IR 05000259/1983018
| ML20024F729 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 07/12/1983 |
| From: | Cantrell F, Paulk G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20024F595 | List: |
| References | |
| 50-259-83-18, 50-260-83-18, 50-296-83-18, NUDOCS 8309090625 | |
| Download: ML20024F729 (8) | |
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pa"%,jg UNITED STATES
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NUCLEAR REGULATORY COMMISSION g
o REGION 11
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101 MARIETTA ST N.W., SUITE 3100
ATLANTA GEORGIA 30303 g.....,/
o Report Nos.:
50-259/83-18, 50-260/83-18, and 50-296/83-18 Licensee: Tennessee Valley Authority 500A Chestnut Street Chattanooga, TN 37401 Docket Mos.:
50-259, 50-260 and 50-296 License Nos.: DPR-33, DPR-52, and DPR-68 Facility Name:
Browns Ferry 1, 2, and 3 Inspection at Browns Ferry site ne Decatur, Alabama f@
['1 Inspector:
G. L. Paulk
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Date Sfgned Approved by:
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F. S. Cantrell, Section'JkJef D/te Sfgned Project Branch No. 1 Division of Project and Resident Programs SUMMARY Inspection on May 2-6, 1983 and an enforcement meeting at Browns Ferry on June 1, 1983.
Areas Inspected This special inspection involved 29 resident' inspector-hours on site in the area of fuel handling operations on Unit 1.
Results Of the one area inspected, five violations were identified:
Violation of License Amendment Number 42/ Violation of 10 CFR 50, Appendix B, Criterion V; Violation of 10 CFR 50, Appendix B, Criterion XIV; Violation of Technical Specification 6.8.3; Violation of 10 CFR 50, Appendix B, Criterion II; and Violation of Tech-nical Specification 6.3.A.2.
8309090625 830901 PDR ADOCK 05000259 O
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REPORT DETAILS 1.
Persons Contacted a.
Inspection Licensee Employees J. A. Coffey, Acting Pcwer Plant Superintendent J. E. Swindell, Assistent Power Plant Superintendent J. R. Pittman, Assistant Power Plant Superintendent L. W. Jones, Quality Assurance Supervisor W. C. Thomison, Engineering Section Supervisor A. L. Clement,-Chemical Unit Supervisor D. C. Mims, Engineering and Test Unit Supervisor A. L. Burnette, Operations Supervisor R. Hunkapillar, Operations Section Supervisor T. L. Chinn, Plant Compliance Supervisor M. W. Haney, Mechanical Maintenance Section Supervisor T. D, Cosby, Electrical Maintenance Section Supervisor R. E. Burns, Instrument Maintenance Section Supervisor J. H. Miller, Field Services Supervisor A. W. Sorrell, Supervisor, Radiation Control Unit BFN R. E. Jackson, Chief Public Safety R. Cole, QA Site Representative Office of Power Other licensee employees contacted included licensed reactor operators, senior r.eactor operators, auxiliary operators, craftsmen, technicians, public safety officers, quality assurance, quality control, and engineering personnel.
b.
Attendance at Enforcement Meeting Licensee Employees H. J. Green, Director, Nuclear Power H. Abercrombie, Assistant Mcnager, Nuclear Production J. A. Coffey, Acting Power Plant Superintendent J. Domer, Nuclear Licensing-L. Jones, Quality Assurance Supervisor D. Parker, Nuclear Power J. Hutton, Nuclear Power R. Cole, QA Site Representative B. R. McPherson, Engineering, BFNP A. L. Burnette, Operations Supervisor K. W. Whitt, Nuclear Safety Review Staff L. W. Parvin, Quality Engineering J. H. Miller, Field Services Supervisor J. E. Peters, Quality Engineering T. L. Chinn, Plant Compliance Supervisor
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NRC R. C. Lewis, Director of Project and Resident Programs (DPRP)
A. R. Herdt, Branch Chief, Division of Engineering and Operational Programs (DEOP)
F. S. Cantrell, Section Chief, DPRP G. L. Paulk, Senice Resident Inspector, DPRP J. M. Puckett, Enforcement Specialist, Program Support Staff G. Barber, Enforcement Specialist, Office of Inspection and Enforcement F. Jape, Section Chief, DEOP 2.
