ML20101Q479
| ML20101Q479 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 07/06/1992 |
| From: | Zeringue O TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9207140296 | |
| Download: ML20101Q479 (34) | |
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Nuclear Regulatory Commission ATTNa 3ocument Control Desk Washington, D.C.
20555 i
Centlemen In the Matter Of
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Docket Nos. 50-259 Tennessee Valley Aut5ority
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50-296 BROWNS PERRY NUCLEAR PLANT (BFN) - UNI;d 1 AND 3 OPERATIONAL READINESS i
PROGRAM AND EMPLOYES CONCERNS References 1)
Letter frcm TVA to NRC, d7ttd November 12, 1991, Units 1 and 3 Operatienal Readiness Program 2)
Letter trom NRC to 'rVA, dated - Apra 1 1, 1992, Return to Service of Browra Ferry Nuclear Plant, Units 1 and 3 3)
Letter from NRC to TVA, dated June 4, 3992, Summary of the May 29, 1992, Heeting with tha Tsanesoea Valley Authority Regarding Oparrtional Re.diness Review for the Browns Ferry Nuclear Planc, Unit.:
i In Reference 1, TVA provided the NRC_ Staff with a description of the Units 3 and 3 operational Readiness Program.
In Reference 2, NRC requested a meeting to discuss TVA's planned Operational Readiness Program and a list of issues identified by the Employee Concerns Program and-Employee concerne Special Prog;am_that_would not be resolved prior to th>
restart of each-unit. As documented in Reference 3,-TVA met with the Staff on May 29, 1992, to discuss these issues.
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As discussed in that meeting, TVA committed to revise the operational Readiness Program to include a review by an independent operational j.
Readiness Review Team. The enclosure to Reference 1 has been revised accordingly-and superseded. The updated description of the operational 4
Readiness Program is included as Enclosure 1.to this letter.
I Additionally, the list of Corrective Action Tracking Documents (CATDs) l.
from the Employee concerns Special Program that are not required to be I
closed prior to the restart of each unit is included as Enclosure 2 to l
this letter. While some of.the listed.CATDs may be closed prior to the j.
restart of Units 1 and 3, their closure is not-considered to be a-restart
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prerequisite.. open employee concerns will continue to be processed-in i.
accordance with approved Concerns Resolution StaJf procedures, which establish the priority of corrective actions based on the safety-
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eignificance of the issue.- This is consistent with the approach taken for l
Unit 2 restart.
l A summary list of commitments contained in this letter is provided as If you have any questions, please contact R. R. Barons Manager of site Licensing, at.(205) 729-7570.
9-i sincerely, 1i l
O' J.
Zer!;ngue Enclost re -
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N); Resident Inspector -
Br iwnt Ferry Nuclear Plant' i
Rouch 12, Box 637 -
1 Ather.',' Alabama 35611-Mr. Thierry M. loss, Project Manager U.S._ Nuclear Regulatory-Commission i
One White Flint, North 11555-Rockville Pike Rockville, Maryland 20852-i.
Mr. B.: A. Wilson, _ Project Chief f
' U.S. Nuclear Regulatory Comission
-Region II i
101 Marietta. Street, NW,' Suite'2900-4 l
Atlanta, Coorgia 30323
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ENCLOSilRE 1 BROWNS FERRY NUCLEAR PLANT (BFN)
UNITS 1 AND 3 OPERATIONAL READINESS PROGRAM INTRODUCTION 1
This enclosure provides an overview of the Unit 2 Operational Readiness Program, a discussion of lessons learned, a description of the differences between the Unit 2 and the Units 1 and 3 operational Readiness Program,-and an outline of the program to transfer Units 1 and 3 to Browns Ferry Operations.
OVERVIEW OF THE UNIT 2 OPERATIONAL READINESS PROGRAM The purpose of the' Unit 2 Operational Readiness Program wGs to provide TVA management with assurance that the required systems were operable, the i
organiratian was in place and personnel were-able to conduct operations safely, and the activities, programs, and'. commitments' required for Unit 2 restart were complete. :This comprehensive effort was considered necessary because of the extended duration'of the outage, changes in the site and support organizations, realignment of responsibilities, implementation of new programs to correct past probloms, and the extensive plant upgrades implemented during the outage.. This program was described by TVA in References 1 through S.
HRC review and approval of.this program is documented In References 6 and */.
NRC inspections of Unit 2 readiness to operate are documented in References 8 through 14.
A tiered approach was used to evaluate the readiness of LFN Unit 2 to operate.
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I The three primary elements were:
l A Senior Management Assessment of Restart Team (SMART) provD'ad an-e overview of the. restart preparations.
This team consisted o TVA Vice Presidents within Nuclear Power.
Their ultimate purpose was to provide a recommendation for plant restart to TVA's Senior Vice President,-
Nuclear Power.
Independent reviews were performed by internal TVA' Organizations, including an Operational Readiness Review performed at the' direction of the Senior Vice President, Nuclear' Power.. Independent reviews by.
external organizations included the'American Nuclear In'aurers,-Nuclear Mutual Limited, and the Institute-for-Nuclear Power Operations (INPO).
A Browns Ferry Self Assessment-for Operational Readiness Program was'
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conducted. This vite-program verified the-completion ~of restart commitments, addressed organization and' program re'adiness using an,INPO
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type.self accessment,..and ensured the implementation of a methodology-i for returning systema'to ser' rice.
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ENCLOSURE 1
- Page 2 of M BROWNS FERRY NUCLEAR PLANT.(BFN)
UNITS 1 AND 3 OPERATIONAL READINESS PROGRAM i
(CONTINUED)
The overall layout of the Unit ' Operational Readiness Program is shown below l
in Figure 1.
I FIGURE 1 OVERVIEW 0F UNIT 2 OPERATIONAL. READINESS PROGRAM FENIOR IGNAGEMENT ASSE85HENT 0/'
RESTART TEAM (SHART) OVERVIEW
!'I INDEPENDENT REVIEWW-Nuclear Safety Review Board Quality Arsurance e
Operational Readiness Review Team e
Nuclear Insurers o
Institute for Nuclear Power Operations r
m SELF ASSESSH5NTS FOR OPERATIONAL READINESS OPERATIONAL READINESS PROGPAM e
Implementation of Browns Ferry nuclear-o Performance Plan (DFNPP) Commitments An Evaluation of Performance Objectives o
Verificatton of Restart Prerequisites o
" WALKING YOUR SPACES" PROGRAM e
- FOCMED SELF-ASSESSMENTS J
A summary of.each of the reviews follows.
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ENCLOSURE 1 Page J of 15 BROWNS FERRY NUCLEAR PLANT (BFN)
UNITS 1 AND 3 OPERATIONAL READINESS PROGRAM (CONTINUED)
SENIOR MANAGEMENT ASSESSMENT OF RESTART TEAM (SMART) OVERVIEW The objective of SMART was to ensure that appropriate standards of excellence were achieved for the restart of BFN Unit 2.
The SMART overview of s'artup preparations included a combination of reports from responsible management, results from independent reviewe, and personal observations.
In their overview, SMART used the following six acceptance bases to assess the plant's readiness for restarts Commitments made to NRC that were t'.ed to restart were resolved.
Work required to entablish operability of systems required for rectart was complete.
e The self-assessmqnt p;ogram was established a nd ef f ectively implemented.
Independent review results were evaluated and rectart related corrective e
actions were verified as completed and longer term actions scheduled, e
Pertinent performance indleat 're were established and performance trends were petisfactory for restart.
A power ascension program, including NRC hold points, was established.
INDEPENDENT REVIEW Independent reviews were performed by internal TVA Organizations, including a special Operational Readiness Review performed at the direction of the Senior Vice President, Nuclear Power.
Independent reviews by external organizations included the American Nuclear Insurers, Nuclear Mutual Limited, and INPO.
These independent reviews provided a measure of the effectiveness of the working level self-assessments as well as an external evaluation of the general status of the recovery effort.
Summarized below are examples of independent reviews which provide' readiness information to line management and to SMART.
NUCLEAR SAFETY REVIEW DOARD (NSRB)
The NSRB is TVA's offsite safety review board.
The NSRB assessed the status of preparations for restart of BFN Unit 2 from a safety oversight perspective.
This review included an overall assessment of the restart plan for BFN Unit 2, the. restart test program, and issues from past NSRB meetings.
NSRB provided recommendations to assist-the Srnior Vice President, Nuclear Power, in his decision to approve restart.
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i EldCLOSURE 1 Page d of 15 BROWNS FERRY NUCLEAR PLANT (BFN)
UNITS 1 AND 3 OPERATIONAL READINESS PROGRAM (CONTINUED)
QUALITY ASSURANCE (QA)
Site QA and QA audit organizations performed numerous independent reviews of programs and actions related to the restart of BFN Unit 2.
Examples of these reviews are provided belows Independent verification of the closure of restart commitments e
identified in the Browns Ferry Nuclear Performance Plan (BFNPP).
An operational readiness assessment based on a safety Systs-Functional e
j Inspection.
i Monitored the Design Baseline and Verification program.
e the annual QA assessment provided a comprehensive review of the l
e effectiveness of BFN's implementation of the QA program.
J OPERATIONAL READINESS hEVIEW TEAM The Senior Vice President, Nuclear Power estaolished an independent review team to assess the overall restart readiness of DFN Unit 2.
The team consir'.ed of both senior level TVA managers and equivalent level experien ed personnel from outside nuclear organizations.
This assessment was conducted in three phases and primarily f'oeussed on the readiness of the operating and support organizations to perform restart testing, start-up, cperations, and j
maintenance. Three reports were issued and the concerns raised in these reports were resolved.
NUCLEAR INSURERS The American Nuclear Insurers performed several inspections of plant vperations during the recovsry period.
Nuclear Mutual Limited performed their standard inspections.
Results and recommendations from these inspections were used to gauge progress and were evaluated by SMART in determining restart readiness.
INSTITUTE FOR NUCLEAR POWER OPERATIONS During 1988 and 1989, INPO mado five assist visits to Srowns Forry and evaluated maintenance, work control, and human performance.
INPO annual evaluations were conducted in April 1988 and 1989 and covered all major fune 'onal areas. The findings and recommendations from those evaluations and visi. were used to improve operations and processes and also provided performance based comparisons of the effectiveness of the recovery initiatives, j
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ENCLOSURE 1 Page 5 of H DROWNS FERRY NUCLEAR PLANT (DFN)
UNITS 1 AND 3 OPERATIONAL READINESS PROGRAM (CONTINUED)
SELF. ASSESSMENTS FOR OPERATIONAL READINESS The self assessments for operational readiness consistad of three elements:
the site managed BFt1 Operational Readiness Program, the " Walking Your Spaces" Program, and focused self-assessments. A summarl' of each of these reviews is provided below OPERATIO!1AL READ!!1ESS PROGRAM The site managed self assessments for operational readiness of Unit 2 eddressed the following three primary program elements:
Implementation of the Drowns Ferry tiuclear Performance Plan commitments j
i An evaluation of performance objectives for principal organizations e
Verification of restart prerequisites e
A summary of each of these reviews is provided ao follows:
Browns Ferry tiuclear Performance Plan Implementation The first element of the site managed Operational Readiness Program ensured that the BFilPP restart commitments were resolved prior to restart.
This program ensured that major restart commitments, such as Appendix R and Environmental Qualification, were completed.
