ML18033A846
| ML18033A846 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 07/13/1989 |
| From: | Carpenter D, Little W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18033A842 | List: |
| References | |
| 50-259-89-18, 50-260-89-18, 50-296-89-18, NUDOCS 8907260288 | |
| Download: ML18033A846 (19) | |
See also: IR 05000259/1989018
Text
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UNITEDSTATES
nNUCLEAR REGUI-ATORY<<COMMISSION
REGION II
101 MARIETTASTREET, N.IN.
ATLANTA,GEORGIA 30323
Report Nos..:
50-259/89-18,
50-260/89-18,
and 50-296/89-18
Licensee:
Valley Authority
6N 38A Lookout Place
1101 Market Street
Chattanooga,
TN
37402-2801
Docket Nos.:
50-259,
50-260,
and 50-296
License Nos.:
and
Facility Name:
Browns Ferry Units 1, 2,
and
3
Inspection at Browns Ferry Site near Decatur,
h
Inspection
Conducted:
February
10 - May 22, 1989;
June 12-14,
1989
Inspector.
enter,
1te
anager
Accompanied
by:
K. Ivey, Resident
Inspector
A.
Lon
, Pro't
ngineer
Approved by:
1 t
'ction
1e
Inspection
rograms,
.
TVA Projects Division
'UMMARY
Scope:
This special
reactive
inspection
was
performed to follow-up on the findings
identified in
NRC Inspection
Report (IR) 89-04 and to review and evaluate
the
licensee's
response
to those findings.
Results:
As
a result of this inspection,
three violations were identified
260/89-18-01:
Failure to Comply with 10 CFR 50.59 (paragraph
2).
260/89-18-02:
Inadequate
refueling procedures
(paragraph
4).
259,
260,
296/89-18-04:
Failure
to provide cross disciplinary review
(paragraph
7).
~5072602+s
I"-IDOCf 0>0004
5'DC
The inspection
verified'weaknesses
'in the. areas of fuel loading procedures
and
operations,
and'programs
for"preparation,
review and approval of procedures.
An unresolved. item on the adequacy of station
and administrative procedures
was
identified.
Cl
REPORT DETAILS
Persons
Contacted
Licensee
Employees:
0. Kingsley, Jr., Senior Vice President,
Nuclear Power
C.
Fox, Jr., Vice President
and Nuclear Technical Director
J.
Bynum, Vice President,
Nuclear
Power Production
"0. Zeringue, Site Director
"G. Campbell,
Plant Manager
J.
Hutton, Operations
Superintendent
- D. Mims, Technical
Services
Supervisor
J.
Lewis, Reactor Engineering
~P. Carier, Site Licensing Manager
J.
Savage,
Compliance Supervisor
T. Bradssh,
Plant Reporting Section
"N. McFall, Compliance
Engineer
"S.
Rudge, Site
Programs
Engineer
~P.
Salas,
Licensing Engineer
~Attended exit interview
Other
licensee
employees
or contractors
contacted
included
licensed
reactor operators,
compliance
and engineering
personnel.
NRC Resident
Inspectors:
"D. Carpenter,
Site Director
~C. Patterson,
Restart
Coordinator
"W. Bearden,
Resident
Inspector
~E. Christnot,
Resident
Inspector
~K. Ivey, Resident
Inspector
NRC Personnel:
"B. Wilson, Assistant Director for Inspection
Programs
"W.. Little, Section Chief
A. Long, Project Inspector
Acronyms used throughout this report are listed in the last paragraph.
Unreviewed Safety question Determination
NRC Inspection
Report (IR) 260/89-04 concluded that the loading of 74 fuel
assemblies
into the Unit 2 core without adequate
core monitoring consti-
tuted
a potential
unreviewed safety question
(US(), as defined
The licensee's
response
to IR 89-04,
issued
March 1, 1989, stated that the
unmonitored core loading did not constitute
a US(, in that the probability
or consequences
of an accident
were not increased,
and
no margin of safety
was
reduced.
