ML18033A698
| ML18033A698 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 03/30/1989 |
| From: | Linda Watson Office of Nuclear Reactor Regulation |
| To: | Kingsley O TENNESSEE VALLEY AUTHORITY |
| References | |
| NUDOCS 8904170213 | |
| Download: ML18033A698 (31) | |
Text
AC CKlZRA.TED D1STKBU'HON DEMONSTRA.710.'i SYFI EM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:8904170213 DOC.DATE: 89/03/30
,NOTARIZED:
NO DOCKET FACIL:50-259 Browns Ferry 'Nuclear Power Station, Unit 1, Tennessee 05000259 50-260 Browns Ferry Nuclear Power Station, Unit 2, Tennessee
- 05000260 50-296 Browns Ferry Nuclear Power Station, Unit 3, Tennessee 05000296 AUTH.NAME AUTHOR AFFILIATION-WATSONIL.J.
Assistant Director for Inspection Programs-RECIP.NAME RECIPIENT AFFILIATION KINGSLEY,O.D.
Tennessee Valley Authority
'I
SUBJECT:
Forwards summary of 890202'nforcement conference re unmonitored loading of 74 fuel assemblies into plant.
DISTRIBUTION CODE'EOID COPIES RECEIVED LTR i
ENCL L SIZE TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:1 Copy each to: L.Watson,D.M.Crutchfield,B.D.Liaw,S.Black R.Pierson 1 Copy each to: S.Black,D.M.Crutchfield,B.D.Liaw,L.Watson R.Pierson 1 Copy each to:
S. Black,D.M.Crutchfield,B.D.Liaw,L.Watson R.Pierson 05000259 i
05000260 05000296 RECIPIENT ID CODE/NAME PD INTERNAL: ACRS AEOD/DEIIB NRR SHANKMAN,S NRR/DLPQ/PEB ll NRR/DOEA DIR 11 NRR/DREP/RPB 10 NRR/PMAS/ILRB12 0
ERMAN.IJ REG FIL,02 EXTERNAL: LPDR NSIC NOTES:
COPIES LTTR ENCL 1
'1 2
2 1
1 1
1 1
1 1
1 2
2 1
1 1
1 1
1 1
1 1
1 5
RECIPIENT
, ID CODE/NAME GEARS,G AEOD DEDRO NRR/DEST DIR NRR/DLPQ/QAB 10 NRR/DREP/EPB,10 NRR/DRIS DIR 9A NUDOCS-ABSTRACT OGC/HDS2 RGN2 FILE 01 NRC PDR COPIES LTTR ENCL 1
1 1
1 1
1' 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
R I
h NCTE K) ALL'"RICG" RECIPIBGS:
PLEASE HELP US IO REDUCE KLSTB!
CONZACI'IHE DOCXJMEÃ1'DNHKL DESK RDCN Pl-37 (EXT. 20079)
IO EIZKQQTB KKGt NME PBCH DIBTRH3UTIQN LISTS FOR DOCUMENIS %DU DCH'T NEED!
TOTAL NUMBER OF COPIES REQUIRED:
LTTR 30 ENCL 30
MAR 3 0 1989 Docket Nos.
50-259, 50-260, 50-296 License Nos.
DPR-33, DPR-52, DPR-68 Mr. Oliver D. Kingsley, Jr."
Tennessee Valley Authority 6N 38A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Dear Mr. Kingsley
SUBJECT:
ENFORCEMENT CONFERENCE
SUMMARY
'(NRC INSPECTION REPORT NOS. 259,260,296/89-04)
This letter refers to the Enforcement Conference held at our request on February 2,
1989.
The issues discussed at this conference related to the unmonitored loading of 74 fuel assemblies into the Browns Ferry Unit 2 core during January 1989.
Enclosed are a
summary of the conference, a list of attendees, and a
copy of the handout which accompanied your presentation.
It is our opinion that this meeting was beneficial and has provided a better understanding of the inspection
- findings, the enforcement
- issues, and the status of your corrective actions.
We are continuing our review of these issues to determine the appropriate enforcement action.
In accordance with Section 2.790 of the NRC's "Rules of Practice,"
Part 2,
Title 10, Code of Federal Regulations, a
copy of this letter and its enclosures will be placed in the NRC Public Document Room.