Management Interviews a.
A management interview was conducted on May 6, 1983, with the Power Plant Superintendent and other members of his staff. The licensee was informed of the violations identified during this report period.
b.
An enforcement meeting was held at BFNP on June 1, 1983.
See paragraph 6 for summary.
3.
Licensee Action on Pr,ious Enforcement Matters Not inspected.
4.
Unresolved Items Unresolved items were not identified during this inspection.
5.
Unit 1 Refueling Operations Unit I was shutdown for a refueling outage on April 16, 1983.
On April 24, 1983, the licensee reported that during unloading of the Unit 1 core, 130 irradiated fuel bundles were placed in a high density fuel storage rack that had not had the required post installation test to verify proper boron concentration.
Boral testing is required by the safety evaluation for license amendment 42 to Unit 1 operating license.
In license amendment 42, regarding boral testing, the licensee is quoted as follows:
"The presence of the neutron absorber material in the fabricated fuel storage module will be verified at the reactor storage pool site by use of a neutron source and neutron detectors. There will be a permanent
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record of all test results that will provide a comparison between the test results for each Boral sheet and the neutron absorption rate I.
taken where there is no Boral sheet. A significat increase in the neutron absorption rates will verify the presence of Boral. Module subcriticality calculations have demonstrated k 0.95 at 95% con-eff fidence level with any four complete Boral sheets missing. A module will be accepted unless measurements indicate that five or more Boral
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sheets are not present."
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Technical Specification 5.5.B states that K effective of the spent storage pool shall be less than or equal to 0.95.
On April 24, 1983, 130 irradiated fuel bundles were loaded into high density rack #8 (per drawing C 5445-E-102) in the Unit 1 fuel pool, K effective on
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rack #6 was unknown. Boral testing required by Unit 1 license amendment 42 to verify K effective had not been conducted.
The Plant Superintendent was informed at the exit on May 6, 1983, that this was a violation of license amendment number 42 (259/83-18-01).
The inspector reviewed other details related to the Unit 1 defueling opera-tion to ascertain regulatory requirements were satisfied.
Technical Instruction (TI) 14, Special Nuclear Materials Control and Accountability System, is the procedure used for refueling operations.
TI 14, Attachment B1, is the fuel assembly transfer form which directs fuel bundle movements.
TI 14 for the Unit 1 unload was approved by the Plant Superin-tendent as required on April 18, 1983. Defueling of the Unit 1 core commenced on April 21, 1983.
The inspector reviewed TI 14 activities to verify procedural adherence.
The inspector noted the following areas where the licensee failed to follow procedures as related to TI 14:
a.
TI 14, Attachment B1 (Fuel Assembly Transfer Form), requires that the fuel handling operator sign for fuel movement verification of location and orientation during inter-fuel pool transfers.
On April 21-22, 1983, nine bundles were transferred in accordance with field change 1 to the Unit I unload fuel transfer form without proper verification signoffs (steps 1-9).
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b.
A review of the official copy of the fuel assembly transfer form indicated that for steps 14-39 (the movement of 26 fuel bundles), no operator verification signoffs for fuel bundle location and orientation was completed.
c.
The shift engineer is required to review fuel move completed data sheets. No shift engineer review was indicated for the movement of bundles steps 14-26 on April 22, 1983.
d.
TI 14 requires that fuel bundles be placed in the spent fuel pool in the specified sequence of row-rack-column for location purposes.
Five different operators during nine different fuel movement operations placed fuel bundles in the wrong location in the Unit I spent fuel pool.
The operators placed the fuel in rack-row-column sequence vice
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the procedural requirements.
e.
' Fuel movement operations from the Unit I core to the Unit I fuel pool requires that the fuel handling operator signoff on the fuel transfer form to verify location and orientation of the fuel bundle moved.
TI 14 requires a first party signoff be made by the fuel handling operator.
During a review of the fuel transfer forms and discussions with plant personnel, the inspector noted that the operators do not
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signoff on the fuel transfer forms as required by TI 14.