This
was
based
on TVA's determination, after reloading
was
stopped that 'an =-inadvertent criticality was not
a credible event
due to
core
design
and interlocks
and rod blocks which prevented
control
rod
withdrawal.
As
documented -in paragraph
3, the
NRC confirmed that the
interlocks
and rod blocks were operable.
The
NRC'-has 'eviewed
TVA's position
an'd still concludes
that the
unmonitored
core
loading did constitute
a US(, in that the margin of
safety
as
defined in the
TS Bases
was decreased.
The Basis for TS 3. 10.A
clearly states
that
during core alterations
the
margin of safety is
.provided by both refueling interlocks
and operational
procedures.
For the
reasons
documented
in *paragraph
4 of this
report,
the
procedures
controlling refueling were
inadequate.
Based
on TVA's evaluation after
.
refueling
was
stopped
the
NRC agrees that the reduction in safety margin
was slight and this will be considered
in determining the severity level
of the violation.
Another
reason
that
the
reload
scheme
should
have
been
considered
an
unreviewed
safety question
is that the analyses
on which TS 3. 10.B. l.b.2
is
based
do not bound the Cycle
6 reload conditions.
A review of the
NRC
safety evaluation for the
TS dated October ll, 1979,
and the bases for TS
3. 10.8. l.b.2
should
have,
led
TVA to this
conclusion.
Pertinent
statements
in these
documents
include:
. especially
during
core
loading, it is
necessary
to
monitor flux levels.
In this
manner,
there
is
reasonable
assurance
that
any approach to criticality would be detected.
(NRC Safety Evaluation for TS 3. 10.B. l.b.2)
The
NRC Safety Evaluation
was based
on reload following a normal
refueling
outage.
(Reloading with reconstituted
fuel after
a
four year outage is not normal.)
The basis for TS 3. 10.8. 1.b.2 states
that,
"A large
number of
fuel assemblies
will not
be required to maintain three counts
per
second."
(TYA knew that the cycle
6 reload
scheme
would
require
>200
assemblies
to
be
loaded
before
3 cps
would be
reached.)
"The, minimum count rate requirement in the Technical Specifica-
tions accomplishes
three safety functions: .....
(3) it provides
assurance
that the
SRH detectors
are close
enough to the array
of fuel assemblies
to monitor core flux. levels. 'NRC Safety
Evaluation for TS 3. 10.B. 1.b.2).
The
NRC Safety
Evaluation
assumed
that with a
SRM about
two
feet
away
from
16
or
more fuel assemblies
that the loss in
sensitivity would
be at most
one
decade. 'VA conservatively
estimated
that
the sensitivity
loss
would
be at least
.two
decades
per foot between
the core
and the detector.
The
NRC
analysis
assumed
the
were
much
more
sensitive
than
actually appeared
to be the case.
Cl
TVA's. response
to.IR, 89-04 indicated that since the
TS
LCO is written such
that the limit is less-than
a specified value,
then they are relieved of
the responsibility for determining
an acceptable
operat'ional limit needed
to accomplish the
TS objective,
which in this
case
was core monitoring,
. and that any
SRM count rate below three
was acceptable,
even zero.
This
is 'not an acceptable
practice.
It is concluded that
a violation of 10 CFR 50.59 did occur in that TVA
chose
to
use
a
core
loading
scheme that
was not bounded
by previous
evaluations,
and
the
procedures
for the
core
reload
scheme
were not
adequate.
This resulted
in a reduction of the margin of safety described
in the. basi's for TS 3. 10.
This
was not identified by TVA,,a written
safety
evaluation
was
not prepared,
and
the
NRC was not notified as
required
by 10 CFR 50.59.
Violation 89-04-01 is closed
and this issue is
identified as Violation 260/89-18-01.
3.
