TS interpretations, caution orders, and TACFs n.

Turnover impacts o.

ACRS concerns 2.

Management Evaluation During Restart Readiness Inspection (locluded in !.1.)

Region II ops MC 40500; 36800 (include tech, staff and mgr. training)

Scheduled: 2 - 4 months prior to restart B.

QUALITY ASSURANCE (QA)

Issue The NRC's 50.54(f) letter referred to a number of instances of poor performance in the QA area including three successive SALP periods with ratings of "3" in QA at both Sequoyah and BFN.

In response to the 50.54(f) letter, TVA revised its QA topical report with a number of changes, including:

1) restructuring the nuclear QA organization to include a representative at each site reporting to the new l

Director of Nuclear Quality Assurance; 2) consolidating all nuclear QA and quality control (QC) functions under the Director of Nuclear Quality l

Assurance; and 3) increasing emphasis on corrective action and root cause I

analysis programs.

NPP, Volume III, Sect. !!.2.6 and Attachment IV-2 documents TVA's commitments to strengthen QA at BFN.

Continued weakness in the area of root cause analysis and recurrence control have resulted in a lack of confidence in the ef fectiveness of corrective actions.

Inspections Conducted and Status The NRC must develop confidence that the changes are properly implemented and have a positive impact on the site performance indicators.s The NRC must concur with the licensee's selection of these ~ performance :1ndicators and established goals for restart.

Since the new component level Q-List I

development is a phased approach, the NRC must concur with the scope of j

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the short term activities and then agree to the licensee's schedule for the long term Q-List. As a final activity, the NRC must determine that the site 0A program and implementation of the program appropriately include all those planned and systematic actions necessary to provide adequate confidence that a structure, system, or component that is important to safety will perform satisfactorily in service per 10 CFR 50, Appendix B.

The following inspections have been conducted:

QA program: 86-08, 87-02, 87-20 QA organization / administration:

85-38, 85-48, 86-12, 87-24 Audits:

85-38, 88-18 Corrective action program: 86-36, 86-43, 87-24, 87-37, 87-41, 88-21 Q-List:

87-37, 88-05, 88-10, 88-16 Offsite support staff: 85-47 Engineering Assurance: 87-37 QA surveillance reports: 88-04 QC inspection activities: 86-15 Document control / records: 85-56, 86-08, 87-37 QA training for craftsmen: 88-05 Engineering training: 89-12 Inspections Conducted 1989 1.

Quality Verification Team Inspection - MC 35702 - IR 89-12 Jenison, Team Leader Completed: May 8, 1989 Inspections Planned 1.

Programmatic Team Inspection - MC 35701, 36100 Jenison, Team Leader Prerequisites: Letter from TVA verifying that new QA program will not significantly impact site QA/QC.

Scheduled: February 5-9, 1990 a.

Topical Implementation (MC 35502,35001) b.

Q-list /CSSC effectiveness c.

CAQR resolution process including generic reviews, timeliness, root cause analysis, and effectiveness d.

QA oversight of engineering e.

QA training adequacy f.

Other (MC 35750,39701,39702,40702,40703,40704) e

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Assess Offsite Review Committee - MC 40701 Carpenter /RI staff Prerequisites: None Scheduled: Ongoing C.

SEISMIC ISSVES Issue Deficiencies were identified for the torus, piping and piping supports, cable tray supports, conduit supports. HVAC ductwork, drywell steel platforms, miscellaneous steel, lower class over Class I features, secondary containment penetrations, and miscellaneous civil issues. The NRC's 50.54(f) letter requested information regarding the programs being used to evaluated the seismic adequacy of some of these issues.

In response to the 50.54(f) letter TVA submitted program descriptions in the August 1986 NPP, which was subsequently revised in June 1987, and a separate April 1987 submittal.

A program summary and review meeting was hvid with the NRC in September 1987. ' A continuing dialogue between TVA and NRC staff on seismic issues was established.

TVA will perform comprehensive review of these issues and demonstrate acceptability for operation prior to restart.

l Inspections Conducted and Status TVA identified a range of seismic issues in Volume 3 of the NPP. Selected resolution of these issues has been submitted to the NRC for review and approval. Additional resolution of outstanding items is still required.

The staff has issued an SER for cable tray supports. Several programs are still in the discovery stage. Corrective action may need to be augmented after further staff review and observation of TVA performance.

Partial inspections and reviews have been conducted on several programs.

The following inspections have been conducted:

Drywell platform steel:. 86-14, 86-30 Seismic anchorage concerns:

87-27 Cable trays: 85-41, 85-51, 86-02, 86-36, 87-07, 87-19 Pipe supports and restraints:

85-26, 85-30, 85-51, 86-02, 86-19, 87-19 IEBs 79-02 and 79-14:

85-21, 85-26, 85-30, 85-41, 86-19, 86-30, 87-07, 87-19, 87-26, 88-12, 88-19 Conduit and supports:

85-51, 87-07, 87-19 CR0 piping:

86-06, 87-07, 87-08, 87-19 HVAC concerns: 86-06, 87-07, 87-14, 87-19 Torus modifications:

85-26, 86-35, 87-07, 88-18

Torus attached piping

87-07

'Small bore piping: 86-02, 87

• Secondary containment penetrations:

85-57 Seismic design programs:

88-38, 88-39

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The following areas are considered to be resolved for restart without further inspection:

a.