Performance Objectives Evaluation The second element of the site managed Operational Readiness Program involved the establishment and assessment of performance objectives. 'The purpose of the performance objective evaluation was to ensure that line organizations functioned effectively and were prepared.for plant restart and operations.
This effort was considered necessary because of the extended duration of the outage, changes in the plant orgard eatic ns, realignment of responsibilities, implementation of new programs to correct past problems, and the extensive plant upgrades implemented during the outage.
The performance objectives evaluation was an assessment of station personnel, programs, practices, and management effectiveness using industry standards of excallence as guidance for comparison to actual plant practices.
This site conducted activity tunt,tioned in a manner similar to an ItiPO evaluat. ion.
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ENCLOSURE 1 -
Page 6 of n j
i BROWNS FERRY NUCLEAR PLANT (BFN) 1 i
UNITS 1 AND 3 OPERATIONAL READINESS PROGRAM I
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Restart Prerequisites Verification The third element of the BFN Operational Readiness Program involved the development and verification of checklists to ensure that equipment status supported restart.
The purpose of these checklists was to provide a systematic metnod to ensure that open work and outstanding programmatic items 3
affecting system operability were dispositioned prior to declaring a system operable.
The checklists addressed the following areas:
Maintenance / work request backlog Outstanding hold orders e
e Modification status Temporary alterations
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- Surveillance status
- Preventative maintenance status e
Instrument maintenance status Chemistry control e
+ Restart testing
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Outstanding equipment problems e
Drawing adequacy e
Procedure adequacy j
Design basis e
" WALKING YOUR SFACES" PROGRAM The " Walking Your Spaces" program was a one-time, limited duration program focused on increasing management awareness of field activities and presence in the field, Corrections were made on the spnt or documented for later attention as necessary.
Each manager reported either verbally or in writing the significant results of nis walking spaces to his immediate supervisor.
Thic was a one-tiite, limited duration program which was concluded prior to the restart of Unit 2.
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FOCUSED SELF-ASSESSMENTS 4
Several focused self-assesamonts were conducted in the early stages of the recovery effort to provide in-depth reviews of plant functional areas.
The purpose of these assessments was to compare actual plant performance to site.
performance objectives and other performance criteria based on established standards of excellence (e.g.,
The following subjects were selected for the focused self-assessments:-
e Maintenance Radiological Control e
e Operations Technical Support (System Engineering) e Chemistry e
ENCLOSURE 1 Page 7 of 15 BROWNS FERRY NUCLEAR PLANT (BFN)
UNITS 1 AND 3 OPERATIONAL READINESS PROGRAM (CONTINUED)
LESSONS LEARNED SENIOR MANAGEMENT ASSESSMENT OF RESTART TEAM p 4RT) OVERVIEW The SMART provided valuable oversight and shared the combined experience of senior Nuclear Power managers.
The SMART review will be repeated as part of the return to service of DFN Units 1 and 3.
INDEPENDENT REVIEWS The independent external raviews and QA audits and oversight provided objective and constructive guidance from unconstrained viewpoints.
The normal periodic reviews by INPO, the American Nuclear Insurers, and Nuclear Mutual Limited will be included in the Operational Readiness Program for-Units 1 and 3.
The QA function for Units 1 and 3 has been augmented by technical audits of the contractors; those reviews will be included-in the Units 1 and 3 Operational Readiness Program.
As discussed with the NRC Staff on May 29, 1992, an independent operational Readiness Review Team (ORRT) will evaluate programs and management systems directed towards multi-unit operation.
It will be conducted as a single phase review with additional phases scheduled, as required.
This evaluation will be based on lessons learned from the Unit ? Operational Readintas Review and current plant operating experience.
It will include such items as staffing of key organizations, support of multi-unit operation (e.g.,
prioritization of work orders, coordination of LCO's, who has authority to make decisions on shift), implementation of the System Preoperability Checklist (SPOC) and System Plant Acceptance Evaluation (SPAE) programs (discussed below), and Unit 1 separation.
The staffing of the Units 1 and 3 ORRT has not been finalized. However, consideration is being given to personnel from TNPO, TVA's corporate office, the NSRB, and contractors.
Reconcendations f rom the ORRT will be forwarded to SMART for review.
SELF-ASSESSMENTS FOR OPERATIONAL READINESS The BFN Unit 2 Operational Readiness Program used a checklist approach to ensure that equipment status supported restart.
These checklista provided a systematic method to ensure that open work, outstanding programmatic items affecting system operability, and required system testing.and open items were dispositioned prior to declaring a system perable.
Detailed descriptions of the SPOC and SPAE checklists are contained in References 15 through 17.
Items included in the SPAE_ checklist (such as drawing updates, closure of unveritied assumptions used in engineering calculations, etc.) were, in many cases, dispositioned just prior to the return of a system to service.
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ENCLOSURE 1 Page 6 of M DROWNS FERRY NUCLEAR PLANT (BFN)
UNITS 1 AND 3 OPERATIONAL READINESS PROGRAM (CONTINUED)
The ability to define the scope of work required to return Units 1 and 3 to service early in the outage recovery process allows Units 1 and 3 to coordinate this w(rk in a more systematic method.
Closure of items will be more closely tied to completion of the associated programs.
Therefore, Units 1 and 3 SPAE processes will utilize enhanced checklists which reflect the incorporation of many of the detailed checklists into the closure processes of the individual programs.
The Unit 2 performance objective evalur. tion ensured that line organizations function effectively and were prepared for plant restart and operations.
The successful restart and continued operation of Unit 2 demonstra e the successf ul completion of this objective.
Since Units 1 and 3 will be returned to service by the same organization responsible for the restart and operations of Unit 2, a separate re-evaluation of the operations organization and its.
programs and procedures is not necessary. However, an evaluation of such items as staffing of key organizations, support of multi-unit operation, Unit 1 separation, and the increased staffing requirements caused by the return to cervice of additional unit (s) will be included as part of the Evaluation of the Unique Aspects of Multi-unit Operation.
The f ocused self-assessmente perf orn.ed by site organizations prior to the restart of BFH Unit 2 provided in-depth reviews of plant functional areas as well as evaluations of identified problems.
The purpose of these assessments was to compare actual plant pe;formance to site performance objectives and other performance criteria bas <.d on established standards of excellence.
The Browns Ferry Operations organization continues to monitor performance tret.ds during Unit 2 operations and will continue to monitor performance as Unite 1 and 3 are turned over and returned to service.
Additional focused self-assessments as part of the Units 1 and 3 operational readiness program is not required.
The " Walking Your Spaces" program was a one-time, limited duration program focused on increasing management awareness of field activities and presence in i
the field. This program was concluded prior to the restart of Unit 2.
As such, Units 1 and 3 do not require a formalized " Walking Your Spaces" program.
ENCLOSURE 1 Page f of 15 BROWNS FERRY NUCLEAR PLANT (DFN)
UNITS 1 AND 3 OPERATIONAL READINESS PROGRAM (CONTINUED)
DIFFERENCES BETWEEN THE UNIT 2 PRECEDENT AND THE UNITS 1 AND 3 PROGRAM TVA's overall commitment to use independent and self assessment programs, in order to achieve and maintain excellence, remains unchanged.
The Units 1 and 3 Operational Readiness Program is being enhancsid to take advantage.of the j
lessons ; earned from the restart of Unit 2 and to addreas the unique aspects ef the return to service of Units 1 and 3.
One purposa of the Unit 2 Operational Readiness Program was to evaluate personnel performance and standards. Adequate levels of personnel performar,et have been established and continue to be monitored.
Appropriate standards Are in place.
The restart of Unit 2 and its continued safe operation. demon.atrates that this objective has been met.
The focus of the Units 1 and 3 Restarc organization and its Operational Readit.ess Program is in readying the individual units for restart, as opposed to operational management activities.. A comparison between the Unit 2 -3nd the Units 1 and 3 Operational Readiness Programs is shown below in Figure 2, 4
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FIGURE 2:
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COMPARIS0N BETWEEN THE UNIT 2 AND UNITS.1 AND 3 OPERATIONAL READINESS PROGRAMS i
- UNIT 2 UNITS I AND 3 j
OPER ATIONAl, READINF%S PROGRAA1 OPER ATIONAl, READINESS PROGRANI -
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1 SENIOR AIANAGEMENT ASSESSNIENT OF SENIOR MANAGEMENT ASSESSMENT OF j
RESTART TEAM (SMART) OVERVIEW -
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1-INDEPENDENT REYlEWS
~ INDEPENDENT REVIEWS -
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- Nuclear Safety Reuew Board
- Nuclear Safety Re,w Board j
- Quality _ Assurance o Quality Assurance j
e Operational Readiness Review Team
- . Operational Readiness Review Team -
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e Nuclear insurers
- Nuclear insurers --
1 Institute for Nuclear Power Operations
- - Institute for Nuclear Power Operations e
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l SEl.F ASSESNM5:NTS SEl,F ASSESSMENTS-FOR Ol'ERATIONAl. READINESS FOR OPERATIONAL, READINESS -
e OPERATIONAL READINESS PROGRAM '
-- e OPERATIONAL' READINESS PROGRAM.-
o implementation of the Browns Ferry '
o implementation of the Special Programs
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Nuclear Performance Plan (BFNPP).
c' Evaluation of the Unique Aspects a l-0 An E,aluatism 6f Performance Objectives Multi unit Operatio" l
o Verification of Restart Prerequisites o-Verification of Restart Preren" les -
E o " WALKING YOUR SPACES
- PROGRAM e FOCUSED SELF-ASSESSMENTS 1
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ENCLOSURE 1 Jage il of 15 BROWNS FERRY NUCLEAR PLANT (BFN)
- UNITS 1 AND 3 OPERATIONAL READINESS PROGRAM
)'
(CONTINUED)i e
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. SENIOR MANAGEMENT ASSESSMENT OF RESTA.3T TEAM OVERVIEW OF UNITS 1 AND 3 I
s The SMART review will be repeated as_part of the return to service.of BFN 1
Units-1 and 3.
The direction, seniority of membership, and cbjective of the SMART overview of Units 1 and 3 will remain unchanged.
INDEPENDENT REVIEW OF UNITS 1 AND 3 i
Input from the independent reviews _of. Units 1 and 3 will continue to be used in order to provide a~ measurement of the offectiveness.of the'workingLlevel self-assessments, The normal independent reviews by-INPO, American Nuclear-i Insurers, Nuclear Mutual-Limited, NSRB, and QA will be utilized =to assess l-ret.diness for restart. The independent Operational Readiness Review Team will r
evaluate programs and management systems directed towards multi-unit operation.
it-l SELF-ASSESSMENTS FOR OPERATIONAL READINESS OF UNITS 1 AND 3 4
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The self assessments for operational readiness of Units 1 and 3 will-consist j
of a site managed Operational Readiness Program.. This program w'll focus on the implementation.of the speci 1 prc, grams, the additional resources required for operation of the additional unit, and completion of. restart prerequisites.
(
As discussed in the Lessons Learned.section, a_special " Walking Your Spaces" I
. Program and focused'self-assessments are-not required,for'the. Units.1 and 3-
. Operational. Readiness Program. A summary of the changes.between the Uqit 2 Self-Assessment for Operational Readiness program and the_ Units.1 and program is provided as follows:
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~ Implementation of the Special Programs 1-As stated ~in Reference 18,1TVA considers the submittal and subsequent 1j' revisions to the Corporate Nuclear Performance Plan _and the BFNPP. collectively i-satisfid thefrequirements of the-NRC's September.l'1,;1985. request-for-BFN pursuant to__10-CFR 50.54(f'.