Operability of Refueling Interlocks
Based
on discussions
with licensee
personnel
and reviews of documentation,
the inspector
determined
that the
SRM downscale
rod block function was
as
required
during the Unit 2 core reload,
and
no control rods
could have
been manually withdrawn with SRM readings of less
than
3 cps.
The
SRMs provide signals
to the Reactor
Manual Control
System
(RMCS) for
various control
rod blocks,
including
a downscale
rod w>thdrawal block.
TS 3.2.C.,
"Control
Rod Block Actuation",
and associated
Table 3.2.C,
provide the limiting conditions for operation for the instrumentation that
initiates
rod blocks.
This
TS requires
a
SRM downscale
rod block with a
trip level settinq of greater
than or equal to 3 cps.
A minimum of three
channels
are required to be operable.
This function is to be in place at
all times except the following:
A and
C downscale
functions are bypassed
when
IRMs A, C,
E, and
G are
above
range
2.
B and
D downscale
functions are bypassed
when
IRMs B, D, F,
and. H are above
range
2.
The function is bypassed
when the
mode switch is placed in RUN.
The system
readiness
review,
and the surveillance instruction (SI) which
~ verified
the
operability of this
function were
performed prior to
beginning
fuel
loading.
Surveillance
test,
2-SI-4.2.C-4
(A-D),
"Instrumentation
that Initiates
Rod
Blocks/Scrams
SRM Calibration
and
Functional
Test,"
was
performed for channel
A
on
December
14,
1988;
Channel
B
on
December
16,
1988;
Channel
C
on
December
13,
1988,
and
Channel
D on December
15,
1988.
No violations or deviations
were identified.
4.
Refueling Procedures
The refueling activities that began
on January
3, 1989 were controlled by
the following procedures:
TI-147,
Rev.
3,
December'16,
1988,"."Fuel
Loading After a 'Complete
Core
Unload"
2-GOI-100-3,
Rev. 4,
December
22, 1988, "Refueling Operations"
TI-14, "Special
Nuclear Material Control"
NIZAM, Part II, Sec.
1.1,
Paragraph
3.2,2 establishes
requirements
for the
preparation,
review
and
approval,
use
and revision of plant operating
instructions
including
'fuel-handling
instructions
for
refueling
operations.
Among other things the following are required to be included
in the fuel-handling instructions:
3.2.2.2
"They .....
provide for continuous monitoring of the neutron
flux throughout core loading, .....".
3.2.2.3 ".....
specific instructions
shall
be
prepared
for each
refueling ......"
General
requirements
for all instructions states
in paragraph
3. 1.2.6 that
"Limitations on the parameters
being controlled ..... shall
be specified."
Based
on
the
above
TVA requirements
the refueling
procedures
were
deficient as follows:
None of the above refueling procedures
required continuous monitoring
of the neutron'flux throughout core loading.
The refueling procedures
appear
to
be written to try to cover all
fuel loading
schemes
allowed by TS 3. 10.B resulting in Sections
3.37
and 5.4 of 2-GOI-100-3;
and Section 4.0 of TI-147 being confusing
and
sometimes
inconsistent
and conflicting.
Specific instructions for
the fuel loading
scheme
used
(TS 3. 10.B. l.b.2) were not provided and
the refueling procedures
need to
be revised
to address
each of the
schemes
allowed
by the
TS in order to require adequate
core neutron
monitoring.
The
procedure
minimum count
core
loading
monitoring of
did not
address
specific limits or, values for the
rate to be expected for the
scheme
selected,
in order
to
ensure
continuous
the neutron flux.
The
NRC reviewed
2-GOI-100-3
and TI-147 and the following concerns
and
deficiencies
were
identified
(additional
concerns
are identified in
IR 260/89"04):
TI-147 did not reference
NIZAM, Part II, Section 1.1
and
which establish
requirements
for fuel loading procedures.
.. TI-147, .Section
4.-2 was "not consistent. with 2-GOI-100-3, Section 3.37
"" even though both specified criteria for halting fuel loading.