Cable Trays b.

Torus Modifications Inspections Conducted in 1989 1.

Follow-up Inspection For Closure of IEB 79-02 and 79-14 Based On SER Output.. IR 89-15.

John Fair Team Leader Prerequisites:

90% of design complete supporting 79-02 and 79-14.

Conducted: January 23 - February 3,1989 2.

Seismic Design Program - irs 89-21, 89-29, 89-31, 89-39 7

Thomas Cheng, Team Leader Prerequisites:

None Conducted: January 23, 24; February 20-24; April 26-28; August 16-18, 1989 3.

Civil Calculation Program Thomas Cheng, Team Leader Prerequisites:

None Conducted: March 13-24, 1989, 1R 89-30 June 6 - August 18, 1989, IR 89-32 4.

Small Bore Piping and Tubing HQ - John Fair Conducted August 29 - September 1,1989, IR 89-36 Inspections Planned 1.

Pre-Restart 79-02 and 79-14 (Large Bore)

John Fair, Team Leader (3) l Prerequisites:

90*4 of design complete Scheduled:

October 16-27, 1989 2.

Followup Civil Calculation / Seismic Design Program Thomas Cheng, Team Leader (2) l Prerequisites:

All required restart evaluation to be completed Scheduled: November 27 - December 1,1989 (at Browns Ferry) 1 3.

Field Inspe'etion of Seismic Issdes'(MC 50090)

RII, MPS (1 or 2)

Prerequisite:

79-02/14 mods in progress Schedule: December 4-8, 1989

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Seismic Program Followup John Fair Team Leader Schedule: TBD 0.

FIRE PROTECTION Issue Final NRC concurrence on the Appendix R compliance program is required for the restart of Unit 2, A BFN plan to implement the requirements of Appendix R was developed by TVA and submitted for NRC approval on January 31, 1986. Additional information, ' supplementing the January 1986 program submittal, was sent to the NRC on November 21, 1986.

Five exemptions from Appendix R requirements have been requested by TVA and approved by the staff. Modifications to comply with Appendix R will be completed prior to Unit 2 restart. Additionally, BFN has undergone major fire protection upgrades that should be evaluated.

Inspections Conducted and Status The NRC staff is presently reviewing the BFN Appendix R compliance program. The staff has found that the program will meet NRC requirements.

An SER on post-fire safe shutdown was issued on April 14, 1989.

The following inspections have been conducted:

Fire protection program:

86-09, 87-21 Appendix R modifications:

87-37 Inspections Conducted in 1989 1.

Appendix R Team Inspection post-fire safe shutdown systems and procedures)

OSP PSB/NRR Team Conducted: May 1 - 5, 1989 IR 89-13 2.

Appendix R Team Inspection (fire protection systems and procedures)

ADSP Team Conducted July 17 - 21, 1989 IR-89-28 i

9 Inspections Planned 1.

Fire Protection Program - MC 64704 R II Prerequisites:

Fire protection mods. complete (schedule completion by February 28,1990)

Scheduled:

March 26-30, 1990 2.

Appendix R Closeout R. Wescott, ' ADSP Prerequisites:

IR 89-13, 89-28 Ols and IFIs ready for closure.

Schedule:

March 26-30 1990 E.

ENVIRONMENTALQUALIFICATION(EQ)

Issue Insufficient documentation existed to demonstrate that electrical equipment at the plant was environmentally qualified as required by 10 CFR 50.49.

TVA has developed an upgraded EQ program to identify equipment, specify environments, verify equipment in the field, document qualification, specify maintenance requirements, maintain EQ binders, and replace unqualified equipment if necessary. The necessary documentation is being completed and field verified.

Any required modifications will be completed before restart.

Recent TVA program assessments indicate that the EQ Program is a major factor in the Unit 2 restart schedule.

Inspections Conducted and Status An in-depth NRC team inspection was conducted in May 1988.

Equipment specific deficiencies were found in eight EQ binders, The program in general was judged acceptable; however, the Qualification Maintenance Program is still in its inf ancy and co'uld not be properly evaluated.

The following inspections have been conducted:

EQ: 87-26, 87-33, 87-37 EQ team inspection:

88-11 Inspections planned 1.

EQ Follow-up Team Inspection - tis 2515/75, 2515/76 NRR, Team Leader (5 including I from RII)

Prerequisites:. TVA EQ readiness _ letter 2 weeks prior to inspeciton (90% of packages, 75% of mods & MRs complete)

Scheduled:

February 12, 1990 (proposed)

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TECHNICAL SPECIFICATIONS

!ssue TVA and the NRC have identified and agreed upon a list of 30 TS changes requiriag approval by the NRC before BFN can enter the startup mode.

These changes involve c'larifications, corrections, modifications, and organization and regulatory changes.

f Inspections Conducted and Status Due to a loss of configuration control the licensee has submitted a number of TS changes to support the plant modifications.