ReferencesL18 and 19 document the completion of'
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i-the-BFNPP corrective actions for Unit'2 restart. Therefore, TVA considers the
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BFNPP applicable only to Unit _2.
The program elements associated'with the.
- implementation of the BFN.P'for-Unit 2.will:be Lplaced with an; assessment of F
the:special programs for Units 1 and 3.
The applicability of=theseaspecial j
programs to the restart of Units 1 and 3'was detailed'in Reference 20 and-subsequent program specific submittals.
The. completion of the: commitments
. contained in the.BFNPP was_-verified.by? Site 1.icensing and independently-reviewed-by QA prior-.to the' restart of Unit 2.
The completion-of;the special
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programs on Units-1.and-3 will be verified by Restart: Licensing and independently reviewed an a case-by-case _ basis as--determined by.'Rostart Licensing.
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ENCLOSURE 11.
- Page 12 of 15 BROWNS FERRY NUCLEAR PLANT (BFN)-
UNITS 1 AND 3 OPERATIONAL READINESS PROGRAM
.(CONTINUED)j Evaluation of the Unique Aspects'of Multi-unit Operation 1 The purpose of the Unit 2 performance objective evaluati,n was to ensure that-line organizations function effectively and were. prepared for'plantLrestart and operations.
The. performance objectives evaluation was an assessment-of station' personnel, programs, practices, and management effectiveness.using industry standards of' excellence.as guidance for comparison t'o actuai' plant-practices. The evaluation of Units 1 and 3 will focus on the staffing, j
. experience, qualifications and training of: the additional Browns Ferrya operations personnel required to support the return to service,-operations, j
and maintenance otethe additional units.
It'will also-include prioritization of work orders, coordination'of-LCO's,'who has authority,o make decisions on shift), implementation-of.the SPOC and SPAE programs,-and Unit 1. separation.
Verification of Restart Prerequisites The BFN Unit 2 Operational Readiness Program l involved the. development and verification of checklists to ensure ahat equipasnt status supported. restart and that. start-up commitments-and programs _were completed.
The ability to.
define'the scope of work required to return Units-1.and 3 to service early in' the outage recovery-process allows Units 1-and-3 to' coordinate this workEin a' more systematic method..This enhancement to the restart process allows BFN to implement improvements to the restart prerequisites. verification process.
Completion of items such as drawing updates, closure of unverified' assumptions used'in engineering calculations, maintenance requests, etc., will be more closely tied to completion of the associated 1 programs. Therefore, the-checklists' associated with the return to. service'of. Units 11 and-3-systems will not require the same level of detail associatedEwith the Unit 2'3PAE' processes.
CONCLUSION 1
TVA's'overall commitment to use independent and self assessments programs, in order to achieve and' maintain excellence, remains unchangod.. The overall 1
Units 1 and 1 Operational. Readiness Program will proceed lin-a. manner similar.
I to the Unit 2 precedent.
The Units 1-and 3,OperationaliReadiness. Program will result'in the same.. level of assurance as the. unit.2 program.'.The. differences between the units 1 and 3 program and the. unit:2 precedent were_ designed to
~ incorporate lessons learned from1the BFN Unit'2 experience'and to address _the unit-interactions and differences introduced by the return-toiservice of!BFN Units 1 and 3.
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UNITS 1 AND 3 OPERATIONAL READINESS PROGRAM (CONTINUED)
NRC's Safety Evaluation of the Unit 2 operational Readiness Program is documented in References 6 and 7.
However, the majnrity of the evaluations of BFN's operational readiness were documented in NRC Inspection Reports.
An particular, the NRC conducted two Operational Readiness Assessment Team (ORAT) inspections just before the restart of Unit 2.
TVA expects the regulatory framework for the assessment Units 1 and 3 operational readiness to be similar to the Unit 2 precedent.
Therefore, TVA does not consider a specific SER necessary to document tho acceptability of the minor differences between the Unit 2 and the Units 1 and 3 Operational Readiness Programs,
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BROWNS FERRY NUCLEAR PLANT (3FN) j-UNITS 1 AND 3 OPERATIONAL READINESS PROGRAM
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.(CONTINUED)
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References I
Descript!on of the Browns Ferry Unit 2 Operational: Readiness Program-
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- 1) TVA letter,-dated August 28, 1986, Browns Ferry Nuclear Performance Plan 2)
TVA' letter, dated July'1, 1987, Revision 1 to the Browns Ferry Nuclear-Performance Plan f
- 3) TVA-letter, dated August 24, 1988, Management Self Assessment ~ (MSA)'of
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Readiness for Restart i-s-
- 4) -TVA letter, dated October 24, 1988,aRevision 2 to.the Browns, Ferry.
i Nuclear Performance Plan-tc
. operational ~ Readiness (OR)' Program
- 5) TVA letter,--dated December 23, 1988, f
i 1
NitC Safety Evaluations 7-4 5
- 6) NRC letter, dated October 24,-1989,- Supplement I to_the Safety Evaluation Report of the Browns-Ferry-Nuclear Performance Plan -
}
NUREG-1232,~ Volume 3 1
t
]
- 7) NRC letter, dated January 23, 1991, -- NUREG-12 32 ; Volume 3, supplement 2, l-Browns. Ferry, Unit L' i-L NRC Inspection Reports a
- 8) NRC letter, dated May 23 1986, Report Nos.:- 50-259/86-14;: 50-260/86-14 =
i and 50-296/86-14
- 9) NRC letter, dated January 12, 1987, Report Nos.. 50-259/86-32, j
k 50-260/86 32 and-50-296/86-32
- 10)
NRC-letter, dated August 5,.1987, Report Nos._50-259/87-26, 50-260/87-26 f-Land 50-296/87-26
- 11). LNRC = letter, ' dated April '10, [1989, Report'Nos. 50-259/88-36,'50-260/88-36 ic and 50-296/88-36 12)c NRC letter, dated February 1,1 1990, Report Nos..
[
50-260/89-60 and 50-296/89-60' 50-259/89-60, n
.13 ) - NRC letter, dated April-12,_ 1991,.NRC Inspection. Report 50-260/91-201-f Browns Ferry Unit 2 Operational Readiness Assessment-Team Inspection 4
9 i
i 2
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g 4
ENCLOSURE 1 Page 15 of 15 BROWNS FERRY NUCLEAR PLANT (BFN)
UNITS 1 AND 3 OPERATIONAL READINESS PROGRAM (CONTINUED) 14)
NRC letter, dated May 30, 1991, NRC Inspection Report 50-260/91-202 Browns Ferry Unit 2 Operational Readiness Assessment Te,sm Followup Inspection Unit 2 Prerequisites
- 15) TVA letter, dated July 6, 1988, Prerequisites for Fuel Reload 16)
TVA letter, dated October 21, 1988, Prerequisites for Reloading Fuel in BFN Unit 2
- 17) TVA letter, dat ed December 29, 1988, System Status Control other Correspondence
- 18) TVA lettec, dated April 16, 1991, Completion Status of Corrective Actions identified for Unit 2 5'7 start in Browns Ferry Nuclear Performance Plan (BFNPP) 19)
TVA letter, dated May 14, 1991, Notification of Completion of Corrective Actions Ident.*ied for Unit 2 Restart in Browns Ferry Nuclear Performance Plan (BFNPP)
- 20) TVA letter, dated July 10, 1991, Regulatory Framework for the Restart of Units 1 and 3
-...- -.....~, -...
.._.--- ~. ~ - -. ~,
~
I ENCLOSURE 2 j
i 1
BROWNS FERRY-NUCLEAR PLANT (BFN)_-
CORRECTIVE ACTION TRACKING DOCUMENTS -
i-
+
l-I-84-33-BFN-01 PREPARE AND CHECK.THE ISOMETRIC ANDl SUPPORT LOAD j;
DRAWINGS FOR EECW AND REACTOR DRAIN AND VENT SYSTEMS.
j ISSUE THESE DRAWINOS.
PERFORM AN EVALUATION-OF-l-
PROBLEM N1-110-1R.
PROVIDE VERIFICATION' DOCUMENTATION j-SUITABLE FOR AUDIT.
i' l
I 34-33-BFN-02
- BFN-DNE~ MAS NOT PROVIDED VERIFICATION DOCUMENTATION f:.
FOR THE FOLLOWING THAT.DNE ENGINEERS HAVE;BEEN MADE
' AWARE OF THE FACT THAT STRESS ALLOWA9LES-ARE NOT-TO BE.
- EXCEEDED' THAT.THE EXAMPLES OF EXCESS STRESSES ~GIVEN.
l-IN THIS REPORT.
i R-81-02-BFN-01 NSRS REPORT-R-81-BFN-01 DEVELOP A TVA POLICt REGARDING.
LOSS OF' SAFETY ~ FUNCTION!
IMPROPER INSTALLATION OF PIPING SUPPORTS.IN THE RESIDUAL HEAT REMOVAL (RHR)fhND'
{
EMERGENCY EQUIPMENT COOLING WATERJ(EECW)= FIPE LTUNNELS AT: BFN - RESULTED. IN THE POTENTI AL. FOR DEGRADi.TIONE OF l
SAFETY SYSTEMS-CAPABILITIES DURING EARTHQUAKE LOADING.
)
CONDITIONS ALLOWED BY BFN(TECH SPEC'3.5.C ARE IN j
. ERROR. WATTS BAR SHOULD'REVIEWLTHIS. ISSUE To a
DETERNINE'IF THIS. ISSUE'IS= APPLICABLE TO WBN.
e 3
R-85-07-NPS-01 NSRS REPORT R-85-07-NPS-01. MANAGER OF POWER'AND ENGINEERING-APPOINTMENT'OF'A RECORDS MAMAGER.
A' MANAGER SHOULD BE: APPOINTED TO ENSURE THAT RECORDS-OF b-QEB SOURCE INSPECTED EQUIPMENT AND MATERIALS.ARE-INDEXED AND STORED.: THE. SCOPE ~SHOULD INCLUDE ALL-PAST AND FUTURE QED SOURCE INSPECTED ~ PROCUREMENT-RECORDS h
h SWEC-BFN-05-01
. BY. ORIGINAL DESIGN AILOSS-OF OFFSITE POWER WOULD~HAVE 1'
PREVENTED l DIESEL GENERATOR' PARALLELING.
THE DESIGN ERRONEOUSLYcASSUMED THIS'.SIGNALLCOULD'BE RESET.AFTER I
10' MINUTES. WITH PARALLELING' CAPABILITY'. INHIBITED, h
FSAR SAFETY _ DESIGN BASIS COULD:NOTLBEiMET.-
SWEC-BFN-05-04 A-FIRE RECOVERY = PLAN COMMITMENT'TO' SEPARATE ADS j_
AUTOMATIC AND MANUAL. RELIEF' CABLES:WAS'NEVER-ADEQUATELY: MET' SUBSEQUENT MODIFICATIONS MALZ THE PROBLEM WORSE.
j S'.JE C-B FN-0 7 DRAWINGS FOR SEVERAL. SYSTEMS 1WHICH CONNECT _ TO - SAFETYi SYSTEMS DO NOT REFLECT IN-PLANT CONFIGURATION.
4 i.
f SWEC-LFN-09-01 THE LEVEL B3 TWEEN THE' TORUS LEVEL DETECTORS SOMETIMES WAS GREATER'THAN THE MAXIMUM-ALLOWED IN ACCORDANCE.