'TI-147, Section 4.2 allows fuel loading to be
resumed after being
stopped for the specified reasons,
provided the "specific corrective
action
has
been taken."
Specific corrective action is not identified
in- any of the procedures,
and the process, .including approvals,
for
resuming refuel is not addressed
in any of the procedures.
TS 3.10.B requires that only two
SRMs shall
be operable.
If only
two are
and if the
two readings
doubled,
both TI-147,
Section 4.2.8
and 2-GOI-100-3,
Section
5.4 would allow refueling to
continue.
This is not considered
to be prudent action.
Sections
3.37
and 5.4 of 2-GOI-100-3 state
that refueling shall
be
halted for any of the eleven
reasons
stated
therein.
One of the
reasons
(3.37. 1) is
"Unexpected
subcritical multiplication (i.e.,
any unexplained
or
abnormal
increase
in SRM readings)."
None of the
procedures
gave
any guidance
as to what could
be expected
for the
loading
scheme
used,
especially if the count rates
were
< 3cps.
With the
scheme
used
and with the
SRM's
one to two feet away from
the fuel,
the
operators
needed
guidance
as
to what constituted
expected
or unexpected
behavior of the
SRMs.
It is not clear what
step
3.37.3
means.
It appears
that the "Note" is meant to modify
3.37.3,
but this
needs
to
be clearly stated
so that the user of the
procedure
does not have to assume this is the case.
The failure to establish
and
implement
adequate
refueling procedures
in
accordance
with TS 6.8. 1. l.a and
NIZAM, Part 2, Section l. 1 is
a violation.
(VOI 260/89-18-02).
The
NRC is concerned that these
procedures
had been
processed
through the Procedures
Upgrade
Program
and through screening
and
cross-disciplinary
reviews.
In response
to URI 260/89-18-03
(paragraphs
5
and 8)
TVA is requested
to address
why they believe that these
reviews
apparently failed and
why they have confidence that the Procedure
Upgrade
Program
has corrected
the procedure
problems .that have existed for several
years.
5.
Screening
Reviews of Fuel
Load Procedures
Inspection
Report 89-04 stated that procedures
issued for the Unit 2 fuel
1oadin~ did not receive
adequate
screening
reviews in accordance
with SDSP
27. 1,
'Evaluation of Changes,
Tests,
and Experiments - Unreviewed Safety
question
Determination."
IR 89-04 further stated
that the
lack of
resulting safety evaluations
contributed to the unmonitored core loading
event.
The
reviewed
procedures
included
2-GOI-100-3,
"Refueling
Operations,"'evisions
0 through 4, TI-147, "Fuel Loading After a Complete
Core Unloading," revisions
0 through 3,
and MRTI,
Master Refueling Test
Instruction," revisions
1 through 4.
The licensee's
response
admitted that administrative deficiencies
existed
in the documentation
of the screening
reviews;
however, it stated that
a
failure to implement the technical intent of SDSP 27. 1 did not occur.
The
response
indicated that the screening
reviews, addressed
only changes
made
to the procedure
and not the entire procedure.
The licensee
concluded
that the reviews were proper
and the conclusions
were correct.
The NRC"'inspectors're-reviewed
the-screening
reviews performed for the
procedure
revisions
referenced in'R 89-04 to determine if they had been
completed
in accordance
with SDSP 27.1.
The reviewed procedures
included
2-GOI-100-3,
"Refueling Operations,"
Revision
0 through 4; TI-147, "Fuel
Loading After a Complete
Core Unloading," Revision
0 through 3; and MRTI,
'Master Refueling Test Instruction," Revisions
1 through 4.
The
NRC inspectors
determined
that the procedure
changes
incorporated
by
the
revisions
which
were
reviewed
for
IR
89-04. were
format,
administrative,
and clarification related
changes,
and did not affect the
technical
aspects
of the
procedures
in
a
manner
to require
a safety
'valuation.
There
were
many administrative
errors identified with the
preparation of screening
reviews,
however
none affected the determinations
made from the reviews.
