ML18094A095
| ML18094A095 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 07/17/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18038B919 | List: |
| References | |
| 50-260-97-07, 50-260-97-7, 50-296-97-07, 50-296-97-7, NUDOCS 9707250114 | |
| Download: ML18094A095 (6) | |
Text
Tennessee Valley Authority Browns Ferry Units 2 and 3 NOTICE OF VIOLATION Docket Nos. 50-260 and 50-296 License Nos.
DPR-52 and DPR-68 During an NRC inspection conducted on Hay 11
- June 21,
- 1997, two 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 6.8. 1.1.a requires that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, Febr uary 1978.
Section lc of the Regulatory Guide recommends administrative procedures for Equipment Control (e.g.,
locking and tagging).
General Operating Instruction O-GOI-300-1, Operations Routine Sheets, 5.22, EOI (Emergency Operating Instruction) Tools and Equipment Inventory Checklist, dated Hay 5, 1997, states that ladders are secured with GGHKA padlocks at the designated EOI ladder stations. 5.22 includes EOI Inventory Form 0-EOI-000-0010 EOI Ladder Stations which describes, in par t, a 20.ft Extension Ladder, in place and padlocked, at ladder station 3-RB-565-1, Reactor Building Elevation 565'.
Contrary to the above, on Hay 27,
- 1997, NRC inspectors identified that 0-GOI-300-1 was not adequately established to ensure EOI ladder station control.
A 20 ft extension ladder was not in place and padlocked at ladder station 3-RB-565-1.
The 'ladder that was found at ladder station 3-RB-565-1 was not adequate to support an EOI Appendix action.
This is a Severity Level IV Violation (Supplement I).
B.
10 CFR 50, Appendix B, Criterion V, requires, in part, that activities affecting quality shall be prescribed by procedures of' type appropriate to the circumstances and shall be accomplished in accordance with these procedures.
Foreign Haterial Exclusion control, an activity which affects quality by preventing the introduction of foreign materials into systems relied upon to safely operate and shutdown a
nuclear power plant, is accomplished by implementing the requirements of Site Standard Practice SSP-12.8, Foreign Haterial Exclusion.
Instruction 1.0.C of Appendix E of SSP-12.8 states that clear material or other material which would be difficult to identify underwater shall not be used on the Refuel Floor, unless specifically authorized by the refueling floor Senior Reactor Operator, Shift Operations Supervisor, or Haintenance Supervisor.
Enclosure 1
9707250il4 9707i7 PDR ADOCK 05000259 8
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NOV Step 12 of Section 3.5.A of SSP-12.8 requires that a baseline inventory be performed and the log book reconciled prior to activation of a Foreign Material. Exclusion Area after it has been inactive for greater than seven days.
Section 3.2 of SSP-12 '
requires Form SSP-62, FHE Requirements Reference
'Sheet, to be filled out by the supervisor of a work activity involving Foreign Material Exclusion controls.
Contrary to the above, during the period of Hay 28-June 2,
- 1997, NRC inspectors identified that activities affecting quality were not accomplished in accordance with prescribed procedures in that the requirements of Site Standard Practice SSP-12.8, Foreign Material Exclusion were not properly implemented:
1.
Personnel were observed in possession of a roll of clear plastic wrap material on the refueling floor.
The material was being utilized on the refueling floor in support of health physics activities and was not specifically authorized.
2.
Baseline inventories and log book reconciliations were not being performed prior to some reactivations of the spent fuel pool FHE areas after they had been inactive for greater than seven days.
0 3.
Forms SSP-62, FHE Requirements Reference
- Sheets, associated with Work Orders 97-004237-000 (Removal of paint from refueling floor overhead beams) and 97-003911-000 (1B/1D residual heat removal system heat exchanger cleaning) were not filled out properly.
The level of foreign material exclusion protection prescribed in SSP-12.8 was not properly indicated on the forms.
This is a Severity Level IV Violation (Supplement I).
In reference to violation B, 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, and 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 violation, (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 t
shown, consideration will be given to extending the response time.
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NOV 3
In reference to violation A, 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 full compliance will be achieved is adequately addressed in Problem Evaluation Report BFPER 970889 and on the docket in the enclosed NRC Inspection Report.
- 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.
Because your response will be placed in the NRC Publ,ic 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'ersonal 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 17th day of July 1997
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