?
WITH TECHNICAL SPECIFICATIONS.
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ENCLCMSURE 2; Page 2 of )?
BROWNS FERRY NUCLEAR PLANT (BFN)'-
CORRECTIVE ACTION TRACKING DOCUMENTS (CONTINUED)
SWEC-BFN-17-02 IN JANUARY 1984 HPCI RESTRAINT R-24 WAS. DISCOVERED FAILED.. IN MARCH'1984 HPCI RESTRAINT.R-23 WAS.
DISCOVERED _ FAILED. JDOTH RESTRAINTS WERE IN THE UNIT 2 HPCI DISCHARGE PIPING. -NO STRESS ANALYSIS WAS SUBSEQUENTLY PERFORMED ON THIS SECTION OF HPCI PIPING TO ENSURE-PIPING INTEGRITY.
SWEC-BFN-26-01 THE. UNIT'3 HPCI.ST?%M ISOLATION VALVE-(FCY-3-73-16)
WAS-FOUND HISSING A DRIVEN RETAINER GEAR RING.
THE' PROBLEM WAS. IDENTIFIED BY TVA AFTER REASSEMBLY OF THE VALVE FOLLOWING-THE PINION GEAR. INSPECTION.-
SWEC-BFN-36-01 DESIGN CRITERIA NO.-BFN-50-D707 REV. 2-ANALYSIS OF AS-BUILT PIPING SYSTEMS, WAS PARTIALLY REVIEWED BY THE.
NRC INSPECTOR WITH RESPECT TO PIPE SUPPORT-DESIGN REQUIREMENTS.- IT WAS NOTED'THAT THE'
~
FREQUENCY / DEFLECTION. CRITERIA FOR THE PIPE SUPPORT
-DESIGN WERE NOT ADDRESSED-IN THE DOCUMENT.-
3WEC-BFN-38-02 A DESIGN ERROR WAS. DISCOVERED IN THELELECTRICAL~
CIRCUIT FOR TWO HAND SWITCHES (63-24 &J63-25) WHICH ALLOWED BY-PASSING-THE INTERLOCK FOR'DRYWELL PURGING-IN THE "RUN" MODE OF OPERATION.
SWEC-BFN-40-01 UNITS 1, 2, AND 3' DIESEL-GENERATOR BATTERY _ RACKS WERE
-NOT SEISMICALLY. MOUNTED AS REQUIRED:BY TVA.-
SWEC-BFN-44-04
. FAILURE TO DO SAFETY EVALUATI'ON ON HPCI.
SWEC-BFN-44-05 REACTOR BUILDING FLOOD 1 LEVEL SWITCHES' NOT SEISMICALLY -
QUALIFIED.-
SWEC-BFN-46-01
. INADEQUATE DESIGN CONTROLS FOR' SAFETY RELATED CALCULATIONS i]R'SAFITY-RELATED CABLE TRAY. SYSTEMS INE THE CONTROL BAY-. AREA,. DIESEL GEPERATOR BUILDING-AND FOUND'THEM TO BE IMPROPERLY DESIGNED. ; CABLE TRAY.-
-f SUPPORTcDESIGN CALCULATION IN THE REACTOR BUILDING SHOWED A LACK OF THOROUGRNESS, CLARITY, CONSISTENCY AND ACCURACY.
SWEC-BFN-46-02I THE-NRC-REVIEWED THE CALCULATIONS;FOR-THE= SAFETY RELATED CABLE TRAY. SUPPORTS SYSTEMS. ~THE INSPECTOR:
IDENTIFIED EXAMPLES'WHICH INDICATED THAT CALCULATIONS HAD EITHER NOT.BEEN CHECKED!OR IN SOME CASES-NOT SIGNED ~BY THE DESIGNER.THEREFORE,,THE REPOR7 STATES THAT DESIGN VERIFICATION HAD NOT BEEN-IMPLEMENTED IN AN ACCEPTABLE MANNER.
_________.m.
___.. ~. _ _ _.
b iz (-s i
ENCLOSURE 21 Page S of U p
BROWNS FERRY NUCLEAR PLANT (BFN)
F
. CORRECTIVE ACTION TRACKING DOCUMENTS i
(CONTINUED) i i-SWEC-BFN-46-04 NRC INSPECTION REPORT 85-41-REFERS TO A JUNE 1985
(
IN-DEPTH STUDY ~INTO CABLE. TRAY / LOADING PROBLEMS-t CONDUCTED BY';TVA WHICH CONLuvu2D THAT THE INSPECTED-4 CABLE TRAYS COULD NOT DE SEISMICALLY QUALIFIED FOR-EITHER INTERIM OR LONG TERMLOPERATION WITHOUT f
- ADDITIONAL INSPECTION AND EVALUATIONS.
SWEC-BFN-48-04
- A TVA REPORT DATED JULY-27,-1986 NOTED PROBLEMS'WITH CLOSED.OUT WORK PLANS.
AN.NRC SURVEY OF 64 WORK' PLANS FOUND THAT AN: ESTIMATED 50 PERCENT CONTAINED DRAWING DISCREPANCIES.
~
t SWEC-BFN-49-01
-TVA'HAD' REPORTED TO NRC ON AREAS WHERE LEAK RATE TEST--
l IS'NOT IN STRICT _ COMPLIANCE WITH 10.CFR 50, 4
APPENDIX-J. 'THESE AREAS CONCERNED.-. VALVES TESTED IN e
p
- THE WRONG DIRECTION,: VALVES 1 TESTED USING THE WRONG r
-MEDIUM,-AND-VALVES WHICH WERE NOT ROUTINELY TESTED l
BECAUSE THEY4WERE PREVIOUSLY IDENTIFIED AS ISOLATION'
}
VALVES DUT ALSO FUNCTIONED AS CONTAINMENT-ISOLATION VALVES.
CORRECTIVE ACTIONS =ARE BEING RACKED.UNDER NCO 85-0171-001, 002,.003, 004 AND NCO 85-029-001,
_002, 003, 005, 006, h
SWEC-BFN-51-01 COMPLETE CORRECTIVE'ACTYON TAKEN TO.CLOSE OUT NR'C f
INSPECTOR FOLLOWUP ITEMS'IFI-85-52-06s IFI-86-01-02..
F 7
THESE ITEMS ARE ALSO.BEING TRACKED AS SLT-85-1059-002 INADEQUATE PUBLIC ADDhESS SYSTEM.
SWEC-BFN-59-01
-NUMEROUS COMPONENTS ARE NOT ENVIRLNMENTALLY QUALIFIED.
{
SWEC-BFN-60-07' A PERMANENT POST-ACCIDENT SAMPLING SECTION SYSTEM IS' NOT INSTALLED FOR UNITS.1, 2, OR 3.
t' SWEC-BFN-60-20 THE 1985 SALP REPORT' STATED THE~ REVIEW OF.THE
~
INSERVICE TEST (IST)~_ PROGRAM HAS BEEN DIFFICULT'-
BECAUSE OF THE. LICENSEE *S: TENDENCY TO SEEK' WAYS TO'-
4 DISAGREE WITH NRC STAFF INTERPRETATIONS OF THE ASME.
CODE, AND-DELAYS IN THE' TIMELY RESOLUTION OF THESE:
. DISAGREEMENTS.
[-
10400-BFN-05 EFFECTS.0F A. CONCRETE EDGE ON THE' EMBEDDED PLATE" CAPACITY NEEDS'TO BE REVIEWED.
E J-1 li 4
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- ENCLOSURE 2 Page 4 of'17 i
BROWNS FERRY NUCLEAR PLANT (BFN)
CORRECTIVE ACTION TRACKING DOCUMENTS-
~ ;
L (CONTINUED);
E 10700-NPS-04 REVIEW PROCUREMENT SPECIFICATIONS FOR COPPER TUBING SPECIFICATIONS ~ARE TO CLARIFY IF BENDING QUALITY
~
TUBING (TEMPER PROPERTIES) IS DESIRED, AND IF SO j
PRFVENT ANY. SUBSTITUTION OF NON-BENDING QUALITY 4 TUBING
}
UNLESS UNIQUE: IDENTIFICATION IS UTILIZED.
i f-30900-NPS-02 ON THE.USE OF A FISHfHOOK TOOL TO BREACH FIRE BARRIERS I
WAS NOT VERIFIED. - HOWEVER, THE USE OF FISH TAPE WAS l
FOUND TO BE ALLOWABLE'IN.M&AI-13.- FISH TAPE.HAS-BEEN j.
DELETED FROM WBN MAI-14.- THIS SAME CHANGE-SHOULD BE
?
j EVALUATED AT SQN.--
4 i
3 10900-NPS-03 TERMINATIONS-USING PIDG LUGS ON' SOLID CONDUCTORS HAVE j-BEEN-QUESTIONED-IN:SCR'WBNEEB8537. 'THE CONDITION ALSO!
J' EXISTS AT SQN.
j-11103-NPS-01 CRITERIA FOR-MECHANICALLSHOCK ARRESTORS-(SNUBBERS) IS i-NOT CONTAINED IN UPPER TIER-' DOCUMENT TVA GENERAL
~
CONSTRUCTION' SPECIFICATION G-43, LAND PACIFIC SCIENTIFIC DOCUMENT NUMBER 141 HAS NOT.ALWAYS BEEN AVAILABLE AT-ALL FOUR NUCLEAR: PLANT SITES.: CORPORATE
{'
REVIEW AND RESOLUTION NEEDS'TO BEL-TAKEN SO THAT I
STANDARD CRITERIA CAN BE-ESTABLISHED AT-ALL FOUR TVA l
NUCLEAR PLANTS.
j' 11200-NPS-01
.THERE IS CURRENTLY NO'DNE CORPORATE REVIEW OF SITE.
WORK CONTROL : PROGRAMS. -LACK OF SUCH A REVIEW'
[
PRECLUDES.THE~ TRANSFER 0F PROGRAM ENHANCEMENTS FRO!!'-
j SITE,TO SITE ~AND VIOLATES THE NUCLEAR PROCEDURES j.
SYSTEM POLICY: ISSUED-BL.S. A.. WHITE ON JUNE,6,~1986 WHICH SAYS THAT THE PROCEDURES!USED AT EACH SITE FOR A
}
- GIVEN ' TASK :SHCULD BE THE SAME; NOTEL THIS.IS'NOT PART OF THE WBN EFFORT.
k-11300-BFN-04 THE PARAMETERS ~OF.NRC OIE= BULLETIN 79-02 PAVE'NOT BEEN i-FULLY ADDRESSED.AT BFN.
PERFORMANCE AND COMPLETION'OF-WORK DESCRIBED BY'BFEP>PI-86-05 AND SMMI.5.1-A ARE
- ~
REQUIRED TO-ANSWER THE REQUIREMENTS SET FORTH BY-THE
~
BULLETIN.
!?
11300-BFN-05 h
- PO'SMMI/MMI'HAS BEEN INITIATED'BY'THE SITE TO DETAIL THE INSPECTION AND ACCEPTANCE PARAMETERS (INSPECTION / ACCEPTANCE CRITERIA,.-INDEPENDENT _(QC)
VERIFICATION,-ETCl) OF THE. S AMPLE PROGRAM. DETAILED BY i
~ BFEP PI186-29.-
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ENCLOSURE 2 Page 5 of 17 l.
