ML20058C710

Response to Operational Readiness Review Phase Two Rept

ML20058C710
Person / Time
Site:	Browns Ferry
Issue date:	09/10/1990
From:	TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20058C708	List: ML20058C706 ML20058C710
References
NUDOCS 9011050013
Download: ML20058C710 (85)

Text

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EI M Rases VALLET AUTBORITT' EMLEAR 70ER BROWS FERRY WCLEAR PLANT i

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-RESPONSE TO i

i OPERATIONAL READINESS REVIEW I.

FRASE-TWO MPORT BROWN 8-FERRY UNIT TWO

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SEPTEMBER 10,.1990 l

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TABLE OP CONTENTS 1

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Aareures and Abbreviations............................................

2 A.

lasensistaat Attainment of Espected Standards of, Ezes11ence.......

5 5...Shutdeva from Power Operations to Cold Shutdeva................... 11 C.

Reselbt19 et ladestry Iaenes..................................... 13 D.

Assressive In-Depth Puresit of Toshaisal Isenes................... 18 B. Line Orsemisation/Trainias laterface.............................. 23 F.

Simulater Trainias................................................ 28 E.

Attenties to Operational Details.................................. 33 I. Preventive Maintenance......'...................................... 38 1

1.

Mh mtenance Work Praattees........................................ 41 J.

Maintenance Planning.............................................. 49 l-E.

Procedure Quality................................................. 53 i

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Chemical 8amplins and Analysis Proceduras.........................

60..

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Signatures /!aitials in Procedures.................................

64 N.

sameral Reployee Training......................................... 68 O.

Occupational Safety......................'......................... 70 l

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Appendix A........................................................ 79 i

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ActGEBBB AMD ARRRErIAT10am AtARA - Aa..ew As leasemably Aehievable ARI -

Amerissa Beelear lasurers ABIER' - Amerisaa Steiety of Neehemiaal Basincere

'A808

Ameilitant Shift Operatieas'8uperviser ADO,-

Assistaat Unit Operator SFR -

Breens Perry Noelear Plant Y ~8alanes of' Plant 90P

'8WR -

Boiling Wa'ter Reactor

'3W50'8-BeilingWAterReasterOwnereGroup

'CAQY ~ Conditien Adverse to Qaality 4

CI -

Chemical Instruction CED -

Control Rnd Driv's C8sc - Critical _ Systems, Structures, and Ceaponente BCC8 - Baergency Core Coeling Systen BCE -

Engineering Change Retite BCP -

Estimated Critical Positica

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e BPI -

Blectrical Preventive Eastruction EPRI - 31estric Power Researek lastitute 38F -

Engineered Safety Peature Fr -

Fiesal Year GB -

Seneral Flestris Company 90! -

Seneral Operating Instreetion '

505 -

!!ydras11e Centrol Unit EPCI - Righ Presosto Coolant Injection II -

' Inspection and Raforeament 0366W 2

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r AcRDEMB AED ARRRINIAT10E8 (Contitt:ed) 188CC - 1stergramalar Strese Correstea Cracking 15P0 - lastitute of Bealear Power Operations 8051 -

Neehaniaal Maintenasse lastreetism NPAC - Maintamaase Planalms and Centrol MR -

Natatsmance Request

• /A -

Be't' pplicable RR -

Realeiur Bagineering M ~

WE' lear Emperience Review a

51Cd Noaintent Change' RNRG - Realear Managers Review Group ERC -

Buclear Regulatory Ceeniesten 9

RSRB - Ruclear Safety Review leard NURRG - Nuclear Regulatory Caenission Regulation Ort -

Operating Experience Report ORR -

Operational Readinese Review 088& - Gesapational Safety and Realth Administration 081L - Operations 8estien lastructica Letter PM -

Preventive Maint aanse PIC -

Plant Manager Instreetten VHF -

Post Meistessace Testing R&DCOB-Radielegical Centrol BBP -

Radielegical Energency Plan RER -

Residual Beat Removal, BER8W - Residual Beat Removal Service Water R8C8 - Red Sequence Centrol System 0366W 3

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"'ACBGEMBR AED ARRRRFIAT10ER (Coatiated)

RVWL - Reacter Vessel Water Level RWE -

Red Worth Minimiser SC'1'-

Byetas Calibratten Eastruction 8887 - Site Direeter Standard Practice 83R -

Safety Realuaties Report 81 -

8sree111ames lastreetion SIL -

Servies Informaties Letter 80ER - Signifiaamt.0perating Bayerienee Report 808 -

Shift Operations Superviser SPAR - System Plant Acceptance Svaluatica SPDS - Safety Parameter Display System SP0C - System Preoperability checki,iat SQR -

8equoyah Rutlear Plant SEX -

Seures Ran8e Monitor 8R0 -

Senior Reacter Operator STA -

Shift Technical Adviser STD -

Standard T1 -

Teebaical lastrostion T901 - Tracking and Reporting of Open items TTA -

Tennessee Valler Aetherity 30 - -

Omit Operator O

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IncoEa1RTERT AuAIBERRT 07 XIPECTED STAERARDS Ga ERCELLEECE l

1.

Gaasass laceastetencies asisted in the degree to which high standards of escellence were being achieved.

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We believe the ORE taas's r%ervations esppert est posities that general improvements have been & in the sendset of operations and asintenanae activities. Our taak new is to establish a uniform standard of performanas for all site activities. The managensat and organisational streeteres are in place to sessagliah this seal. Bach of the items below will be monitored restinely by plant managensat to easste consistaat performance. Additionally, the BFR tread reports maaitor everall performance.

3.

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Sete shift. turnover meetings were esasseted very well with alsar, lose annetacaments and with participation encouraged. Others, while sevetias the required ash,ie.ets, did se in each a pro forma, low key mammer that a clear understandias of material presented was met assured.

REAP 0ESE/ACTIOR PLAB Tha importance of consistency is continually reinforced during each. Shift Operations Supervisor,(808) aceting. Turnover meetings were specifically addressed as an agenda item at the scheduled SOS a eths en April 20, 1990.

The Operations Management Observation Check program includes checklist items to ensore formally doeuneated periodic assessments of the shift turnover are condseted by Operations managers. A uniform level of consistemey is presently being noted through this program and by ether observattens by Operations management who restinely attend tunnevers. Addittenally, Operations managers who attend the shift turaeger meetings are providing prompt feedback directly to individual 808's when their performance warrants.

Operations ocasiders this action seaplete but will contiana with eteervationst and will address any.inconsisteneias which might develop with asisting staff er new perseenal who participate in turnovers.

Operations naa nata Ceaplete 0366W 5

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TECORRIRTEEr ATTAIERWfr GF EEPRCTED RTAEDARDS OF ExcILt2Ec2 (Contiaded) o

a. Baala (contianed) b.

performance of perseasel in the Shift Operations Supervisor (808) and Assistaat Shift Operations Supervisor (A808) positions during the stealator enereises indicated videly varying standards. More detail is provided in another concern (Item # F) on Simulator Traintag within this report. In smaral, those not assigned regular shift posittens were less rigorote than the regularly assigned arov.

nassenRR/Acr10s Pras Operattees has developed an instreetion identifying the responsibilities and standards for espected conduct of Operations personnel while la stealator trainias. This instruction has been reviewed by Operations perseenal who train on the stasiator beginning with the surrent training eyele (etarted J ae 85, 1990).

' Use of this instruction will m eure a consistant direction, and management maaitoring of performance will ensure a consistent

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Ramaannihla Graanimation Operations Dum Data Complete c.

Si;andards maint'ained in the Operations Support Center showed considerable variation. In some instances, review was minimal, e.g., the requirements for tagging were determined largely from the response of the maintenance personnel involved: Maintenance Requests (IGts) were closed without apparent review of post Maintenance Testing (79tt). In other cases, review of work scope, tagging, and possible impact on the plaat were thorough prior to authorising work.

HERPOMBR/ACTIOR PLAN The topie of proper standards will be revisited with the Shift Operatises Supervisors at each 808 aseting as well as with all management taaluding A808s at weekly staff meetings. Operations Support Cent.or activities were discussed at an 808 aseting to ensure that each 808 a derstands the standards in this important worti area and to idatify any obstacles which prevent consistent implementaties from oseurring. Additionally, we have upgraded the qualification of OSC perseenei and have increased annagement eversight of ' heir activities.

t A standardised tagout method for repetitive maintenames activities is scheduled to be developed following the next upgrade,of the MPAC work control system.

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pCOMISTEHf ATTAI!MtHT OF REPRCTED STAERARDS OF RECELLEBCE (ContiEued)

a. mania (Continued) e.

(Continued)

Refer also to the discussion in the response to Concera J of this report eencerning tapteestation of the new maintenanee planning and work esatrol process.

Rameannihla Semaalaation Operations BBA.Ji&&g Casplete d.

Considerable variaties was asted in the quality of instruction in elacaroom trainias periods. While only a few classes were maatteres, m 4rmance varied fron'estellent preparation and

' presentation to a mediocre grasp of the subject and routine.

.folleving of the lessoa plan. In one instance, the instructor was se unfamiliar with the subject that he could not answer trainess' questions.

ERREERRlA210R_RLAR In one of the classes observed by the ORR team, a relatively new instructor was teaching "lessoas learned" from a Sequoyah event and had diffleulty responding to detailed questions related to Sequoyah systeam. Considerationlaad been given to usins a Sequoyah instructor for this type of presentation, but was not considered feasible for a two-hour lecture once a weak for six weeks. :This is not a typical case.

To ensure consistently good instruction, inst;uctors are evaluated by major sanual evaluations, frequ a t walk-in evaluations, and student / instructor evaluations.

Operations managassat routinely audits elassroom presentations and instreeter perfonnease, and provides feedback to Training in accordamse with Bealear Trainias lastruction NT 3.920, " Instructor Trainias." The frequaner of these audits has been increased to ensure at least two audits per week.

Raananalbia Ormanimatlan Trainias BBS B&18 Casoing e.

Response by members of management to industrial safety concerns, in ose case, was the statement awe dea't come under [0ccupational Safety and Realth Administration] 085&," as opposed to others expressing concern for providing a safe worker environment.

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reconstaTzar AnArmatar or marmerrn stAnnaans or macrLt.naca (contiamed) 2.

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(Coatimmed)

RR270 ERR /ACTIOB PLAR Ris item is disenssed ta'the response t,e sensern 0, u.ais item 1.

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Se Operations llamac%t Observatica sheek program regstres two observattens per week by am *hift.eparations ammagers. Only ese had been performed la the past te se months. Nest of the observattens required of co-ahift a.,wers (508/A808) have been performed. While many of the observed ens performed included meanlagful eraments, sees appeared espetficial.

BRSPOEER/ACTIb.M M e Operations Remagement Observaties Check 3,togram has been inacasistently implement'ed in resent osaths. la order to help.,

ensure senststenay, this program has been proceduralised as sa Operations Section lastreetion Letter. This provided the mesessary guidanse as to the frequency of the observatica and the.

items to be shocked. It also indicates responsibilities for implemiaMti~siii'and administraties of the program. The prostra has recently been revised and given mov emphasis. Non-shift Operations management personnel are scheduled for two o% ervation checklista per week. The checklists are being performed with a high degree of regularity. This program is. periodically reviewed to, ensure that appropriate areas of concern are being stressed.

Additionally, the Operations Superintendent reviews and signs all observatica cheek sheets.

Hannonalbla Ormastination Operations Daa_BAta Ceaplete s.

During asiatenance en a reactor feedwater turbine, internal parts were left unaevered and disassembled parts were saattered on the fleer. On the other hand, the Bish pressure Coolant Injection (EpC1) pump turbine, whiek was left ta a disassembled state while avattias parte delivery, bad all esposed parts wrapped and protested.

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IEc0EsisTErr Au AimetET OF EIPICTED STAEniRDS on R CELLIECE (ContinuCd) 2.

Rania (Continued)

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s. (Continued) l IISPOBRE/ ACTION PLAN i

At the time of the Ott evaluaties, the Turbe 4enerator coordinator and the maintenance foreman learned of this esacera and performed as assessment. The feedwater pump work was judged as not being up l

to eart et asistamaase standards. The parts es, the floor were reorganised and all feedwater supeoed parts were eevered at the and of eaak shift to keep parts alcan.

The foreman involved and his general foreman have been conselled sombernias proper ways to store and handle disassembled equipment and e tts. They were aise reminded that 30F equipment and s

disassembled parts are stored and handled with the same care as safety-telated items.,. -

l A asiat'emaase' Peer tval'estion program was developed and

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implemented for trial use sa May 1, 1990 with full implementstion en June 15, 1990. This program is na#,or the direction et the Maintensase Producties Manager. The program is beir4 used to defiat clear sad concise standards of workmanship and work quality, and is also used as a learning tool to further promote high standards of excellence.

The maintenance Peer Evaluation Program has been field tested and the program itself is acceptable. Corporate Ruclear Maintenance l

will provide assistance to conduct individual field evaluations using the tyN program. These individuals will hold immediate j

l follow-up meetings with foremen, general foremen, and craftsmen to L

review performance and suggest improvements. A similar approach i

was used to review maintanar.ce documentation and was very i

effective in improving the quality.

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l Eaamannibla Ormanization Maintoaanse RRL2418 Detsber 15, 1990 h.

While the dictate to follow procedures was well known and followed generally, there were still instances of non-compliance.'

EISPOERE/ ACTION PLAR procedural sempliance has been and will contians to be emphasised throughout all aspects of operations and work processes. Various-tr.end reports indicate this message is being embraced by site personnel. The thresaold for incidents has been lowered using the category four incident investigation report. Personnel. errors are also being routinely monitored using the Personnel Error Monthly i

Evaluation Report.

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IMfXatt11TEtt! AiTAIIAWrf 0F EEPtcTED RTANDARDE OF EE1LLENCE (Continued) 2.

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These actions have been effective in reducing the rate of pereoanel error and alto provide a mechanian to flag to management areas needing further attention.

1.

During observation of a Radiological Emergency planning Training Drill, the team seted training benefit was only obtained when the

- Plant Manager was present. Be was the only manager or drill observer present who provided constructive criticism and n

coaching. When the Plant Manager lef t the control room, overall performance declined (e.g., ceam a ications, command and control) and critician/ coaching was met given.

'Etapograt/AcTfdN PIM Drill. controllers and.nsna m t observers.have been instrueted to provide on-the-spot performance feedback to drill participants during training drills. A number of drill have been conducted since t.his concers was identified. Performance has improved substantially as seted by the Nuclear Managers Review Group in their review of this concors during August 1990.

Rannonsible Orennimation Radiological Emergency Preparedness Dum Data l

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.o 30 Ruurn0Ws rnost Pmma GPERATICBR TO COLD REDTDOWB 1.

Canaam The plant procedure for unit shutdeva and see1down places the unit in a esadities requiring very careful operator actica to ensure the reaeter remains shutdeva during plaat tooldova. Industry experience indicates that events distracting the operators during such a ahutdown seald result La sa inadvertent eritisality.

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Tbs procedure for plant skateewa/aeoideva (901-100-12A) has been' revised to eliminate a reactor aaram from about 30 percent power as the normal means of plant abstdeva. This abange was ande to reduce the anaber of screas and associated transients.

b.

The procedure requires aermal abstdeva by fully inserting all sentrol rods per a red program which requires match inserties of many reds.- Oeeldova, up to 70*F/bre is permitted to start as seen as the reaeter is subaritical. A precaution is included to coordinate the eseldova with red insertion to prevent inadvertent criticality.

c.

The lastitute of peelear power Operattens (INFO) has identified an incident at a Boiling Water Roseter (SWs) in which an inadvertent criticality occurred while tenducting such a shutdown. INP0 noted the diffleulty in balancing the effects of rod insertion, heat removsi, decay heat generation and menon poisoning in this condition.

112P0ERE/ACT10B PLAR (Basis items a - e)

Operations management has reviewed the Limerick event as diseuesed in INF0 Operating Bapartense Report 03-3148 and INPC Case Study 49-007 as related to the plant shutdown procedures (2-001-100-12A and 2-401-100-12C). It has been concluded that forced coeldova of the reaster should met begin until all control

= rods have been inserted. The procedures will be changed to refleet this decistaa.

Raamannihla Drammination Operattens DBLBd&g 8eptember 30, 1970 t

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amurnown FRem rmata eranAripqq re coLn snornown (csati m d) 2.

Saala (contimmed) d d.

Adeguate trainias of operators for such a shutdown any be difficult as INp0 acted that the simulater for the plant discussed above could not duplicate the event. The current RFN restart trainias progres does met Lacande sianlater training for such a i

abetdown.

j e.

