ML18094A066

Responds to NRC 810109 Ltr Re Violations Noted in IE Insp Repts 50-259/80-40,50-260/80-35 & 50-296/80-34.Corrective Actions:Fuel Handling Stopped While Control Rod Inserted. Procedure Written for Unloading Control Cells

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: ML18094A066
References
NUDOCS 8103120749
Download: ML18094A066 (10)

Text

TENNESSEE VALLEY AUTHOR lT'ebruary 5, 1980 James P. O'Reilly, Director

'I FFO II f~(t . 3I'r.

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

~ - Nucl ear-Regulati'on and Safety Subscribe me thi ~~d day sworn of

~b e ore 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 Technical Specification 3.10.A.6 states that any number of control rods may be removed or withdrawn from the core and the refueling interlocks bypassed on withdrawn control rods after the fuel has been removed from the cell.

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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 '..;' ~

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fuel was removed from the respective cell as allowed by Technical Specification 3.10.A.1 and 3.10;A.6.a..

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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

addition to 1.B and 1.C above, fuel handling crews will'eview

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'n 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 requir4ments. Surveillance Instruction 4.10.A.1 requires and'esting all control rods to be fully inserted during the test.

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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.

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~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 is documented in plant. logs.

A TVA investigation 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 Ste s Which Will Be Taken To Avoid Further Noncom liance reemphasized:'orrective 2~

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.

3~ Date Full Com liance Will Be Achieved Full compliance:regarding

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the October 6, 1980, incident was achieved on January 1, 1981.

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