BROWNS FERRY NUCLEAR PLANT-(BFN) i CORRECTIVE ACTION TRACKING DOCUMENTS
[
(CONTINUED) i.
s 2
i-11300-NPS-02 GENERAL CONST.' SPEC. G-32 IS INADEQUATE'WITH RESPECT TO SSD BOLT INSTALLATION AND INSPECTION TIGHTENING ~
CRITERIA. NO ENGINEERING EVALUATION / LABORATORY' TESTS
.9TERMINE THE LFFECTS OF HAVE BEEN PERFORMED TG f
OVER-TIGHTENING _ON THE BOLT AND/OR ANCHOR SHELL.4 BOLT j
ANCHOR INTEGRITY CANNOT BE VERIFIED.
ALSO, TRAINING i
IS INADEQUATE AS INCONSISTENCIES HAVE BEEN IDENTIFIED:
g
- IN.BULT-INSTALLATION HETHODOLOGY USED BY CRAFTSMEN.
11300-NPS-03 WBN-NCR-6320.AND-THE SUBSEQUENT POTENTIAL. GENERIC 2
CONDITION _ EVALUATIONS HAVE. IDENTIFIED RUSTED / CORRODED I
CONCRETE ANCHOR BOLTS.AT.THREE OF THE NUCLEAR' PLANTS.
I 6
. EVALUATION IS-REQUIRED TO DdTERMINE THE SIGNIFICANCE =
j OF RUSTED, CORRODED CONCRETE ANCHOR BOLTS FROM A.
GENERIC STANDPOINT AS WELL AS POTENTIAL DEFICIENCIES l
IN SITE MAINTENANCE / SURVEILLANCE ~ CRITERIA.:
19200-NPS-06 INCONSISTENCIES WERE IDENTIFIED IN THE APPLICATION OF j
QA.REQUIREMENTSiFOR CONDUIT.AND. ASSOCIATED HARDWARE.
NEITHER: G.C.S.G-40 NORL TVA SPECIFICATION 21.001 CONTAIN-SUFFICIENT QUALITY ASSURANCE' STATEMENTS TO g
ENSURE THE INTENT-OF ESTABLISHED DNE REQUIREMENTS ARE
- MET.
NOTE: WORK THIS CATD WITH CAP NUMBER C019203-SQN-03, 19201-NPS-01
- THE W.S.:RAUGHLEY; MEMO,iDATED.5/14/86 DOES NOT. FULLY ADDRESS THE ACCEPTABILITY-OR PRESCRIBE.THE;NECESSARY-INSTRUCTIONS FOR ALL ACTIVE TVA NUCLEAR SITES TO -
F FOLLOW WHICH WOULD ENSURE PAST~ FLEXIBLE CONDUIT
~
- INSTALLATIONS-ARE IN-COMPLIANCE'WITH OR MEET.THE-INTENT OF GENERAL-CONSTRUCTION: SPECIFICATION G-40,
[
REV. 9i SRN 11. -IMPLEMENTATION:OF-THE: POLICY MEMO AT l
i EACH SITE WOULD ONLYLPARTIALLY ADDRESS'THE' GENERIC.
- 6 IMPLICATION OF_WBN.NCR-6529; 19201-NPS-02 G'C.6.-C-40LSHOULD BEl REVISED:TO INCLUDE SPECIFIC
--TORQUE VALUES AS REQUIRED'PER THE-. APPLICABLE MANUFACTURERS ~ INSTRUCTIONS,-RELATED TO~THE
' INSTALLATION'OFl FLEXIBLE CONDUIT ASSEMBLIES. THIS ACT' WOULD ASSURE THIS INFORMATION WAS AVAILABLE TO-THE I'
CONSTRUCTING ORGANIZATIONS.
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ii ENCLOSURE 2
-Page 6.of-17; BROWNS FERRY. NUCLEAR PLANT (DFN)-
CORRECTIVE ACTION TRACKING DOCUMENTS
. (CO.NTINUED)-
'I -
20000-NPS-01 IMPLEMENTATION OF.NEP-5.2, " REVIEW," IS'NOT COMPLETE j.
OR FULLY EFFECTIVE AT THIS TIME.
DESIGN VERIFICATION.
4 IS NOT YET FULLY EFFECTIVE AS DEMONSTRATED BY F
CONTINUED DIFFICULTIES IN COMPLETING TECHNICALLY SOUND f..
CORRECTIVE ACTIONS. - SYSTEMATIC INTERFACE OR SYSTEM.
REVIEWS ARE NOT YET'SCOPED, SCHEDULED.OR l!,
PROCEDURALIZED.- SCOPE AND METHODOLOGY-OF OPERATION i
'AND MAINTENANCE DATA REVIEWS ARE NOT AVAILABLE.
l TECHNICAL REVIEW BRANCH INSTRUCTIONS ARE NOT YET I
i ISSUED IN EEB, CEB, MEB AND NEB.
L 1
l 20000-NPS-03 NO METHOD' CURRENTLY EXISTS BY WHICH TVA ONP MANAGEMENT-CAN MEASURE SHIFTS IN EMPLOYEES'-ATTITUDES TOWARD
' QUALITY AND MANAGEMENT EFFECTIVENESS.
+-
i:
4-l 20101-BFN-02.
BROWNS. FERRY E*GINEERING PROJECT P'JCEDURE, BFEP-PI_-
86-18, R1,x FOR ALL" UNITS OF BFN-.DOES NOT CURRENTLY-1 INCLUDE REQUIREMENTS FOR UPDATE AND MAINTENANCE OF THE' C/R DATA BASE OVER THE-LIFE OF THE' PLANT.
l 20104-NPS-01 EEB DESIGN CONTROL PROCESS PROGRAM'TO REVIEW.ALL 3
ELECTRICAL' DESIGN GUIDES AND DESIGN STANDARDS AND f
RECOMMEND DELETIONS,' ADDITIONS, AND REVISIONS, HAS NOT j
BEEN FULLY--IMPLEMENTED..
I-20105-BFN-02 BFNPP COMMITMENTS--53 THROUGH 56sINDICATE'THAT.BFN.
AS-BUILT ENGINEERING DRAWINGS MAY-NOT ACCURATELY l-REFLECT THE PLANT CONFIGURATION. -INACCURACIES IN THE AS-BUILT _ DRAWINGS MAY HAVE BEEN. REPRODUCED IN-!THE i
20405-BFN-02
'IN SOME SAFETY RELATED SYSTEMS, PIPING MAYLBE' j -'
-NONCONFORMING:DUE TO ERRORS IN PIPING: BILL OF' MATERIAL PROCUREMENT DOCUMENTS BECAUSE IN-ALNUMBER-OF: CASES, THE SAME INDIVIDUAL THAT INITIATED-THE WORK =WAS ALLOWED.TO " CHECK" THE WORKa i
t i
20501-NPS THE SARGENT'AND LUNDY DEVELOPED ELECTRICAL ENGINEERING h
BRANCH. CONTROLLING INSTRUCTIONS FOR ELECTRICAL:
b
_~ CALCULATIONS HAVE NOT.BEEN. ISSUED AND/OR:-FULLY-
' IMPLEMENTED.
(
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' ENCLOSURE 2_
Page 7 of )7 i
BROWNS FERRY NUCLEAR PLANT (BFN)'
L
' CORRECTIVE ACTION TRACKING DOCUMENTS 2
(CONTINUED)
I j
20901-BFN-02 IF INACCURACIES OR OMISSIONS OF CSSC ITEMS ARE IDENTIFIED INLTHE BFN CSSC LIST AS A RESULT OF TVA j.
CORRECTIVE ACTIONS:FOR CATD 20901._BFN 01,?AN ~
ASSESSMENT OF THE' RETROFIT-ACTIONS NECESSARY TO ESTABLISH CONFORMANCE TO REQUIREMENTS OF THE OA l
PROGRAM WILL BE NECESSARY BY.TVA FOR-EACH ZTAM SO
-- i DE NTI FI ED. OMISSIONS-FOUND IN THE a'r 611 CSSC LIST s
l
'MAY REQUIRE RESOLUTION PRIOR TO RESTART; f
I 21202-BFN-01 PROGRAM-TO IMPLEMENT:IEB 79-14 FOR BFN'COMMENCECIIN-1979, BUT IS NOT COMPLETED.
[
21302-BFN-01 DISCREPANCIES WERE FOUND BETWEEN THE FSAR SECTION 13.4
~
j'
'(TEST
SUMMARY
).AND A FEW TEST RESULTS' PACKAGES,-REFER-TO-ELEMENT SECTION 9.6-FSAR COMMITMENTS FOR SPECIFICS.
3-j 21302-BFN-02 PROCEDURAL DEFICIENCIES OF EVALUATION INCONSISTENCIES-WERE FOUND IN TEST'RESULTS PACKAGES AS DESCRIBED:ON-THE ATTACHMENT - 4,PAGES._
4 l
{
21804-NFS-01~
EXISTIRGITVA PIPING DESIGN CRITERIA:DO:NOT EXCLUDE FLEXIBLE,.SHORT,.OPEN-ENDED BRANCH LINES'FROM THE l
MOMENT OF INERTIA RATIO DECOUPLING RULES.
THIS EXCLUSION COULD RESULT IN THIS TYPE OF LINE'NOT BEING i
SEISMICALLY: QUALIFIED BECAUSE SUCH PIPING COULD f1 RESPOND DYNAMICALLY TO MOTION OF THE:-RUN LINE AND SUCH l
RESPONSE WOULD NOT BE PROPERLY ACCOUNTED FOR.
f 22003-NPS-01 DOCUMENTATION:OF PUNCHING' SHEAR EVALUATION WAS: NOTI l-
' INCLUDED IN THE PIPE-SUFPORT CALCULATIONS. ' PUNCHING-l-
' SHEAR-REQUIREMENTS WERE NOT INCLUDED-IN THE' APPLICABLE PIPE SUPPORT DESIGN CRITERIA-(
REFERENCE:
JM86-09). NOTE-
{
.1 THESE DEFICIENCIES..ARE NOT SEQUOYAH RESTART _. ISSUES.
NOTE'2t: 'THESE DEFICIENCIES WERE!PREVIOUSLY IDENTIFIED I
FOR BROWNS FERRY.IN CATD 22003 BFN:01.
i i
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c ENCLOSURE 2 Page-8_'of H
{L BROWNS FERRY NUCt EAR PLANT (BFN)-
4' CORRECTIVE ACTION TRACKING DOCUMENTS (CONTINUED) i t..
I 22201-BFN-01 FIVF. ANCHORS ~ 4'/B'1349-31,: 47B1349-35, 47BiJ49-17,
(
47B3349-27,-AND-47B3349-29) DO NOT SPECIFY GAP OR~HAVE
[
l' A "NO WELD TO PIPE" NOTE.
THE POSSIBILITY FOR WELD j-FUSING TO THE PROCESS PIPE EXISTS FOR THESE ANCHCRS.
j
.THE SAME POSSIBILITY EXISTS FOR TWO OTHER ANCHORS j
(478452-149 AND 47B452-150), WHTCH DO HAVE A "NO-WELD i
TO PIPE" NOTE IN THE DRAWINGS. 'THE-ANCHORS WITH-WELD l
FUSED TO THE PROCESS PIPE MAY._OVERSTRESS THE PROCESS PIPE-AS WELL AS:THE-REAR' PLATE.
