IR 05000259/1988005

Forwards Correction to Insp Repts 50-259/88-05,50-260/88-05 & 50-296/88-05.Notice of Violation,Inadvertently Omitted, Now Encl.Response Requested within 30 Days of Ltr Date

ML20197D570
Person / Time
Site:	Browns Ferry
Issue date:	05/25/1988
From:	Barr K NRC OFFICE OF SPECIAL PROJECTS
To:	White S TENNESSEE VALLEY AUTHORITY
References
NUDOCS 8806070330
Download: ML20197D570 (2)

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['wJ MAY 2 51988

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Docket Nos. 50-259, 50-260, 50-296 License Nos. OPR-33, DPR-52, OPR-68 ,

Tennesee Valley Authority ATTN: Mr. S. A. White Manager of Nuclear : Power 6N 38A Lookout Place

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1101 Market Street Chattanooga, TN 37402-2801 Gentlemen:

SUBJECT: CORRECTIONTONRCINSPECTIONREPORTNOS. 50-259/88-05, 50-260/88-05, 50-296/88-05 NRC Inspection Report 50-259/88-05, 50-260/88-05 and 50-296/88-05 was inadver-

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tently forwarded to you without the Notice of Violatio The enclosure to this letter. provides that Notice of Violation. Please insert it into your copies of the inspection repor Since your receipt of the Notice of Violation has been delayed, your response is requested within 30 days of the date of this lette We regret any inconvenience this may have caused. If you have any questior:,

please contact u

Sincerely, 0./b

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. N Kenneth P. Barr, Acting Assistant Director for Inspection Programs TVA Projects Division Office of Special Projects Enclosure:

Notice of Violation cc w/ encl:

H. P. Pomrehn, Site Director Browns Ferry Nuclear Plant R. L. Gridley, Director Nuclear Engineering M. J. May, Site Licensing Manager J. G. Walker, Plant Manager TVA Representative, Rockville Office

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. MAY 2 51989 Tennessee Valley' Authority 2 a bec w/ encl:

S. D. Ebneter,' OSP i

.S. U.' Richardson, OSP S.-Black, OS 'B. D.'L'iaw, OSP-W._ Little, OSP/RII Gc E. Gears, OSP D. Moran, OSP

. A. J. Ignatonis, OSP/RII A. H. Johnson, OSP/RII

. J..Rutberg, OGC NRC Resident Inspecto DRS Technical Assistant NRC Document Control Desk State of Alabama OSP/RIl., OSP/RI OSP/ I AJ n:wb A gnato WLfttle 05/4 9'88 05/,tr/88 05/)f88 >

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ENCLOSURE 1 NOTICE Of VIOLATION Tennessee Valley Authority Docket Nos. 50-259, 50-260, and 50-296 Browns Ferry 1, 2, and 3 License Nos. DPR-33, DPR-52, and DPR-68 During the Nuclear Regulatory Commission (NRC) inspection conducted on March 1-31, 1988, five violations of NRC requirements were identified. The violations involved: (1) failure to adhere to Technical Specification (TS)

administrative controls involving the Plant Operations Review Committee (PORC)

activities; PORC meetings per Technical Specification and (2) failure to properly verify, by inspection, the proper performance of a maintenance activity; (3) failure to provide required retraining in the areas of QA/QC and regulatory compliance for craft personnel and foreman; (4) failure to comply with procedural requirements for testing charcoal from the Standby Gas Treat-ment System and initiating LREDs; and (5) failure to properly control revisions to Temporary Alteration Control Forms (TACFs).

In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C the violations are listed below: TS 6.5.1. addresses the requireme +,s for PORC function TS 6.5.1.2.a. requires the following compositio Chairman: Plant Manager Alternate Chairman: Assistant to Plant Manager Alternate Chairman or Member: Technical Services Superintendent Member: Unit Superintendents (3)

Merber: Maintenance Superintendent Mo:ber: Quality Assurance Supervisor Member: Health Physics Supervisor TS 6.5.1.2.b. states that all alternate chairmen and alternate members shall be appinted in writing by the PORC chairma TS 6.5.1.8 requb 's PORC to maintain written minutes of each meeting including expediteo 'eeting Contrary to the above, the requirements were not met as follows:

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' The acting Maintenance Superintendent who is not authorized by Plant tfr : Instruction (PMI) 7.1, Plst Operations Review Comittee, to be an alternate chairman, chaired a PORC meeting on March 10, 198 A15c during the same PORC meetine, an individual acted as an alter-n=1 a for the Health Physia a ervisor without being a; pointed i-

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' Tennessee Valley Authority 2 Docket Nos. 50-259, 50-260, and 50-296 Browns Ferry 1, 2, and 3 License Nos. DPR-33, DPR-52, and DPR-68 Written minutes of the expedited PORC meeting cond :ted c~ ch 10, 1988, in which a deficient condition with the Reactor 6m Jing overhead crane was discussed were not maintaine This is a Severity Level IV Violation (Supplement I) and is applicable to all three unit . 10 CFR 50, Appendix B, Criterion X requires that a program for inspection of activities affecting quality shall be established and executed by or for the organization performing the activity to verify conformance with the documented instructions, procedures, and drawings for accomplishing the activit Browns Ferry Standard Practice 3.2, Quality Control Inspection Program, irrplerents this criterion in section 5.2.1 which states that one of the examples of an activity that should be verified by using QA inspection hold points is satisfactory operation of valves following maintenanc Contrary to the above, the requirement was not met on November 20, 1987 when a check valve in the Emergency Equipment Cooling Water System (EECW)

