ML18039A347

Notice of Violations from Insp on 980301-0411.Violations Noted:Written Procedures Not Implemented in That Model TDA-5A (or Equivalent) DOP Generator Not Used to Perform Testing

ML18039A347
Person / Time
Site:	Browns Ferry
Issue date:	05/05/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML18039A346	List: ML18039A345 ML18039A347 ML18039A348
References
50-259-98-02, 50-259-98-2, 50-260-98-02, 50-260-98-2, 50-296-98-02, 50-296-98-2, EA-98-223, FACA, NUDOCS 9805210292
Download: ML18039A347 (6)

Text

Tennessee Val 1 ey Authority Browns Ferry Units 1, 2.

and 3

NOTICE OF VIOLATION Docket Nos.

50-259.

50-Z60. 50-296 License Nos.

DPR-33, DPR-52.

and DPR-68 EA 98-223 During an NRC inspection conducted on March 1-April 11, 1998.

four violations of NRC requirements were identified.

In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below:

A.

Technical Specification 3.7.B.2.a.

Standby Gas Treatment

System, states that the results of the in-place cold Dioctylphthalate (DOP) and halogenated hydrocarbon tests at ~lOX design flow on High Efficiency Particulate Air (HEPA) filters and charcoal adsorber banks shall show

~99K DOP removal and ~99K halogenated hydrocarbon removal when tested in accordance with ANSI N510-1975.

Section 9 of ANSI N510-1975 requires that an air-aerosol mixing uniformity test be performed as a

prerequisite to the in-place leak tests of HEPA filters to establish acceptability of the DOP injection por t locations.

Contrary to the above.

in-place cold DOP and halogenated hydrocarbon tests were not performed in accordance with ANSI N510-1975 for the Standby Gas Treatment System.

The surveillance procedure for the downstream HEPA filter did not incorporate the results of an air-aerosol mixing uniformity test.

This condition was identified on April 6,

1998, and has existed for at least the last two years.

This is a Severity Level IV Violation (Supplement I).

Technical Specification (TS) 6.8.1.1.c requires that written procedures shall be established.

implemented, and maintained for surveillance and test activities of safety-related equipment.

Section

5. 1 of.

Surveillance Instruction O-SI-4.7.B.4.

Standby Gas Treatment System In-Place Leak Test of High Efficiency Particulate Air Filter Banks, and Section 5. 1 of Surveillance Instruction O-SI-4.7.E.2.A, Control Room Emergency Ventilation System In Place Leak Test. state that an Air Techniques Incorporated Model TDA-5A (or equivalent) Dioctylphthalate (DOP) generator is to be used for the tests.

Contrary to the above, written procedures were not implemented in that a Model TDA-5A (or equivalent)

DOP generator was not used to perform the testing.

A Model TDA-6A DOP generator was used to perform the testing.

The Model TDA-6A generator produces significantly lower concentrations of DOP aerosol than the Model TDA-5A and is not equivalent.

This condition was identified on March Z4.

1998.

The incorrect generator model was utilized for at least the most recent periodic testing performed prior,to this date on each system.

This is a Severity Level IV Violation (Supplement I).

Technical Specification 6.2.2.a states'n part, that shift manning requirements, shall as a minimum.

be as described in Table 6.2.A.

98052l0292 980505 PDR ADQCK 05000259 6

PDR ENCLOSURE 1

NOV D.

Technical Specification Table 6.2.A requires.

in part. for two units in operation, a minimum shift crew consisting of five active licensed reactor operators and three active licensed senior reactor operators.

Contrary to the above, at various times between January 1,

1997, and March 6.

1998. the minimum shift crew requirement of Technical Specification Table 6.2.A was not met, in that the licenses held by at least one of the reactor operators and/or one of the senior reactor operators were inactive.

The licenses became inactive because of fai lures to meet the practical experience or training required by 10 CFR 55.53.(e) or (f), "Conditions of Licenses, respectively.

This is a Severity Level IV violation (Supplement VIII) 10 CFR 50, Appendix B, Criterion XVI. Corrective Action. states that measures shall be established to assure that conditions adverse to

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uality, such as failures, malfunctions. deficiencies, deviations

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efective material and equipment, and nonconformances are promptly identified and corrected.

In the case of significant conditions adverse to quality. the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.

Contrary to the above, a condition adverse to quality was not identified during inspection of the inboard Unit 2 High Pressure Coolant Injection System exhaust line rupture disc.

The process used to determine the "as found" condition of the disc material was not adequate in that the disc material itself was not inspected.

Subsequent inspection identified that the disc material was degraded.

This is a Severity Level IV Violation (Supplement I), applicable to Unit 2 only.

Pursuant to the provisions of 10 CFR 2.201

~ Tennessee Valley Authority is hereby required to submit a written statement or explanation to the U.S.

Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, D.C.

20555 with a copy to the Regional Administrator, Region II'nd a copy to the NRC Resident Inspector at Browns Ferry, within 30 days of the date of the letter transmitting this Notice of Violation (Notice).

This reply should be clearly marked "Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or. if contested.

the basis for disputing the violations (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 achieved.

Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response.

If an adequate reply is not received within.the time specified in this Notice, an order or a

Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken.

Where good cause is shown. consideration will be given to extending the response time.

1

NOV

'If you contest this enforcement action.

you should also provide a copy of your response. to the Director. Office of Enforcement.

United States Nuclear Regulatory Commission, Washington, DC 20555-0001.

Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction.

If personal privacy or proprietary information is necessary to provide an acceptable response.

then please provide a bracketed copy of your response that identifies the information that should be protected and a

redacted copy of your response that deletes such information.

If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g. explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information).

If safeguards information is necessary to provide an acceptable

response, please provide the level of protection described in 10 CFR 73.21.

Dated at Atlanta, Georgia this sthday of Hay 1998