BFEP' REPORTED.THAT ALL ANCHORS (38) IN TORUS ATTACHED, RIGOROUSLY
[_
-ANALYZED; PIPING: SYSTEMS'WERE REVIEWED FOR.THE CONCERN.
l HOWEVER, TWOTANCHORS-(47b452-83.AND 47b452-168) WERE NOT INCLUDED IN THE REVIEW.
i 22203-BFN-01 PIPE SUPPORT DRAWINGS 17B452-7(1/R1 AND 47B452-708/R1 DO NOT?JPECIFY SHEAR LUG ORIENTATION.
PIPE-SUPPORT
[
DRAWING 47B452-1P2/R0 DOES'NOT-SHOW LUG' DETAIL-FOR l
- PLATE 1/2" X 4-1/2" 2'4-1/2" ANDfFILLET' WELD SPECIFIED
~FOR WBX31 AND EXISTING STEEL IS NOT CLEAR.
LUG DETAIL I
891'FOR PIPE SUPPORT 47B458-91/R0 DOES'NOT SPECIFY-HOLE. SIZE.
22500-BFN-02
-NO SEISMIC QUALIFICATION FOR BATTERY RACKS THAT.
f SUPPORTS CLASS 1E_ BATTERIES,'IS'AVAILABLE.
22500-BFN-03 SEVERAL INCONSISTENCIES EXIST BE'IWEEN AND WITHIN ' THE '
FSAR:AND.CSSC LIST FOR THE IDENTIFICATION OF'THE~
PROPER DESIGN CLASSIFICATION OF TH5:_FOLLOWING BATTERY' SYSTEMS: (1) 48 VOLT DC ANNUNCIATION SUPPLY SYSTEM (2) i
-48 VOLT DC COMMUNICATION-SUPPLY'.SiSTEM:.(3) 24 VOLT-DC NEUTRON MONITORING SUPPLY SYSTEM 1(4).750' VOLT'DC STATION SUPPLY SY3 TEM.
22600-BFN-01
-FOR UNITS.1, 2, AND 3:
-A.
NEED SATISTAC'IORY J RESOLUTION OF-SCR BFN MEB 8605 TO' ADDRESS.SEISMICs
[_
INTERACTION BETWEEN:AS-BUILT. CLASS I-hNO CLASS-II COMPONENTS'(INCLUDING LIGHTING F_IXTURE SUPPCRTS).
B.
Nr "OMPLETE PROGRAM-EXISTS TO' DESCRIBE AND CONTROL ~THE SEISMIC. INTERACTION ~ EVALUATIONS FOR CURRENT AND FUTCRE-
. DESIGN _. ACTIVITIES.
1_-
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1-ENCLOSURE 2-Page-9 of[17 1-BROWNS FERRY NUCLEAR PLANT (BFN)
L CORRECTIVE ACTION TRACKING DOCUMENTS (CONTINUED) f i__
22600-brN-02 FOR.BFN UNITS-1, 2, AND 3 7G-NO DESIGN CRITERIA FOR' LIGHTING FIXTURE SUPPOPT EXIST FOR CURRENT AND FUTURE DESIGN OF LIGHTING FIXTURE SUPPORTS..
B. NO' TYPICAL DRAWINGS OR SPECIFIC DRAWINGS EXILT SHOWING SUPPORT
- 7 i
DETAILE FOR LIGHTING: FIXTURES, OTHER.THAN= DRAWINGS =
l:
_48W1234-1,
-2, AND
-3. C.'No CALCULATIOhS.ON LIGHTING FIXTURE SUPPORTS EXIST, OTHER'THAN CALCULA?~TNS FOR MATN. CONTROL ROOM LIGHTING FIXTURE SUPPORTS. D._-NO
[
ANALYTICALLDATA WERE PROVIDED IN_EN DES CALCULATION, 1:
" MISCELLANEOUS STEEL MAIN CONTROL ROOM I-IGHTING," TO-DEMONSTRATE.THE ADEQUACY OF.THE' CONTROL RDOM-LIGHTING
=ETRUCTURE'AND FIXTURE SUPPORTS.TO WITHSTAND A-SEISMIC-l EVENT.- NO}END BRACING MEMBERS WERE PROVIDED<IN THE f
EAST-WEST DIRECTION OF.THE CONTROL ROOM LICHTING
^
j STRUCTURE ON DRAWINGS 48W1284-1,
-2, ANDL-3.
22800-BFN-02 LACK.0F WRITTEN. REQUIREMENTS TO USEIAC INTERACTION' j
~ EQUATION COULD RESULT.IN-IMPROPER DESIGN OR i
REEVALUATION OF.UNISTRUT CLAMPSESUBJECTED TOL SIMULTANEOUS LOADS IN MORE TRAN ONE DIRECTION.
l l
22902-BFN-01 AS DEFINED BY APPENDICES B-AND C OF-THE APPLICABLE ECTG REPORT,LTHERE ARE-POTENTIALLY RADIOACTIVE PANEL
- DRAINS ROUTED INTO. FLOOR DRAINS 'INSTEAD OF INTO CLOSED -
DRAINAGE SY3TEMS.
23208-BFN-01 CALCULATIONS-PERFORMED.FOR'SOME SAFETY RELATED SYSTEhs USED A FORMULA TO CALCULATE MINIMUM PIPE WALL l
THICKNESS WITH YIELDS VALUES LESS THAN ALLOWED!BY THE APPLICABLELINDUSTRYLCODEJB31(1.0-1967),
i'
~ 23702-NPS-031
. DESIGN GUIDE DC-E2.3.5,:R3 DOES'NOT' PROVIDE'CUIDANCE i--
' FOR SIZING MOTOR BRANCH ' CIRCUIT PROTECTION DEVICES FOR
=
- MOTORS. RATED LESS..THAN:1/2;HP..ITLALSO LACKS l
. DIFFERENTIATION BETWEEN= MAGNETIC ONLY-BREAKERS AND.
MOTOR CIRCUIT PROTECTORS.
23o01-BFN-02 NO EVIDENCE COULD BE.FOUND.TdAT THE CORRECTIVE' ACTION
~
FOR. CAR 86-0078,u0079, AND 0080'(COMPUTERIZED CABLE J-PROGRAMS FOR ALL THREE UNITS AT BFN)^HAD bEEN--
IMPLEMENTED.
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i ENCLOSURE 2:
Page)0'ofI7 L
BROWNS FERRY NUCLEAR PLANT (BFN) f CORRECTIVE ACTION TRACKING DOCUMENTS
'(CONTINUED);
i.
23900-9FN-05 THERE IS.NO QA LEVEL DOCUMENTATION FOR ASSURANCE THAT ALL'OF THE ABANDONED OR SPARED CABLESEARE' INDICATED ON I
THE MANUALLY ROUTED CONDUIT AND CABLE SCHEDULE-i
. DRAWINGS FOR UNIT I AND 2.
THERE ARE NO RECORDS FOR l
. ABANDONED OR SPARED CABLES FOR THE - COMPUTER GENER%TED :
i FILL QUANTITIES CANNOT BE-VORIFIED,'AND THERE ARE NO j
RECORDS AVAILABLE FOR RACE %hY' FILL 1FOR UNITS 1.AND 2
-i j
KANUALLY ROUTED CABLES- - NO.QA LEVEL PROCEDURES EXIST:
TO ENSURE THAT USERS WILL NOT VIOLATE TRAY FILL l
QUANTITIES.
[
23900-BFN-07L NO-QA LEVEL PROCEDURES EXIST FOR THE DEVELOPMENT OF' j'
THE-CONDUIT AND CABLE-SCHEDULES.
THEREFORE,..THEE j
. ADEQUACY OF DESIGN, ROUTING, REVISION, AND ISSUE.
j PROCESS FOR CABLES-AND CONDUITS CANNOT BE VERIFIED.
23900-BFN-08
- THERE ARE NO PROCEDURE ' FOR CONSTRUCTIO(
"y AEcoRD THE INSTALLED CUT OR TERMINATED CABLE LENGi- %
ALSO,_
j THERE IS NO PROCEDURE FOR THE FEEDBACK OP s.,3LE LENGTH j
DATA AND FIELD-REVISION'OF CABLES.TO ENGINEERING s.
3 23900-BFN-09 TVA ONGOING PROGRAM-OF INCORF7 RATING THE APPROPMIATE j
CABLELLENGTHS OF INSTALLED CABLES PER. POLICY MEMO PM 1
87-26'IS NOT COMPLETED.
[
24104-BFN-01 DURING WALKDOWN-PERFORMEU BY THE Ei'ALUATION TEAM THE f
FOLLOWING OBSERVATIONS WERE }aDE 1 - A) DIESEL A3A,:THE i
ADAPTER CAN:BE ROTATED-BY-HAND)APPROXIMATELY A QUARTER
}
TURN.
B) DIESEL'B3B, THERE!IS':A LIGHT MOVEMENT AT THE
~
CONNECTOR NUT.
C)1 DIESEL C3C,.zTHE COUPLING AND.
I' ADAPTER-CAN BEEROTATED BY::HANDcAPPROXIMATELY~A QUARTER
{
TURN.. D) DIESEL'D3D THE COUPLING,AND: ADAPTER'CAN-BE-
+
ROTATED. SEVERAL' TURNS DY HAND. c E) THE1 CONDITION'OP THE LOOSE ASSEMBLIES HAS NOT BEEN REVIEWED FOR' SAFETY :
[
-IMPLICATION AT BFN.
j
' 24200-BFN-04 IHPLEMENTATION OF ECNS'P0753 AND 09822-TO SATISFY NRC i
r VIOLATION NOTICE.IS PART OF A LONG TERM--COMMITMENT BY=
l
.TVA.
' NO ANALYSIS COULD BE FOUND TO JUSTIFY THE CHANCE-lOF CONDUIT FROM NONCLASSE1E TO DIVISION ~II.S A
. INDICATED BY NRC BFN BWP 8304 RI.
ALSOP NO' EVIDENCE-j' COULD-BE~FOUND OF.ANY' REVIEW PERFORMED TO DETERMINE.
WHETHER SIMILAR CASES'MAY EXIST.
}
i.
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ENCLOSURE 2 Page 11 of 17 BROWNS FERRY NUCLEAR PLANT (BFN)
CORRECTIVE ACTION TRACKING DOCUMENTS (CONTINUED) i 243OO-BFN-02 THE FSAR DOES NOT REFLECT CURRENT DIESEL-GENERATOR LOADING AND IS VAGUE AS TO THE EXTENT OF BFN COMPLIANCE YO SAFETY GUIDE 9.
IN ADDITION, THE STANDBY DIESEL GENERATOP SYSTEM DESIGN CRITERIA (BFN-50-7082) IS ALSO UNCLEAR ABOUT THE EXTENT OF BFN COMPLIANCE WITH SAFETY CUIDE 9.
26600-NPS-01 NO INTEGRATED PROGRAM COULD BE IDENTIFIED FOR THE DESIGN AND THE DESIGN CONTROL OF RACEWAY AND CABLE SYSTEMS.
30103-BFN-01 THE REACTOR FEEDWATER (RFW) PUMP LOW LOAD BYPASS LINES (MIN FLOW LINE) MAY HAVE EXCESSIVE PIPE VIBRATION.
HOWEVER, THIS CANNOT BE VERIFIED UNLESS INSPECTION IS PERFORMED DURING OPERATION.
THE INSPECTION SHOULD INCLUDE A CLEARANCE CHECK AND THERMAL MOVEMENT VERIFICATION TO ESTABLISH IF ADDITiDNAL HANGERS ARE 14ECESSARY.