Should you have any questions concerning this matter, please contact us.
Sincerely, 438.+co~
g+PP $7'02 3 gppppgip qo330 r DR
~>o~~
pHU G
Enclosures:
- Enforcement Conference Summary 2.
List of Attendees 3.
-'Handout Linda J.
Watson, Acting Assistant Director for Inspection Programs TVA Projects Division Office of Nuclear Reactor Regulation cc w/encls:
(See page 2)
MAR 3 0 1989 Oliver D. Kingsley, Jr.
cc w/encls:
F.
L. Moreadith, Vice President, Nuclear Engineering
- 0. J; Zerinque, Site Director Browns Ferry Nuclear Plant R.
L. Gridley, Director Nuclear Safety and Licensing P. Carier, Site Licensing Manager G. Campbell, Plant Manager TVA Representative, Rockville Office General
D.
M. Crutchfield, NRR B.
D. Liaw, NRR S.
C. Black, NRR R.
C. Pierson, NRR G.
E. Gears, NRR D. Moran, NRR W.
S. Little, NRR/RII A. H. Johnson, NRR/RII A. Long, NRR/RII P. Burnett, RII J.
- Rutberg, OGC NRC Resident Inspector NRC Document Control Desk RIOR jg4Long 3/P /89 RII N
WLittle 3/$)/89
ENCLOSURE 1
Enforcement Conference Summary
'he NRC opened the enforcement conference with a
summary of events associat'ed with the unmonitored loading of 74 fuel assemblies into the Browns Ferry Unit 2 core during January 1989.
NRC senior management reitterated the major issues which TVA had been requested to address during the conference.
-The opening NRC remarks were followed by a
TVA presentation (see licensee
- handout, Enclosure 3).
Introductory remarks by the Senior Vice President of Nuclear Power included an acknowledgement that loading fuel without adequate core monitoring was not a
sound technical practice.
Causes of the event were discussed in general
- terms, and included the licensee's emphasis on ver-batim compliance without questioning the regulations.
The licensee's critique of the event concluded that management had failed to maintain a safety-conscious overview adequate to identify fundamental safety issues.
Techni.cal support from GE had focused on fuel handling technique rathe'r than nucle'ar safety.
The Vice President of Nuclear Power Production discussed the corrective actions taken by TVA to assure adequate core monitoring during the completion of fuel loading.
These actions had been confirmed by NRC inspectors on site.
Fuel
'oading was completed with zero loading errors'.
The Vice President of Nuclear Power Production addressed the condition of existing Technical Specifications (TS) and the Final Safety Analysis Report
( FSAR) with respect to core neutron monitoring during core alterations.
TVA acknowledged that the relevant TS and FSAR Sections were inadequate and should specifically require core monitoring during fuel loading.
A commit-ment was made to submit changes to the TS and FSAR to assure adequate core monitoring.
The licensee disagreed with the conclusion in NRC Inspection Report 89-04 that the unmonitored core loading represented an unreviewed safety question (US/).
Information supporting TVA's position was presented by the Manager, of Nuclear Fuel Engineering.
TVA stated that the FSAR did not require continuous neutron monitoring during refueling, and that the Source Range Monitors (SRMs) were not considered in any accident described in the FSAR.
Although FSAR Section 7.5.4. 1 contained a statement that a three cps,minimum SRM count rate was required, the licensee stated that the requirements of that particular FSAR section were electrical power generation bases rather than plant safety design bases.
The licensee acknowledged that SRMs would play a role in preventing an inadvertent criticality.
- However, inadvertent criticality during refueling was addressed in the FSAR with the conclusion that it is precluded by the nuclear characteristics of the core and by refueling interlocks.
The licensee concluded that the only reasonable inadvertent criticality scenarios would be; I) the withdrawal of more than one control
- rod, or 2) at least four worst case fuel loading errors combined with one control rod withdrawn near or in the same cell.
Erclosure '1 Because each of these scenarios required noncredible-combinations of multiple mechanical failures and personnel er rors, the licensee concluded that inadvertent criticality was outside the safety design basis.
TVA stated that GE concurred that the're had been no USQ.
NRC management noted that the licensee safety analysis and USQ determination were made after the unmonitored core loading had already occurred.