The review performed for 2-GOI-100-3,
Revision
0,
was
documented
as the
required
two-year
technical
review.
From the
procedure
deficiencies
identified in paragraph
4 of this report it is evident that the core
loading procedure
had not received
a thorough,
accurate
technical
review.
It appears
that
the
Procedures
Upgrade
Program
did not result in a
thorough
technical
review of the refueling procedures.
Many procedure
deficiencies
have
been identified in the past six months,
bringing into
question
the
adequacy
of the
Procedure
Upgrade
Program.
This will be
pursued further as Unreso'lved
Item 260/89-18-03,
Adequacy of Procedures.
One of the purposes
of SDSP 27.1 was to describe
the method of performing
screening
reviews to determine if a safety evaluation is required.
Part
of
SDSP
27. 1 is
Form SDSP-147,
"Screening
Review
Form for Documenting
Applicability of a Safety Evaluation."
This form is inadequate
in that it
does
not
require
answering
one
of
the
questions
specified
in
is the margin of safety
as defined in the basis for
any technical specification
reduced?
TVA initiated Condition Adverse to Quality Report
(CAQR) No.
BFA890175902
on February 22,
1989
as
a result of a licensee audit (No.
SSA89902)
~
This
audit identified
numerous
screening
reviews
which were
completed with
insufficient documentation
supporting
the determination
that
no safety
evaluation
was
required.
The audit evaluated
20 screening
reviews to
determine if they complied with requirements
and concluded that
17 of the
20 screening
reviews
were deficient in one or more areas.
Furthermore,
the
audit
team
concluded
that
required
safety
evaluations
were
not
performed
as
a result of
some of the errors.
Similar inadequacies
were
also identified
by the
Independent
Safety
Engineering
Group
(ISEG) in
their November
1988 monthly report.
Violation 259,260,296/89-04-02
is
closed
and
the
concern
about
the
adequacy
of the screening
review process, will be pursued in the closeout
of URI 260/89-18-03.
6.
Cross-Disciplinary-'Review-of-.Fue1;-Load"Procedures
Impacting Plant Safety
Inspection. Report 89-04.stated
that the fuel load procedures
issued for
the Unit
2 core reload did not receive
required cross-disciplinary
or
affected
section
.reviews.
The
licensee's
response
stated
that the
procedure
revisions primarily involved administrative
changes,
and that
they had received appropriate. cross-,disciplinary/affected
section reviews.
1
The
requirements
for the
qualified technical
review of procedures,
including cross-disciplinary
reviews,
were outlined in
SDSP 7.4,
Onsite
Technical
Review
and
Approval of Procedures.
The qualified technical
reviewer determines
whether the procedure is technically correct,
adequate
for
performing
the
task
involved,
and
in
compliance
with plant
administrative
requirements;
and
determines
whether
additional
cross-disciplinary
review
is
required.
Step
4.4
required
that
cross-disciplinary
reviews
be performed whenever steps
in a procedure
may
affect equipment
under another
group's direct control;
whenever
another
group will be
required
to perform physical
action,
not
included in
previously
approved
instructions,
to
allow the
performance
of the
procedure;
and in cases
where parts of the procedure
are outside of the
reviewer's expertise.
The licensee's
response
stated that only the
changes
to the procedures
were
reviewed.
However,
as
part of the
two-year
review, the entire
procedure
should
have
been
reviewed
to address
changes
in the plant,
requirements,
FSAR,
and
TS,
and
assess,
whether
the
procedure
was-
technically adequate
to ensure that it could perform its intended
purpose.
The following examples
of the
lack of cross-disciplinary
review for
refueling procedures
as well as other procedures
are identified:
2-GOI-100-3, revision, 2,
added the following step:
5.20.34
Mhen
directed
by the
SOS,
INSTALL all shorting
links
removed in accordance
with Attachment
9,
RPS shorting
links.
Even though revision
1 included
a step for removal of the shorting
links,
no step
was
included for their reinstallation.