30103-BFN-03 THE REACTOR FEED WATER (RFW) PUMP ?,0W LOAD BYPASS LINES (MIN FLOW LINE) MAY HAVE EXCESSIVE PIPE VIBRATION.
HOWEVER, THIS CANNOT BE VERIFIED UNLESS AN INSPECTION IS PERFORMED DURING OPERATION.
THE INSPECTION SHOULD INCLUDE A CLEARANCE CHECK AND THERMAL MOVEMENT VERIFICATION TO ESTABLISH IF ADDITIONAL HANGERS ARE NECESSARY.
30107-BFN-01 THE EXTENT OF DEFICIENT AND UNQUALIFIED COATINGS IN LEVEL 1 AREAS IS INDETERMINATE. AN UNQUALIFIED COATINGS LOG HAS NOT BEEN DEVELOPED AND MAINTAINED TO ENSURE THAT SOLID DEBRIS PRODUCED BY UNQUALIFIED COATINGS WILL NOT COMPROMISE THE EMERGENCY CORE COOLING SYSTEM.
30115-NPS-OI DEFICIENCIES WITH COMPONENT IDENTIFICATION ON DRAWINGS AND DATA BASES HAVE BEEN IDENTIFIED TO EXIST AT ALL SITES AND ARE PERCEIVED TO RESULT FROM THE LACK OF CENTRALIZED CONTROL FOR ASSIGNMENT OF COMPONENT IDENTIFICATION.
PROVIDE CORRECTIVE ACTION PLAN FOR RESOLUTION TO THE ISSUES AS DISCUSSED IN THE REFERENCED REPORT (ATTACHED). THE INDIVIDUAL SITE DIRECTORS MAVE BEEN NOTIFIED BY CATD TO ADDRESS MISSING AND/OR INCORRECT EQUIPMENT TACS.
o ENCLOSURE 2 Page 12 cf 17 BROWNS FERRY NUCLEAR PLANT (BFN)
CORRECTIVE ACTION 'RAChidG DOCUMENTS (CONTINUED) 30200-NPS-01 UNDER THE ELECTRICAL AND COMMUNICATION EQUIPMENT SUBCATEGORY, TWENTY-TWO CATDS HAVE BEEN ISSUED TO DATE IDENTIFYING SPECIFIC DEFICIENCIES AT ALL FOUR NUCLEAR SITES. THE TWO SIGNIFICANT APEAS WHERE PROBLEMS WERE IDENTIFIED WERE IN RAYCHEM CONTROL AND SHUTDOWN BOARD Bb5 VOLTAGE REGULATION.
THE SPECIFIC DEFICIENCIES IN THE ENGINEERING, OPERATING AND QUALITY ASSURANCE ORGANIZATIONS AND INCLUDED PROCEDURAL WEAKNESSES, VAGUE OR NONEXISTING ACCEPTANCE CRITERIA AND WEAKNESSES IN THE CONTROL AND AUDITING PROCESSES.
BECAUSE THE DEFICIENCIES CROSSED ORGANIZATIONAL AND FUNCTIONAL LINES, TVA*S CORPORATE ORGANIZATION SHOULD ENSURE A PROGRAMMATIC CORRECTIVE ACTION RESOLUTION FOR THESE TWO AREAS AND CONSIDER APPLYING ANY LESSONS l
LEARNED TO OTHER MAJOR ELECTRICAL PROGRAMS.
30202-NPS-01 DPM N7701 STATES THAT RELAYS THAT MONITOR SAFETY RELATED AUXILIARY POWER SYSTEM VOLTAGE HAVE EFFECTIVE O VOLT SETPOINTS.
THE DESCRIPTION CONTINUES, IGNORING THE FACT THAT AUTOMATIC BOARD TRANSFERS ARE INITIATED FOR DEGRADED VOLTAGES (E.G. 95% THAT LASTED FOR 5 MINUTES WBN) THE DESCRIPTION OF VOLTAGE TRANSFER i
EVENTS AS APPEARS IN DPM N7701 IS CONTRARY TO THAT GIVEN IN THE FSAR.
30400-UPS-03 AS NOTED IN THE FINDINGS AND COLLECTIVE SIGNIFICANCE SECTIONS OF REPORT 30400, THERE Id A LACK OF CORPORATE 4
CONTROL OVER DESIGN AND CONSTRUCTION STANDARDS AND REQUIREMENTS AND THEIR USE'AT THE NUCLEAR SITES.
30103-BFN-01
- 1. MANHOLES NEED A GENERAL CLEANUP.
- 2. SUMP PUMP ROUTING CHECKS ARE NOT ADEQUATE TO ENSURE CONTINUED OPERATION.
- 3. MANHOLE C IS COLLECTING SURFACE WATER BECAUSE THE MANHOLE IS IN A LOW AREA, AND ACCORDING TO THE DRAWIhG 10N319-l'RA, THE COVER SHOULD BE ABGVE GRADE.
4.
SOME OF THE SUMP PUhPS ELECTRICAL SUPPLY CORD PLUGS CONTAIN A CIRCUIT' INTERRUPTING DEVICE THAT IS CAUSING NUISANCE T9IPS.
- lIS TRIPPING WAS OBSERVED IN MANHOLES E AND G.
-*s.
ENCLOSURE 2-Page u of n BROWNS FERRY NUCLEAR PLANT-(BFN)E CORRECTIVE ACTION TRACKING DOCUMENTS (CONTINUED) -
30403-BFN-02
-1.
SEVERAL-DOZEN CABLES HAVE BEEN ROUTED OUTSIDELTHE-CABLE TRAYS IN' MANHOLE.T AND THERE ISl INADEQUATE SLACK ~
~
TO GET..THE CABLES IN-THE TRAYS.
A'LARGE' NUMBER OF CABLES ARE. ROUTED THROUGH MANHOLE T, ANDJIT MAY NOT-BE POSSIBLE TO~PUT ALL-THE-CABLES IN TRAYS.
EXCEPT FOR MANHOLE T, ABOUT THE-ONLY CABLES THAT-ARE'OUT OF.THE TRAYS.ARE SPARE. CABLES,iPULL WIRES, AND SUMP-PUMP POWER. CABLES.
IN--MANHOLE H, A COUPLE OF CABLES CROSS-l TRAYS ON THELINSIDE-EDGE ~OF.THE TRAY, AND ONE CABLE IS.
OUT OF THE-TRAYS..IN MANHOLE'E, SOME.0F.THE 4-KV-BUS lj -
TIE CABLES: FOLLOW THE TOP EDGE:OF THE CABLE TRAY.
THE DRAWINGS FOR MANHOLES-F, G,'H,1AND'J.SHOW A METAL-f BARRIER AND COVER IN THE TRAYS 1N) SEPARATE 480-V AND i
4-KV CABLES. THESE BARRIERS.AND. COVERS-'ARE NOT
[
INSTALLED. LIT IS DOUBTFUL'THEY COULD BELINSTALLED AND:
j STILL MAINTAIN' SUFFICIENT BEND RADIUS ON-THE~4-KV~
j.
CABLES. THE 4-KViBUS TIE LINE CADLES ARE ABANDONED a-ANYWAY, SO THE BARRIERS--MAY:NOT BE NEEDED, l
30403-BFN-03 THE TERMINAL STRIP'IN-JUNCTION BOX--7118 IN MANHOLE T j
NEAR THE CAS HAS BEEN-FLOODED AND'IS SEVERELY'
- CO RRODED, -THE BOX WAS INSTALLED UNDER-INCOMPLETE.ECN j
PC286. -IT CONTAINS CADLES FOR CCTVG', H,1 AND,J.
THE:
MANHOLE NEEDS'A SUMP' PUMP. cTHE TERMINAL; STRIP SHOULD
{
BE' REPLACED WITH A ; WATERPROOF - SPLICE. : :AN FCR.AGAINST i
ECN P0286:COULD ADD A SUMP ~ PUMP AND REMOVE THE^
TERMINAL STRIP I
)
30403-NPS-01 PROBLEMS'WERE IDENT1FIEDIWITH STANDING-WATER IN
-ELECTRICAL MANHOLES-AT ALL SITES ALTHOUGHETHIS.IS-NOT k-CONSIDERED SAFETY-RELI. ED.
A' POTENTIAL SAFETY ISSUE
};
MAY EXIST WITH REGARD TO " WATER-TREEING".-OF; INSULATION l-ON' LEVEL V VOLTAGE CABLES. CATD130403-SQN-01 WAS WRITT2N FOR DNE:TO ADDRESSETHIS: ISSUE i AT : SQN;-- HOWEVER,
4
.BECAUSE THIS ISSUE IS GENERIC,-A RESPONSE-SHOULD BE j
MADE APPLICABLE FOR'ALL SITES.
4
(
30600-NPS-01:
AS NOTED~IN.THE'FINDINGSi PRELIMINARY 1 ANALYSIS, AND COLLECTIVE' SIGNIFICANCE' SECTIONS OF. REPORT 130600.
'VARIOUS PROBLEMS EXIST %ITH PROCEDURESLRELATED TO FIRE PROTECTION.- THESE. PROBLEMS iiINCLUDE ' PROCEDijRAL ~
CONTENT, PERSONNEL ERROR IN FOLLOWING PROCEDURES, AND LACK OF ADEQUA'IE aPROCESS L TO ~ ENSURE ~ CCMMITMENTS T ARE' REFLECTED IN PROCEDURES.__ THESE: DISCREPANCIES WERE i
OBSERVED AT THREE-OFETVA'S FOUR NUCLEAR--SITES.
Y.
..,.:.,._,.,,-,. A..-,
.~,e
,1,J-
...,.;a.,.-..-._,'2
4.
24-or i7 ENCLOSURE 2 i #
BROWNS FERRY NUCLEAR PLANT (BFN)
CORRECTIVE ACTION TRACKING DOCUMENTS (CONTINUED)-
j 30600-NPS-02 AS NOTED IN THE. FINDINGS, PRELIMINARY ANALYSIS, AND COLLECTIVE SIGNIFICANCE SECTIONS OF REPORT.30600,
'THERE-ARE INADEQUATE CONTROLS FOR REVIEW OF BESULTS TO ENSURE COMPLIANCE WITH COMMITMENTS RELATED TO FIRE PROTECTION. THIS DISCREPANCY WAS OBSERVED AT WATTS.
BAR NUCLEAR PLANT.
i 30700-NPS-01 AS~NOTED IN THE_ FINDINGS, PRELIMINARY ANALYSIS AND COLLECTIVE SIGNIFICANCE PERSONNEL' LACK UNDERSTANDING-OF REGULATORY REQUIREMENTS OR COMMITMFNTS.
THIS-DISCREPANCY WAS OBSERVED AT WBN AND SQN.
30711-NPS-01 A DIFFERENCE IN OPINION-HAS-BEEN IDENTIFIED BETWEENa LINE MANAGEMENT AND NSRS REGARDING SINGLE FAILURE l
CRITERIA FOR THE MSIVS AT BLN.
BASED ON AVAILABLE 3l DOCUMENTATION'TO DATE, THERE HAS-BEEN NO RESOLUTION'TO THIS ISSUE.
i' j
30801-BEN-01 THE PHASE II; TASK FORCE HAS RECOMMENDED THAT-1 APPROPRIATE PMRSONNEL SHOULD, MEET AND DEVELOP A PLAN-f.