Although the results of the licensee analysis provided perspective on the safety significance of the event it did not appear that the licensee had performed a
valid safety.analysis and USQ determination prior to commencing fuel load without continuous core monitoring.
The Browns Ferry Plant Manager addressed NRC concerns regarding programmatic failures in the procedure review process.
The Plant Manager stated that all fuel loading procedures had received cross-disciplinary review which met or exceeded the requirements of plant procedures and TS.
Although the licensee acknowledged that the fuel loading procedures reviewed by the NRC inspectors did not receive cross-disciplinary -review when issued in 1988, the licensee stated that these procedures were administrative revisions to previous procedures which had already received the required cross-disciplinary review.
The initial issue of 2
GOI 100-03 was described by the licensee as a "unitization and format change" to a previous procedures Therefore, the licensee did not believe that another extensive, in-depth i eview was required for the fuel loading procedures issued in 1988.
The Plant Manager further stated that all 10 CFR 50.59 evalua-tions of the fuel loading procedures were technically correct and appropriate to the circumstances, although he acknowledged that a number'of administrative errors had been made.
In conclusion, the Plant Manager stated that the unmonitored core loading did not result from a
problem with the procedure review process, but from the licensee's emphasis on verbatim compliance.
The NRC management questioned how a review process could be considered adequate which approved procedures that did not require continuous core monitoring'n
- addition, the NRC questioned why thorough technical and cross-disciplinary reviews of the fuel loading procedures were not performed as part of the pro-cedure upgrade program.
During the discussions regarding the adequacy of the procedure review process, the Technical Services Supervisor acknowledged that he had questioned the lack of core monitoring during his review of the fuel loading procedures.
He stated that he and the reactor engineers had reviewed the applicable TS and the asso-ciated Safety Evaluation Rep'ort (SER),
and had concluded that continuous core monitoring was not a requirement.
At the request of the
- NRC, the Technical Services Supervisor read aloud selected portions of the SER which NRC management considered to clearly indicate that continuous core monitoring was required.
TVA management did not agree that the SER wording reflected a requirement for'ore monitoring.
The Nuclear Technical Director discussed planned program enhancements to preclude the occurrence of similar. events in the future.
He stated that a
new corporate management directive on 10 CFR 50.59 will be issued to address administrative deficiencies and incorporate industry enhancements.
TVA management will also strengthen the nuclear experience review program, and
'ormalize a
process for responding to vendor information such as GE Service Information Letters'(SILs).
Enclosure 1
The Vice, President of Nuclear guality Assurance discussed the status of an overall Browns Ferry TS assesssment.
A short-term assesssment of TS required to support fuel loading had been completed without identifying any specifica-tions requiring immediate technical revision.
A long term assessment will be completed by reviewing the TS for consistency with applicable documents, and good operating practices.
Completion of the Browns Ferry Unit 2 TS assessment by March 31,
- 1989, was projected.
The TVA presentation was concluded by the Senior Vice President of Nuclear Power.
A commitment was made to provide the NRC with additional written information supporting the TVA position on.each of the major issues of the inspection.
ENCLOSURE 2 List of Attendees 1.
TVA Licen 0
J.
C.
0 R.
H.
P.
J.
D.
J.
J.
B.
P.
L.
C.
T ~
D.
S
~
N.
C.
R.
L.
G.
G see Personnel:
Kingsley, Jr., Senior Vice President, Nuclear Power Bynum, Vice President, Nuclear Power Production Fox, Vice President and Nuclear Technical Director
- Kazanas, Vice President, Nuclear guality-Assurance Gridley, Director, Nuclear Licensing'ampbell, Plant Manager Carier, Site Licensing Manager Lewis, Reactor Engineer Mims, Technical Services Supervisor
- Robert, Manager, Nuclear Fuel Engineering Robertson,
- Manager, Nuclear Fuel Schofield, Compliance Licensing Supervisor Licensee Contractors:
P 0
N M. 'Marriott, General Electric
- Repka, Bishop, Cook, Purcell, and Reynolds
- Reynolds, Bi shop, Cook, Purcel 1, and Reynolds 2.
NRC D
B.
F, S;
P.
D.
R.
D.
T.
W.
A.
R.
T.
M.
S.
R.
C.
S.
M.
D.
R.
P. I.
E.'.