Attachment
9
to the procedure
provides
a sign off for when the shorting links are
installed;
however, it does not include steps requiring installation
of the shorting links.
The addition of this step in revision. 2
constituted
a requirement
for maintenance
personnel
to perform
a
physical
action not included in a previously approved
instruction.
No review of the
procedure
revision
was
performed
by maintenance
personnel.
2-GOI-100-3, revision 3, revised
a "NOTE" between
steps
4. 17 and 4.18
to
include
more
specific
information for when
two maintenance
instructions
(MMI-34 and
EPI-0-079-CRA001)
are to
be performed
and
which specific steps of the procedures
are to be performed.
The original note in -revision.2 only required that the two procedures
be
performed
weekly during fu'el handling evolutions;
however,
the
revised
note in revision.3:stated
that,
'MNI-34 and
EPI-0-079-CRA001 shall
be performed
no more than
30
days
before
fuel
handling
evolutions'.
HMI-34, Part
B
and
. EPI-0-079-CRA001,
Steps
7.2. 1 through 7.2.6
and
Steps
7.2.9
through 7.2. 16, shall
be performed
weekly during fuel handling
evolutions,
additional
sections/steps
shall
be performed weekly
during fuel handling evolutions
as
designed
by the maintenance
supervisor."
The only review of this revision
was
performed
by operations.
The
determination
of specific
steps
to
be
performed
in maintenance
procedures
appeared
to
be outside
the reviewer's
area of expertise
and
a maintenance
review should
have
been
performed
as required by
SDSP 7.4.
Operating Instruction 2-0I-74, Residual
Heat
Removal
System Operating
Instruction,
Temporary
Change
(TC)-10, approved 9/19/88,
incorporated
steps
to provide for lifting leads in the
RHR system logic to allow
the
RHR pumps to
be started with suction from the condensate
system
for flushing the
RHR loops.
Specifically, the revision added steps
for maintenance
personnel
to install
and
remove jumpers;
however, the
procedure
revision did not receive technical, cross-disciplinary,
or
affected
section
review by the maintenance
organization
as required
by SDSP 7. 4.
The failure to
provide
cross-disciplinary
review of procedures
in
accordance
with
SDSP 7.4 is
a violation of TS section 6.8. l.l.j which
requires
that
administrative
procedures
for
technical
and
cross-disciplinary
reviews
be
implemented
(VIO 259,260,296/89-18-04).
Violation 259,260,296/89-04-03
is closed.
7.
(Closed)
Unresolved
Item 259,260,296/89-04.-04:
Core Alteration Technical
Specifications
Prior to 1979,
Browns Ferry TS required
a minimum detector count rate of 3
cps, to ensure
core monitoring during fuel loading.
In the response
to IR
89-04,
TVA acknowledged
that the safety evaluations
submitted to the
NRC
for the
1979
and
1984 revisions to
TS 3. 10 were superficial
and did not
properly
account
for attenuation
between
the
core
and the detectors.
Although
the
basis
of
TS
3. 10 required
monitoring to. assure
early
detection
of
an
inadvertent
criticality,
TS 3. 10.B. l.b.2
and
TS 3. 10.B. l.b.3 were not supported
by valid analyses
to show that the
SRHs
would promptly detect
such
an event.
NRC management
has concluded that
while the
TS were not
as prescriptive
as might be desirable
they did not
relieve
the
licensee
from the responsibility for monitoring the
core
neutron
count rate
throughout core loading.
The technical specifications
are
adequate,
'however they -do require the licensee
to evaluate
and plan
his refuel activities before
hand.
TVA committed to, develop
and
subm'it TS and
FSAR changes to better ensure
adequate
core
monitoring in the future.
Also,
a
TS
assessment
was
initiated to evaluate
TS
requirements
against
design
bases
and
good
operating practices,
and
ensure that all changes to the facility license
are
supported
by valid analyses.