FOR. SAFETY RIJGING THE-MAIN STEAM RELIEF VALVES TO AND FROM THE DRYWELL.. INCLUDED.IN~THIS PLAN SHOULD BE DEVELOPMENT OF A SPECIFIC RIGGING Ph0CEDURE,~A-4 MODIFICATION FOR INSTALLING'A HATCH IN THE'DRYWELL~
GRATING, AND.THE ADDITION-OF JIB CRANES AND DED7CATED 4.
RIGGING EQUIPMENT FOR MSRV REMOVAL.-
[
~30901-NPS-01 IDEt:TIFICATION. 0F AN ACCEPTABLE SUBSTITUTE-FOR TEFLON TAPE HAS NOT-BEEN AGGRESSIVELY PURSUED.
INCONSISTENCICS EXIST BETWEEN.WBN, BFN, AND SQN ON THE 4
p RESTRICTIONS.0F USE OF TEFLON TAPE.
i
-31211-BFN-01 THERE ARE'NOT "AS CONSTRUCTED"-DRAWINGS'FCR'OUTSIDE-f SECURITY LIGHTING..WORKPLAN-8521 (ECN PO286)_WAS
-PARTIALLY COMPLETED.AND MARKED UP DRAWINGS.WERE NOT.
1_
SENT TO DCC PER' STANDARD PRACTICE BF 8.3.
AS AL RESULT,~NO;"AS~ CONSTRUCTED" DRAWINGS WERE' ISSUED 3;
REFLECTING.THE. ACTUAL-. EQUIPMENT CONFIGURATION.
4 MAINTENANCE PERSONNEL HAVE HAD TO. MAINTAIN AND REPAIR ~
ii SECURITY LIGHTINGEUSING-DATA-FROM_ECNfP0286.
31212-NPS DURING PERIODS OF INOPERATIVE ELECTRONIC SEARCH EQUIPMENT,rACCEPTANCE CRITERIA'FOR THE " PAT'DOWN:
t.
SEARCH" FUNCTION ~ MAS NOT BEEN ADEQUATELY ADHERED TO BY:--
PSS OFFICERS.
L 4
1.
~
1 t
4
o ENCLOSURE 2 Page 15 of 17 BROWNS FERRY NUCLEAR PLANT (BFN)
CORRECTIVE ACTION TRACKING DOCUMENTS (CONTINUED) 31300-NPS-01 AS NOTED IN THE FINDINGS AND COLLECTIVE SIGNIFICANCE SECTIONS OF REPORT 31300, THERE HAS BEEN A LACK OF CORPORATE CONTROL OVER THE IMPLEMENTATION OF DESIGN, CONSTRUCTION STANDARDS AND REQUIREMENTS INTO THE OPERATIONS ACTIVITIES AT BFN AND SQN RELATIVE TO CONCRETE AND GROUT REPAIRS.
31303-NPS-01 DURING EVALUATION OF A CONCERN IN FACT SHEET. NUMBER 313.03 WBN, RELATING TO THE CONTROLLED USE AND LABELING OF CHEMICAL CLEANINO AGENTS, SOLVENT ECT.
IT i
WAS FOUND THAT EACH TVA SITE HAS A SITE SPECIFIC PROGRAM TO ADDRESS THIS ISSUE HOWEVER, MO CORPORATE PROGRAM-EXISTS TO ADDRESS THE CONTROL USE OF CHEMICALS l
AND THEIR LABELING REQUIREMENTS FOR USE SUCH AS, l
SYSTEM COMPATIBILITY ETC.
40300-NPS-01 THERE IS A LACK OF CONTROL OF SCRAP MATERIAL A PROGRAM NEEDS TO BE IMPLEMENTED THAT WOULD CONTROL SCRAP OR RETIRED MATERIAL FROM THE WORK AREA THROUGH REMOVAL FROM THE SITE.
NOTE:
THIS IS NOT PART OF THE WATTS BAR EFFORT.
4 40700-BFN-07 SOME WORKPLANS AT BFN DO NOT PROVIDE DOCUMENTED TRACEABILITY FOR CSSC PRESSURE BOUNDARY MATERIAL.
THIS VIOLATES PROCUREMENT AND TRACEABILITY REQUIREMENTS IN 10 CFR 50, APPENDIX B, CRITERIA VII AND VIII.
(SEE MATERIAL CONTROL FACT SHEET 40700-BFN-ONP) 40700-BFN-0B BFN PERFORMS MODIFICATIONS ON CSSC SYSTEMS WITHOUT REVISING ORIGINAL DESIGN AND CONSTRUCTION DRAWINGS AND DOCUMENTATION.
ALSO, BFN PERFORMS MODIFICATIONS WITHOUT APPROPRIATE DESIGN INPUT DOCUMENTATION. THIS IS IN VIOLATION OF 10 CFR 50, APPENDIX B, CRITERIA III, V,'AND VI.
40700-NPS-01 CONTRARY TO THE REQUIREMENTS OF 10 CFR 50, APPENDIX B, CRITERION VIII, THE TVA MATERIAL CONTROL PROGRAM DID/DOES NOT ENSURE THE RECEIPT, STORAGE, AND INSTALLATION-OF CRITICAL SYSTEMS, STRUCTURES, AND COMPONENTS (CSSC) MATERIAL THAT IS PROPERLY CERTIFIED AND MARKED, IDENTIFIED, AND VERIFIED TRACEABLE TO ITS CERTIFIED MATERIALS TEST REPORT (CMTR) THROUGHOUT THE FABRICATION, EREC1 ION, INSTALLATION, AND USE OF THE ITEM.
i
. ENCLCHBURE 2 Page 16 or 11 I
BROWNS FERRY NUCLEAR PLANT (BFN)-
1 CORRECTIVE ACTION TRACKING DOCUMENTS (CONTINUED) a i
1-
?F 'NPS-02 A BROAD-BASED MANAGEMENT DEVELOPMENT PROGRAM MUST BE-IMPLEnENTED TO: UPGRADE THE COMPETENCE OF INDIVIDUAL ~
l-MANAGERS IN THE SHORT TERM AND ENSURE'THE SUCCESSION l
OF ABLE MANAGERS IN THE LONG TERM.
i2' 705-NPS REPRESENTATION OF-MINORITIES, WCMEN, AND-THE HANDICAPPED WITHIN THE OFFICE OF NUCLEAR POWER IS~FAR BELOW EXPECTED PERCENTAGES AS DETERMINED BY THE U.S.
j
. EQUAL. EMPLOYMENT OPPORTUNITY COMMISS77N.
a i
707-NPS-01 UP-TO-DATE--ORGANIZATION' BULLETIN 3 HAVE-NOT BEEN~ ISSUED FOR THE DIVISION OF NUCLEAR ENGINEFRING~AND THE
- DIVISION ~OF NUCLEAR CONSTRUCTION, t
4 i
717-NPS-04 MANAGEMENT CONTROLS ARE NOT--IN PLACE OR NOT' SUFFICIENT l-TO INSURE THE QUALITY OF JOB DESCRIPTIONS-MEET OR i-EXCEED THE QUALIFICATIONS OF A' REGULATORY DOCUMENT.
l, --
f 717-NPS-14'
" TRAINING RECORDS" ARE FRAGMENTED THROUGHOUT NUCLEAR-POWER.
j l
80106-BFN-01 SIGNIFICANT CONDITION REPORT.SCR WBNWBP8601 R 0 WAS-1
[f
- A POTENTIAL GENERIC CONDITION _WHICH. REQUIRES'AN WRITTEN ON' OCTOBER 23,'1986.. IT WAS DETERMINED TO BE l
ENGINEERING' EVALUATION TO-BE MADE'AT._OTHER TVA-SITES.
J (TVA MEMORANDUM;VJ.Rf LYONS.TO THOSE LISTED -- OCTOBER
- 23, _1986 RIMS: B26 - 86 1023- 016 ). A REVIEW;OF THE
{'
CONDITION WAS' PERFORMED AT BFN BY R: WRIGHT-ONEDECEMBER 22,'1986 AND COUNTER SIGNED BY T.JC, CHAPMAN ON-DECEMBER 30,'1986. : THE CATO.IS-WRITTEN:TO DETERMINE WHAToACTION WAS DONE!BY BFN TO RESOLVE THIS-PROBLEM CONDITION.
REPORTED ATTEMPTS TO'OBTAIN THIS INFORMATION FROM MR. WRIGHT DURINV.THE WEEK 0F.
JUNE-8,-1987 HAVE BEEN-UNSUCCESSFUL.7 80454-NPS-01 THE QACEG PERFORMED AN. EVALUATION OF THE ISSUE: DEALING 4
WITH; TVA FSAR COKHITMENTS, SAFETY EVALUATION REPORT
[
- (SER) AND'NRC QUESTION' RESPONSES BEING TREATED LIGHTLY
=
, OR NOT BEING MET AT ALL.. PRIOR TO THE:QACEG f
-EVALUATION OF THIS-ISSUE,. SiGNIFICANT-. CONDITION ~
- REPORTS ~(SCR)z SCRGENNEB8602.AND-SCR;BLNNEB8702-HAD BEEN. GENERATED WHICH ADDRESS.THE-ACCURACY OF--FSAR j-
' STATEMENTS. -CATD 80454-NPS-01'IS BEING USED TO TRACK-0 THE COMPLETION.0F THE CORRECTIVE ACTION AND ACTION TO
+
PREVENT RECURRENCE OF BOTH SCRS.
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.T ENCLOSURE 21 Page.17"of-17.
BROWNS FERRY NUCLEAR PLANT'(BFN)
CORRECTIVE ACTION TRACKING DOCUMENTS (CONTINUED).
I-85-373-NPS-02-10
" VALIDITY OF NDE OJT DOCUMENTATION," FOLLOW-UP
' INVESTIGATION TO DEFINE IN DETAIL THE FINDINGS.
DOCUMENTED.
90700-BFN-01' THE PERSONNEL SAFETY HAZARDS ASSOCIATED WITH MAIN STEAM RELIEF. VALVE REMOVAL AND RE-INSTALLATION IN-THE DRYWELL AREA HAS-BEEN WIDELY-KNOWN-BY PLANT.EHPLOYEES-AND MANAGEMENT SINCE AT LEAST AUGUST.OF=1979.
3FN-DCR-1879 WAi ISSUED TO IMPROVE THE SAFETY OF-THIS.
OPERATION. THE IMPLEMENTATION.0F THIS DCR HAS BEEN-POSTPONED SEVERAL-TIMES.. INTERMEDIATE MEASURES-TAKEd TO SAFELY PERFORM THIS JOB ARE LARGELY UNKNOWN'TO THOSE PRESENTLY DOING THE WORK.'
90900-NPS-05c INTERFERENCES WITH FIXED LADDER RUNGS ARE-NUMEROUS-THROUGHOUT THE PLANT.
SOME PIPING-INTERFERENCES <
GREATER-THAN TWO INCHES IN DIAMETER, INDICATE INADEQUACIES IN THE DESIGN: REVIEW PROCESS.
91000-BFN-02 ADDITIONAL LIGHTING AND HANDRAILS HAVE NOT.BEEN INSTALLED ON'THE IHTAKE GATE STRUCTURE-NO.-3 TO RESOLVE AN EMPLOYEE SAFETY CONCERN AND COMPLETE DCR D3251. THIS WORK.SHOULD NOT BE DELAYED UNTIL THE.NEXT OUTAGE, UNIT 3, CYCLE 5.
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