Crutchfield, Acting Associate Director for Special Projects Liaw, Director, TVA Projects Division McCoy, Assistant Director for Inspection Programs Black, Assistant Director for TVA Projects
- Burnett, Reactor Inspector, RII Test Programs Carpenter, Browns Ferry Site Manager Castleman, Plant Systems Engineer Goodwin, Technical Assistant to Director of TYA Projects Division Little, Browns Ferry Section Chief, TVA Inspection Programs Long',
Browns Ferry Project Engineer, TVA Inspection Programs
- Pierson, Assistant Director for TYA Technical Programs
- Rotella, Reactor Operations Branch Troskowski, Office of Enforcement
ENFORCEMENT CONFERENCE FEBRUARY 2, 1989 AGENDA 7OPIC I.
INTRODUCTION II.
COMPLETION OF FUEL LOAD III.
TECHNICAl SPECIFICATION/FSAR REQUIREMENTS IV.
SAFETY EVALUATION V.
PROCEDURES Vl.
IMPROVEMENTS A. 10CFR50.59 IMPROVEMENTS B. EXPERIENCE REVIEW C. TECHNICALSPECIFICATION REVIEW Vll.
SUMMARY
SPEAKER O. D. KINGSLEY,JR.
J. R. BYNUM J. R. BYNUM J. ROBERT G. G. CAMPBELL C. H. FOX C. H. FOX N. C. KAZANAS O. D. KINGSLEY,JR.
I CD C/l
INTRODUCTION
~ TVAIS HERE TODAYAS FOI LOW-UP TO OUR JANUARY9-1 0, l989 MEETING AND TO RESPOND VERBALLYTO THE MAJOR CONCERNS RAISED IN F. R. McCOYs LETTER TO O. D.
KINGSLEY,JR., DATED JANUARY30, 1989. TVAWILL PROVIDE FORMALLYDOCUMENTED INFORMATION ADDRESSING CONCERNS IN THATLETTER IN THE NEAR FUTURE.
~ WE RECOGNIZE THATWHATTVADID AT BROWNS FERRY WITH RESPECT TO REACTOR CORE MONITORINGWAS NOT A SOUND TECHNICALPRACTICE. THE REACTOR CORE SHOULD HAVE BEEN ADEQUATELYMONITORED DURING FUEL'LOADING.
~ WITH REFERENCE TO THE TELEPHONE CALLOF FRIDAY, JANUARY6, 1989, WITHTHE NRC, TVADID NOT PROPERLY CONVEY OUR CONSERVATIVE SAFETY CONSCIOUS APPROACH TO PLANT OPERATIONS.
~ WE WILLALSO DISCUSS THE CORRECTIVE ACTIONS TVA HAS TAKEN ANDWll L TAKETO ENHANCE APPROPRIATE PROGRAMS TO PRECLUDE THE OCCURRENCE OF SIMILAR EVENTS IN THE FUTURE.
COMPLETION OF FUEL LOAD CORE MONITORING CONVERTED IBMTO SRM INSTALLEDTWO FUEL LOADINGCHAMBERS k
MODIFIED REFUELING PROCEDURE DEVELOPED BY GENERAL ELECTRIC SIMILARTO INITIALCORE LOADING-APPLICABLEPERSONNEL TRAINED ON PROCEDURE REVISIONS/LESSONS LEARNED RELOAD COMPLETION
SUMMARY
ACCOMPI ISHED UNDER TECH SPEC 3.10.B.l.b ONE SRM/FLC IN QUADRANTOF FUEL MOVEMENTAND ONE IN ADJACENT QUADRANTWITH > 3 CPS ACCOMPLISHED WITH GE TECHNICALOVERSIGHT a
TECH SPEC 5 FSAR REQUIREMENTS I
~ TECHNICALSPECIFICATIONS AND FSAR SHOULD SPECIFICALLY REQUIRE (AND ASSURE ADEQUATE) CORE MONITORING DURING FUEL LOADING
~ TVAACKNOWLEDGEDON JANUARY5, 1989 THATCORE MONITORINGWAS NECESSARY
~ TVAWILLSUBMITCHANGES TO ASSURE PROPER CORE MONITORING
TECHNICALSPECIFICATION REQUIREMENTS 1973-1975 TWO SRMs OR FLCs ONE IN QUADRANTBEING
'OADED AND ONE IN ADJACENT QUADRANT C
1975-TO PRESENT TWO SRMs OR FLC, AT LEAST ONE IN QUADRANTBEING I OADED OR IN'ANADJACENT QUADRANT,LESS THAN3 CPS ALLOWEDDURING FULLCORE UNLOAD 1979-TO PRESENT TWO SRMs OR FLCs LESS THAN 3 CPS ALLOWEDIN FULLCORE RELOAD AND CORE LOADED IN SPIRAL.
