ML18024B328
| ML18024B328 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 11/26/1979 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18024B327 | List: |
| References | |
| 50-259-79-30, 50-260-79-30, 50-296-79-30, NUDOCS 8002120452 | |
| Download: ML18024B328 (6) | |
Text
0 APPENDIX A NOTICE OF VIOLATION Tennessee Valley Authority Browns Ferry, Unit Nos.
1, 2, and 3
I,icense Nos.
DPR-33, DPR-52 6 DPR-68 r Based on the NRC inspection on October 9-12 and October 15-17, 1979, certain of your activities were apparently not conducted in full compliance with NRC re-quirements as indicated below.
These items have been categorized as described in correspondence to you dated December 31, 1974.
A.
As required by 10 CFR 50, Appendix B, Criterion X, an inspection of activi-ties affecting quality shall be performed by individuals other than those
- who performed the activity.
The accepted Quality Assurance Program, Section 17.2.10, requires inspections to be performed during maintenance, modifications, or repair activities affecting the quality of CSSC items at TVA plants to verify conformance with applicable requirements.
Contrary'o the above, Unit 1 HPCI rupture disc was replaced as required by Trouble Report 135958, without the necessary inspection requirements being specified or completed.
This is an infraction.
This item applies only to Unit 1.
B.
As re'quired by 10 CFR 50, Appendix B, Criterion XI, a test program shall be established with written test procedures which incorporate the requirements contained in applicable design documents.
The accepted Quality Assurance (QA) Program, Section 17.2.11, requires-that modifications shall be tested in accordance with original design requirements.
The Unreviewed Safety Question Determination, for Engineering Change Notice (ECN) L 1496, Disc replacement of Flow Control Valves (FCV), stated in the justification for no increased possibility of accident or malfunction that the chattering FCV's "will be operated over their entire operating range and observed by qualified personnel...".
Contrary to the above, RHR Service Water FCV's 3-23-52, 3-23-34, 2"126, and 3-23-40 were modified but they were not tested over the entire operating range and observed by qualified personnel, as required by the Unreviewed Safety Question Determination analysis.
This is an infraction.
C.
As required by 10 CFR 50, Appendix B, Criterion XVIII, "A comprehensive system of planned and periodic audits shall be carried out to verify com-pliance with all aspects of the quality assurance program...".
The accepted Quality Assurance
- Program, Section 17.2.18 states in part, "Audits shall be conducted in accordance with a formal audit schedule which shall be updated at least every six months.
Each element of the Office of Power Quality Assurance
- Program, such as design and document control, and each area of soo~~s
Tennessee Valley Authority
-2" Browns %'erry, Unit Nos.
1, 2 and 3
License Nos. DPR-33, DPR-52 and DPR-68 Appendix A plant operations, such as normal operation, inservice inspections, and radiological control, shall be audited at least once every two years".
Contrary to the
- above, the Outage Group had not been audited during the period from October 6, 1977 to October 12,
- 1979, and was not scheduled for future audits.
This is an infraction.
D.
As required by 10 CFR 50, Appendix B, Criterion III design control measures shall provide for verifying or checking the adequacy of design, such as the performance of design reviews.
The accepted equality Assurance Program commits TVA to ANSI N45.2.11-1974.
ANSI N45.2.11, Section 3.1 states applicable design inputs, such as design
- bases, regulatory requirements, codes and standards, shall be identified, documented and their selection reviewed and approved.
Design analyses shall be legible and be in a form suitable for reproduction, filing and retrieving.
Additionally, design documentation and records which provide evidence that the design and review process was performed in accordance with the requirements of this standard shall be collected, stored and maintained.
Contrary to the
- above, 16 of 16 safety-related design changes reviewed showed no documentary evidence of having completed and reviewed design inputs.
This is an infraction.
As required by 10 CFR 50.59 and EN DES EP 4.02, an Unreviewed Safety (}uestion Determination (USED) will be made for all changes to the facility as described in the safety analysis report.
The determination shall address three specific items which provide the bases for the determination that the change does not involve an Unreviewed Safety question.
Contrary to the
- above, Engineering Change Notices P-0124, P-0081, L 2073 and L 1967 were implemented with USED's which did not address all three items necessary to establish that the design change did not involve any unreviewed safety questions.
This is an infraction.
As required by 10 CFR 50, Appendix B, Criterion XVII, "Sufficient records shall be maintained to furnish evidence of activities affecting quality...the records shall also include closely related data such as qualifications of personnel...".
The accepted equality Assurance Program, Section 17.2.17 states in part, "The plant superintendent shall provide storage, preservation and safekeeping of the required quality assurance records in accordance with TVA-established requirements and regulatory requirements...".
1.
The accepted equality Assurance Program Table 17.2-7, Topic J, commits TVA to qualification of nuclear power plant inspection, examination, and testing personnel to internal TVA levels of capability.
Appropriate
Tennessee Va'lley Authority "3"
Browns Ferry, Unit Nos.
1, 2 and 3
License Nos.
DPR-33, DPR-52 and DPR-68 Appendix A quality assurance groups will provide certificates for documenting training and qualification for inspection, examination,
- testing, and other personnel.
I Contrary to the above, certificates of training and qualification for individuals conducting receiving inspections were not being maintained by the Plant QA Staff.
2.
Engineering Change Notice (ECN) L 1911 required the cognizant engineer to test the voltage on terminals 1 and 2 of the resistor box, to verify the voltage to be 48VDC + 2.5VDC, to log the actual reading and sign that the acceptance valves were verified.
The modification being tested herein was to install new resistors in the power supply to the HPCI turbine speed control.
The cognizant engineer did sign an October 20, 1978 that the test was conducted but, contrary to the above, the actual voltage readout was not properly annotated.
3.
As required by Standard Practice BFA8, the maintenance supervisors are designated as responsible for filing of records relating to maintenance activities.
Contrary to the above, Maintenance Instruction MMI 14.4.1.3A (required by Trouble Report Number 106568 which was issued for the repair of a cracked sensing line to PT68-82) could not be located.
Additionally, the inspection records for this activity could not be located.
The above three items constitute a deficiency.
G.
As required by Technical Specifications 6.3.A.5 detailed written procedures shall be prepared, approved and adhered to, for preventive or corrective maintenance operations which could have an effect on the safety of the reactor.
Contrary to the
- above, procedures were not being followed for Trouble Reports
- 104531, 85353,
- 13512, 135958 and 134173 as indicated below.
These were not being reviewed as required by the OEM and Standard Practices BF 7.1 These were not filed as required by Standard Practices BAF8 These were not designated as Critical Structures, Systems and Components (CSSC) as required by OEM Part III, Section 1, Paragraph 4.2.
This is a deficiency.