The plant shutdeva/seoideva seguense abound provide adequate margia against inadvertent aritisality without undue operater 4

burden. Startup staalater tratatag should address this evolution.

RESPOIRE/ACTIoM FLAN (Basis items 4 and e)

As stated in the reopease to items a - e above, the precedure will be revised to specify that forced eeeldewn abeuld met begin until all esatrol.rede:are inserted. This eliminates the need for inserporating'the above mentioned shutdeva mothed inte restart trainias er..the sionister.

l Initial startup training for the licensed operaters has just been sempleted for a sia-week cycle. Dorias this cycle, the simulater esercises.iavelved startup from a cold, aanen-free, saberitical eendition through cleeure of the generater breaker.

Aft'r.br.eaker e

closure, some of the planned startup tests were also performed to

, familiarize the operators with the power ascension tests. Another six-week cycle is currently scheduled on the simulator to perform additional startups, tests, etc., prior to unit 2 startup.

Rannonsible oraanimation Operations-Dua Date l

December 4, 1990 l

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C6 3ps01M IGE OF IEDtt3TRY Itamts

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cantara Evaluation of industry-wide technical issues for applicability to BFN, in same instances, had met been eenducted in sufficient depth.

taanname simmarr The review of technical issues affecting the' plant was previously divided between teehaital support engineering and asiatemance

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ensiaeers. This tended to rednes the effectiveness of technical reviews ' sines everall responsibility was met always clear and techniaal espertise was in differ et ersemisations. This asiatenance engineering funstion has be m transferred to technical services thm consolidating technical kasvledge and review accontability within a single organisaties, The development and implementation of the systen ergineering organisatten'is providing a e ntralised organisational basis with the skills and knowledge assessary to meure a detailed "O teshaical assessment of past and mew technical' issues. *

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..w The ORE Team anderses the use of.gaaerie-approaches to issues developed by evners groups, and' ether organisations as part of a systematic evaluaties of technical issues. Bowever, the following examples indicated that.SFN any be too willing to accept generic t

l solutions without independant challenge and critical reviews a.

The Nuclear Regulatory Commissica (NRC) IE Bulletin 88-04, Evtantial Safety-Related pump Lose, requested licensees to investigate and correct, as applicable, two miniflow desita concerns. The first concern involved the potential for the dead-heading of one or more peps in safety-related systems that

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have a miniflow line common to two or more pumps or other piping configurations that do not preclude pump-to-pump interaction during miniflow operation. The sacer.d concerned the adequacy of

.the installed siaiflow capacity fC a single pump in operation.

The original RFR evaluaties of these concerns appeared limited.

Specifically (1) yor the Residual Beat Renewal (RIR) and Core Spray pumps, the TVA reopease indicated.tha': adverse pasp-to-pump interactions would set be espected. This comalusion was apparently based en a generie review by Geeral Electric Campany (GB).

Bowever, as evidensed Ff differences in susceptibility to this problem betwesh the two Sequoyah Noelear plant unita due '

to ladividual pray flow charseteristica, ette specific evaluations appear necessary. Unit specific calculations were not on file and the Ott Teen could not confirm their esistense.

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masaturros or umnstar rast44 (Contin ed) l 2.

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(Continued)

(2) The bu11stia also required licensees to evaluate the adequacy of the mini - pump flow during miniflow operation. The bulletia indicated that miniflow lines have traditionally been designed for 5 percent to 15'p'ercent of p ep design flow and that some ymp nanatacturers gav are advising that pumps ehem14 have assim e flow espasities of 25 pers et er more for

.estended operattom to protest against hydraulic instability or impeller retiresistian problems. For RFN, RER and Core Spray simitieve of about 6 percent and 10 percent respectively were calculated. The file did met contain i

vender agreensat with the acceptability of these flow rates and the time spent in the miniflow mode.

The 038 Team acted that ainaltaneously.and independently, the SFN j

Noelear Ruperience Review group had requested a reevaluation of I'

the SFR response to the bulletia in the. light of the Sequoyah experience.

RRSPbERE/ACTroEPLAN o

i As a general policy we believe an active, involvement with vendors and owners groups is healthy and beneficial for TVA. We agree, however, that results and conclusions based on external evaluations must be carefully assessed for applicability to Browns Ferry's configurations and systems.

Corporate as well as site personnel worked tesether in preparing the BFN response to II Bulletin 88-04. The BFN response was based both on the results of the Boiling Water Reactor Owners Group (BWROG) Interia Response te Bulletin 88-04 and an assessment of the applicability to our individual plant configuration. The

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BWR00 report was prepared by' General Electric (GI.).

8FN participated in the SWR 04 effort and had input into the report.

The WWB0G report. concluded that for pump, configurations where two pump's mint=== flow 11 ass eenverse into one line.that is t

osatrolled by a single valve, if the pump characteristice were such that a relatively small shaase in discharge pressure resulted la a large ebense in flow, there is potential to deadhead the pump with the lower shutoff head. It aise eeneluded that for esses where the individual 11 ass are orificed, and.the pressure drop in the commen line devastream is a small part of the overall tydraulia resistance, there abould be little p ep-to-pep interaction. Brevas Ferry's RER and Core Spray Systems minimum flow lines are individually orificed and the miniflow bypass salonistions show that the line losses in the common downstream line are a small part of the overall hydraulic resistance. This war, stated in the plant' specific information section o't the response to NRC Sulletin 88-04.

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The RER problem that escurred at Sequoyah Nuclear Plant was the result.

of their plant specific esafiguraties. The minime flow lines at SQN l

are two independent ase-orifteed miniflev liase with separate control valves that tie into the eresstied susties lines for the RER pumps.

This is aestrasted to the desism at 3F5 skish sensists of individual tightly orificed liams that discharge to a single line returatag to the l

terne. Bad the NWROS ganaria response bem applied to the SQN i

eenfiguraties, the sensinstem would met have precluded the need for spesific saiculattens to evaluate the potential for deadhgading an RER pump. As noted is the Ott report, the site determined that, in light of the SQN problem that the issue abould be reevaluated by Noelear Engineering for RFN. The taleek by Nuclear Engineering included a l

review of the SQN lacid et lavestigatica 49-097, seasideration of various low flow scenaries, review of SFN and SQN reopeases to 13 Bulletia 84-04, and review of the SFN Operating lastructions for the l

RER and Core Spray systems. Results of the releek did not. indicate any reases to change the BFN position sa NRC Bulletin 84-04. The review.

l did recommand, however, that Systems Bagineering evaluate the Operating ;I and Surveillance Instructions for the Core Spray systen to ceafirm that; low flow operations restrictions asseunt for 1rdividual pump characteristice. This review has bem completed and it has been l

determined me adverse pop interactions are anticipated. This L

evaluation was based on the operating and surveillance instructions, the individual pump characteristics, and anticipated plant operating conditions. This response has been forwarded to the Nuclear Experience-Review group and subsequently subaltted to the corporate NER l

organisation as an updated reopease en July 2,1990. (reference RIMS RIO 900702 963).

NRC Bulletin 88-04 also raised an' issue about the adequacy of the existing. design miniflow path flow rates. The basis for this concern was that the miniflev discharges were designed at 5 percent to 15 percent of rated pump flew based on pump heating considerations, and that pump asaufacturers were mov reconnending minimum flows of 25 percent to 35 percent based en flev separation er hydraulic-l' instabilities. ylev sepagaties er hydraulic instabilities due to L

inadequate minism flow eesid cause abalanced leadias and vibration L

loading to eseessive wear and resultant shortened pump life. The BWROG; l

report stated operating and asiatenance history for BWR plaats indicated that, for the type of service experience for the RER and Core:

o Spray pumps, low flew or deadheaded operaties has had no detectable affect en pump availability. The BW.100 also searched the Nuc1' ear Plant i Reliability Data Systen history filesi and found no cases of pump i

failure or degradaties below requirst espacity that could be attributed to low flev er deadheading of safety related pumps. Addittenally,

====i== tion of pumps during asistsam se inspections aft,ar neraal 0366W 15 l

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anAOLtf?IOR OF JRTRY ftatrtA (Continued) i i

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Basia (Continued) i 1

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(Continued) operatias histories and for esses where p eps had been inadvertently i

re deadheaded for proleased periods had similarly not uncovered any L

indicaties of eseessive wear. This empertense base imeludes at least i

one case at the Fermi Nuclear plant ukere en RER pep was inadvertentlyj l-operated deadheaded for one and one half hours because of a spurious 1

isolaties. At SFM RER* pumps had been disassembled for wear ring 1

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modifications and replaeament durias this outage and indications of the type of wear discussed in ERC Ba11stia 48-04 were met ebeerved. A i

l represatative of the pump vender has also inspected RER pop impe11ers and indicated that wear patterns are characteristic of normal expected usage Flev separatten and hydraulis lastabilities would result in the gradual degradaties of pop performenee. m basis for the vendor receanended j

increased miniflow rates.is an asemed camalative time spent in ~

i alatflow mode. For, this,reassa they reconnend a flow rate of at least i L 35 to 40 percent for esatianees operaties and 25 to 30 percent for L

intermitt et operaties in the staisua flow mode. Intermittent operaties is defined as less them two hours of minimum flew operation

(

in any 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. N total time the safety related pumps will operate j y

in minimum flow mode over.the life of the BWR plant, as given in the response, is at the'very most one percent of the time given by the pump i,

manufacturers for intermittent operation. The ASME 8ection KI. testing.

l program would also detect degradation of pump performance due to any reason well before any affect on the pumps ability to meet its safety !

fumation.

Rannonsible Ormanization l:

System Engineering l

Due Data Complete b.

Questions senseratag the cesservatism of the plant shutdown /cooldova procedure are discussed ta easther consera (Item # B) within this report. These questions arose from review of an industry event, reported by 15p0, in uhlah a WWE superimeed an inadvertent I

l' criticality using a similar procedure. m TVA review of this nuclear suportemos its was limited to the minimum required to address the specific defiel estes initially reported by INp0 at the other utility.

(i.e., trainias em the procedure, definitica of esatrol room reopensibilities, sismiator fidelity).

Initiative was ast taken to questies the ' prudence of using a abatdeum/cooldova sequence ukish seald place undue burden on the operators. m review of staalater fidelity' also appeared limited to assessing the ability to simulate a positive reactivity' addition, rather than verifying the ability to simulate actual plant response L

during such an event.

L 0366W 16

.-...-.~.---.--..-- -

d p

j C.

$11012110E AF_.1ERATRY 112H12, (Conti :::ed) i 2.

Baaia (Contianed) l b.

(Continued) kRaltEAX/ ACTION FIAR BFR did met initially recosaise the sisaiticance of this INP0 item.

Discussions htween RFN Techsteal Support and the Nuclear Fuel ersamisatten have subsequently takaa place to identify the best way to j

resolve the issue. Three alternative akutdown methods discussed were:

1.

Prohibiting reacter teoldown u til all control rods are inserted.

2.

Specifyias the cooldown rate as a function of control rod density se that soberiti'eality is assured.

I 3.'

Manually seramias the reacter at a specified power leve1 or~after )

saberiticality is achieved (prior to reactor cooldova).-

Option 3 is the simplest and most'expeditione way of shuttias down' -.

l Its chief drawback is increastas the transient duty cycle en the' vessel; from the seren. Option 2 is the most complex and has the most pitfallsi related to increased asaltorias requirements and calculational i

dependenetes. Option 1 was considered the best path considerias'

)

complexity and minimising reactor fatigue cycles and will be adopted for routine shutdowns as previously indicated in the response to ites B' of this report.

The axistias simulator core model would need a considerable upgrade to adequately model a complex shutdown sequence. The basic principles of reactivity monitorias either for startup or shutdown are similar and, webelievetheesistiassimulaterandtrainiasprogram,particularlyas{'

aussented by the lessoa plans related to the industry criticality l

events provided by INPO, does a good job of preparias operators for the!

vast majority of anticipated plant situations. The simulator upgrade project does include better core models and will improve fidelity of the sinalation eseraises in this regard.

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l 0366W 17 l

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So W "#ttfvt IE ft#WTR ptfnetffe CF verumfrat. TEttfte 1.' caneara Technical issues had met always been evaluated in sufficient depth or aggressively pursued to completion.

3 kammenae Simmarv The review of technical issues affecting the' plant was previously L

divided between technical support

,ineering and asistaansee engineers. This tended to reduee the effectivanass of technical-reviews staae everall responsibility was met always tiear and technical espertise was la differet ersamis.tions. This maintenance engineering functies has bem transferred to technical services thus consolidating technical knowledge and review accentability withir. a single organisaties. The develepasst and implementstica of the system e sineering organisation is providing a sentralised organisational i

basis with the skills and knowledge necessary to ensure a detailed technical ~ assessment of past and asw technical iss' ass. Additionally, this provides a teames point to soordinate and to followup en laplementation of corrective actions.

.. :n.

2.

Basia

]

a.

The June 1989 Ott Report previously identified a concern that

. vendor recommendations were not implemented in a timely manner.

l-An example given was GB Service Information Letter (SIL) 419, a

" Category 1" 81L issued in August 1985 (A Category 1 is defined by GE as an item "that could have an early impact on BWR plant L

availability, reliability, or safe operation"). This SIL recommends the inspection of certain oae-inch Bancock gate valves

~

in the Bydraulie Control Units (BCU). ByN intends to perform the inspection prior to restart. The work was scheduled to be perferned concurrently with the scram diaphrass replacement. Work on the west bank ECU's was started on August 28, 1989, but no inspections of the. subject valves had been made to yebruary 1990.

The ORE Tean'was told the inspections were being postponed to be performed while working the east bank, because of lack of parts.

Zaplementation of this SIL has been delayiwi for over four years.

Continued failure to aggressively pursue this potential safety-related issue seald impact restart schedules, especially if taspection results increase the scope beyond that currently r

anticipated.

1 P

9 0366W 18

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AmsttaaIVE 15-udPTE 7titatf1T OF TECERICAL IS2tMS (Crcti=ed) 3 '. Baaia (Continued) a.

(Continued) masPOEst/ ACTION PLAR pellowing issuance of $1L 419, SFN revised maintenance pirocedure i

Ist!-28,"Centrol Red Drive Rrdraulie Centtel Unit Module - Repair and I

Replassment" to inspect the valves as modules were removed for scheduled antatensaae. This was in sempliance with the samediate recenseadations of the SIL. A lens ters ressamondation was made to seasider replacing the gate valve wedges with a material less susceptible to 1GSCC.s la response to the subject Ott eencern in 1989, SFN committed to; perform taspection of the isolation valves en 20 percent of the unit 2 500 istor to startup. State then, all of the 85-417 valves have been hspected. Twenty-five percent had wedges which exhibited cracking. These. wedges have besa replaced.

~,

[ This valve inspectica required that an adequate supply of spare parts

..-, be available to eenpensate.for the possibility of have a part break during the inspection that would require a long system outage..This would result in being unable to stroke rods for an extended per.iod of time. procurement Request 8906450 was issued by plant asiatenance on 4

Jsly 28,-1939 for replaeement parts for the valves. With expedition, the order was issued to GB en October 5, 1989. TVA tried to further 1

expedite the order from GI without success. The last of the spare parts were shipped from GE in the middle of March 1990. Velays in I

issuing a' purchase requisition and supply problems were due to difficulties in obtainias'a supplier who could supply wedges that,,

were not susceptible to IG8CC. Only one company, General Electric, would supply upgraded wedges of a new design and material that should preclude tracking.

l The Nuclear Ruperience Review progran ensures the review and tracking of 81L's. Escalation provisions and periodic reporting to management provides a means to monitor timely dispositioning of review items and to flag areas needing attention.

As discussed in the ORE phase One report, GI was contracted t'o provide what is kasus as the GB Systen Rev w as part of the Regulate 7 perforemace Improvement pisa. This review, in part, consisted of a review of SILs on 22 primary systems including reactivity control, BCC3/RCIC, and the pCIS systems.,

h 9

0366W 19

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Do AGERESSfYR IE-hEPTR PtfRatfIT OF TECREICAL ISX!!ES (Contitu:d) 3.

Aaala (Coattated) a.

(Continued)

A commitment to disposition GB System Review recommendations became a part of Volume III of the Nuclear Performance Plaa. System engineers reviewed and disposittooed these reeaMations which included 81La,,

on their assigned systems. These dispos'itioned items were then subsegmently presented, reviewed, and approved by a System Bagineering Review Board and PORC.

Addittomally, ia early 1989, a separate review was conducted for all GB SILs issued after 1984. This review was conducted for the purpose of ensuring the response was adequate and that any identified action items are being tracked thronsh implementation.