TVA has submitted a number of the required TS changes for staff review.

The other changes are scheduled to be submitted to allow time for NRC review and TVA implementation prior to restart. The staff expects to issue the last restart TS amendment 90 days following submittal by the licensee. Additional TS change requests are expected from TVA prior to restart; however, their approval and implementation have not been e stablished as a restart item.

TVA has completed a TS assessment program to verify compliance with plant hardware, design basis and NRC safety evaluation.

NRC inspections are planned to verify that the TS reflect plant configuration along with training for the changes.

1.

Inspection For TS Adequacy - MC 71301 Patterson(ADSP)

Prerequisites: TVA verification of TS complete, DBVP discovery and design complete, and all TS changes identified.

Conducted:

September 25-29,1989,IR89-47 issued (October 21, i

1989) l 1

Inspections Planned 1.

TS Implementation and Adequacy Patterson (ADSP)

Prerequisites:

TS activities implemented for restart, training conducted on TS changes, procedures issued, outstanding items ready for closure i

Scheduled - January 29, 1990 G.

PROCUREMENT / PIECE PARTS Issues

.From TVA NSRS reports issued between 1983 and 1985 and during an inspection in November 1986, the NRC determined that TVA had procured replacement parts for safety-related equipment without appropriate procurement controls to ensure that replacement items were tested or qualified for their safety-related applications.

11 Inspections Conducted and Status TVA has undertaken an extensive program to review and evaluate past and present procurement of replacement items.

TVA is establishing the qualification of items or replacing items on equipment required for restart on a priority basis.

The NRC is reviewing TVA's programmatic approach. The staff SE is yet to be issued.

BFN's approach it very similar to the approved Sequoyah approach.

The following inspections have been conducted: 87-08, 87-09 Inspections Planned' 1.

Team Inspection NRR (5)

Prerequisites:

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Review of installed 50.49 equipment essentially complete and all required replacements identified.

Majority of replacements completed.

2.

More than 20 dedication packages performed under new program available for review.

3.

More than 20 items receipt inspected under inspection criteria established under new program.

4.

Sample of close-out packages for equipment with critical characteristics verified by post-installation testing available for review.

5.

50.49 equipment warehouse inventory essentially complete.

Scheduled:

Februa ry 19, 1990 - twoweeks(proposed) a.

Procurement program (MC 38701,38702) b.

Replacement parts, including sampling in plant parts and conditions in the warehouse, c.

Commercial grade item dedication programs and processes (MC 38703) d.

Close IEB 88-10 H.

RESTART TEST PROGRAM (RTP) l Issue Due to the prolonged plant shutdown and extensive modifications, a comprehensive RTP is required to ensure plant ' systems are capable of meeting their safe shutdown requirements.

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12 Inspections Conducted and Status A RTP has been developed which includes individual and integrated system testing, a backup control test, and criticality and power ascention testing.

The DBVP developed the system test requirements necessary to satisfy the safe shutdown analysis. The program involves developing test procedures

and, where possible, utilizes existing operation and surveillance instructions.

A summary description of the program was submitted on July 13, 1987.

To date, TVA has not completed all of the detailed test procedures.

The staff is in general agreement with the intent of TVA's program and has issued an SER.

The following inspections have been conducted:

RTP: 87-12, 87-27, 87-30, 87-33, 87-42, 87-46, 88-02, 88-04, 88-05, 88-10, 88-16, 88-21, 88-24, 88-28, 88-32, 88-33, 88-35, 89-03, 89-08, 89-11, 89-19, 89-20, monthly Resident Inspection Reports.

Restart Review Board: 87-14, 87-30, 87-37 Special tests: 86-28, 87-33, 87-42 Inspections Conducted 1.

Phase I Restart Test Review Christnot Prerequisites:

None Completed: December 1988 a.

Review five fuel load systems (test results and test exception resolution) (MC 70329)

Inspections Planned 1.

Phase 11 Restart Test Review (post fuel load) 1 Christnot, RI, Prerequisites:

Final review ands approval of 75% of restart tests, excluding power ascertain tests Scheduled:

In progress a.

Three non fuel load systems (procedures, observations, results, exceptions) b.

Overall s'ammary based on Phase I, Phase II, test exceptions, and SPOC review.

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InitialCriticalityandPowerAssenhonTestingProgramherMC2514 2.

Patterson, lead (ADSP/RII)

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TVA to develop detailed plan, including hold points.

Procedures approved and issued 30 days prior to restart Scheduled: April 16, 1990 3.

Review and observation of primary plant hydro, LLRT and ILRT -

MC 61720, 70307, 70313, 70323 Hydro and LLRT to be inspected by RI and Region II staff.

ILRT to be inspected by RII.

Prerequisites: None Scheduled:

ILRT, February 28, 1990.

Hydro, March 26, 1990.

LLRT, TBD I.

OPERATIONAL READINESS FOR RESTART 1

Issue A comprehensive effort to assess BFN material condition and personnel readiness to support safe plant restart and operation is required due to the current extended outage, changes in the ss te and support organizations, realignment of responsibilities, and implementation of new programs to correct past problems.