. SEQUENCE ONLY 1984-TO PRESENT TWO SRMs OR FLCs, FOUR ASSEMBLIES MAYBE LOADEDADJACENTTO SRMs TO ESTABLISH GREATER THAN3 CPS AND FUEL LOADED IN SPIRAL SEQUENCE AFTER ADJACENT FUEL LOADING
FSAR REQUlREMENTS FOR SOURCE RANGE MONITORS
~ SECTION 7.5.4 SOURCE RANGE MONITOR SUBSYSTEM
- NO SAFETY DESIGN BASIS
- 7.5.4.1 POVfER GENERATION DESIGN BASIS
~ SECTION 13.9 REFUELING OPERATIONS
- NO REQUIREMENT FOR CORE MONITORING.
~ NO CREDIT IS TAKEN IN THE FSAR FOR SRMs OR FLCs IN ANY ACCIDENT
BROWNS FERRY UNIT 2 FUEL LOADINGSAFETY EVALUATION
~ OBJECTIVE
- EVALUATELOADINGOF 74 FUEL ASSEMBLIES IN BFN UNIT 2 WITHOUTCONTINUOUS SRM MONITORINGTO DETERMINE IF AN UNREVIEWED SAFETY QUESTION EXISTED
~ REACTOR CORE SHOULD HAVE BEEN MONITORED DURING FUEL LOADING
~ FSAR CONCLUSIONS ON REFUELING ACCIDENTS
- BOUNDING EVENT IS A FUEL ASSEMBLY DROP ACCIDENT
- INADVERTENTCRITICALITYDURING REFUELING IS PRECLUDED BY THE NUCLEAR CHARACTERISTICS OF THE CORE AND THE REFUELING INTERLOCKS
EFFECTS OF SRM MONITORING ON FUEL LOADING
~ MONITORING DOES NOT AFFECT:
-.FUEL ASSEMBLY DROP ACCIDENT
- REACTOR PROTECTION SYSTEM FUNCTION
- CONTROL ROD FUNCTIONS
~ MONITORINGCOULD AFFECT DETECTION OF UNEXPECTED REACTIVITYINCREASES FROM EVENTS SUCH AS:
- MISLOADEDFUEL ASSEMBLIES
- CONTROL ROD WITHDRAWAL
- RECONSTITUTION ERRORS
- FUEL MANUFACTURINGERRORS
- LOSS OF POISON MATERIALFROM CONTROL BLADES
- MODERATOR TEMPERATURE DECREASES
~ THE SAFETY EVALUATIONSHOWED THATTHE FIRST TWO EVENTS HADTHE GREATEST POTENTIALFOR SIGNIFICANTREACTIVITYINCREASES.