Reagangihla_Qrnamizatina Maintenance Daa lata Complete b.

Incident investigation report 89-93, Low Scram Pilot Air Reader Pressure Scram en 12/6/89 eaused by a failed solder connection, described a failure (separation) of an one-half inch solder joint.

The report noted that maintenance history revealed nine previous

" broken" connections associated with the control air system at Brwns Ferry. While the investigation report appeared thorough, a discussion with a cognizant metallurgist indicated t3at the joint solder. wetted area appeared to have complete bond. Metallurgical and chemical analyses of the solder and piping were not done to determine if the flua, solder c'.astituents'or any impurities in the bonding may have contributed to the failure.. A more thorough analysis may have indicated the cause of this recurring failure.

M As_part of the referenced incident investigation, analytic assistance was provided by the Weslear Engineering Materials Group. The.

tests /anaminations perfereed were based upon their own expertise and

• asterial observations, and were assepted by the plant as a reasonable approach. We agree that the solder /fluz characteristics could have been formally analysed to eslo est certain potential failure mode contributors. The failed parts were discarded after the investigation so we cannot explore this avenue in arrears.

4 e

4 0366W 20

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9.

AARRRAAIVE IENutPTR PmtSUTT OF TRCENICAL IRAURS '(Coatiased) 3.

Baala (Coatianed) b.

(Continued)

RESPORRR/ACTIQB PLAN (Continued)

The centrol air system at BFR was designed and built utilising sepper tubing with soldered joints. Fluk and solder used at Bilt are boesht to the sans specifications which allev for use on both safety and non-safety etapanants. The quality of the fabrication materials was tkBs aet eensidered a Tatiable. The original quality assuranse inspections and arattamen qualifications were typteally act as rigorous during initial asastruction as they cre today..laproper work technique during original construction was concluded to be the root cause as identified in the event report.

During a recent ostage of the seram air header, it was leak ahecked and all identified leaks repaired. Sheuld similar problems in this area resecur, we will espand the cause determinaties. Maintamance Reebniques related to this system and problem will aise be reviewed for adequacy.

Raamanaihla Ormanimation Maintenance Daa Data September 28, 1990 c.

Although the NRC II Bulletin 88-04 concern.

fety-relatid pumps (see itea C. of this report), it is not appasant that a review of Balance of Plant systems where dual pump operation is possible has been made er an evaluation of miniflo? adequacy has been made or planned.

RESPQRSE/ACTIDR.PLiB The miniflow arrangement discussed in IB Bulletin 88-04 is not a standard arrangement used for industrial applications and typical pump configurations. Its use at Boiling Water plaats is limited to low pressure core injecties type systems and there is an engineering basis for this particular application.

t 9

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D.

AGRE52AIVE IR.2utPTR PMtStf1T OF TECENICAL 112tfES (C;ctiged) i

2.. Ragia (Centinsed) i e.

(Continued) i I

The Systems Engineering Section has reviewed the other pump 6.afigurations on the various piping systems met addressed by TVA's response to EtC Dalletia 88-04..In the few instances d ere aisimum flow lines are installed, asse are configured with common i

ainimum flow piping shared by parallel peps.

We agree that safety issues raised by NBC er internally by TVA should be evaluated for falt *--,em Brovas Ferry. Non-safety systems are obviously import asintainiad high plant reliability and uncorrected y..ans can likewise involve significant capital risks.

d.

In a menoread s on May 25, 1989, the ORR Team provided detailed sessants that resulted from perfornias a partial simulator validation.ef the startup preeedure, 2-401-100. Amons other comments, the ORE Team identified a conflict in the plant conditions at which the Immediate Raase and Averase power Range Monitors overlap is verified per a Surveillance Instruction ($1).

(The G01 and SI specified inconsistent power levels.) The ORE Team also noted that resolution of this conflict must consider the

)

need to assure proper average power raase monitor function prior to enterias a mode in which intermediate ranse monitor scram functions are defeated. This comment has yet to be resolved. The conflict still exists and trainias is being conducted despite the disparity.

RESPONSE / ACTION PLAN Although the May 25, 1989, memorandum was overlooked in error and as formal review assignment was made, the Operations Department was aware of. the memorande comments and was in the process of addressing them. A formal assiganaat was subsequently made for ji Operations to address each specific comment. The particular discrepancy etted in this esmeers as well as reveral other 1

e specific comments have been resolved by a revision to i

2-001-100-1A. Other items are edergoing further evaluation. The L

Operations training group will be notified of the resolution results and will insure operator trainias has been updated as necessary prior to Unit 2 power ascension. please refer to the response to Concern B for additional infomation on Operations management involvement in simulator enereises.

[.

Ramaannihla Graanimation L

Operations Das Data September 15, 1990 0366W 22 l

b.

..... _ _. _, - ~.. _ _ _ _ _ _.. _ _, _ _ _ _ _ _ _ _. _. _,

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pnI Onam1AT10E/TlimM INTERFACI 1.

Agafsa Training effectiveness was being impacted by defleiencies in the communication among line organisations and training, and the lack of timely support for training activities.

Ramaanan gunmarv goveral steps as described below are being takaa to improve Training's involvement is plant' activities and to improve sammunications between organisations. Management expectations and participative roles are being formalised. For example, the Training Manager now functionally 4

reports directly to the plant Manager. This ensures that Training is a

routinely involved in plant affairs and provides an active interface with key plant organisations. INp0 esaments during the recent accreditation visit' vere positive concerning Training's interface with other line organisations.

i.ny.,3 e.

. w. n

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2.

Agaia s.

A decision to eliminate the use of Keft vs rod position curves i

from the startup procedure ami to implement the use of criticality

~11mit guidelines was not esauspicated to Training.

MRSPONSE/ ACTION PLAN A meeting was held between BWR F'Je1 Engineering and Reactor Engineering on March 29; 1990. Training participated in *his meeting which addressed the specific misunderstanding about the Kaff vs rod position curves and the use of criticality limit

~!

guidelines. A representative from both BWR Fuel Engineering and teactor Engineering will also participate in the startup training for Licensed Operator Requalification. Training will continue to i

4 participate in meetings between BWR Fuel Engineering and Reactor Engineering throughout startup preparation activities.

I Rannonsible Graanimation Training / Fuel Engineering / Reactor Engineering RBs DA13 Ongoing (through startup) j b.

Training and Operations plans for the incorporation of the interia safety parameter Display System into the stamistor were inconsistent.

0366W 23 L

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LIER ORGANIZATwB/TRAINIBG prrpFACE (Conti m uj 2.

Agais (Continued) b.

(Continued)

P2POESE/ ACTION PLAN A meeting was held between Operations and Operations Training on l

March 28, 1990 to ensure that plans for interia SPD8 use and I

associated training needs were esamealy understood. A stand-alone l,

personal computer versica SPDS work station was installed in the trainias center and was initially used to train operators. The SPDS will be fully integrated into the simulator prior to startup. Appropriate 01's, license training plans, and roqualification traid as piens related to SPDS usage have been developed and will be implemented prior to startup.

l Ramaannibla Ormanimation i

l Operator Trainias/ Simulator Services 1

EELE&ta I

December 10, 1990 i

c.

Revised reactor vessel water level curves needed to support training on the modified system had not been prepared by Nuclear Engineering.(NE). The training is in progress. Senior NE management was not aware of the critical need for this information.

RESPONSE / ACTION PLAN l

Operations Training and simulator Services are aggressively

)

pursuing these water level curves with NE task engineers for ECN-P7131. The problem has been escalated to senior NE management

(

concerning the critical need for this information to support pending training exercises. A meeting was also held with NE l

management on' February 13, 1990 to discuse overall Training needs

~

for the Simulator Upgrade Project.

]

Reasonalble Ormanimation Nuclear Engineering EELD&ta October 1, 1990 d.

Resolution of some rod worth minimiser parameters was not completed in time to support initiation of startup training.

RESPOERE/ ACTION PLAN Reactor Engineering is currently performing software testing on the tod Worth Minimiser (ItRI) package to verify that the software

'l l

will perform in~accordance with vendor requirements. :This testing l.

will identify any discrepancies in the IWM. Following system L

debugging, details on the operation of this new package will be taught in Licensed Operator Requalification.

0366W 24 l

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B.

LIRE ORGARIELT m IffREFACI (Conti2OOW 8.

Bagia (Continued) d.

(Coatinued)

Raanannibla Graanimation Operator Training m

October 1, 1990 e.

Late sempletisa of numerous Technical Specification changes required piAer to restart any tapact the ability to adequately cover these in trainias. Traialas had not been informed of the plaaned changes which would parait advance preparation of training information.

BRAPORRE/ACT10B PLAN Review of recent' technical specification changes are a standard session of the requalificaties classes. Most technical specification abanges have a 60 day tapleasatation period so ample time asists for shift personnel review. If there are a large number of changes received near startup, special arrangements.will be made with regard to operator training. Site Licensing is actively pursuing early submittal of all restart technical specification changes to minimize potential impact in this area.

Operations has been working with Licensing to prioritize the remaining Technical Specification changes to ensure the most important are processed as soon as possible.

In addition, Licensing routes proposed Technical Specification changes to affected organisations (including Operations) for review. Operations then provides information on proposed changes to the Training Department to ensure adequate advance notice for operations related changes.

As noted above, special training sessions will be conducted prior to startup to address any technical specification changes made which were not. previously addressed la the regular six-week training rotation.

Raamana'ihla Graanimation Operater Training DRs Ji&&g December 4, 1990 f.

Sequoyah has initiated training en proper Technical Specification usage. The need for this trainias had not been evaluated for Browns Ferry.

e 4

4 0366W 25 4

a 3

3.

Lima omaan11Arion/TnA m me i m RFACE (Conti%:edj j

2.

Raais (Continued) i f.

(Continued)

EERPOE21/ ACTION PLAR Brevas Ferry Training has obtained and' reviewed the asterials used at Sequoyah to present trainias se propei Technical Specification usage. After evaluaties of the Sequoyah material, the Operations Trainias Namaser and the Asting Operetteas Superintendent

)

determined that the approach used at SQN was not appropriate at syn. We do, however, mete that ansk of the SQN asterial had been previously integrated into the Liseased Regualification program.

Ramaanalhia Ormanimation j

Training ha nata Ceaplete J

3 The decision on templetica of modifications which would impae't I

operations and trainias (e.g., source range screas) had not been reached or clearly a - teated to Trainias.

RESPONRE/ ACTION PLAN A aceting was held between Operations and Operations Training on March 28, 1990 to ensure a common mderstanding on this item. The modifications to the 8tMa (remote function for 3RM scraa coincidence shorting links) were discussed. The modification has l

subsequently been completed and placed on the simulator.

1 l.

l tagagnaihla Ormanization p

Operations and Operations Training l

DBL. Data l

Ceaplete h.

Instances were noted of inadequate cosauaication of expectations' to trainias by lias management, and of reluctance by Training managensat to bring issues of landequate support to appropriate lias annagement attention.

RESPORIE/ ACTION PLAN A meeting was held between Operations and Operations Training on March 28, 1990 to ensure spea lines of communications. A statement of expectations has been issued as an Operations 8ection Instruction Letter entitled "Canduct r> Training". Attachment A of OTIL-14, " Student / Instructor Responsibilities" is used in initial and continuing trainias for sianlator instruet' ors and for operators. Managennent personnel routinely monitor training activities and will assure that these standards are being I

reinforced.

0366W 26

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3.

LIElt ORGAR11AnuR/TRAIMM IMitRFAQ (Contianes) 3.

kula (Contissed) h.

(Cent ased)

The ette organisation has been realigned such that the Training Manager fumettomally reporte directly to the Plant Manager. This i

vill reesit la direct interfaen regularly between high levels of trainias and site management. This will allev ear instances of inadequate eupport for training to be effectively communicated and resolved.

Raamanalbla Dramminatian Plant Manager /Traialag Daa Anta Ceaplete/0againg 6

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0366W 27

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Full' advantage was met being obtained from simulater training to ensure operator readiness for startup and to reinforce the requisite standards for eenduct of operations.

tannamaa Rumanarv An eagoing high level et meangement attenties and involvement is a i

accessary ingredi et la anzinising benefits derived from sisalator 1

training. A joint sommunique out11mias management espectations regarding sinalater trainias for both Operations and Training has been proptred. Addittamally, as discussed in the below responses and in 4

response to Centern I, steps have bem undertaken which increase Operations manag e mt's direct ihvelvement in staalater training and to improve commuLications between Trainias and the site organisations.

2.

Ragia During observations of severa! requalification simulator training esercises using the plant startup procedure, the ORE Team noted the following a.

In some cases, requisite control room formality was not maintained. For example, instructors and operators were involved in conversations not related to the evolutions in progress.

b.

Instances of inadequate communications were observed including imprecise orders and alarms / conditions being announced in too low a voice to be clearly heard.

l c.

Operating practices required in the control room were not consistently enforced (e.g., obtaining 808 and Reactor Engineer signatures authorising use of rod pull sheets, logging unusual l.

events).

112POR11/ACT10B FLAB (Banis items a - c) l A meeting was held between Operations and Operations Training on March 23, 1990. A statement of expectations was 1assed as an Operations Section Instru tica Letter atitled " Conduct of.

Trainias". Operations Tr/ainias !astruction Letters are used in initial and esatinutas f.rainias for stealator instructors and for operators. Additionally, the Operations Management Observation Progfan taaludes a weekly observaties of trainias activities.

Rennenalble Ormastination Operations and Operations Trainins Dua Data Complete 0366W 28 pa-

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SIMUIATOR TRAININq (Continued) 2.

kaia (Continued)

~'

d.

Opportunities to establish preferred operating practices were not used effectively. For example, the method and n eber of verifications of individual rod positions was left to the discretion of each mit operator.

i pBPONSE/ACTf0N FIAN The methodology for dete*.sining and verifying individual rod

- positions has been resvaluated sad procedures have boca revised to remove soms of the, administrative burden from the operations personnel. The applicable sis will be revised to delete the'-

j requirement for recording the time when each rod move is completed.- In addition, clarification has been added to reflect Tectrical Specification requirements for independent verification and who performs the verification. As a general rule, feedback from simulator sessions is routinely utilised by Operations to improve instructions.

r~.

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,e 3..e y

L Ramponsihla Organisation '

Reactor Engineering Due Date Complete o

e.

Thorough critiques were not &1 ways held at the end uf each simulator session.

RESPONSE / ACTION PLAN The Plant Manager will provide discrete instructions to the.

f Training Manager regarding the expectations for thorough critiques by the simulator instructors. Additionally, a schedule was published by operations on March 27, 1990 listing the' operations managers and the dates they are; scheduled to observe simulator training. A schedule was-published by 0perations Training on.

March 16, 1990, listing the Training managers sad the dates they are se,heduled to observe' simulator training. 'these* schedules have been issued only to operations and Operations Training management observers (not-to the instruetors or the crews). These

~

. observations are continuing and are reviewed regularly at the L

Curriculum Review Committee meetings. This review, along with clear espectations of the crew and instructor, will ensure proper conduct of simulator training.

s H

Rampanalble Organimation Operations and Operatione Training Dum Data i

Ongoing u

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BDRILATOR TEiliuBC (Continued)'

l

- 2.

33313 (Continued)

L l

f.

The training may not fully reflect intended procedures to be used for actual startup. For example, instructors noted that a l3 modification to incorporate source range scrans might be performed before startup, and the procedure required use of Keff vs rod position curves which were not planned to be used during actual l-startup.

i ERSPORRE/ ACTION FflE i'meeling was he'id st1Ileen SWR Fuel Engineering.and Reactor

~

Engineering on March 29,~1990. This meeting addressed the specific misunderstanding about the Keft vs rod position curves and the use of criticality limit guidelines. A representative-i from both BWR Fuel Engineering and Reactor Engineering vill participate in Licensed Operator Requalification Week 6 (week.3 of startup related training) beginning on April 2, 1990. Training will continue to participate in meetings between BWR Fuel Engineering and Reactor Engineering throughout startup.

The decision to include source range monitor coincidence shorting 1

links was conveyed to training on March 23, 1990 (see response to iten I.2 3).

We do not expect'aajor changes in the startup procedures prior to startup. Additionally, startup activities will be monitored carefully by Operations management and all evolutions will be rigorously planned.. Prestartup reviews will also focus on use of

.the startup procedures and extra training requirements will be i

identified as needed.

Reanonsible Ormanization i

Training / Fuel Engineering / Reactor Engineering Due Data ongoing (through startup) 6 4

Simulator hardware / software deficiencies detract from training

- 1 effectiveness. For example:

(1) The core map printout frequently printed incorrect rod positions requiring resolution.