TVA has established programmatic guidance for operational readiness verification.

TVA is currently documenting commitments and test statements of intention from the BFN NPP to be used to verify adequate NPP implementation. TVA is also defining performance objectives, criteria, and evaluation plans to ensure that I

site organizations function effectively and are prepared for plant restart and operation. On June 16, 1989 TVA issued the report on the first of a two phase operational readiness review conducted in May 1989.

' Inspections Conducted and Status l

l-The NRC will independently assess TVA's readiness for restart. The NRC is currently reviewing TVA plans for the operational readiness program as I

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described in the BFN NPP.

Inspections Planned' 1.

Restart Readiness Team Inspection Region II Team Leader (8)

Prerequisites: TVA final team report on operational readiness Scheduled: April 23, 1990 (2 weeks) a.

HP, Security b.

Corporate oversight c.

Implementation of lessons learned from SQN restart d.

Corporate SER open items y.;

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Assess senior management in place at the time of restart (MC 36800) f.

Assess maintenance backlog and MTI Ols g.

Follow-up on the resolution of Site Management Effectiveness concerns and areas of limited coverage (using Murley criteria)'

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Procedure adequacy i.

Control room professionalism J.

Review TVA's operational readiness self assessment k.

Offsite support staff (MC 40703) 1.

Follow-up on outstanding QA issues and evaluate QA effectiveness, m.

Tech, staff and management training.

2.

System Alignment (minimum of three systems)

Brady, Team Leader (6)

Prerequisites:

When final system alignments for criticality have begun.

Scheduled: May 7, 1990 J.

TRAINING Issue From results of NRC requalification examinations, the NRC determined that the TVA operator training program had several programmatic weaknesses.

Inspections Conducted and Status TVA has undertaken a comprehensive one-time training program to upgrade all licensed operators.

Beginning in 1987, TVA increased its annual requalification training for licensed operators from four to at least six weeks.

The TVA BFN simulator was moved to the BFN site to improve -

operator access to the simulator and to allow for more effective overall training.

The licensed operator training program achieved INF0 accreditation in March 1986. TVA's programmatic approach is acceptable to the staff.

Inspection of the reactor operator training program is complete. Pass rates on the NRC admin 1stered requalification examinations i,

for TVA operators to complete the upgrade course were greatly improved, l

The overall pass rate was 80 percent or better. NRC requalification testing of TVA operators must be completed.

Due to a change in the methodology of evaluating the final group, some restrictions have been imposed on those operators pending an evaluation using the " pilot program" i

l-techniques.

The following inspections have been conducted:

86-14, 86-32, 87-26, 88-08, 89-12.

-Inspections Completed in 1989 v.

1.

Group IV' Operator Reexamination and Assessment of the Requalification Program Via Requalification Examinations w

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m 15 Brockman (RII)

Prerequisites:

TVA notification that Group IV operators are ready for the exams.

Conducted July 10-21, 1989 Inspections Planned 1.

Overall Staff Training Rll Team (5)

Prerequin tes: None Scheduled: December 18-22, 1989 MC 41500:

2 Operator Requalification Program Verification Casto, Region II Prerequisites: Adequate sample of individuals ready for requal exams. All attribures of CAL 86-01 ready for closure Schedule: January 22-26 and February 5-9, 1990 MAINTENANCE Issue Programmatic problems in site maintenance were previously identified in SALP and inspection reports. This area received three SALP category "3"

- ratings.. The problems were attributed to such factors as poor supervision of work activities, inadequate planning, ineffective root cause analysis, inadequate training, and poor coordination between different organizations to support maintenance activities.

Inspections Conducted and Status BFN has developed and is implementing a comprehensive maintenance improvement program (MIP) that identifies several essential improvements.

The problem encompasses TVA's own assessment of needed improvements and those identified by INP0 evaluations /r'ecommendations and NRC deficiencies.

Program elements being improved include:

programmatic aspects of maintenance, preventive failure analysis, maintenance procedures upgrade, training, personnel certification qualifications, and facilities for the conduct of maintenance.

To ensure success, BFN committed resources and established a staff of senior line managers with authority to develop and '

implement the MIP. Several team inspections have been conducted and the NRC is concerned that significant weaknesses in the maintenance area continue to be identified by the licensee's internal inspections and

-audits, external auditing organizations, and the NRC resident inspectors.

Increased emphasis is needed by both TVA and the NRC as the maintenance request backlog work-off rate has increased as restart milestones are approached.

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16 The following inspections have been conducted:

Maintenance program:

86-32 MIP:

87-27, 88-02 VMCP: 87-26, 87-27 M&TE: 85-36, 87-33 Calibration: 85-53, 86-05 Preventive Maintenance: 88-24, 88-28, 88-32, 88-33, 88-35, 89-03, 89-08, 89-11, 89-19, 89-20 Inspections Planned 1.

Performance Based Maintenance Team Inspection (TI 2515/97)

Region II Prerequisites:

Programmatic issues resolved and program in place & implementation demonstrated, completion of ATWS mods, IR-89-17 concerns ready for closure.

