ML18039A652
| ML18039A652 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 12/24/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18039A651 | List: |
| References | |
| 50-260-98-07, 50-260-98-7, 50-296-98-07, 50-296-98-7, NUDOCS 9812240099 | |
| Download: ML18039A652 (4) | |
Text
NOTICE OF VIOLATION Tennessee Valley Authority Browns Ferry Units 2 and 3 Docket Nos. 50-260, 50-296 License Nos. DPR-52, DPR-68 During an NRC inspection conducted on October 4-November 14, 1998, two violations of NRC requirements were identified.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Action," NUREG-1600, the violations are listed below:
A.
Technical Specification (TS) Limiting Condition for Operation (LCO) 3.0.4 states, in part, that when an LCO is not met, entry into a mode or other specified condition in the Applicabilityshall not be made except when the associated actions to be entered permit continued operation in the mode or other specified condition in the Applicabilityfor an unlimited period of time. This Specification shall not prevent changes in modes or other specified conditions in the Applicabilitythat are required to comply with actions or that are a part of a shutdown of the unit.
TS 3.5.1, Emergency Core Cooling System Operating, is applicable in Mode 1 and Modes 2 and 3, except High Pressure Coolant Injection...[is] not required to be operable with reactor steam dome pressure ~150 psig.
Contrary to the above, on October 14, 1998, the licensee failed to comply with TS 3.0.4 when a specified condition in the Applicabilityof TS 3.5.1 was entered without meeting the associated LCO. The High Pressure Coolant Injection System was inoperable for maintenance activities when the specified condition for operability in the applicability statement was reached (150 psig) and continued to be inoperable until approximately one hour later.
This is a Severity Level IVviolation (Supplement I). This violation is applicable to Unit 3 only.
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B.
10 CFR 50 Appendix B, Criterion V, requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
The licensee's Nuclear Quality Assurance Plan TVA-NQA-PLN89-A,Revision (Rev.) 8, Section 6.1, states that the Quality Assurance Program requires that quality;related activities shall be prescribed by documented instructions appropriate to the circumstances.
Activities shall be accomplished in accordance with these procedures and instructions.
TVAnuclear power mechanical design standard DS-M18.2.18, Rev. 10, Note T2054, requires nonconformances to the requirements of the contract to be handled in accordance with the vendor's quality assurance program.
Nonconformances with a disposition of "Accept As-Is" or "Repair" shall be submitted to TVAfor approval. TVA standard program and process procedure SPP-4.2, Material Receipt and Inspection, Rev. 0, implements the requirements of TVANQA-PLN 89-A concerning receipt and inspection requirements for quality-related materials.
Section 3.6 of this procedure
'pecifically implements the requirements of DS-M18.2.18 and requires responsible 98i2240099 98i209 PDR ADOCK 05000259 8
PDR Enclosure 1
0
NOV engineering personnel to disposition material nonconforming conditions and document the results of the disposition on a Receiving Unsatisfactory Report (RUR).
Contrary to the above, on October 8, 1997, contract number 121 076190ZNU4138 was placed with Fisher Control without imposing the requirements of DS-M18.2.18, Note T2054, for a QA Level 1 purchase order. This failure resulted in an inadequate receipt inspection on November 14, 1997, which was performed for TVAItem Identification Code (TIIC) No. CBW9098C. This procurement action involved the purchase of three Fisher Pressure Controller Model 4160 flappers, part number 1H2669-41132.
The vendor provided nonconformance report (NCR) Nos. 544579-1, -2, and -3 in connection with deviations from the vendor specification for the flapper diameter.
Fisher design required a diameter of 1.99 to 2.00 inches and the measured diameter of all three flappers was 1.95 inches.
The vendor also provided a recommendation for use as-is.
These nonconformances were never dispositioned by Procurement Engineering and the results documented on a RUR, in accordance with
. the requirements of procedure SPP-4.2.
This is a Severity Level IVviolation (Supplement I).
The NRC has concluded that information regarding the reason for the violation, the corrective actions taken and planned to correct the violation and prevent recurrence and the date when full compliance was achieved are already adequately addressed on the docket in the enclosed Inspection Report 50-259,260,296/98-07.
However, you are required to submit a written statement or explanation pursuant to 10 CFR 2.201 if the description therein does not accurately reflect your corrective actions or your position.
In that case, or if you choose to respond, clearly mark your response as a "Reply to a Notice of Violation," and send it to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001 with a copy to the Regional Administrator, Region II, and a copy to the NRC Resident Inspector at the facilitythat is the subject of this Notice of Violation (Notice), within 30 days of the date of the letter transmitting this Notice.
If you contest this enforcement action, you should also provide a copy of your response, with the basis for your denial, to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001.
If you choose to respond, your response will be placed in the NRC Public Document Room (PDR). Therefore, to the extent possible, the response should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction.
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In accordance with 10 CFR 19.11, you may be required to post this Notice within two working days.
Dated this 9th day of December 1998