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ADERATOR_TRAINIBG (Continuod) 2.

Baala (Continued)-

g.

(Continued)

(2) Frequent (several ';imes per minute) source range period alaras were received which instructors and operators stated to be unlike the plant. In some cases, the alara continued distracting personnel from the statt'up procedure; in others, it was silenced.

(3) In one instance, a rod position amenaly was corrected withose investigation, apparently because it was assumed to be a misslator aalfumation.

RESPCERE/ACT105..PLAR In" response to the specific items cited above, the' core' asp

' printout'problen'end the source range period alare problem have been corrected by Simmiator Services. The rod position anomality.

'was known to 'be a = simulator malfunction because the instructor had not input the nalfunction at the instructor console. Also, the erew had just completed a malfunction on rod mispositioning as part of a scenario.

The overall method of handling simulator problema is addressed in a Ruclear Training position paper. This position paper assigns

_ priority to problem reports (pes) according to the following (1)= problems that would produce significant negative training are handled immediately, (2) problems that will require only a reasonable amount of. work but do not produce negative training are handled next, and (3) problems that are significantly beyond the scope of the simulator model or will require significant man-hours to correct because of the model are not attempted, but will be-corrected by the'aimulator upgrade project. This position paper has been used with-INP0 and NBC with favorable results.

Raanannible Graanization Operator Training Due Data

. Complete h.

In some cases, instructors did not adequately cover lessons-learned or_ actively participate in the training evolution.

RES20ERE/ACTIGE_ELAR This item is addressed in the response to items a - e above..

0366W 31

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i F.

A11Rf1ATOR TRAlhillG (Continued)'

l 2.

Baala (Continued)

i. Both Ope' rations and Training management expressed concern that simulator performance might regress following the recent successful completion of requalification examinations. Bovever.

neither group was proactive in preventing this from occurring. No management personnel were present during the first startup training conducted en February 19, 1990.'

RESPORRE/ACTIOR MAN This itea'is addressed in the response to items a - e above.

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so ATTERTION TO OPERATIONAL DETAILS 1.

Gangsga I

Risorous attention to operational details was sometimes lacking.

j 1

Rannonae Stamary l

~

As discussed in the response to concern A and this concern, a* number f

of management actions have been initiated in this topical area and will be followed up on. The Sq8s will be required to document a discussion of these issues with each crew and the plant Operations i

Manager and Operations Superintendent will also discuss this as a l

generic issue in their weekly meetings with the Operations crews.

The continued nonitoring of operator performance by operations Management, coupled with emphasis at all levels on attention to detail, is being encouraged by Plant Management. The consistent implementation of the Operations Management Observation Check Program, j

scheduled periodic management-crew' meetings, 808/A808 plant tours, use i

of the training A00 and the assignment of a Unit operations Manager to i

the task of improving ADO performance are all intended to promote and l

improve rigorous attention to operational details. AUO'perf.nraance has noticeably improved in recent months as indicated in :ecent l

reviews by ANI, NSRB, and NRC.

2.

Raala 1.

During a required de-energization of a 480-volt shutdown board:

a.

No notification was given to the refueling crew although the action caused all area radiation monitors to alarm on'the refuel floor.

~b.

Power was lost to two effluent monitors because the back-up-supply was previously tagged out.

l

~2.- One breaker was noted removed from the 430-volt' common board.

without the proper record in the Configuration Control'Los. This l

condition had apparently existed for over two months.

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AffErff 05 TO OPERATIONAL DERAILS (C3ntinOtd) 2.

Rania (Continued)

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SESPORSE/ACTIOR PLAR (Basis items 1 and 2)

The need for careful planning of plant evolutions and communications is emphasised to the crews during normal daily operations by the 808 and reinforced during simulator training.

Bach operator has attended a briefing uenducted by the Operations Superintendent on attention to detail and the importance of fully assessing the operational impact of each planned evolution.

All systems under configuration centrol were reviewed and identified discrepeneias were corrected.- The Operations Superintendent issued a memorandum to all operations personnel regarding these discrepancies. A weekly audit is being performed by the status control group and QA has been requested to

' periodically: audit the process and provide feedback to the M:.

Operations Superintendent.

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Ranoonsible Ornanization 4u

.r' at w Operations.

Dua Data Complete f'

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4 0366W 34

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A'rrmrrION TO OPRRATIONAL DrrAILS (C$ntinued) 2., Ragia (Continued) 3.

Assistant Unit Operators (AU0s) did not note several maintenance items for which Mits needed to be prepared.

4.

Unit Operators'(U0s) and AU0s did not always take action to correct inoperable indicating lights.

5.

Ceemmnications were not always at the espected standard. This was particularly noted in phone calls free outside to the Control Room and during a radiological emergency drill.

6.

Exemples of improper legs, aosenmiestions deficiencies and inattention to operation vere noted during simulator training.

These are discussed in acre detail in another concern (Item # F) within this report.

7.

On two occasions, AU0s used an uncontrolled, copied page of a procedure to perform an evolution.

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RESPONSE /ACTIOR PLAN (Basis items 3 - 7)

See the response following item 11 of this section for a discussion of steps-being taken to improve performance of Operations personnel.

8.

The 440-volt boards 2A and 2B for turbine building ventilation'are not on the rounds sheet,.although an AU0 observed-did check them.

These should be on the rounds sheet.

RESPONSE / ACTION PLAN (Basis item 8)

' Rounds sheets.for units 1 and 3 were revised to nore accurately reflect the status of these units. A more detailed revision is underway for all round shee'ts to be completed prior to startup.

This revision is being reviewed extensively by all operating crews.

and will-be of a very high quality prior to beginning power operations. These items will be considered for that revision.

Rennensible Genanisation Operations Dua.. Data Unita 1 and 3 - Complete Unit 2 -. November 30, 1990 0366W 35

9.

An AUC found two valves micpisitionod wh m he started ta perform o 1

sareen '

kvash pracedure..Be astified

esntrol"esca preperly betsro ecpo01tioning the volves, but did not leg the ctaditien.

t

10. A Bold order tag was noted still attached to a breaker which had i

been removed from the switchboard for repair.

11. A team member noticed a roll of tape resting on the top of r. Core Spray pump room sump pump so that it interfered with the float level detector. When the roll of tape was removed, the level j

indicator visibly moved. A similar observation was made during a tour with an ADO in the RER/IPCI pump roca where a grease gun was adrift with the potential for interfering with the sump level device.

BREP0BER/ ACTION PLAN (Basis items 3 - 7, 9 - 11)

A Unit Operations Manager has been assigned to assist with A performance upgrade. He voths directly with the AU0s on all issues surrounding job perft.rasace. He is tasked with monitoring ADO perfora m e in the plant as well a; during traintaa periods.

His dutier, also include rounds sheet rette,4on, ADO watchstanding upgrades, and, direct managentat oversight and involvement on non-licensed operator-issues. In addition to sho Unit Operations Mesager, the on-ahift 808 and A808, aloca with staff management, will tour with the AU0s stress.'as proper watchstanding techniques, safety, and plant ownership.

ADO performance has noticeably improved in recent months. The

-best indicator are the reports of the same organizations which

- previously raised the issue of ADO performance. Recent reviews by ANI, NSRB, and NRC have consistently noted improvements i'n attitude and performance by the AU0s. Water spills in the plant 1

have been dramatically reduced as one specific example.

In addition, all AU0s.are scheduled to work at SQN for a week in a power operation environment. This pro 6 ram is already under way.

Watchstation proficiency walk-through arama will be started again in August, which will help sustain the momentta. Hands on task training for the AU0s has been changed to allow all AU0s-to provide. training to each other to help anpand their skills and confidence. The values and goals portion of the Franklin Time Management course has been scheduled in ADO requalification training to help instill ths proper attitude in the AU0s.

Additional 880 licensed personnel are being made available to the areve which will allow more direct supervisory involvement.

i 0366W 36 e

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G, ATTENTION TO OPERATIONAL DETAILS (Cgntinu::d) l~

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2. Ragia (Continued)~

l l-The improvements already noted, the additional programs already scheduled, plus the natural catalyst of the startup provide high i

confidence that AU0s will perform well for startup and power operations.

Rannonsible Ormanization l

Operations

(

L Dna Data

[

Complete /0ngoing

-l l

L

12.. Some floor drains were not routinely cleaned of debris or checked l

so they could perform their faction. -In some cases, these were

, adjacent,to a sample station or in spaces was a radioactive spill

.would be worsened by a, plugged' drain.

-(1) There was no screen in'a floor drain outside the east and of L

the control bay.~This' drain had been a factor in a reportable discharge sample to the State 1,ast November.'

i (2) The drain by the issue station for personnel protection clothing on the 565-foot level of the Turbine Building did not L

drain properly when water from another' drain system backed up L

in the area.

RESPONSE / ACTION PLAN (Basis item 12)

The Maintenance drain scupper cleaning crew was a temporary crew dedicated to.the initial cleaning of the floor drains. Once the, initial cleaning had been completed, the decision was made to complete subsequent cleaning under minor.asintenance or work request depending on location and type of drain.

Reanonsibla Ormanization 4-Operations Dum Data Complete 0366W 37

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PREVElfffvE MIlmtluRCE g,

ggggggg Some Preventive Maintenance (PM) activities have been deferred and removed from the overdue list without adequate technical justification.

taneensa suemarv We agree that timely performance of scheduled preventive maintenance enhances plant reliability. The three tier objectives and goals program has established a goal to maintain the percentage of late preventive maintenance to below the 1N70 industry average. Resource limitations have necessitated the prioritisation of some preventive maintenance items. A program is in place to evaluate each preventive maintensnee item prior to deferral and only those items which can be technically justified are deferred. As each system is returned to service, outstanding. preventive maintensnee items which have not been=

performed are reevaluated to ensure that adequate technical justification exists for not performing the preventive maintenance items. This self checking system is intended to ensure that all..

preventive maintenance required to support operability is performed.'

2.

Basia l

a.

The June 1989 ORR report detailed a concern with the large number

- of-backlogged PM items. Maintenance management stated that, in addition to increasing PM performance, one of the methods for reducing the backlog of outstanding PM activities (greater than 125 percant overdue) was deferral based on operational or technical assessments. The integrity of a deferral process is essential to'-

ensure that the PM program remains credible.

)

/

A listing of 32 PM activities was provided to the ORE Team by the L

PM manager. This list was typical of PM items that had been categorized as "Not Performed" and that had been removed from the PM schedule and rescheduled to a later date. These items are-no longer considered to be overdue and are not tracked as such.

A comment section was provided for each PM task on the list. A review of these connants revealsd that approximately 20 percent of these "Not Performed"' items had questionable justifications for i

deferral..The following are typical of the statements found under.

i the comment sections: (Note that the ORE Team did not review kny

.i additional backup documentation that may have been contained in

'1 Plant Records.)

"Not Tech Justified"

" Deferral Not Approved"

" Procedure Does Not Fit Work" I

"No Manpower" 0366W 33

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E.

PREVElffIVE MAIRTENANCE (Continued)

I 2.- Basis (Continued) a.

(Coatinued)'

Purther discussions with FM program personnel revealed that these items should not hava been removed from the overdue list until 1

they had received'the appropriate technical justification for t.

deferral in accordance with the requirements of the Site Director Standard Practice (8D87) 6.3, ' Preventive Maintenance Scheduling and Tracking." If the taak does not meet those requirements, it l

abould be tracked as everdue.

IRSPONSI/ ACTION FLAR l-

'All PMs which were greater than 28 percent late had received a technical evaluation. In a number of cases the evaluation concluded the FM should be performed. Some of these PMs were later inadvertently removed from the late FM list. A thorough r

review of the FM database is in progress and PMs without adequate justification for non-performance will be considered late and reclassified appropriately.

Considerable emphasis has been.placed on performing PMs on schedule and has resulted in a reduction in the number of late PMs by about 45 percent since December 1989.

The new Maintenance Planning and Control (MPAC) System is designed to automatically track PM items that are not performed by their due. dates. Subsequent status changes such as deferrals or PM being performed can also be tracked by MPAC. MPAC was implemented in April 1990 and it was learned then, however, that the new system would not accept the existing PM status terminology, e.g.,

"Not Performed," "Not Technically Justified." Approximately 6000 itens required data conversions to-a terminology that MPAC would accept.. Thirty-five hundred are completa and the remaining 2500 vill be completed by September 30, 1990. Once tho' data conversions are complete, MPAC will' track the status of all PMs and errors such as those cited will be eliminated.

Rannonsibla Ormanlaation Maintenance r

Dum Data September 30, 1990 i

0366W 39 i,

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PREVElfrIVE MAIETENANCE #(Ctatinued) 2.

331a (Continued) b.

One specific FM that the CRE Team noted had not been performed since 1985 was a taak for monitoring flow blockage in'the unit two RER Service. Water System. This activity has a periodicity of one month, p'

A Systems Engineer indicated that performance of this task was part of the responses.te NRC Generie Letter.89-13 and INP0 Significant Operational Event Report 44-01. This system was in service during 1989 when fuel was installed in the unit 2 reactor, and could have ll been performed during that period.

RESPONSE / ACTION Ft.AN The subject PM, (30235) has not been removed from the 25 percent Late. I List. Tb1 FM had been properly deferred and placed in the deferred-status until November 29, 1989 when it was reactivated. It is now and has been on'the 25 percent late list and is being carried as late.

I The FM for monitoring flow blockage in the kERSW heat exchangers for Unit 2 has not been performed;since 1985 when Unit 2 was shutdown.

This FM involves the performance of TI-63, EER8W ylow Blockage Monitoring, which measures the pressure drop across the service water side of the heat awehangers and in the supply lines once every pix l

months.- This TI has no specific performance criteria, but rather records data and monitors it for significant changes and adverse trends needing investigation. ' Flow blockage in these heat exchangers (which have been cleaned during this outage) normally occurs only during prolonged use of the heat exchangers. With Unit 2 shutdown, these heat exchangers are only in service during the performance of

- the Surveillance Instruction (SI) that verifies the RER3W pumpe can meet their Technical Specification and ASMB Section XI flow and head 1

requirements. This SI is run once per quarter and each heat awahanger is in service for about 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

. This PM is scheduled to'he run prior to fuel load so that a baseline for future reforance can be. established.

Additionally, RFN has committed.to several actions in our reply to NRC Generic Letter 89-13 " Service. Water System problems Affecting Safety Related Equipment" to further ensure reliability of the RERSW system.-

0366W 40 h

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2. ! nfirrENANCE WORE ptACTICES l

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GARRAER f

Observations in the area of maintenance work practices indicated that continued attnation is required to achieve high standards of

'l performance.

i Reasonna Summarv As noted by the ORE team, some work practices are still not at our e

level of expectations..These situations are being addressed by the current maintenance staff who are dedicated to achieving a high degree of excellence..'These individuals are daily ceamanicating a higher I

level of expectations and are raising acceptable work performance h

standards.

Indicators such as reduced personnel errors, CAQs, safety, l'

Licensee Event Reports, and increased productivity show that current-approaches are being effective..

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The new work order and maintenance planning system will further serve l=

to improve the execution of the entire maintenance process by providing an integrated planning and scheduling methodology.

ws,

Additionally, a Peer Evaluation program has been developed. This i

program is under the direction.of the Maintenance Production Manager and will be used to obtain clear and concise evaluations of l

workmanship and performance gus11ty while being used as a learning "f '

tool to further promote high standards of excellence.- It was implemented for trial use on May 1, 1990 with full implementation on i

June 15, 1990.

It la expected that through the continual evaluation of work practices, quality, safety, and professionalism by peers, higher standards will be achieved. Refer to the response to Concern A, L

itaa.3, for further elaboration on the Peer Evaluation Program.

2.

33313 a.

Rigging for disassembly of a complaz horizontally mounted 18-inch valve was performed using a direct lift from the hook of the-Turbine Building crane.

(This was a craft decision; no procedural guidance was provided.) The use of a chain-fall and sling from the crane book would have allowed for finer control and alignment and is a standard maintenance rigging practice.

IRSPONSE/ ACTION PLAN We agree that the chainfall and sling method would have provided finer control and alignment. This information was provided to all rissers during the monthly information meeting with instructions to be alert for the best possible rigging techniques to use.

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0366W 41

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C 16 NAI1rrENANCE WORE PRACTfcES (Continued) l 2.

Ramis (Continued)

SESPONSE/ ACTION PLAN (Continued)

Consideration was given to including rigging requirements and techniques in maintenance instructions and have planners provide rigging details in work instructions.