TVA letter confirming readiness for the inspection.

Sci,aduled: ' Team onsite preparation week of December 10, 1989.

Inspection the weeks of January 8 and 22,1990.

'M.

ELECTRICAL DESIGN ISSUES Issue

?

Employee ' concerns, INP0 findings, and various other audits and reviews detected significant deficiencies 'which have been categorized as

" Electrical Issues."

Corrective action consists of those activities I

necessary to establish, through analysis or modifications, that the plant

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l configuration is consistent with requirements of electrical design i-standards' and specifications.

Issues involved are AC/DC calculation l

deficiencies, cable pulling issues, flexible conduit, cable ampacity, cable separation, thermal overloads, cable splices, fuses, cable and bus l'

l-protection, DG component rating, standby DG loading, and instrument accuracy.

1 Inspections Conducted and Status Programs have been established for each of the specific issues including y

walkdowns -of the installed configuration, qualification tests of I

representative configurations, calculations, replacement, and rework.

Review of the remaining issues will be documented in the Volume 3 SER.

l.

The following inspections have been conducted:

86-24.

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17 Discussions between TVA and the NRC staff are continuing with regard to identification and resolution of each of these issues.

Inspections completed 1.

Instrumentation Adequacy Assessment 4

Johnson, Team Leader Prerequisites:

Fuel reload and 10 safety related system SP0Cs completed.

i IR 89-06, Inspection conducted January 30 - March 10,1989.

a.

Instrument accuracy b.

.Setpoint scaling c.

Material condition d.

Frequency of out-of-tolerance conditions e.

Sense line slope (installation).

f.

Operational parameter verification

.c

. Inspections Planned.

1.

Electrical Design Issue Closeout Audit / Inspection Marinos, Team Leader (3)

Prerequisites:

Final ampacity calculations complete Scheduled: December 4-8, 1989 a.

Cable ampacity b.

Diesel generator loading c.

Cable separation d.

Flex conduit L'

e.

Thermal overloads (SSFI identified problems)

I f.

Cable splices i

g.

Fuses l

h.

Cable and bus program (pending Watts Bar problem resolution)

L 1.

DC component rating l

j.

Breaker trip settings (subcategory Rpt. 26500, paragraph 4.2.7)

N.

ROUTINE ONSITE INSPECTIONS Issue Inspections were commenced in September 1988 to resume the routine 2515 inspection program at BFN. This is consistent with the reestablishment of the SALP process which began with the licensee's fuel load date of January 1, 1989 and enclosures on January 31, 1990.

a y

C-18 Inspections Planned Carpenter /RI staff 1.

MC 71707: Operational Safety Verification 2.

MC 71710: ESF Walkdown 3.

MC 61726: Monthly Surveillance Observation 4.

MC 62703: Monthly Maintenance Observation 5.

MC 71500: Balance of Plant 6.

MCs 92700, 92701,-92702: LERs, Followup, and Violations / Deviations 7.

MC 93702: Onsite Followup of Events at Operating Power Reactors 0.

VERTICAL SLICE TEAM INSPECTION Branch, Team Leader (12)

Prerequisites: Five identified systems fully returned to service for restart (90% of modifications complete).

Scheduled: Weeks of November 27 and December 11, 1989 Confirmatory inspection to ensure that TVA's improvement programs are being effectively implemented.

l 1.

Engineering review l

2.

Construction quality L

3.

Program implementation a.

System turnover L

b.

Maintenance /Q List / Piece Parts /EQ l

c.

Training / Procedures

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d.

Contractor recommendations l

e.

ECN control / drawings l

f.

Restart. tests P.

REGION II SUPPORT INSPECTIONS The following inspections have been conducted:

HP program: 85-27, 85-42,85-55l 86-10, 86-16, 86-18, 86-26, 86-29, 86-41, 87-28, 87-34, 88-10, 88-14, 88-23 EP program: 85-23, 86-01, 86-36, 87-18, 87-31, 88-26 EP exercise / organization: 85-52, 85-53, 86-32, 86-33, 87-39, 88-30 Security:

85-37, 85-46, 85-54, 86-13, 86-21, 86-31, 86-37, 86-44, 87-23, 87-35, 87-44, 88-01, 88-03, 88-20, 88-29 Security / regulatory effectiveness review team: 87-05, 87-23, 88-03 Security /NPP improvements: 87-17

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- q, 19 Inspections Conducted Remedial _ accountability drill (IR 88-34)

Remedial full scale drill (IR 89-14)

Inspections Planned 1.

Routine 2515 Modules Recommend appropriate RII DRS or DRSS section.

Prerequisites:

None Schedued: Ongoing / Unannounced a.

Health physics b.

Emergency preparedness c.

Security d.

Chemi stry 2.

Full Scale Emergency Exercise RII staff Prerequisites:

None Scheduled:

Nov. 1 - 2, 1989 (Note: Acceptable performance of an emergency exercise is required for restart - see IR 88-30)

Q.