JANUARY 5 CORE CONFIGURATION REACTIVITYANALYSIS SHUTDOWN MARGIN(/o AK) 76 BUNDLES LOADED CORRECT CONFIGURATION ARI 7.59 SRO 2.65 ASSUMING 3 WORST LOADINGERRORS 6.72
. 0.83 ASSUMING 4 WORST LOADINGERRORS 6.34
-0.19 ACCEPTANCE CRITERIA (REQUIRED SDM +
ANALYSISUNCERTAINTY) 0.70 GE PERFORMED INDEPENDENT CALCULATIONSON THE 76 BUNDLE CONFIGURATION AND VERIFIED THE TVARESULTS
SAFETY EVALUATIONCONCLUSIONS
~ SAFETY EVALUATIONREGONFIRMED INADVERTENTCRITICALITYNOT CREDIBLE
~ BROWNS FERRY UNIT2 FUEL LOADINGDID NOT CONSTITUTE AN UNREVIEWED SAFETY QUESTION r
~ GE-REVIEWED AND CONCURRED WITH THESE CONCLUSIONS
~ FUEL LOADINGWITHOUTADEQUATE MONITORlNGWAS NOT A SOUND TECHNICALPRACTICE AND WILLNOT BE REPEATED
REVIEW OF CURRENT PROCEDURE PROCESS INTRODUCTION
~ BFN PROCEDURE PROCESS FULLYIMPLEMENTS REGULATORY REQUIREMENTS I'
PREPARATION OF PROCEDURES USED FOR FUEL LOAD ADEQUATELYCOMPLIED WITH PROCEDURAL REQUIREMENTS
SDSP-27.1 SCREENING REVIEW/
50.59 EVALUATION
~ APPLIES TO A NEW PROCEDURE
~ APPLIES TO CHANGES TO AN EXISTING PROCEDURE DELINEATES SCREENING REVIEW PROCESS
~ DELINEATES 10CFR50.59 SAFETY EVALUATIONPROCESS
~ THIS PROCEDURE IS CONSISTENT WITHTHE REQUIREMENTS.OF 10CFR50.59'
SDSP-7.4 TECHNICALREVIEW/APPROVAL
~ DELlNEATESTECHNlCALREVIEW PROCESS (T/S 6.5.3)
~ PROVIDES REQUIREMENTS FOR CROSS-DISCIPLINARY. REVIEW (T/S 6,5.3)
- PROCEDURE MAYAFFECT EQUIPMENT UNDER ANOTHER GROUP'S CONTROL
- ANOTHER GROUP REQUIRED TO PERFORM A PHYSICAL ACTION NOT PREVIOUSLY INCLUDED
- BEYOND THE EXPERTISE OF THE GROUP MAKINGTHE REVISION
REVIEW OF CURRENT PROCEDURE PROCESS PROCEDURES USED FOR FUEL LOAD REVIEVfEDAGAINST CRITERtA
~ GOI - 100-3 "REFUELING OPERATIONS"
~ Tl -147 CORE ALTERATIONS,FUEL HANDLINGIN SFSP; VESSEL DISASSEMBLYAND REASSEMBLY, CAVITYLEVELCONTROI AND COORDINATION OF SURVEILLANCEINSTRUCTIONS "FUEI LOADINGAFTER A COMPLETE CORE I
UNLOADING" LOADINGFUEL TO FULLCORE SIZE AFTER COMPLETE UNLOAD
REVIEW OF CURRENT PROCEDURE PROCESS
~ Tl -14 "SPECIAL NUCLEAR MATERIALCONTROL"
~ SI - 4.10.B CONTROL, ACCOUNTABILITY,INVENTORY, DOCUMENTATION,AND REPORTING REQUIREMENTS FOR SNM "DEMONSTRATIONOF SRM SYSTEM OPERABILITYDURING CORE ALTERATIONS" SRM SYSTEM OPERABILITYDEMONSTRATION DURING CORE ALTERATIONS 15
I REYIEW OF CURRENT PROCEDURE PROCESS PR CEDU NUMBER OF REVI I
N REVISION
'C NTENT CROSS DISCIPLINARY/
AFFECTED SECTION REVIEW RE IREMENT RE LT 2-Sl 4.1 0.8 ALLADMIN.
EXCEEDED CONCLUSIONS CORRECT 2-Tl-'147 MOSTLY ADMIN.
MET OR EXCEEDED CONCLUSIONS
-CORRECT 2-Tl-14.
60% ADMIN.
40% TECHNICAL-MET OR EXCEEDED CONCLUSIONS CORRECT 2 GOI 100-3 70% ADMIN.