I,t was decided, however, that because of the many variations of' rigging required and even variations that could be used on any single lift, that rigging techniques and_ choice of equipment should be left as a skills-of-the-craft activity. Detail rigging instructions would unnecessarily hinder the craftsman in the performance of their work and would probably require excessive procedure and work instruction changes once work had started. Maintenance craftsmen receive training in rigging techniques, requirements,' safety, and

-inspection to_ supplement their work experience. Work planners,,

,. specify which jobe require rigging, applicable site standards, aEd craft taak qualifications.

..taanonsibla Ormanization Maintenance Dua Data Complete b.

Inspection of the removed body to bonnet gasket from the valve L

discussed above showed evidence of uneven compression of the L

gasket although there was no evidence of steam leakage. The L

procedure contained in the work package for reassembly provided no specifications for alignment or bolt torquing sequence. Further investigation pointed to the conclusion that the bonnet was most likely misaligned during a previous reassembly and that the misalignment took up the load on the gasket. Although a detailed l.

Print of the valve was provided as part of the work package, it was not present at the worksite.

Rasconaa/ Action Plan Maintenance history indicates that the misalignment of the bonnet occurred four years ago. Such poor work practices would no longer be performed or tolerated by our craftsmen due to the extensive training that they have had and the new standards being espoused.

BFN now has a Maintenance Training Program that was implemented in July 1937..This program meets INP0 guidelines and was accredited by the National Nuclear Accreditation Board on September 13, 1937. specific valve training has been provided to'the mechanical craftaman as a certification qualification task. Certification is a prerequisite for working on valves. Instructions for the l

assembly and torquing of valve bonnets is included in the training course.. Additionally, a work package is required to be at the j

work site, except in a contaminated area, and even then it should j

e be available ismediately outside the C-sone. This item was also i

discussed with the mechanical craftsmen during the monthly information meeting as an example of unacceptable work practices.

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MAINTENANCR WORE PRACTICES (C:ntinutd).

2.

RAAia (Continued)

Ranoonaa/ Action Plan (Continued)

A recent maintenance related audit, BFA90019, by the BFN.QA audit group showed work quality was acceptabic.

Raanonsible Oraanleation Maintenance Dna Data

• ~ ~

Coselete' c.

During maintenance on a reactor feedwater turbine, internal parte were left uncovered and disassembled parts were scattered.on.the floor. On the other hand, the IPCI pump turbine, which was left in a disassembled state while swaiting parts delivery, had all exposed parts wrapped and protected.

RESPONSE / ACTION PLAN This item is addressed in Concern A, iten g of this report.

d.

A maintenance crew, marked as Not Applicable (N/A) a step in a procedure which called for vacuuming equipment because they could not 1

obtain a vacuum cleaner.

L RESPONSE / ACTION PLAN The maintenance crew should not have N/A'ed this procedure step due

(

to unavailability of cleaning. equipment. Maintenance foremen and I

general foremen were not counselled in this case because it was l

initially believed that the use of N/A was acceptable in accordance I

with procedures. After further review, it was determined that the j

N/A was improper and this item was disc.ussed with the electrical

.I craftsmen during the monthly information meeting as an example of the ?

need for adherence to procedural detail. A Maintenance Peer t

Evaluation Program has'been developed and is azpected.to reduce the incidence of work discrepencies such as this. item.

Reasonsible Ormanization Maintenance j

EER DA11 Complete 1

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0366W 43

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MAI1rrENANCR WDRE PRACTICES (Cgntinued) g 2.

Bagia (Continued)

[

j.

e.. A work crew was observed torquing baseplate bolts. In this case, the bolts were overtorqued, than were backed off to obtain the correct torque. The foreman indicated that he saw no problem with overtorquing bolts as long as the final torque obtained was correct.

I-RES70ERE/ ACTION PLAN l

l We agree with the observation that this torquing method is an l

unacceptable practice since excessive overtorquing could potentially cause bolt yielding not readily detectable by inspection.

Proper torquing techniques and their importance have been discussed.with craftsmen, foremen, and general foremen as a continuing training item.- A formal lesson plan has also been prepared and is being used. Attendance at all maintenance continuing training classes is-mandatory and attendance records are kept.

~

Reanonsibla Graanization Maintenance

• g Dum Data Complete L

f.

An electrician was observed wearing a metal watch while working in an l

energized panel.

l' RESPONSE / ACTION PLAN i

All electricians were reminded during their weekly safety meeting of the safety hasards of wearing.netal jewelry while working in an

[

energized panel. They were further cautioned by the electrical supervisor during the monthly information meeting. Maintenance' supervisors and foreman also monitor this type safety item durins their field observations. Refer also to the response to concern 0 in this report for a discussion of activities to involve field personnel as line advocates of the industrial safety program.'

Rannonsible Orsanization Maintenance Due Data Complete /0ngoing i

a 0366W 44

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NATNTkNANCE WORE PRACTICES (CGatinued)

H 2.. Raala (Continued)

s. Although the work package required performance of a procedure and the a-work package permitted no options for partial completion, a maintenance crew performed only certain sections of the procedure j;

L, based on oral directions from an engineer.

!i L

anSPONSE/ ACTION PLAN L

~

rked as Craftsmen have been made aware that work packages shall be written unless returned to Planning and revised correctly. A maintenance engineer can provide clarification of.the instruction but does not have the authority to change instructions without routing the package through the approval process. This item was also discussed in the monthly communication meeting.

Maintenanceengineersweresurveyedtodetermineiftheyunderhtood that oral instructions could not be used to change a vo:k instruction. Each engineer surveyed clearly understood ths.t work is performed only to approved instructions and changes must be returned to the planner for incorporation into the work control doctment prior j to working.

Additionally, the Plant Manager conducted meetings with all his employees including craftsmen and engineers and emphasized the

.importance of following procedures.

Resnonsible Ormanization Maintenance Due Data Complete h.

One maintenance work package called for the replacement of valve packing. The PMI called for a stroke test and leak test. During

-repacking it was determined that the valve stem was damaged and another MR was initiated to replace the stem. The otroking was performed for the first MR and the leak test requirement was deleted - !

since it would be covered by the second MR for the valve stem.

(It could not be determined who changed the requirements.)

Unfortunately, the PMr for the second MR referenced the PMr covered.

under the first MR for the valve packing. This results in no PMr.for,

valve leakage being performed even though the valve was completely-disassembled.

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MAINTENAMCI if0RK PRACTICES (C:ntinu:d) l

'2.

33313 (Continued)

h. (Con'tinued)

RESPONSE / ACTION PLAN I

Browns Ferry has tak e several steps to, improve the quality of i

pre-job work scoping and the planning of work packages. The basic work planning and. control procedure, Site Director 8tandard Practice iT (SDSP) 7.6, has been replaced by a new maintenance management j-system..The new process, which.is titled. Maintenance Management.

System", is comprehensive and designed to provide detailed guidance in each facet of the planning process..It was implemented on March 19, 1990, and was subjected to a period of debugging. The system has been debugged and is factioning well.

8D8P-7.6 procedurally controls the performance of post maintenance.

tests. Section 7.6.5 instructs the person performing the PMT to return the package to the originating planner for changes such as the L

.one described in this concern. Planners then verify the legitimacy.

l of the referenced work order.

Resoonsibia Ormanization Mkintenance l'

Dua Date Complete.

i. The work instruction for one MR required that the packing be adjusted on a valve. If that did not work, the work crev was instructed to replace the. entire valve, since no parts were available. The completed work section stated that the valve bonnet had been replaced 1

with no further-explanation or change to the work instructions.

RESPONSE / ACTION PLAN The mechanical craft have been instructed that if a work. package cannot be worked as written, the package is to be returned to Planning for revision. -This. incident was placed on the monthly 1

communication meeting agenda and discussed again by the mechanical supervisor.'

Reanonsible Oraanization Maintenance Due Date Complete j.. During observation of a job to replace -bearings in a pap, the foreman stated,.when questioned by a team member, that'he would have

. removed one of the shields from a double shielded bea'ing. The work r

instruction required that the double shielded bearing be replaced, but did not authorize the bearing modification.

0366W 46

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D 10 MAINTENANCE WOEK PRACTICES (CSntinued) 2.

Rasis (Continued)

j. (Continued)

RESPONSE / ACTION PLAN 1

The craft have been informed that work instructions are to be followed and a revision to the work scope must be preceded by a work '

package revision. As stated in FMI 6.2, Conduct of Maintenance, maintensace personnel are responsible fort (1) follwing the instructions, (2) comparing the instructions with the work to ensure its adequacy and accuracy, and (3) stopping work and setting the instruction corrected if it is wrong. Any modification must be properly approved and documented before it can be worked with a work

, request.

.I Righer performance, standards and a better understanding of the conduct of maintenance requirements are being reinforced daily through the routine interaction,of_ craftsman, foremen,. general. _,

t u,

foremen and maintenance supervision.

Rannonsible Ormanization Maintenance

, Due Data Complete k.

Cleaning etepe in a preventive maintenance procedure had' beer l'

completed when a team member pointed out considerable dirt and grease in the bedplate (fire hazard). The crew at that point cleaned the bedplate.

l>

l RESPONSE / ACTION PLAN J

.BFN agress houscheeping is.an area of maintenance that needs l

continuous attention. A formal lesson plan was developed and y

craftsmen and foremen informed of their housekeeping responsibilities as' detailed in SDSP 14.6, " Building and Facilities Housekeeping and Cleanliness". The lesson plan was given to the eraftsmen as part of maintenance continuing training. Attendance at all maintenance continuing training classes is mandatory and attendance records are kept. This item was emphasised again to the craftsmen by identifying 1 the level'of cleanliness expected by the discipline supervisors during the monthly information meeting.

BFN is improving the housekeeping program by implementing the-I following changes:

1

1. ' Areas of responsibilities will be subdivided into smaller areas and the responsible individual's name will be posted' conspicuously in the area.

6 0366W' 47

0

.o.--e 7

MAINTENANCE WORK PEACTICES (Continued) 2.

Baais (Continued)

RESPONSE / ACTION PIAN (Continued) 2.

A plant housekeeping coordinator as recommended by INP0 guidelines will be assigned to ensure that a u deficiencies are addressed.

Rampanaihla Arganisation Maintenance Dua nate e October 15, 1990 1.

Two instances were observed of maintenance work packages which had been workediup.to three weeks beyond-thei. expiration date of the controlled-procedure copies in the package.

RESPONSE / ACTION PIAN..

m All maintenance craft.(electrical, mechanical, and I&C)'have been informed that the instructions in their work packages must be verified to be the latest approved instruction prior to performing the work. This information was reinforced by each discipline supervisor during the monthly information meeting.

Reasonsible Orennization -

Maintenance Due Data Complete n.

The exhaust motor and fan for a shutdown board battery room were removed for repair. The exhaust duct was loft open in a manner that greatly reduedd the effectiveness of the battery roce exhaust ventilation. The condition was corrected only after a second MR was processed to close the duct opening.

RESPONRR/.ACTIOK E AM Electrical craf tsmen have been informed of this poor work practice and instructed that when systems are opened for work and must be lef t unattended, the system shall be covered and put-in the safest condition possible. - This example of poor, work practice was discussed during the craf t monthly information meeting by the ~ discipline supervisor.

Raspannihla. Organization Maintenance Dum Date Complete g

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lu1HTERARCU%ARKING 1.

Gangarn observations by ORR Team members indicated that continued attention in the area of planning skills is required to achieve high standards of performance.

Reasonae Summarv Several steps have been taken to improve the quality of pre-job work scoping and the planning of work packages. The basic work planning and control procedure, 8DSP 7.6, has been replaced by a new maintenance management system. The new system combined with new

(

computer software (MPAC) is comprehensive and designed to provide detailed guidance in each facet of the planning process. It is p

subdivided into nine detail sections that provide complete guidance on the entire maintenance planning and work execution process.

It was

' implemented on March 19,1990,~ and was subjected to a period 'of debugging. The system is currently functioning well.

A two-phase planner. training program has been developed to upgrade

=

planner capabilities. A joint program curriculum was prepared by the planning and technical supervisors of Watts Bar, Sequoyah and Browns u

Ferry. Phase-one consiste of the basics that all planners must complete. It includes such items as work plan preparation, bench mark-.

standards for job duration estination, and Post Maintenance Testing (PMT) planning. All planners have completed this phase.

Phase two planner training covers a broad scope of core training courses designed to make planners more versatile. BFN training is

• ' coordinating the development of phase two course curriculum modules and a training schedule with TVA corporate Training and BFR Maintenance.

Browns Ferry's long term plans to upgrade the capabiliti~es of individual work planners should significantly impr'ove work package instructions. In the interim a lead engineer in each discipline is assisting in work planning. The lead engineers are providing expertise and will continue.in this function until the planneio are fully trained. Results to date show that the additional technical

- expertise is improving the quality of work packages.

Maintenance planMnq has historically not been as thorough for non-CSSC work as it has for safety related work. With the full implementation of the new maintenance management system, non-CSSC planning is in essence planned to an equivalent degree of thoroughness as for CSSC work. -The work instructions do not contain superfluous information or leave maintenance activities to the discretion of the craftsmen.

e 0366W 49 v

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MAI1rrENANCE PLANNINfs' (Ctatinued) 2.

33313 a.

One non-Critical System, Structures and Components (non-CSSC) work package for a valve packing adjustment described the method to I

adjust the packing in great detail. However, the planner also referenced se.ction 4 of Mechanical Maint aance Instruction (196-51), "haintenance of C88C/Non-C88C, Valves and Flanges," as part of the work instruction. For the' work activity described, 39G-51 is superfluous information. Further, while the PMI specified a leak test, there was no requirement for ensuring that the stem would move after the packing 'was adjusted.

b.-

One package ~ for a non-C88C ptusp required the replacement of a mechanical seal. The package contained the following deficiencies:

(1) In the packasei the planner referenced two'different mechanical seals with a note that the craftsman determine which was correct.

(2) A Fla'nt' Manager's Instruction'6.2 " Skill of the Craft;"-

l authorisation was used to allow the craftsmen to perform the repair with no formal instruction other than a generic vendor manual.

(3) In addition to replacing the mechanical seal, the work instruction told the craftsmen to check the pump shaft and bearings for damage and replace parts "as necessary."

i (4) Parts information that was provided as part of the package contained data'for every major pump part including shaft, wear rings, impeller, etc.

(5) There were no alignment measurements or acceptance criteria L

for coupling adjustaant even though the coupling would be removed to replace the seal.

l:

(6) Retest requirem ets specified only a leak test on the seal.

i In the ev et that pusp internals were replaced, there was no requirement for additional PIE to ensure that the pump L

produt.ed design flow.

l~

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One Instrument MR involved the. leak of glycerine from a gauge face.- The work instructions said'to troubleshoot,. tighten the

' fitting, repair as necessary, and recalibrate, as required. The MR required a return of the package for replanning only if welding was necessary for repair. However, this gauge was installed in a thermal well and replacement is accomplished by unscrewing the gauge; no welding is required.

l d.

Another Instre et MR gave the mechanic blanket authorization to trouble shoot, repair, and replace' parts as necessary and to then determine the necessary PMT.

0366W 50 4

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MAIlrFENANCE PLANNINC (Continu d)

-2.

BasiA (Continued) e.

One work package was for the repair of a cable which was pulled too far from a conduit. The work instruction referenced a t

procedure for the repair of flexible conduit. This procedura did not address how to repair the cable.

f.

For one work activity, unnecessary work'was specified. The l

craftsman were required to disassemble a small pump to determine L

if the proper bearings were installed. This bearing information could have been determined from the previous lubrication FM data sheet which listed the vendor part number for the bearings. This information was also listed on'the' label plate of the pump.

.j s.

Operations personnel indicated that electrical planners are

' inexperienced and do not apparently a derstand the scope of work since some requests for tasouts are incompatible with work to be performed.

h.

On one work activity, workers stopped the job because the -

(

component label plate differed from the MR.

In addition, the component was wired differently than indicated in the work package.

l 1.

The team noted that although some of the October 1989 responses to the June 1989 ORR 3eport have been implemented, the following items are.still outstandir.

ll (1) The revision to SDSP 7.6, " Maintenance Request and Tracking,"

has not been implemented.

(2) Engineers have not been assigned to senior planning positions.

(3) Planners still do no.t review completed work packages.

(4) Planners are not proactively involved in work packages that they have prepared, once the package is in progress.

1 (5) Planners are still not required to mark appropriate sections of the procedure as N/A when preparing work packages, j

RESPONSE / ACTION PLAN (item 1)

(1) 8D87-7.6 was implemented March 19, 1990.

t.