ALLEGATION /0 PEN ITEM REVIEW FOR RESTART ADSP Staff Prerequisites: None Scheduled:

Ongoing (Refer to Browns Ferry 2 " Status of Restart Readiness" memorandum) i R.

PROCEDURE UPGRADES Issue Audits and inspections identified a number of deficiencies and weaknesses in procedures. A procedure upgrade program was implemented to address these problems. The near-term portion of the program focused on resolving deficiencies in the procedures which affect the safe restart, operation, and shutdown of the plant. Procedures that are not required for restart, operation, and shutdown will be upgraded as part of the long-term program.

The-program requires a review of procedures for technical content, administrative controls, regulatory requirements, and performability.

The NRC must develop confidence that the new procedures are appropriate to

the circumstances, contain appropriate quantitative or ' qualitative acceptance criteria for determining that the activity was satisfactorily

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20 accomplished.. and that activities can be accomplished in accordance with the instructions. The NRC must also concur with the scope of procedures selected for restart and agree to a schedule for the long-term program.

The NRC will additionally assess the potential. adverse impact on plant operations created by the large number of changes over the relatively short time period.

Inspections Conducted and Status The NRC has concurred with the scope of procedures included in the upgrade program with the exception of maintenance instructions.

This exception will be addressed in.the mairtenance inspection activities (see paragraph R ) ', A team inspection of the Emergency Operating Instructions (E0Is) was conducted in August 1988.

The following inspections have been conducted:

Ol's: 87-09, 87-27 SI's: 86-14, 87-14, 87-30, 88-02, 88-24 E0I's: 87-46,88-200 A01's: 87-27 Inspections Planned I.

Procedure Adequacy (Except E01s)

Programmatic closecut by letter dated January 3,1989.

Final team inspection is required, as stated in NRR' letter to TVA, January 3,

1989,

.NRR Prerequisites:

TVA certification that procedures are ready for startup.

Schedule:

March 5-9,1990 (proposed) a.

System engineer concept b.

SI validations c.

SI verification d.

Procedural compliance e.

Station Procedures 2.

E01s NRR Prerequisite: Address IR 88-200 Concerns Schedule: January 29 - February 5,1990 (Proposed)

S.

ANTICIPATED TRANSIENT WITHOUT SCRAM (ATWS)

Issue' 10 CFR 50.62 (ATWS Rule) was issued in July 1984 and includes modifica-tions in three areas: 1) recirculation pump trip (RPT), 2) standby liquid

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. Os 21 control (SLC), and 3) alternate rod injection (ARI). In October 1985, TVA submitted to the NRC its proposed solution and schedule for BFN. The TVA NPP Volume 3, in August 1986, committed BFN to implement the ATWS rule before Unit 2 restart.

Inspections Conducted and Status TVA submitted the detailed plant specific design criteria on July 15, 1988, following. submittals on conceptual design and several working level-meetings between the TVA and NRC staffs.

The staff's review was documented; in letters to TVA dated. January 22 and April 19, 1989.

Modifications of Unit 2 are in progress 1 The ATWS rule implementation was inspected during the Design Verification Team Inspection (IR 89-17 issued August 10,1989).

Inspections Planned ATWS Closeout Inspection (Part of MTI)

H. Li Prerequisites:

Completion of restart ATWS modifications.

IR 89-17 concerns and open items ready for closure-Schedule:

During MTI i

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22 II. INSPECTIONS COMPLETED A.

DESIGN BASELINE VERIFICATION PROGRAM (DBVP) AND DESIGN CALCULATIONS 3

REVIEWS j

Issue Questions were raised during a review conducted for TVA by Gilbert Commonwealth' in 1985 regarding the adequacy of the existing TVA design control process.

Examples included missing calculations, incomplete design documentation, and failure to update as-built drawings to reflect plant configuratinn.

TVA developed the DBVP to reestablish the-design 3

baseline for' BFN.

This. program includes:

1) establishing the plant configuration; 2) reconstructing the design basis; 3) reviewing and evaluating modifications; 4) defining and performing required tests to verify functionality of DBVP. systems; and 5) performing modifications developed from this program.

TVA instituted a review of essential design calculations to verify that the calculations existed and were adequate to support.the design of BFN.

.As a result of the calculation reviews, TVA estimated that a large number l

of calculations would not be retrievable. TVA initiated a review of the engineering calculations in the electrical, nuclear, mechanical, and civil L

areas.

1 l'

Inspections Conducted and Status The staff conducted a major team inspection-in October 1987 during which both programmatic and specific deficiencies were identified. The licensee L

responded to these concerns in April 1988. These responses were reviewed by an NRC team inspection.

The DBVP is considered to contain the essential elements needed to achieve its intended goals and objectives.

The design calculation. inspections have been integrated with those of the l

DBVP.

j The staff evaluation of the DBVP is near completion. Additional sampling of program implementation will be achieved during a vertical slice Safety

?

I System Functional Inspection -(SSFI) style inspection performed af ter fuel load.