Unresolved Item 259, 260, 296/89-04-04
is closed
and this issue will be tracked
as inspector followup item 259,
260,296/89-18-06.
(Closed)
Unresolved
Item
259,260,296/89-04-05:
Adequacy
of
the
Procedure
Review Process
(PORC Review Responsibility)
Inspection
Report
89-04
questioned
the
adequacy,
of the
licensee's
procedure
review process
including the responsibilities
of the Plant
Operations
Review
Committee
(PORC) for procedure
reviews.
Technical Specification section 6.5. 1.6 lists the activities for which the
PORC is
responsible
and allows for
PORC delegation
of .the performance of review
activities;
however, it requires that the
PORC maintain cognizance of and
responsibility for the reviews.
The licensee's
response
detailed the qualified technical
reviewer
process'hich
was initiated as part of the delegation of the
PORC procedure
review
activities,
and indicated that the
PORC instituted
an oversight review of
this
process
to maintain
cognizance
of the reviews.
PORC's
oversight
included
a review of 2-GOI-100-3,
Rev.
0 on December
6, 1988.
The qualified technical
reviewer process
and the
PORC oversight of this
process
appear
to be in accordance
with TS requirements
and the licensee's
approved
procedures
and,
therefore,
this
item
does
not constitute
a
violation
and is closed.
The adequate
implementation of the procedure
review process will be
assessed
during the follow-up of VIO 260/89-18-01
and
URI 260/89-18-03.
(Closed)
Unresolved
Item
260/89-04-06:
Adequacy
of the
Licensee's
Reportability Determination
Inspection
Report 89-04 questioned
the determination that the termination
of fuel loading
due to a lack of monitoring was not reportable
per 10 CFR 50.72,
50.73, or plant implementing procedures.
TVA submitted
a voluntary
reportable
occurrence
report,
BFRO-50-260/89001,
to the
NRC on January
26,
1989,
although
the
licensee's
response
restated
the position that the
event
was not reportable.
Even though loading fuel unmonitored placed the
plant in an
unanalyzed
condition,
the safety evaluation
indicated that
this condition did not significantly compromise plant safety,
and the
inspectors
agree
that this event is not reportable.
This item is not a
violation and is closed.
10
10.
Exit Interview
The inspection
scope
and findings were summarized
on June
30, 1989, with
those person's
indicated .in paragraph
1 above.
The inspectors
described
in detail
the
inspection
findings listed below.
The licensee
did not
identify as proprietary any of the material provided to or reviewed by the
. inspectors
during this 'inspection.
Dissenting
comments
were not received
from the licensee.
Item Number
0
9-18-
1
260/89-18-02
260/89-18-03
Violation - Failure to meet the requirements
of
paragraph
2.
Violation - Inadequate
refueling procedures,
paragraph
4.
URI - Adequacy of procedures,
paragraphs
4,
5 and 8.
260/89-18-04
BFNP
CAQR
GOI
IR
ISEG
LER
MMI
MRTI
NRC
PMI
SDSP
SOS
Violation - Failure to provide cross-disciplinary
review, paragraph
6.
Browns Ferry Nuclear Plant
Condition Adverse to Quality Report
Final Safety Analysis Report
General
Operating Instruction
Inspection
Report
Independent
Safety Engineering
Group
Licensee
Event Report
Mechanical
Maintenance Instruction
Master Refueling Test Instruction
Nuclear Performance
Plan
Nuclear Regulatory
Commission
Nuclear Reactor Regulation
Operating Instruction
Plant Manager Instruction
Plant Operations
Review Committee
Quality Assurance
Residual
Heat
Removal
Reactor Protection
System
Site Director Standard
Practice
Safety Evaluation Report
Surveillance Instruction
Service Information Letter
Shift Operating Supervisor
Source
Range Monitor
TACF
TS
USQD
Temporary Alteration-Change
Form
Temporary
Change
Technical Specifications
Valley Authority
Violation
Unresolved Item
. Unreviewed Safety Question
Unreviewed Safety Question Determination