(2) BFN's long term plans to upgrade the capabilities of work planners should significantly improve work package instructions. In the. interim, however, a lead engineer in each discipline is assisting in work planning. The lead engineers-are providfas essential expertise and will continue to do so until the plannars are fully trained to,assee responsibilities. Results to date show that the additional.

expertise is. improving the quality of word packages.

4 0366W 51

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MAINTENANCE PLANNING (CIntinued)

L 2.

Basia (Continued)

I

i. (Continued)

(3) 8D8P-7.6, section 7.6.6 requires all completed work packages to be routed through Maintenance Planning prior to. final l:

closure and being sent to history.,,

(4) 8087-7.6, section 7.6.5 requires all scope' changes, addenda, l-and changes be returned to the Maintenance Planner for disposition.

(5) 8D87-7.6, section 7.6.2 requires planners to N/A any steps that are not applicable to the work package when planned.

J J.

While work package feedback sheets are being routinely returned from the field, a randon rampling of these feedbacks revealed no i

significant comments regarding work package content or quality.

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PROCEDURE QUAL 117 1.

Cancern 9

Deficiencies in procedures have detracted from the ability of plant personnel to conduct maintenance and operations efficiently. In some instances, procedure deficiencies have increased the potential for errors and have resulted in non-compliance.

Raanonaa Steamary Most of the procedures discussed in this section are older procedures and were written prior to issuance of BFN's procedure upgrade style and writers guides. These procedures are scheduled to be upgraded after restart as part of the long-tera procedures effort. Presently, there are 362 working level proegdures in the maintenance area that have not been upgraded. These do not include any surveillance instructions. 827 maintenance instructions and all maintenance surveillance instructions have been upgraded for restart. Those selected for upgrade prior to restart were based on the Probabalistic Risk Assessment (FRA) and those where procedures did not exist prior to shutdown of the plant.

The remaining 362 procedures will be prioritised as needed to perform work and will fall within the approved project schedule.

The. provisions in our new work control program which allow the planners to write specific work instructions on out-of-service equipment address the need for having upgraded procedures for.each ninor anticipated work activity.

BFN vriter and style guidea were developed (using INPO, EPRI, and NRC guidelines) before the corporate writers guides were issued and were used'for the near-tera procedure upgrade effort. The Browns Ferry guides were reviewed by the site staff and the Nuclear Procedures.

Staff anii compared against the corporate writers guides. This review indicated only minor differences between,the guides. A decision was made to continue using the BFN guides to maintain procedural uniformity. As discussed in the response to item j of this concern, we expect to further improve the style guide for future use.

The specific items in the basis for this concern are addressed in the style guide, writers guides, and verification process and will be corrected during the procedure upgrade progree. Busan factors improvement will also be incorporated as part of the long-tera procedure upgrade effort.

6 0366W 53

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PROCEDmtE QUALITY (Continued) 2.

Raala a.

Some maintenance procedures have a sequence of steps which require maintenance crews to have at least four separate discussions with operations personnel prior to starting the work. Two discussions are required with the tinit Operator, one with the Shift Support Supervisor (or the 805) and one with the'808. This is inefficient and unnecessary to safely control the work. In fact, the tsaa observed the sequence of these steps being violated t'o stpedite eemacacing work. This violation contributed, at least in part, to a maintenance crew starting a job without signing off the prarequisites as required.

RERPQHRE/1CTIDE_P!4H

,.. Current maintenance procedures have not been revised to incorporate the advantages of..the MPAC system. Many. electrical

procedures, for example, are written for specific tasks with each procedure written as a " stand alone" procedure. This results in duplication'of prerequisites, precautions, and other administrative type signoffs including Unit operator / SOS notifications.

Currently the MPAC system is being revised to include signoffs, notifications, and other actions that are common to all work activities. Procedures can then be revised to remove these type steps, leaving only the specific information required for the task being performed. The objective is to make maintenance instructions as concise as possible, including only the steps to perform the work. This will streamline the process, making the planning, performance and review of work packages more efficient.

Reanonsible Ormanization Maintenance Dne.. Data MPAC modification - October 1, 1992' Procedure-implementation - two year review process with high usage procedures being revised earlier on an' "as needed" basis.

t, MMI-51 was deficient in numerous aspects and needs to be replaced with a series of procedures more specific to valve type and manufacturer. This is recognised by the Maintenance Procedures Manager.

^

RESPONSE / ACTION PLAN The upgrade of PMI $1 is the top priority of tue mechanical upgrade effort scheduled to begin October 1, 1990. This effort will initially issue individual procedures based on valve type.

More specific procedures based on manufacturers will then be -

developed as the need orises. When these procedures are issued, P9tI 51 will be cancelb.J.

0366W 54

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PROCEDURE QUALITY (Ctatinued) 2.

Baala (Continued) b.

(Continued)

Reasonsible Ormanization Maintensace Dua Date June 1, 1991 c.

The June 1989 okt Report stated that some signature steps in procedures were not clear as to what was meant to be accomplished by signing the step. The BPR response of October 1989 stated a checklist for verifying procedures in SDSP 7.4 " Procedure Review" g

requires that signature steps meet basic requirements. The team considers this checklist (item 56 in the checklist refers to signatures) is not satisfactory. It does not convey, adequately, the need to assess the meaning, clarity, preciseness and lack of ambiguity of signatures. Parther, the BFN response did not discuss a separate procedure validation checklist in SDSP 7.4 which does not have any item that specifically addresses signature steps.

RESPONSE / ACTION PLAN SDSP-7.4 was revised March 23, 1990, to provide a checklist ites-for the assessment of implementation of verification and placekeeping guidelines. This verification checklist is used by preparers and reviewers for all reviews for procedure changes and=

two-year reviews. The procedure style guide, PMI 2.3 was also revised to address site specific examples of verification and placekeeping. Procedures from other utilities were reviewed along with several NUREGs and INP0 Good Practices to ensure appropriate guidance in this area. This will ensure that newly generated and existing procedures are assessed.

Rannonsible ornanization Site Procedures Due Data Complete d.

Electrical Preventive Instruction, BPI-0-000-MDT 201, required certain motor double shielded bearings to be replaced but does not specify en allowed replacement. A work package which included this EPI for work on en air-wash penp motor did not provide this information either.

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PROCEDURI OUAL11f Continu:d) 2.

Baaia -(Coatinued) d.

(Continued)

L RESPONSE / ACTION PLAN l'

EPI-0-000-MOT 001 (201 suffix in ORE basis for concern is a typographical error) is a general preven'tive maintenance procedure for lubrication of motor bearings. Since it is a generie t -

procedure, specific part nasbers are not listed for replacement motor bearings. Nevertheless, non-Intent Change No. 10'(NIC-10) to the procedure was issued to specify bearings that could be used in this specific motor. EPI-0-000-MOT 001 has been changed to include types of bearings that are not to be used in these cases and directs the craftsmen to obtain additional planning information should these bearings be encountered.

It was decided at the' start of the maintenance procedure' upgrade program that a generic preventive maintenance procedure was more l

practical than individual procedures for each type of motor.

Therefore, it was impractical, and not justified economically, to include piece part information for each motor type in a generic procedure.

3 Procedure deficiencies, in general, are being reduced due to more rigorous reviews instituted pursuant to SDSP-2.11, " Implementation i

and Changes of Site Procedures," and SDSP-7.4, " Procedure Reviews."

q e.

A procedure to check radiological control air sampler flow referred to an appendix for the proper hose, but the' appendix did not specify the-size. The team observed a 1/4-inch hose being stretched over a 3/8-inch connector.

RESPONSE / ACTION PLAN i

This hose is supplied by the manufacturer.of the instrument and is stored in the kit with the manometer. This calibration instrument is the only one used by RADCON vbers a hose connection is not made with a mechanical fitting attached"to the hose.

The. subject procedure has been revised to specify the proper hose to be used.

Reanonsible Graanization RADCON Due Data Complete 0366W 56 l'

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PRocRDURR. 0DALITY (Contiated) 3.

&&Ria (Contianed) f.

A mechanteal asiatenance prn edure for aligament of a diesel generator lobe e'l circulatson pump to motor specified a minimum torque value for motor feet-to-foundation bolts. This is poor wording state "minimus" would allow any value over that, however great, to be seteptable.

RERPOEgR/ACT10B PLAR The sited someera is not correct. Mt!-g is the plaat instnetton which addresses malatensace of the standby diesel generator engines. This instructica implements the vender recommended asiatenance program for these engines.

Section C, step 9.16.4 specifies the required torque value for the feet-to-fondation bolts of the diesel g uarator lobe oil circulation piasp. This value is specified as 18 feet pounds and a miniana torque value is not specified. It is customary in industry and TVA to met specify

• a toleranes when specifying torque values. TVA relies on the skills of qualified craftsmen to achieve the specified torque subject to the calibration accuracy of the torquias device used.

This particular step also has 6, goality control hold potat for verificationi Additionally, craft personnel have been reinstructed as to the proper methods of torquing as stated in the response to concern I of this report.

3 A procedure for calibration of a water level indicator for a condensate pot off a EPCI turbine supply line did not adequately specify the adapters and test fixtures needed to perform the calibration. For example, no sketches of the fittures were included.

2RSPONSE/ ACTION PLAN All level indication instrumentation far IPCI is now calibrated by upgraded calibration instructions. 8pecial calibration configurations and takt equipment are included as a part of these procedures.

Ranaensihia Graanization Maintenance Dum Data Ceaplete 0366W 57

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• n (Contin:d) 4 I

2.

Agais (Continued) h.

An 81.4.8.5.2 en effluent monitoring that covers refueling floor i

seatinuous air monitors listed locations for three of the 1

contianous air monitors incorrectly.

J RESPORRE/ ACTION PLAR

)

81.4.8.5.2 is being revised by the Chemistry group to correct these deficiencies.

l Ramaanaihla Ormanimation 3

Chemistry i

Dna Data October 1, 1990 j

1.

Another coneers (Item # L) within this report discusses problems q

with themistry procedures. Concern for excessive signatures and initials in procedures is covered in item # M of this report.

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RESPONSI/ACTIoE_ E&E...

As stated in the response to concern L, efforts are underway to streamline and simplify the C!s and the chemistry-related sis.

The concern regarding excessive signatures, is addressed in the response to concern M and has resulted in a reevaluation of the site philosophy and a revision to the style guide to optimize the I

use of signatures / initials in proceduret Please refer to l

concerns L and M for further details r w eding these actions.

I

j. Procedures in tacying degree did not meet the specific procedure style and writers guides in Plant Managers instructions.

Moreover, these style and writers guides generally did not reflect the mots up-to-date guidelines on procedure preparation in TVA Nuclear Power Standards, e.g., human factor elements. Thus, these guidelines were not being reflected into RFN procedures as major revisions, rewrites, or new precedures are identified and prepared.

RESPORRE/ACTIOR PLAR Nest af the procedures discussed in this report are older procedures which were not writtaa to the BFN procedure upgrade style guide and respective writers guides. As stated in the restanse senary above, these procedures will be upgraded as l

aseied to perform work and in accordance with the approved project schedule.

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PaoctDtrar onALIrr (Conti=ed) 6 2.

34815 (Continued) j.

(Continued) 1 i

Writers guides and style guides establish format and content of

)

&FK procedures for the near term upgrade effort and are utilised to provide specific directions to procedure and instructies writers. The criteria and direettens are based upon guidance by such seuress as 15P0, the Electria Power Research lastitute, and the ERC. We have improved the SFR style guide to provide more esamples and ensure that h a an fasters elements from various searco documents are taaluded to the extent practical. This revision has been reviewed by the Nuclear Procedures staff to ensure adequate impleneataties with respect to Rutlear Power Standards.

To date, RFR has apprezinately 3700 a,2ive site procedures of which apprezimately 2500 have been upgraded. The remaining precedures will be upgraded as part of the lens term upgrade

, plan.

Ramponaihla oraanization Site Precedures i

Due Data Ongoing i

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0366W 59 1

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l ho SEN! CAL 1AMPLIEG AMD 1aALYSIS PtocEDURES

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Chemist p procedures, especially Surveillance Instructions, are.

)

enabersome, and do not consistently support the objective of gathering j

required informaties using proper control and documentation methods i

while practicing ALatA.

I tanneman ammaarv i

i Chemistry procedures are desigaod to provide a standardised methodology for such activities as sample collection, analyses, and i

data leggins /trandias..The Chemistry precedures in the Chemistry lastruction (CIs) format are much more streamlined and user friendly than Chemistry procedures in the Surveillance lastruction (SI) i format. An effort has besa ongoing over the last several years to interporate analyst comments and to streamline / simplify the CI's.

This same type offort is avv being applied to Chemistry procedures in the SI format." The majority of the items listed in the basis of this 1

sencers were already being corrected. As specified in the individual action items,below, this process is being accelerated and the scope broadened to meet the specifie Ott concerns.

i l

2.

Raaia During phase one of the ORR, a concern was expressed that Chemistry Analysts did not censistently demonstrate high standards of performance in sampling and analysis. As observed during this phase of the Ott, the methodology and technique of sampling and analysis had i

improved, but the procedures in use were not fully supportive of this objective.

In several cases observed, the procedures were detracting l-from the task of obtaining samples and data in a manner consistent l

with good practice and ALARA.

4 a.

To support the requirements of tha Technical Specifications, many routine samples and analyses have been shifted into the Surveillance program and are being conducted as 81s.

b.

81 doc eants are more comples and greatly increase the required analyst documentation of the details of the sample or analysis, compared to Chemistry Instructions (CI) used for the same activity when not requiring to meet the Technical Specifiestions.

Instances asisted where different procedures were used on different occasions for the same sample. An example was the requirement to sample reactor coolant every 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> by the SI, but it was done daily per the CI, using a less complex procedure.

c.

The CI program and its results fall under the quality program of the Chemistry Department and, therefore, have credibility. Thus, the extra administration of the 81 contribhtes nothing to the overall quality of the final product.

0366W 60

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MEK! CAL 1AMPLIER AND ARALv$f A PROCEDITRES (Cest100:d) 2.

Basis (Continued)

I c.

(Contiased)

$12POR21/ACTIOR PLAB (Basis items a - e) l The specifie precedures observed by the Okt team, (the reactor eeolant and fuel pool 31s) have been revised ce incorporate the use of CIs for sampling and analyses. The sis for routine j

.Teahaisal Specificaties surveillance requirements (those performed

. more than once/ week) have been revised to utilise CIs for sampling and analyses..

Raanannihla Ormanimation Chemistry Technical Support

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.i ds The requirementa rimposed by some new 81s often detract'from ALARA i..sencepts..because they. require more time, mostly administrative, in radiolosteal areas. To perform the taak and properly make signeffs, the analyst is forced to spend more time in the 1

radiation field and make more ehtries into contaminated areas, therefore contributing to radiological waste while increasing opportunity to spread contamination.

RESPONSE / ACTION PLAN Where sample collection or analyses is conducted in a dose intensive area, the SI has either been revised to use the CI for sampling or streamlined to reduce the admiaistrative burden.

taanonsible Ormanization Chemistry Technical support Dum Data Complete e.

Analysts comments about streamlining the sis and making them more anser friendly" during the validatism process have been countered i

with "it doesn't meet the writers guides." It would appear that i

the writers guides should have the same objectives to obtain the l

sample er conduct the analysis properly. This item is discussed La more detail in another censern (Item # K), within this report.

4 a

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GEM! CAL AAMPLIBE AND ARALYSf$ PROCEDURES (Contimed)

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Raala (Continued) e.

(Continued)

RESPOIII/ACTIOR PLAN Chemistry reviewed this concera with Site procedures staff. It was eeneinded that the 81's aan be streamlined through removal of i

usaecessary sisaeffs and by referencias of C!s already in place while still meeting the' applicable writers guides requirements.

This streamlining and/or referencing CIs is semplete for routine i

sis and these involving AL&RA esseeras. The remaining Chemistry sis will be streamlined as a part of the two-year review protess.

This ederstanJing and goal has been communicated to all Section.

Qualified Reviewers by a memorandia from the Section Supervisor.

l Rannannihia Ormanlaation Chemistry Technical 8upport ti. Dan Bata, c t.. a,, -

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Complete f.

Under observation of an CRR Team member, an 8I for. sampling Fuel pool water took 75 minutes to perform. Records of previous performance of this samplias showed it had routinely been done in a much shorter period of time.

1 RESPONSE / ACTION PLAN The fuel pool se?pling SI has been revised to use the streaalised CI for the sampling process.

Reasonsible Ormanization Chemistry Technical Support Dua Data Ceaplete.

s.