Instead, the shift engineer initials for the operator on the fuel transfer form and then the shift. engineer signs the form for overall shift engineer review.
No indication is on tha form to indicate the shift engineer was signing for the operator, i.e.,
"by, "for".
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The licensee was informed during the exit of May 6, 1983, that failure to follow the TI 14 procedural requirements was a violation of Technical Specification 6.3.A.2. (259/83-18-02).
Also, it was noted by the inspector that TI 14 does not require verification that boral testing of the fuel racks (therefore certification of accept-ability for use) has been accomplished.
10 CFR 50, Appendix B, Criterion V requires instructions, procedures or drawings include appropriate quantita-tive or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished. This is a violation of 10 CFR 50, Appendix B, Criterion V and is a second example of Violation 259/83-18-01.
Prior to the mislocated bundle event the licensee did not have the fuel location tagboards in the control room and on the refuel floor properly marked to indicate that eight high density fuel racks installed in the Unit 1 fuel pool were unqualified for fuel storage since the boral testing on the racks had not been accomplished. Additionally, no plant procedures identified the eight high density fuel racks as-unqualified for fuel storage. The Plant Superintendent was informed that this was a violation of 10 CFR 50, Appendix B. Criterion XIV (259, 260, 296/83-18-03).
The inspector reviewed additional work plans listed below to assure com-pliance of regulatory requirements:
Work Plan 6635 -
Unit 2
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High Density Fuel Rack Mods Work Plan 6355 -
Unit 1
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Removal of Spent Fuel Racks Work Plan 6633 -
Unit 2
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Install 5 Hign Density Fuel Racks Work Plan 7670 -
Unit 3
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Remove Spent Fuel Racks Work Plan 7928 -
Unit 3
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Install High Density Fuel Racks Work Plan 6371 -
Unit 1
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Install High Density Fuel Racks Work Plan 6459 -
Unit 1
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Install High Density Fuel Racks The non-boral-tested racks had been installed in June 1982, under Work Plan 6459.
Eight of the 19 high density fuel racks in the Unit 1 fuel pool have not had boral testing. Work plans reviewed were adequate and detailed the fact that the eight racks had not been tested. Other plant sections (nuclear engineers, plant operations) were not aware that the racks had not been tested.
The inspector noted during the inspection of this event that the first nine bundles unloaded from the Unit 1 core were stored in an incorrect location in the spent fuel pool.
Five operators and two QC inspectors had verified by signoff that the bundles were being transferred to the proper storage location.
The ir.spector reviewed the QC inspector training to determine adequacy to conduct the quality control assignment.
Interviews conducted by
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the inspector and the quality assurance staff indicated that of eight inspectors questioned as to how to identify proper fuel location by row-rack-column as required by TI 14, only two could properly interpret the sheets they were required to signoff and verify.
QC inspectors are required to the verify location and orientation on core to fuel pool transfers.
The inspector informed the Plant Superintendent that QC training was inadequate as related to fuel handling operations and was a violation of 10 CFR 50, Appendix B, Criterion II (259, 260, 296/83-18-04). QC inspector training for the fuel handling operations is conducted by the plant operations staff.
An interview with the nuclear engineer that submitted the fuel transfer forms directing the fuel sequence for unload indicated that he was not aware of the boral testing requirement to assure K effective was less than or equal to 0.95.
The inspector pointed out to the licensee that a similar violation concern-ing the use of high density fuel racks without the proper quality assurance review for boral testing was brought to their attention in IE Report No. 80-47.
In that event, the boral testing was completed satisfactorily but the work plan certification and evaluation were not completed.
Refueling activities at Browns Ferry prior to this event have been adequate and indicative of an efficient fuel handling team.
During interviews and record reviews, the inspector observed several indications of why there appears to be a degradation in the fuel handling operations:
a.
Five different operators were involved in removal of the first nine bundles from the core.
Four of the operators were new on the refueling team.
b.
The nuclear engineer who initiated the fuel transfer forms for the moves to the unqualified high density fuel rack was relatively inexpe-rienced and was not aware of any special tests required on high density fuel racks prior to usage. A review of nuclear engineer qualification requirements indicated the subject of neutron absorber testing was not addressed.
c.
