ML18094A066
| ML18094A066 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 02/05/1981 |
| From: | Mills L TENNESSEE VALLEY AUTHORITY |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML18025B380 | List: |
| References | |
| NUDOCS 8103120749 | |
| Download: ML18094A066 (10) | |
See also: IR 05000259/1980040
Text
TENNESSEE VALLEY AUTHOR lT'ebruary
5, 1980'I FFO I I f~(t.3I'r.James P.O'Reilly, Director Office of Inspection
and Enforcement
U.S.Nuclear Regulatory
Commission
Region II-Suite 3100 101 Marietta Street Atlanta, Georgia 30303 Dear Mr.O'Reilly: This is in response to your January 9, 1981, letter, RII:RFS 50-259/80-40, 50-260/80-35, and 50-260/80-34, concerning
activities
at Browns Ferry Nuclear Plant which appeared to be in noncompliance
with NRC requirements.
As discussed with H.Dance of your staff, we request that the subject inspection
report be withheld from public disclosure
in accordance
with 10 CFR Part 2.790.If you have any questions, please call Jim Domer at FTS 857-2014.Very truly yours, TENNESSEE VALLEY AUTHORITY ti lg L.M.Mills, Manager ear-Regulati'on
and Safety~-'Nucl Subscribe~d sworn~b e ore me thi~day of 1981.otary Public My Commission
Expires Enclosure y+QQlQO Hg Rn Ecual Oppo.eunity
Eriployer
e
ENCLOSURE RESPONSE TO J.P.O'REILLY'S
LETTER DATED JANUARY 9, 1981, REGARDING BRONNS FERRY NUCLEAR PLANT (50-259/80-40,e~50
260/80-35~&0-296/80-34)
Infraction
A As required by Technical Specification 3.10.A.1, refueling interlocks
shall be operable during refueling operation.
Contrary to the above, on October 5, 1980, fuel was loaded into the core with a temporary alteration
on control rod 54-19 which defeated the refueling interlocks
for prevention
of loading fuel with a control rod'ithdrawn.
This is an infraction
applicable
to unit 2.~Res ense Technical Specification 3.10.A.1 requires that refueling interlocks
be operable during core alterations
with two specified exceptions, 3..10.A.5 and 3.10.A.6.Technical Specification 3.10.A.6 states that any number of control rods may be removed or withdrawn from the core and the refueling interlocks
bypassed on withdrawn control rods after the fuel has been removed from the cell.~'It is our position that loading of fuel in control cell 58-19 with control rod 54-19 withdrawn does not violate Technical Specification 3.10.A.1, in that no fuel was loaded into a control cell with the refueling interlocks
"'or'that':cell".bypasse'd;.At,all times,.the bypass was" in.'place wh'en the'..;Ž~~fuel was removed from the respective
cell as allowed by Technical Specification 3.10.A.1 and 3.10;A.6.a..
~A t
Infraction
B As required by Technical Specification 3.10.A.2 fuel shall not be loaded into the reactor core unless all control rods are fully inserted.Contrary to the above, on October 5, 1980, fuel was loaded into the core with control rod 54-19 fully withdrawn.
This is an infraction
applicable
to unit 2.~Res oese Loading of fuel into the core with control rod 54-19 withdrawn was an apparent violation of Technical Specification 3.10.A.2 as reported under BFRO 50-260/8041.
1.Corrective
Ste s Taken and Results Achieved A.Fuel handling was immediately
stopped.Control rod 54-19 was inserted and the refueling interlocks
returned to normal.B.GOI 100-3 (refueling
operations)
was revised to include a procedure for unloading of control cells with placement and removal of refueling interlock bypasses included within the limits of the technical specifications.
C.A checklist was written and included in GOI 100-3 that ensures any temporary conditions
are removed and the refueling interlocks
verified in service each time fuel movement is stopped for an 8-hour"period.
2.Corrective
Ste s Taken To Avoid Further Noncom liance~~e~'n addition to 1.B and 1.C above, fuel handling crews will'eview
this incident in future training classes that are conducted before each refueling outage.3.Date Full Com liance Achieved GOI 100-3 revisions were completed on November 26, 1980.Infraction
C As required by Technical Specification 6.3.A.6, detailed written procedures
shall be prepared and adhered to for surveillance
and'esting
requir4ments.