81 steps were noted to be written without templete regard for the user. For esemple, temperature corrections om eenductivity measurements were sequenced in the procedure while drawing the sample. Bowever, those corrections were not ande at the sample sink, but back at the laboratory.

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CHINICAL 1AMPL_J AND AEALYSfS PROCEDtf118 (C:h. 420d) 2.

Raals (Continued) l l-k.

Some SI step segnancing and logic were not well thought out for example, one procedure required a 100 al sample flush of the same etream before each of three separate determinations were made. The extra flushas were not technically necessary.

RRg70ERE/ACTf05 FLAN (Sasis items a and h)

The subject SI's will be reviewed to ensure the step execution segnance is legiaal.' Additiemally, laboratory personnel have provided input via 81 validations for improving the segeeneing si steps.

j Frequently perfemmed sis and those involving ALARA concerns have been revised. The remaining chemistry 8Is (approminately 67) will be i

reviewed for logical step sequence as a part of their scheduled two-year review.

YeasannihlaOrdanidatlan Chemistry Technical Support Dna Data Ongoing 1.

Much discussion was occurring regarding the need for and value of obtaining Operations concurrence, permission, or signature.for the SI performance. Bere again, the writers guide appeared to be inflazible, I

without proper regard for what Operations really needed.

RESPONSE / ACTION PLAN The need for Operations notification is being reviewed on a case-by-case basis per the guidance provided. in the $1 writers guide.

l These types of signeffs have already been removed from aany Chemistry sis. All frequently performed sis and those involving ALARA concerns have been reviewed. The remaining Chemistry sis will be reviewed as a part of their scheduled two-year review which includes review for 1.;sical step sequence and required notifications.

Tracking and performance of' scheduled and senditional sis is addressed in FMI-17.12 which was implemented en August 31, 1990.

Raanannihla Ormanimation Chemistry Technical Support f

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Ceaplete/ Ongoing l

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0366W 63

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j 12cnATtrams/IMTIALE II Pippgptf1ES l

1.

canearn The encessive use of signatures and initials throughout procedures can i

detract from the importance of verifications required to ensure safety j

and quality. The efficiency of work can also be impacted.

Raamansa suemary There is a tendency to overprescribe signeffs and ehethlist l

requirements in procedures partly due to resslatory and quality assurance influences as well as self imposed restrictions. This practice saa be to theiset. detriment of the procedure. We vill i

reevaluate our philosophy and methodology in this area and revise our writers guides to optimise use of signature provisions in procedures.

2.

Baaia

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a.

Excessive signatures and init N a create an atmosphere in which they mesa little. Reserving them for the more important steps enhances the attention that will be paid to assure the proper action.is taken.

l l

RESPONSE / ACTION PLAN Site procedures has reviewed all IRTIEGs and INp0 Good practices where guidance is given for placekeeping and verification activities to ensure that appropriate guidance is available to procedure writers and reviewers. This guidance has been made available through a revision to PMI-2.3, " Style Guide for Writing l

Instructions," which provideo guidance for all plant working level l

procedures. Also, as discussed in the response to concern K, i

item e, the ?stification and two-ye r review chaaklist in l

SD8p-7.4, " procedure Review," has been revised to include a step for assessing suitability of verification and placekesping provisions.

l The revision to the style guide was coordinated with the Nuclear procedures 8taff to implement guidance from the corporate guide, positive feedbank from several in-plant groups has been received j

en the guidance provided.

l-Rennenaihla Ormanimation l

Site Procedures i

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2.

Saala (Continued)

L b.

The reactor operator controlling rod withdrawal during startup in accordance with procedure 2-3I-4.3.5.14-1, Control Rod Coupling Integrity Check-Al Startup, is required to stop after each rod i

action to initial sad time the action. la some cases, this is for 4

i a single asteh noties. While the team recognised that rod

.I soupling and rod segnance actions most be positively ensured, the i

requirementater the operator to give his attenties to initials and time entries La tha. procedures to this autant distract him from i

his instruments.

IftheIpe'rator's'sismatureandtimearedeemednecessary, Operations should consider rehearsing this procedure at the simulator and working out the optinua use of a second DO, perhaps to the extent of revising the procedure to provide for the second

' UO to verify and sign off for the steps.

RESPONSE /ACTTON PLAN The intent of initialing each centrol rod movement is to document conformance with technical specification surveillance requirement 4.3.8.1.a which reads as follows:

4.3.5.

Control Rods 1.

The coupling integrity shall be verified for tach withdrawn control rod as follows:

a.

Verify that the control rod is following the drive by observing a response in the nuclear instrumentation each time a rod is moved when the reactor is operating above the preset power level of the RSCS.

G l

l l

0366W 65 t

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ArmtrtvaER/IMITIA1A IM PRoctDtRER (Conti!ued) 2.

Anaia (Continued) i

~

b.- (Continued)

We have reevaluated our methodology on this issue and have determined it is acceptable to remove some of the administrative i

burden imposed en Operations. The sis.itsted below beve been i

revised to delete the requirement for recording time whom each rod l

move is completed.

la addition, clarification has been added l

regarding independent verification of rod moves when the RW is J

inoperable er bypassed. Specifically, instruction steps state that when required by Technical Specifications 3.3.3.3.b and l

i 4.3.3.3.b.3 due to RW being inoperable, a second licensed operator or other technically qualified member'of the plant staff (i.e., Reactor Engineer or Shif t Tectatical Advisor) shall verify that' a operator performing rod'aovements is following the rod sequence and so document by placing taltiale in the "IV" blank for each noyamont, completed while RW is inoperable. A note was added to each Control Rod Movement Data Sheet which states that i

independent verification by a second UO or RE or STA is required GG,I when the RW is inoperable or bypassed.

' 2-81-4.3.B.1.a. Control Rod Coupling Integrity Check

' 2-8I-4.3.B.1.a-1. Control Rod Coupling Integrity Check - A1 Startup

' 2-8I-4.3.B.1.a-2, Control Rod Coupling Integrity Check - A1 Shutdown

• 2-SI-4.3.B.1.a-3, Control Rod Coupling Integrity Check.- A2 Startup

' 2-SI-4.3.5.1.a-4, control Rod Coupling Integrity Check - A2 Shutdown

• 2-SI-4.3.B.1.a-5, control Rod coupling Integrity Check - 31 Startup l

• 2-SI-4.3.5.1.a-6, Control Rod Coupling Integrity Check - B1 shutdown

' 2-51-4.3.8.1.a-7, Control Rod Coupling Integrity Check - B2 Startup i

• 2-81-4.3.B.1.a-8, Control Rod Coupling Integrity Check - B2 Shutdown Ramoannible Oremnhation Reactor Engineering Dum Data i

complete c.

Another conceau (Item # L) within this report discusses excessive j

signatures in chemistry procedures that make the procedures inefficient and increase radiation esposure.

RESPONSE / ACTION FIAN This item is addressed in the response to concern L of this report.

d.

Many initials appear to be used simply to track status of the. work rather more than to certify that a key action has been completed properly. The need to constantly signoff work or operations steps may actually detract from proper performance particularly in radiological contamination areas.

_ __.~ _. _ _ _ _ _..___.._ _._ _

_ _ _ _ _ _ _........d n

M.

11ERATtfR11/IEh11LS IN Nt0CEDtfRES (Cutined) 1 2.

&&sia (Continued) i d.

(Continued) l RESP 0BRE/ ACTION PLAN In some cases initials and checkoffs g a.used to simply track status,of completion er placakeeping in a precedure. These are placakeeping methods recessended in INFO and NRC doennents. Verification provisions saa reduce errors: however, task officiamey may decrease and stay times in radiation areas increase when verification previstoms are employed. '

The BFR 8tyle Guide has been revised to allow theckoffs after groups of; fumational steps.' This is very importsat for Al AnA considerations and where checkoffs are not practical for each action in a segusace of related steps.

The following guidane's is provided in 3D8P-2.1 relative to work in radiological contamination areas:

Procedures shall be provided and fellowed step-by-step for all tasks'where operations must be performed in a specified sequence' I

and reliance on memory cannot be trusted. Procedures need not be present for frequently repeated routine procedural action.

If documentation is required by a procedure, the necessary data shall be recorded A& 1hn 11Ak la Performed.

(STD-5.9.50. Paraneanh 5.1.5.1).

Data collected in a contaminated area (C-sone) should be!

verbally relayed to personnel outside the area, or transferred to a clean copy upon exiting the C-sone.

i As noted, provisions are available within the procedures guidelines to 1

minimise time spent in C-sones although some procedures may not be taking advantage of this relaxation. Also, as discussed in iten a, we have reviewed our guidelines on signature requirements and made thea more flexible and user friendly to meet the specific work activity l

needs.

i Rannonsible Ormanisation Site Procedures Dua Data Complets I

l l

\\

l i

i 0366W 67

p

• 3'V" N.

EEEERAL BCPLOYEE TRAINIRG 1.

Cantarn Some documentation issued for General Baployee Training check-in information was out of date, inaccurate, and did not convey a sense of professionalies.

2.

Baaia a.

The quality of the reproduced material in the headouts was often peer and presented an unprofessional ima8e.

la several cases, they were obviously copies of copies. Several were badly aisaligned with logos, etc., running off the paper.

b.

Plant Notice 9, dated March 13, 1985, referred to 8tandard

[

Practices RF-19-11 and RF-2-3.

RF-19-11 was superseded by 8D8P-32.2 on January 10, 1988, and SF-2-3 was superseded by,.

8D87 2.11 on February 20, 1986. Since these treated the issue of*

procedure adherence, the notice would be expected to demonstrate attention to detail. Further, the procedures adherence message eenvoyed Wy-the notice was considered by the ORR Tsaa to be

"~'

incomplete.

c.

Plant Notice Number 4, dated February 27, 1984, implied an exception to the eating, smoking, and chewing in regulate 4 areas.

This subject was'also included in an "All employees memorandum,"

dated December 17, 1987, which also included redundant and out-of-date information.

d.

The personnel contamination monitoring memorandum of July 7,1983, vaa not representative of current practices.

RESPORRE/ ACTION PLAN (Basis items a - d)

The concerns addressed in this section of the report are valid, howev'er, they do not represent the material distributed in the General Employee Training. The material in question was being distributed by the Browns Ferry 31anaa Resources organisation when new employees check in. The checJs-in package has been reviewed.

Poorly reproduced and/or superseded material has been removed from the packages.

Rannomaihla Ormanization Site Busan Resource Services Dua Data Ceaplete 0366W 68

N.

(C:ntinued) i 2.

R&ala (Continued) e.

Discuasions of these findings with various members of the Radiological Controis Department showed that they did not reviev l

the material, except as usera when they renew their personal I

qualification.

RESP 0ERE/ ACTION PLAR The review of the material distributed by Numan Reseurces is now a i

steading agenta iten for the RADC05 Curricula Review Ceemittee which meets guarterly at SFR to revist the training programs.

Most of this material will be eliminated since it is covered by i

ether means (GET training).

Maanonsible Ormanization Browns Ferry Training Department /RADCON Dum Date l

Ongoing i

4 4

4 1

9 9

0366W 69

r

,,.. ~

00 occtFPATIONAL 1AFETY i

1.

GentaEn l

Industrial safety practices and conditions need significant improvement to assure a consistently safe working environment.

i l

Ramoanna Sumnarv RFN management is aware of the need for imp' roved performance in the j

industrial safety area. This need was reidentified during the 1989 INp0 evaluation of RFN. It is a annagement priority to assreasively seek and implement the actions necessary to effect the needed improv enats in performance.

As addressed in the individual items below, the concerns of the 012 team are being addressed.

In addition, a a m ber of other initiatives are being taken to improve performance in the industrial safety areas. These initiatives include items such as

- Use of the NUCLEAR NETWORK for obtaining information on specific safety topics.

l

- Procedure improvements regarding review and critique of accident investigation reports,

- Evaluation of high noise areas and increased audiometric testing l-of personnel.

- A plant-wide ladder and scaffold safety audit.

- A weekly Plant Managers housekeepins and safety tour with his direct reports, modifications managers, and the Industrial Safety supervisor has been established.

I

- An improvement in the number and quality of line management j

interloc. king safety audits.

- Establishment of a plant wide safety team observation program.

A new Industrial Safety !1anaser was hired in April 1989. Since that time, Industrial Safety has received auch greater attention by management at all levels and evidence is acerning that this attention has besa to be effective in reducing safety problems. Monthly averases for important safety indicators for the past 12 months (thtough Jae 1990) have improved as follows:

Per Month Averanen Insurian Findina Data Past 12 Montha Data Lost-Time 2.90 1.03 First aid required 65.20 52s67 Sack (total) 12.13 6.54 Back (lost-time) 1.70 0.25 6

0366W 70

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OCCUPATI0BAL MT (Coatin%d)

Rannonna summarv (Continued) l In addition to these statistics, the cumulative data for lost-time injury and 1

the recordable case injury rates have improved the first nine months of this i

fiscal year as' compared to the first nine months of the last fiscal yeart i.e., the current lost-time rate is 0.43 versus 0.66 and the current j

recordable case rate is 3.04 versus 3.40.

i

• ,The Nuclear power corporate objective has been to achieve the best industrial safety record in the utility industry. In order to reach this objective, achievable Ff 1990 goals were established for lost-time injury rate, recordable case injury rate, and vehicle accident rate. 'These goals are i

monitored monthly by management at all levels. Corrective action is determined and taken when an organisation enceeds its goal. While the 8FN 1

site as a whole has not met these established goals, the data does support the conclusion that the goals are achievable. The plant organisation has, i

i for czample, met"the goals each month (this fiscal year) for lost-time injury ratu sad vehicle accident rate and the recordable case injury rate is now well below the established goal.

~

The Modifications sroup has experienced a number of recordab' a injuries in l

recent weeks. The majority of these injuries were foreign bodies in the eye incurred by craftsmen workins on drywell steel modifications. Discussions with Industrial'5afety, Modifications management,.and Ironworker representatives led to the purchase of "monosossles" for use in the drywell.

i A letter addresting the hazards involved in the dryve11 work was issued to all Modifications employees.

Site management will continue to place a high priority on achieving the needed improvements in safety performance. Management at all levels will be i

held accountable for achieving safety performance in their respective areas which meets or exceeds the site seals. The achievement of these goals will be accomplished through increased management involvement in all aspects of job planning and impissentation.

Additionally, a programmiatic assessment of industrial safety, activities will l

be conducted in preparation for the. OSRA evaluation which is scheduled for early 1991. This assessment will include participants from independent organisations such as the corporate Occupational Realth and Safety organisation and the Nuclear Managers Review Group.

g 2.

RagiA a.

When workmen struck a door frame in the reactor building with a load l

of metal scaffoldins, an electrical are was struck between the metal l

pipe sad the door frame. Follow-up of the event was routine, instead of that expected for an electrical shock hasard.

e 4

0366W 71 l

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O.

OCCtf7ATICEAL BAFETT (Continu:d) l 2.

14413 (Continued) a.

(Continued) l j

SESPONSE/ ACTION PLAN A plant ADO was with the CER Team Auditor when this concern was observed. The ADO took immediate action to have a deficiency tag placed on door 233. The AD0 also initiated paper work which resulted in a maintenance request (Mt 1025903) to evaluate the probles. No problems were found during the investigation of this MR.

J

=

Rannonsible Ormanization

)

Flant Maintenance

Dua Data Complete

~

b.

Means of egress were not consistently marked in RFN buildings as l

required by OSIA 1910.37(g). That regulation requires that access to azits shall be marked by readily visible signs with arrows indicating the direction of travel to reach the nearest exit.

l l

RESPONSE / ACTION PLAN The cited section of the OSHA standard, 1910.37(g) addresses exterior ways of exit access. The section of the OSHA standard to address the above issue is found in section 1910.37(q) Exit Markina item (5) which states: A sign reading " EXIT," or similar deaignation, with an i

arrow indicating the direction shall be placed in every location where the direction of travel to reach the nearest. exit is nel 4 - diateiv annarent. The National Fire Protection Association, Life safety Code 101, section 5, also addresses marking of exits.

l The plant la not designed or constructed in.a manner that facilitates l

full implementation of the 08EA guidelines. Restrictions related to l

security, radiological control, and containment features further complicate the situation. We will, however, survey the facility to ensure adequate markings are available for personnel evacuation.

Raanonsible Graanization Fire Frotection/ Industrial Safety Due Data October 15, 1990 c.

Tripping hasards were noted in walkways in the Turbine Buildings, Reactor Buildings, and Control Bay. These were typically obstructions reaching into the walkways caused by mategial, parts, and tools.

d.