MET OR EXCEEDED 30% TECHNICAL
-CONCLUSIONS CORRECT
REVIEW OF CURRENT PROCEDURE PROCESS CONCLUSIONS
~ APPROPRIATE CROSS-DISCIPLINARY/AFFECTED SECTION REVIEWS WERE CONDUCTED IN ACCORDANCE WITH PROCEDURES
~ 10CFR50.59 SCREENING REVIEWS WERE TECHNICALLY ADEQUATE
NEW 50.59 PROGRAM MANAGER'S INSTRUCTION P.URPOSE:
TO ADDRESS ADMINISTRATIVEDEFICIENCIES AND INCORPORATE INDUSTRY ENHANCEMENTS ONE PROCEDURE DEFINING TECHNICALREQUIREMENTS
~ INCREASES QUALIFICATIONS
~ USES SELECTED NUMARCGUIDANCE
~ STRENGTHENS SAFETY EVALUATIONREVIEWS
~ STRENGTHENS FSAR UPDATE
~ ESTABLISHES 50.59 LIBRARIES
~ LOWERS THRESHOLD FOR PERFORMING SAFETY EVALUATIONS
EXPERIENCE REVIEW NUCLEAR EXPERIENCE REVIEVfNEEDS STRENGTHENING IMMEDIATEACTIONS STATUS
~ ASSiGN PROJECT MANAGERFOR EACH SIGNIFICANT EXPERIENCE REVIEW /ISSUE
~ REQUIRE ACTION PLAN FOR SIGNIFICANTISSUES
~ IMPOSE SCHEDULE FOR INITIATIONOF ACTION PLAN
~ ESTABLISH A SINGLE POINT OF CONTACT AT SITES AND ENGINEERING
~ PREPARE GUIDANCE FOR PROMPT NOTIFICATIONTO SENlOR MANAGEMENT IN PROGRESS COMPLETE COMPLETE
- COMPLETE, COMPLETE
EXPERIENCE REVIEW
SUMMARY
OF FOLLOW-UP ACTIONS TO STRENGTHEN NER PROGRAM CONDUCT CRlTlCALREVIEW OF EXlSTING NER PROCESS STATUS:
~ ONE-MfEEK INPO ASSlST YlS1T-COMPLETE I
~ TWO -WEEK AUD1T BY lNDEPENDENT REVlEW TEAM-UNDERWAY
~
SUMMARY
REPORT DUE FEBRUARY 8, 1989 20
SHORT TERM TECH SPEC ASSESSMENT ASSESSMENT TEAM REVIEWED U2 TECH SPEC APPLICABLEOR POTENTIALLYAPPLICABLETO REFUEI /SHUTDOWN REVIEWED TECH SPECS AGAINSTFUEL LOADSYSTEMS, SERS, SILS, BFN TECH SPEC INTERPRETATION MANUALANDTHE BWR 4 STANDARDTECH SPEC FOR CONSISTENCY AND GOOD OPERATING PRACTICES RESULTS OF ASSESSMENT:
- 1. NO GONGERNS REQUIRING IMMEDIATETECHNICAL SPECIFICATION CHANGES
- 2. ITEMS REQUIRING ADMINISTRATIVECONTROLS
- 3. FURTHER EVALUATIONSFOR POTENTIAL ENHANCEMENTS
BFN UNIT 2 TECH SPEC ASSESSMENT PROGRAM
~ SCOPE
- TS CHANGE CONTROL PROGRAM EFFECTIVENESS
- EVALUATETS INTERPRETATION AGAINSTTS REQUIREMENTS
- EVALUATETS CONSISTENCY WITH DESIGN BASIS
- MONITOR FOR ADEQUATE IMPLEMENTATIONOF TS REQUIREMENTS
- - COMPARISON OF BFN TS WITH STS
- ACTION PLAN
- FIELD WORK COMPLETE
- PROBLEM RESOLUTION
- REPORT APPROVED 2/17/89 3/10/89 3/3 I/89 22
SUMMARY
~ AS STATED ATTHE BEGINNING OF TODAY's MEETING TVAREALIZES THAT PERFORMING CORE ALTERATIONSWITHOUTADEQUATELYMONITORING NEUTRON FLUX LEVELS WAS NOT A SOUND TECHNICALPRACTICE.
~ TVAHAS TAKEN EXTENSIVE CORRECTIVE ACTIONS TO ENSURE THE. REACTOR CORE WAS ADEQUATELYMONITORED AFTER RESUMPTION OF THE RELOAD OF UNIT2 AT BFN.
~ TVAHAS STATED THATTHE FSAR SECTIONS AND TECHNICALSPECIFICATIONS THATGOVERN CORE MONITORING AS IT APPLIES TO FUEL LOADINGARE INADEQUATEAND WILLBE CHANGED TO BE MORE SPECIFIC.
~ TVAHAS VERBALLYADDRESSED THE MAJOR CONCERNS RAISED IN NRCs JANUARY30, t 989 LETTER TO TVA. TVAWILLPROVIDE WRITTEN INFORMATION ON EACH ITEM IN THE NEAR FUTURE.
23