Unqualified racks shown on the refuel floor or control room tagboards were not marked to indicate they were not qualified.
d.
The field services supervisor having overall cognizance of fuel rack installation and certification was in a newly assigned position.
Communications between field services and plant operations was essen-tially non-existent as related to uncompleted work plans in process on high density fuel racks. Thus, operations was using material prior to work plan certification, qualification, and completion.
e.
Lessons learned from a similar violation in IE Report No. 80-47 were not used to prevent recurrence of similar events.
In response to the violation, training was held with plant personnel to emphasize the requirAment that all test results must be evaluated and formally
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documented to assure requirements have been satisfied prior to declar-ing a system ready for use.
This training appears to have been inadequate and/or systems were not established to insure sufficient training in this area to prevent recurrence.
f.
Training for operations and QC inspectors related to fuel location descriptions was inadequate.
This problem area was unknown to QA staff prior to this inspection.
Six out of eight QC inspectors could not adequately determine the location to place a fuel Sundle in the fuel pool although QC second party verification is required.
Five operators signed off that fuel was moved to one location in the fuel pool when actually it was in a different rack location. The inspector voiced significant concern to the Plant Superintendent related to this matter.
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The new high density fuel rack pool configuration makes location identification more difficult du'e to the lack of row or column desig-nators on the individual racks.
h.
The inspector reviewed the refuel floor log and discovered that the first nine bundles moved were placed in the wrong rack (not in accor-dance with the fuel move transfer forms). The Plant Superintendent was unaware of the fuel unload errors made related to the initial nine bundles until pointed out by the inspector during this special inves-tigation two weeks after the event even though the errors were docu-mented in the refuel floor log.
i.
The requirement and need for a licensed senior operator to observe and direct core alterations and be in direct communication with the refuel operators was pointed out to the licensee in inspection report 79-36.
This requirement is defined in T.S. 6.8.3 which requires that a licensed senior operator be in direct charge of a reactor refueling operation. The regulation of refueling crews was further explained in IEC 80-21.
The apparent lack of adequate supervision, as required and
~noted above, contributed to the discrepancies in fuel movement.
The refuel floor supervisor is in charge of overall fuel movements.
He failed to properly oversee and review the fuel movement operation as fuel was moved to incorrect racks and not in accordance with the fuel transfer forms. This is a violation of T.S. 6.8.3 (259/83-18-05).
6.
Enforcement Meeting at Browns Ferry on June 1,1983 Mr. Lewis discussed NRC concerns involving unloading fuel assemblies from the reactor into a fuel storage rack other than the designated rack and the subsequent placing of 130 fuel assemblies in an unqualified high density fuel storage rack.
Specific concerns included:
Failure to conduct boral testing of the high density fuel rack after
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Failure to require verification of acceptable testing of high density fuel racks prior to use.
Failure to provide adequate indoctrination and training for QC
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inspectors and operators so as to preclude mispositioning fuel assemblies.
Failure to identify untested high density fuel racks that had been
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installed in the Unit 1 fuel pool.
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Failure of licensee personnel to properly verify (by sign off) and control fuel movement operations.
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Failure of the licensed senior operator on the refueling floor to properly control the refueling operation as evidenced by the above problem.
Licensee representatives stated they were taking this event seriously and had taken corrective actions. The licensee described the event as deter-mined by their investigation, addressed each concern and stated that the root causes were determined to be a failure of management controls and a lack of attention to details.
It was brought out during the meeting that TVA has the QA records that verify the correct boral content of the fuel racks during manufacture and the licensee considers the boral testing in the fuel pool backup certification of the fuel racks. The licensee is to provide the senior resident inspector with a copy of the QA records for review. Mr. Lewis summarized the NRC concerns and stated that TVA would be notified of any enforcement action based on the TVA presentation and NRC review of the fuel rack QA records.
Subsequent to the meeting, the licensee provided copies of the QA records verifying correct boral content.
These records were revie-ed by the senior resident and by Region II personnel and were found to be acequate indications for the safe use of the high density fuel racks.