Improperly secured welding leads, hoses, and cords were comunen on, walkways and on stairs. These represented both tripping and slipping hazards.

0366W 72

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OCCUPATIONAL Su TY (Ct2titu d) 1 2.

Saala (Continued) 4 d.

(Continued)

RESPOISE/ ACTION PLAN (Basis itens e and d) i

~

A joint walkdown of the above locations was conducted on March 24 and. l 25, 1990, by the Industrial Safety section and a line supervisor fron' Nodifications. All tripping hasards were identified and corrected.

The importance of identifying tripping hasards has been stressed to 1

those individuals performing interlocking safety audits.

1 i

Rannonsible Ormanimation Modifications Dum Data Complete e.

Tripping hasards, holes, and uneven surfaces existed in areas outside the buildings and inanediately alongside roads where no sidewalks are provided.

4 RESPONSE / ACTION PLAN A complete walkdown of plant roadways, entry points to site buildings and established sidewalks was completed on March 25, 1990, by the Industrial Safety section. Three deficient hasards were noted and corrected. This will be emphasised during interlocking safety audits.

Rennensible Ormanization Industrial Safety Due Data Complete i

f.

The barriers around a new section of sidewalk and fire systen valve installatioa southeast of the West Portal were so placed as to present a tripping hasard for pedestrian traffic.

RESPONSE / ACTION PLAN The Plant Maintenance group has renoved this barrier and established a concrete curb around the subject area. Further, full and clear

(

actess has been established on the sidewalk. In the future, in'.orlocking safety audits will emphasise these types of hasards.

Raanensibla Ormanfantion Plant Maintenance L

Dua Data Compiete g.

On two occasions observed, persons pushing large,' heavy wheeled carts were not observant of the safety of persons in the path of the vehicle. On both occasions, "near misses" occurred.

0366W 73

-e :--

00 QCCUPAT10BAL AAFEIT (ContinTd) 2.

Rania (Continued) g.

'(Continued)

RESPOR11/ACTIQR_PLAR The Industrial Safety section has generated a Safety Awareness Bulletin that addresses this unsafe act and the proper precautions to be utilised when performing this work task.

Raanamaihla_0rnanimation Industrial Safety

. Dum Data Compiete h.

The reverse motion warning device was not operational on several vehiclas, including a fork lift, a vendor's large garbage truck, and a large dump truck (# 25) used on site.

RESPORRE/ ACTION PLAN Reverse signal alarms on fork lift trucks are not required by our safety guidelines due to the unobstructed view to the rear.

For larger vehicles reverse signal alarms are required and, if inoperable, a designated flag person must be utilised to assist in safely conducting this type of movement. Dump truck No.25 was taken t

out of service on March 25, 1990 until the reverse signal alarm is repaired.

l Rampensible Ormanization Industrial Safety Dua Data Ceeplete 1.

Many persons with no eye protection were observed entering and leaving the west doors of the machine shop which is clearly posted as an " eye protection required" area.

RRSPONSE/ ACTION PLAN The Industrial Safety section conducted a site vide safety compliance audit on the proper use of personal protective equipment the week of March 26, 1990. Deficiencies noted were brought to the appropriate level of management attention for corrective action. Routine surveys will continue to focus on proper use of personal protective equipment.

Rannonsible Ornanization Industrial Safety Due Data Ongoing 0366W 74

q

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^

?

0, OCCDPAT10BAL LTTY (Contitu d) 1 3.

3saia (Contianed)

J. Workmen were observed standing within touching distance of the buckets and arms of backhoes during digging. Machine operators i

were observed on numerous occasions to move filled buchsts over other workmen.

.l RESP 0ERE/ACT10E PLAN 2

A message sa this iten has been issued to the responsible Modifications craft supervisor from the Industrial Safety y

seetles. These concerns have been addressed at the crew safety noeting with the people, performing this work. Specific safety I

instructions have been provided in order to prevent recurrence of

}

these unsafe acts. Industrial Safety has observed several ensavation operations and has met noted any recurrence of these innsafe acts...,..

Ramaannihla Graanization Modifications and plant Electrical Maintenames Dum Data

-)

Complete k.

Scaffolding toe boards were not always installed as required.

After pointing one case out to the safety department (concomias work on a steam valve to a feedvater pump), the Safety Department I

shut down several jobs to correct the scaffolding.

RESPONSE / ACTION PLAN

.The Industrial Safety section and a Modifications carpenter j

general foreman and foreman toured the unit 2 and 3 reactor buildings and turbine building March 25, 1990, seeking scaffold nonconformances in regard to the use of too boards. Two.

deficiencies were noted and corrected. The proper use of toe boards en scaffolding will be emphasised to those individuals 1

performing interlocking safety audits.

Raanana$hia Ormanimation Modifications 4

Complete t

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. m.e (Contiated) 8.

Ratig '(Contianed) 1.

Two persons on a Plant Manager weekly tour stated that "we don't some under 085&." The 01R Team noted that the TVA Safety Manual includes such of the 08HA regulations.

ERSPOERE/ ACHOR PMN i

The Plant Manager has informed all participants in the weekly housekeepias and safety tour that TVA does in fact come under OSIA regulations.

RamannalhInOrmanimation.

Plant Manager Dna Data Complete c

i -

s,..

m.

Two perseas were observed riding in the back of 4 noving van with opea doore.,.One,was,, seated on a bem near the back of the van and the other was seated on the rear of the van floor with his lege L

out the back of the van-his feet were resting on the power tailsate.

I n.

Motor vehicles appeared to occasionally exceed site speed limits, especially inside the protected area. This was especially hasardous where no sidewalks were provided for pedestrian traffic.

i o.

A workaan was observed stepping on a*s'caffolding handrail made of 2' x 4' lumber. The handrail broke under his weight.

l 1

RESPONSE / ACTION PMN (Basis items a, n, and o)

The Industrial Safety section has addressed these concerns in the same Safety Awareness Bulletin for ites a above.

Ramaannihla Ormanization Industrial Safety L.

Raa Bata Complete it O

9 e

0366W 76 l

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acctf7Aff0BAL L tty (3:ggined) 8.

Saala (Continued) p.

An electrician was observed wearing a natal vatch while working in an energised panel.

RESP 0ERE/ ACTION PLAN A message en this iten was issued by the* Industrial Safety section to the lead alestrical supervisors for the plant and Modifications addressing this unsafe act. Further, the responsible supervisors have,

reviewed this observation along with the appropriate corrective nations during crew safety meetings.

"kaanannihla Graanization Modifications and Plant Electrical Maintenance Dum Data Ceaplets q.

Although part of tha control building was posted as a " safety glasses required" area, this requirement was routinely ignored.

RESP 0ERE/ACT104 PLAN All appropriate areas of the control building have been posted as' to requirements for personal protective equipment. As stated in the response to ites i above, a comprehensive auriit of personal protective equipment has also been performed.

Emanensible Ormanization Industrial Safety Dna Data Complete r.

Safety chains at the head of heavily used vertical fixed ladders were often left shooked. Several were unhooked in low use areas. One was noted with 'a broken catch on the book and another was held in place with a single strand of wire.

l' IRSPONSE/ACTIOR FLAN The Industrial Safety section addressed this concern in the same gaiety Awareness Bulletin as item 3 above. This concern has also been-emphasised to individuals performing interlocking safety audits.

Raanenaihla Ormanization Industrial Satsty Due Data Complete 0366W 77 l

,q

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0o ACCIIPAT10EAL Aufff (Coatinced)

a. Baaia (Continued) s.

The power lead to a portable welding machine vae acted to be stretched tight by the position of the nachine.

RESPORRE/ ACTION PLAN Presently the majority of welding machines at RFR are located around

the unit 3 dryvell. A safety inspectica eetking out this concern was performed by ladustrial Safety end a steentitter general foreman. Ne deficianates were observed. This type of deficioney will be emphasised to these individuals perforatag interleaking safety audits.

Ramaannihla Ormanization Iledifications Bua Bata Complete 4

9 9

4 4

4 9

4 4

6 e

4 e

4 0

0366W 78

....... h Q

- 3

[.

APPENDIX A Okt TEAM C0f9 TENTS ON BFR PLANT FINAL Resp 0R$t DATED OCTOBER 11, 1989 TO INTERIM REPORT OF TER I

OPERATIORAL READINESS REVIEW 0F BROWNS FERRY UNIT 2 1

E1Z58 l

A status of actions from the October SFN response to the J ae 1989 011 Report,.

was provided in the form of a TROI computer printout (Action Status Report)

, to the ORE team the week of 29 January 1989.

i ht i

1.

Section II.A. of the June Ott Report asted that Operator Aids in the Control toon were not in the simulator. The Action Status Report j

indleated this had been corrected. The team noted operator aids in the r

sientator that were not in the Control Room.

. EERPONER/ ACTION FIAN A single individual in Operations has been given responsibility for Operator Aids in the plant. This includes the responsibility to ensure the simulator matches the Unit 2 control room. Whenever new or revised control room aids are produced, he ensures that the simulator is updated also.

2..The Action Status Report listed two item in the response to Section III.A. of the June ORE Report as complete which were not complete. One was issuance of a TVA Nuclear Power Standard on " Conduct of Operations."

The other was an action to revise a drawing which waa reported as complete when a drawing change request was sent to Nuclear Engineering.

RESPONSE / ACTION PLAN The purpose of issuing a Nuclear Power Standard addressing conduct of operations as stated in the response to the Interia 031 Report was to clearly define control room team responsibilities and specify the expected conservative standard of operations. At the time of the original reopense, the schedule for issuing the standard supported BFN's need. When delays were encountered in issuing the WP 8tandard, Operations management made a decision to issue the plant equivalent procedure. This fulfilled the intent of the action stated in the response to the Interia Ott Report.

y 0366W 79

.: -- - - u 3

APPENDfX A 1

i (Contice:d)

[

i-8.

(Continued)

I With the regard to the drawing conse.nt and the response to the Interim Okt Report, the only action initially identified for ORE Concern III-A involving drawings is item (s) which conceras a review of flow diagran drawings and revision by Nuclear Engineerias if aseded. Nuclear l

Engineering has been given the responsibility for reviewing and revistas draviass needed to support plant operaties and maintenance.

+

The review imeludes incorporation of associated Drawing Discrepancies and Design Change Notices. Primary and critical drawings for each erstem are issued in conjunction with the SPAE/Sp0C process prior to declaring the system operable. Essential secondary draviass, as identified by the plant staff, will be revised and issued prior to the,

breaker closure milestone. This consolidated erstematic review will taprove the consistency and usability of the drawings. Primary and critical drawings are also reviewed for legibility by Operations personnel as part of the SP0C process. Corrective actions for all Ott conceras are reviewed by Site Programs prior to closure to ensure that the actions taken satisfy the. Latent of the original response.

Ramannaihla.0rmanization Nuclear Engineering Dum Data December 24, 1990 3.

Section III.A. of the June ORR Report noted that an Operations Section Instruction Letter (OSIL) contained operational information that would more appropriately be placed in a higher tier document. The October

e !-

Response indicated that the specific 08IL and others had been incorporated into higher tier documents. The team noted that another group of documents, Operations Menos, in some cases, contained operational information (e.g., electrical system lineup requirements) which should be reviewed-for incorporation into higher tier documents.

33320NSE/ACTIDN PLAN Operations has performed a review of the operations meno book and eategorised the menos into three types and will disposition them accordingly. Those menos containing short-term information which is ne longer needed have been deleted. Those menos containing information which is still needed, but is not of a type which should be in site instructions, sill be transferred to the plant Operations Manager Instruction book. Menos containing information which should be in a site instruction will be incorporated into the appropriate instruction. These actions will be completed by June 1, 1991, and the operations memo book will be cancelled at that time. In the interim, t

the Operations Management observation Checklist requires a periodie review of the Operations meno book. The intent of this review is to identify information which is outdated, superseded, or should be incorporated into procedures. This periodic check will ensure this information is correct and appropriate.

0366W 80

i O

m :.M APPENDIX A (Continued) 4.

Section VI.C. of the June ORE toport discussed estimated' critical position (BCp) calculations and recommends taking advantage of RCp predictions during approach to criticality. The.0ctober Response did not agree. However, the team found that the Reactor Engineering Group was planning to require minism and maximum rod sequence pull steps below and above which the evolution would be, stopped and an assessment ande (i.e., it criticality is achieved before the lower limit er if it is met achieved by the upper limit).

Inston2E/ ACTION PLAR Although've disagre.1 with the origidal Ott reeemmendation, the plant staff continued to, nisate the basic issue for alternative approaches. This s'.ditional review resulted in formulation of a minimum /manism red position review method related to critical 4

position. The Rosator Engineering Group has issued a Technical Instruction, TI-204, " Approach To Criticality"'which provides for the BCp assessment referenced by the ORE team and a notification to the Shift Operations Supervisor.to halt the approach to critical if the limits are reached.

taanamaihla Ormanization Technical Support Dua Data E

Compiete 5.

Section VI.D. of the June ORE teport discussed Reactor Vessel Water Level (RWL) instrumentation. The Cetober Response discussed some actions to be taken based on the then unit 2 resetor vessel fuel loaded condition. The team noted now that the fuel has been unloaded, Technical Support is planning to do some additional testing of the RWL instruments while the fuel is out. Further, Technical Support obtained a recommendation from the General Electric Resident Insineer i

to. check the newly installed reference les piping for thermal

=

expansion during the power Ascension Program. These additional steps L

abould help ensure the operability of the RWL instrumentation. -

l RESPONSE / ACTION PLAN As recommended, Systems Engineering conducted an industry review to t

determine the types of post modification tests that were performed by

.i other BWRs that implemented siallar modifications. This industry review consisted of mine BWas, five of which performed similar modifications. The results of this review showed that the BFN poet modification test was consistent with industry practice.. The Plant Eatch test programs were unrelated to SFN, since they did not perform a similar modification.

1 e

l l

0366W 81 l

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.,....._.,.._.,.__,._.._..__._____..__m l

q APPEltDIX A (Continued)

',l The recommendation from the ORR was to vary reactor vessel level and verify that the instruments track. This additional testing vill involve a significant man-hour expenditure and will involve some, or all, of the followings e

Procedure preparation including in-depth technical reviews to prevent inadvertent Engineering Safety Feature (EST) actuations Setting of the Steam Separator in the Reactor Yessel Moving a significant voiume,of water Eeactor Vessel Road placement..

.. e,.

.e r

e Continuous cavity wetdown to avoid airborne activity

^

• '.8'ignificant Man-res Exposure.

As part of the power Ascension program, thermal expansion inspections will be performed.g specific systems. The scope of the program is as follows:

i Observe pipins systems to ensure freedom of movement without restriction by any modifications that have been made since the l

completion of OIE Bulletin 79-14 Inspection Program.

Demonstrate that the actual thermal response of critical piping is consistent with the movement data predicted by computer analysis.

t Verify that the suspension components, pipe supports, and snubbers are functioning properly.

Systems Engineering has evaluated the testing that was performed for the subject ECN and has determined that it was technically adequate for proving the installation. After review of the tests that were performed by other utilities, the post modification test performed at SFN was consistent with industry standards.

After reviewing the degree of plant inv917ssent necessary to vary reactor vessel level though its entire range and verify all the

. instruments affected respond correctly, no appreciable benefits are recognised. In addition to the possible impact on the restart schedule, this evolution might also subject the plant to potential unnecessary E8F actuations.

It is the plants position that the integrity of the reactor vessel i

l water level system be proven by the following programs, 0366W 82 i

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,m

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APPREDIE A (Continued)

Existing post modification tests as required bP each respective modification, Baisting surveillance testing requirements as required for the t

involved vessel instrumentation.

Plant Corrective and Preventative Maintenaaee Programs.

l Thermal espansion inspections as part of the Power Ascenaten 1

Prestaa.

Raanannihla Ormanimation l

Technical Support Dna. lata February 18, 1991 l

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COBCURRENCE SERIT jg 9

DOCUMENT RAMB Kanaanaa to Omarational Readinaan Review (011) - Phana Two 883821 ORIGIR& TING ORG trem Farry h1aar Plant DOCIBERT PREPARED BY

1. B. ^=*1 ten ha n/14/co Acessa!6i's0.

R94 000824 924 c.u....a..- a; name/Annovan afamaeman. emonsre nAen 55h,5 f

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8. E. Rudge PAB K, SFR bi hh i

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1.

After each individual concurs, check a or b.

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forward to next individual

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contact this person EXTENSION 2.

When concurrences are complete, forward 'o t

EITERSION 3.

Other instructions.

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