The following inspections have been conducted:

DBVP/CCM: 86-25, 86-32, 87-02, 87-09, 87-14, 87-20, 87-37 DBVP team inspections:

87-36, 88-07, 89-07 Design control: 87-08, 88-04 Drawing control system training: 86-22

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23 Inspections Conducted in 1989

-1.

Followup DBVP Team Inspection Georgiev, Team Leader Prerequisites: Awaiting TVA readiness certification letter that.

calculations are 80%-90% complete for each class and type.

Calculation cross reference system 20*4-30*. complete.

Conducted: March 10, 1989 (IR 89-07 issued June 30,1989) a.

DBVP final inspection b.

AC/DC calculation deficiencies c.

DC component rating d.

Unverified assumptions for procedure / operator actions e.

Mechanical-calculations f.

Nuclear calculations g.

Civil / structural calculations h.

Sample of Control Drawings-1.

Sample ECNs 2.

Design Control Inspection Branch, Team Leader Prerequisites: Fuel load complete, ATWS modifications complete (ECN closecut), drawing control improvements in place,_ fuel load systems drawings _ complete, committed design control process fully implemented,-and EA audit complete.

Conducted: - May 22 - 26,1989 (IR 89-17 issued August 10,1989) a.

Assess design control process (MC 37700,37701,37702) b.

ECN backlog c.

FSAR condition d.

ATWS modifications (TI 2500/20) e.

Control room drawings B.

FUEL LOAD Issue The licensee loaded fuel in January 1989.

The major objective was to exercise operations personnel in establishing and maintaining system operability in order to begin the process of establishing the requisite operational attentiveness following an extended shutdown.

Inspections Conducted and Status Completed.

IR 88-36, 89-03, 89-04, 89-18.

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1 24 Inspections Completed 1.

SPOC Review Carpenter /RI Staff Prerequisites:

None 2.

Allegation /Open Item Review OSP staff Prerequisites:

None 3.

Operational Capability Assessment for Fuel Load - MC 60705 Carpenter /RI Staff

' Prerequisites:

None 4.

Fuel Load Inspections - MC 60710, 71715 RI staff /OSP Staff Prereq;isites:

Fuel load C.

WELDING p

Issue Concerns. were raised at the Watts Bar site regarding TVA's inspection practice and welding rod control program.

These concerns implicated the L

quality of weldments and the ability of.the welds to perform their l

function' at. BFN. TVA conducted a welding reassessment program at BFN in two basic phases.

Phase I is a review of the TVA welding program documents (i.e., design documents, policies, and procedures) to ensure L

-that the welding program correctly reflects TVA's licensing -commitments and regulatory requirements.

Phase II is the actual reinspection of selected welds. The results of. the inspection effort will be used to evaluated -the implementation of the written welding program.

The reinspection results of the sample welds also will be used to determine whether TVA's welding activities in the field meet the applicable code requirements end whether the welds are adequate for service.- During both of these phases, TVA will identify and categorize any deficiencies in the existing welding program, correct the problems, and implement changes to prevent recurrence.

Inspections Conducted and Status The welding programs at TVA are administered by a common project group.

The NRC has reviewed the Sequoyah program and found it acceptable.

Both Phase I and Phase II of the welding program have been submitted for BFN and were reviewed by the NRC staff.

An inspection of Phase I was l

performed in April 1987(87-17). and determined.that the necessary elements existed to' translate welding commitments into specifications' and drawings.

An inspection was performed of Phase II in May and June 1988 (88-13) and

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determined that welding was' adequately implemented and the corrective actions that resulted from the welding program evaluation appear adequate and, if properly implemented, should provide reasonable assurance that the quality of the welds at BFN would be adequately determined.

The following inspections have been conducted:

Welding team inspections: 87-19, 88-13 Welding program reviews: 86-27, 86-03, 87-14 U2 recire safe-ends & pipe replace.: 86-39, 87-01, 87-04, 87-11 U2 reactor vessel shroud access covers: 88-06, 88-15 NDE 86-03, 87-15, 87-16.

Reactor vessel nozzle welding: 86-23 U2 torus modifications: 86-34 U2 RCS pipe welding: 85-33 HPCI welding problems: 85-57 Inspections Planned Some aspects of welding are te be addressed in.the Vertical Slice Team Inspection.

No additional inspections are considered necessary.

D.

INTERGRANNULAR STRESS CORROSION CRACKING (IGSCC)

Issue IGSCC is evident to some degree in all three units. The IGSCC mitigation options are primarily replacement weld overlay, induction heating stress improvements (IHSI), and/or hydrogen water chemistry. IE bulletins 82-03 and 83-02 and generic letters 84-11 and 88-01 were issued by the NRC to address this problem.

Inspections Conducted and Status TVA submitted a response to GL 88-01 on August 1,1988.

TVA performed inspections of 100 percent of all accessible / susceptible welds in the recirculation, core spray, reactor water cleanup, and residual heat removal (RHR) systems for requirement's of IE8 83-02 in 1983. Unit 2 was inspected -to the requirements of GL 84-11 in 1985 (TI 2515/89).

IGSCC mitigation and repair measures on the recirculation and RHR piping implemented on Unit 2 include weld overlay, weld replacement, and welds with shallow cracks mitigated by IHSI.