was improperly installed during ths performance of Maintenance Request (MR) number 792717. The valve was found to be installed backwards on March 15,198 Work instructions of the MR explicitly stated to rein-stall the valve in the proper orientation. No inspection was performed and documented to verify proper orientation of the check valve following -

the maintenance activity. Reversal of this check valve prevented the supply of EECW to the Residual Heat Removal (RHR) pump seal cooler and the RHR pump room cooler from the north EECW heade This is a Severity Level IV Violation (Supplement I) and is applicable to Unit 2 onl Technical Specification 6.4 requires the retraining and replacement program for station personnel to be in accordance with ANSI-N18.1-1971, Selection and Training of Nuclear Plant Personnel. Per Section 5 of ANSI-N18.1-1971 the licensee is required to maintain a training program for replacement personnel and for retraining necessary to ensure that personnel remain proficient. This includes General Employee Training (GET).

Item 1.7 of procedure BFPMI-4.3, Specialized Training, specifies regula-tory compliance training for all employees. The training frequency is annual for foremen and every two years for all others. GET 4.0, Intro-duction to QA/QC, is required to be taken by the employees every two years per procedure PMP 0.202.0 Contrary to the above, the requirements were not met in thst, out of twelve (12) craft personnel arbitrarily selected, the inspector found four foremen and one craf t person delinquent in receiving rec.1 , compliance retraining, and three craf t people delinquent in receivirg Gti 4 retrain-ing. For some of the pecole, the retraining delinquenc. m xeater than

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Tennessee Valley Authority 3 Docket Nos. 50-259, 50-260, and 50-296 Browns Ferry 1, 2, and 3 License Nos. OPR-33, DPR-52, and DPR-68 one year. Regulatory compliance training was instituted in response to the Regulatory Performance Improvement Progra This a Severity Level V Violation (Supplement I) and is applicable to all three unit CFR 50, Appendix:B, Criterion V requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings and shall be accomplished in accordance with these instructions, procedures, or drawing . Contrary to the above, the requirements of Surveillance Instruction 0-SI-4.7.8.6, Standby Gas Treatment System Iodine Removal Ef ficiency were not adhered 'to for the test on Trains B and C completed on January 12, 1988, and Train A completed on February 16, 198 Attachment 5 of SI 4.7.8.6 requires that the charcoal samples be tested in accordance with ASTM D3803, Standard Test Method for Radiofodine Testing of Nuclear-Grade Gas-Phase Adsorbent ASTM D3803 requires that the feed period duration and the elution period duration be 60 minutes and 240 minutes respectively. Test data contained in the completed SI data package document that the actual feed duration was 90 minutes (thirty minutes longer than specified)

and the actual elution time was 90 minutes (150 minutes shorter than

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specified). This is similar to the violation cited in Inspection Report Numbers 50-259, 260, 296/86-11, Contrary to the above, the requirements of Plant Managers Instruction 15.4 (Unique Reporting Requirements) were not adhered to in that the Licensee Reportable Event Determination evaluation was not initiated as required to determine the operability of the Unit 2 Residual Heat Removal System lower containment spray header after an inspection (CAQR 8FP880052) revealed clogged nozzles due to rust on February 3, 198 This is a Severity Level V Violation (Supplement I) and is applicable to all three unit CFR 50, Appendix B, Criterion VI requires that measures shall be established to control the issuance of documents, such as instructions, procedures, and drawings, including changes thereto. These measures shall l assure that documents, including changes, are reviewed for adequacy, approved for release, and properly distribute Contrary to the above, Revision 1 to Temporary Alteration Control Form (TACF) number 3-88-001-111 was not properly reviewed for adequacy, approved for release, and properly distributed. The original TACF was initiated on March 10, 1988 with the majority of the review and approval

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authorizations obtained on March 13, 1988. A revision was initiated on March 15, 1988; however, not all of the approval signatures were updated to reflect approval of the revised information in that: The Operations Supervisor's concurrence signature was dated March 13, 1988.

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- Tennessee Valley Authority 4 Docket Nos. 50-259, 50-260, and 50-296 t

Browns Ferry 1, 2, and 3 License Nos. OPR-33, OPR-52, and DPR-68 The shift Engineer's approval of the TACF was dated March 13, 198 . The File Clerk made and distributed copies of the TACF on March 15, 1988, although four signatures on the TACF were dated March 16, 198 The above information was the onl maintained in the Shift Engineer'y available s office andonwasthethe original TACF condition of form the TACF on March 17, 1988. Similar problems were found with the following TACF's: 2-85-50-24, 2-84-097-57, 2-84-101-64, and 2-85-039-06 This is a Severity Level V Violation (Supplement I) and is applicable to all three unit Pursuant to the provisions of 10 CFR 2.201, Tennessee Valley Authority is hereby required to submit a written statement or explanation to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555 with a copy to the Director, Office of Special Projects, and a copy to the NRC Resident Inspector, Browns Ferry within 30 days of the date of the letter transmitting this Notic This reply should be clearly marked as a

"Reply to a Notice of Violation" and should include for each violation: (1)

the reason for the violation if admitted, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achievei. Where good cause is shown, consideration will be given to extending the response tim FOR THE NUCLEAR REGULATORY COMMISSION

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enneth P. Barr, Acting Assistant Director for Inspection Programs TVA Projects Division Office of Special Projects Dated at Atlanta, Georgia this Jt0* day of May 1988

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