Surveillance
Instruction
4.10.A.1 requires all control rods to be fully inserted during the test.s s~~s
ra 0
Contrary to the above, Surveillance
Instruction (SI)4.10.A.l, Refueling Interlocks, performed on October 4, 1980, was not adhered to in that two control rods were fully withdrawn during the performance
of the SI.This is an infraction
applicable
to unit 2.~Res onse SI 4elO.A.1 was per'formed
on October 4, 1980, to conform with technical specification
operability
requirements
for the refueling interlocks.
Licensed operators on shift were aware that two control rods were withdrawn as permitted by Technical Specification 3.10.A.6."All control rods in" is not a requirement
to perform SI 4.10.A.1, but a condition necessary to prove operability
of refueling interlocks
for all control cells.The technical specification
required that operability
be proven on control cells that contained fuel.The two control cells under maintenance
were unloaded and had refueling interlocks
bypassed.The SI, as performed, met the operability
requirements
of the technical specifications.
Failure to include temporary conditions
in the remarks section of the SI and failure of the instruction
to include steps that make allowances
for"maintenance
rods is a deficiency.
However, the intent of Technical Specification 6.3.A.6 was not violated.1.Corrective
Ste s Taken.-and Results Achieved The operator was instructed
to include any abnormal conditions
in the remarks section of the SI.2.Corrective
Ste s Taken To Avoid Further Noncom liance The'I is'being r'eyisedt t'o include provisions
for coritrol rods under maintenance
within the allowance of Technical Specification 3.10.A.6.3."'Da'te Pull Com 1'iance Will Be Achieved Revisions to the'I will be complete before the next refueling outage in April 1981.
Infraction
D As required by 10 CFR 50, Appendix B, Criterion XVI, implemented
by Topical Report-TYA-TR75-01, Table 17.2.3 and Browns Ferry Operational
Quality Assurance Manual Appendix B, measures shall be established
to assure that conditions
advei se to quality are promptly identified, corrected, and corrective
action is taken to preclude repetition.
Browns Ferry instructional
letter dated July 19, 1980, requires monitoring
and recording of the scram discharge volume headers water level at least once every thirty minutes.Contrary to the above, monitoring
the scram discharge volume headers for the accumulation
of water every thirty minutes was not accomplished
at the required time interval on two occasions on October 6, 1980, and once on October 26, 1980.The failure to correct this problem constitutes
ineffective
corrective
action of the deviation identified
in Inspection, Report 50-259/80-34, 50-260/80-27, and 50-296/80-28.
This is an infraction
to units 1 and 3.A similar item was brought to your attention in our letter dated October 9, 1980.s~Res ense 1.Corrective
Ste s Taken and Results Achieved Regardihg the October 6, 1980, incident, procedures
were modified to clarify the required time that monitoring
is to be conducted.
Each employee that participates
in monitoring
of the scram, discharge header levels has completed a training plan on.the., importance
of this gob and the technique..used to accomplish
level monitoring.
At the beginning of each shift, the shift engineer ensures that employees assigned to this job are familiar with procedures
and requirements
for scram discharge.header: level monitoring..
This isdocumented
in plant.logs.2~A TVAinvestigation
of the October 26, 1980, incident did not disclo'se factual information
sufficient
to support the NRC finding that the required surveillance
at 0600 was not performed.
On the contrary, available information
fully supports the AUO's contention
that the required surveillance
was performed.
Even though it is TVA s position that this incident is unsubstantiated, the measures outlined above regarding the October 6, 1980, incident have been reemphasized:'orrective
Ste s Which Will Be Taken To Avoid Further Noncom liance 3~A monitoring
system is being installed that provides indication
of high-level
on the control room panels.This system is expected to be operational
upon resolution
of technical problems and reliability
questions associated
with the equipment.
Date Full Com liance Will Be Achieved I~',~~(,;, s L Full compliance:regarding
the October 6, 1980, incident was achieved on January 1, 1981.
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