IHSI was implemented on all susceptible welds that could be successfully treated.

TVA has replaced all 10 recirculation inlet safe ends and 2 jet pump instrumentation safe ends on Unit 2.

Replaced safe ends have received IHSI. In the course of material replacement, approximately 90 percent of the susceptible piping welds have been eliminated. Mitigation steps will be taken for Units 1 and 3 prior to restart from their current respective outages.

TVArecognizN'theimportanceofhydrogenwaterchemistryto'mitigatethe

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IGSCC problem and ' interface connections area being installed on Unit 2 this outage to allow mid-cycle introduction of hydrogen water chemistry.

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26 The NRC staff performed an onsite review of BFN's IGSCC mitigation program and was favorably impressed.

The staff has concluded that TVA is ade-quately addressing IGSCC at BFN. Weld inspections performed subsequent to the post-replacemnt IHSI of the Unit 2 safe ends are complete.

TVA is preparing a final response to GL 84-11 and GL 88-01.

The staff has provided its analysis by letters dated December 8 and 30, 1988. Based on additional cracks found in Unit 2, TVA is updating their response to GL 84-11 and 88-01.

On September 28,-1988 TVA submitted the Browns Ferry Microbiological 1y Induced Corrosion (MIC) Program. MIC has been detected at Browns Ferry I

with small random leaks occurring in high pressure fire protection and raw service water carbon steel piping, and ~ with MIC indications' in EECW piping. The indications in the EECW piping were considered acceptable by TVA for restart.

NRC is evaluating TVA's position and program for monitoring this problem.

The.following inspections have been conducted:

IEB 83-02: 86-03 Facility modifications: 87-30 MIC: 87-32, 87-33, 87-45 GL 88-01:

89-05 E.

EMPLOYEE CONCERNS PROGRAM (ECP)

-Issue l

Under the employee concern programs initiated at Watts Bar in 1985 more than 5800 employee concerns were identified.

Approximately 700 safety-related and non-safety-related concerns identified in the original ECp were applicable to BFN by direct reference or generic applicability.

TVA divided the Watts Bar concerns into 9 categories:

construction, engineering, operations, material control, welding, QA industrial safety, management and personnel, and harassment and intimidation (H&I).

Investigations and corrective actions for BFN are being documented and submitted by sub-category reports.

H&I concerns are being addressed separately by the TVA Inspector General. Both the Watts Bar program and the new ECPs were thoroughly evaluated and judged to be acceptable as part of the Sequoyah Unit 2 restart effort.

Inspection Conducted and Status Inspection activities on the new ECP have been completed.

The most recent inspection of the new ECP concluded that the program was adequately established and implemented on-site and acceptable for restart.

Additional sampling of the Watts Bar generic concerns is needed in order to assure that the corrective actions have achieved the desired impact.

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27 The following inspections have been conducted:

ECP:

86-40, 87-26, 87-30, 88-04 ECP team inspection:

88-22 Each subcategory report for the special Employee Concerns Task Group program will be assessed in an SER.

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ENCLOSURE 2 INSPECTIONS FOR WHICH COMMITMENTS EXIST A.I., Aisess Site Management and Organization Effectiveness, Resident Staff B.2., Assess Offsite Review Committee, Resident Staff j

C.1., Pre-Restart 79-02, 79-14 (Large Bore), J. Fair (3) i C.2., Followup Civi.1;Cale/ Seismic Design-Program, T. Cheng (2) 1 C.3., Field Inspection of Seismic Issues, RII MPS (1 or 2)

C.4., Seismic Program Follow-up, J. Fair, ADSP 1

D.2., Appendix R Closeout, R. Wescott, ADSP F.1., TS Implementation and Adequacy, C. Patterson (4)

H.I., Restart Test Review, Resident Staff H.2., Initial Criticality and Power Assention Testing Program, C. Patterson 4).1., Overall Staff Training (MC 41500), RII J

2., Operator Requalification Program, RII s

L.I., Performance Based MTI, RII M.1., Electrical Issues, Marinos (3) 0., Vertical Slice, Branch (12) p if'b N

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y ENCLOSURE 3 INSPECTIONS TO BE REQUESTED FROM NRR E.1., _ EQ Follow-up, NRR (5)

G.I., Procurement / Piece Parts Team, NRR (5) 1.1., Restart Readiness Team, 2 Team Members R.I., Procedure Adequacy; fj

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INSPECTIONS TO BE REQUESTED FROM REGION II i

B.1., QA Programmatic Team Inspection, 3 Team Members Needed D 1., Fire Protection Program - MC 64704, 1 Inspector E.1., EQ Follow-up, 1 Inspector to Participate on Team F.1., TS Implementation and Adequacy, 2 Team Members H.2., Initial-Criticality and Power Assention, 2 Inspectors for 4 Man Weeks Total H.3., ILRT Inspection,1 Inspector I.1., Restart Readiness Team Inspection, Team Leader and 2 Inspectors I.2., System Alignment, 2 Inspectors 0., Vertical Slice Team,1 Team Member i

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