ML20154K889

Notice of Violation from Insp on 880501-0611.Violation Noted:Three Fire Brigade Members Who Entered Drywell for Fire Fighting Operations Not Qualified & Q-list Equipment Data Package (Sys 1) Not in Compliance W/Nuclear QA Manual

ML20154K889
Person / Time
Site:	Browns Ferry
Issue date:	09/12/1988
From:	Mccoy F NRC OFFICE OF SPECIAL PROJECTS
To:
Shared Package
ML20154K885	List: ML20154K880 ML20154K889 ML20154K911
References
50-259-88-16, 50-260-88-16, 50-296-88-16, NUDOCS 8809260038
Download: ML20154K889 (3)

Text

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ENCLOSURE 1 NOTICE OF VIOLATION ,

Tennessee Valley Authority Docket Nos. 50-259, 260, 296 Browns Ferry 1, 2, and 3 License Nos. OPR-33, 52, 68 During the Nuclear Regulatory Commission (NRC) inspection conducted on May 1 -

. June 11, 1988, several examples of a violation of NRC requirements were identi-fled. 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:

A. 10 CFR 50. Appendix B, Criterion V requires that activities affecting quality shall be prescribed by instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures or drawings.

1. During the inspection immediately following the November 2,1987, drywell fire, the following instances in which instructions and procedures were not adhered to for work activities were identified:

a) Plant Managers Instruction (PMI) 8.1, Temporary Alterations, requires that long term alterations shall be controlled using a temporary alteration control form (TACF) in lieu of other mechanisms, such as a maintenance request (MR), which are only for short term alterations.

Contrary to the above, a TACF was not used to authorize tempo-rary connections through penetration EE for recirculation system valve controls and drywell blower controls performed under MRs A793993 and A775468. These MRs were performed in May and October 1987, and should have been considered long term altera-tions.

b) NQAM Part III, Section 4.1 requires that QA Records shall have all blanks filled in or marked N/A.

Contrary to the above, MRs were found with signatures and data missing including MR A775468 which was missing signature's for "Raychem Acceptable" on 6 pages and signatures for "QC Verifica-tion of Standard Test 1" on 5 pages; and MR A322017 which was missing an entry on blocks 26 through 2S which should have documented work performed and the cause of failure.

l 8009260000 eso93p i gDR ADOCK 0500025,9 m

Tennessee Valley Authority 2 Docket Nos. 50-259, 260, 296 Browns Ferry 1, 2, and 3 License Nos. OPR-33, 52, 68 c) PMI 6.2, Conduct of Maintenance S'ection 4.4.13, requires that post-maintenance testing be performed on all plant process equipment following all corrective maintenance, and some pre-ventive maintenance and troubleshooting activities that might have impaired proper functioning of tne component.

Contrary to the above, no electrical checks of any nature were performed as post-maintenance testing following completion of the temporary electrical splices installed under MRs 793993 and 775468; and Electrical Maintenance Instruction (EMI) 7.2, test procedure for Initial Installation and Troubleshooting of Molded Case Circuit Breakers, failed to test the motor starter portion of the breakers. The starters contain the thermal overload elements which perform a necessary function for some modes of end-device failures. .

d) The Browns Ferry Fire Protection Program Plan (FPP-1) requires that fire brigade members be qualified to the training and qualification requirements contained therein.

Contrary to the above, three of the six fire brigade members who entered the drywell for fire fighting operations were not qualified for fire brigade duty in accordance with FPP-1. -

Additionally, 67 of 127 fire brigade members assigned to five operating crews were ineligible for fire brigade duty in accor-dance with FPP-1.

2. During this inspection the following instances of failure to follow procedures were identified:

a) The licensee's Nuclear Quality Assurance Manual (NQAM),

Part III, Section 4.1, Quality Assurance Records, requires that QA records be prepared in black ink, have all blanks filled in or marked not applicable (N/A), and that corrections be made by the single line through, initial and date method. BFEP, PI 87-52, Development and Control of the Browns Ferry Unit 2 Phase I Q-List, Step 5.7.3 requires that QEOP's shall be con-trolled as QA records.

Contrary to the above, the 0-List Equipment Data Package (QEDP) for System 001, Main Steam, contained information in the Tabs entitled B1/ Analyses Cononent Pickoff and the B1/82 Analyses Component Pickof f which cid not comply with the NCAM. Specifi-cally, there were numerous entries made in red and light blue ink, most reviewer blocks did not contain a signature or N/A, and most corrections were made without the dated initials of the person who maoe the correction, k

. Tennessee Valley Authority ,

Browns Ferry 1, 2, and 3 Docket Nos. 50-259, 260, 296 License Nos. OPR-33, 52, 68 b)

Site Director Standard Practice 3.7, Corrective Action, requires that a management reviewer identify based on operability criteria in attachment 5 of the proce, dure, if operability at a nuclear plant could potentially be affected by a condition adverse to quality. SDSP 3.7 further requires that the respon-sible organization determine the significance of the CAQ in i accordance with specified criteria in paragraph 4.12.

l Contrary to the above, inadequate management and organization reviews of CAQR BFF870180 were performed when it was found that the Standby Gas Treatment Building . original designed seismic response was underpredicted. The operability determination was ,

made that no unit operability was affected and the fact that '

General Design Criterion 2 of 10 CFR 50, Appendix A was violated was not evaluated as being significant.

. i This all is a Severity three units. Level IV Violation (Supplement I) and is applicable to I Pursuant to the provis' ions of 10 CFR 2.201, you are hereby required to  ;

submit to the U. S. Nuclear Regulatory Comnission, Attn:

l Desk., Washington, DC 20555 with a copy to t: Document Control  !

Projects, and a copy to the NRC Resident Inc,pector, Browns Ferry 1e Dir!

within 30 days of the date of the letter transmity,ing this Notice a w,ritten ,

statement the or explanation in reply including: (1) admission or dental of violation, t

l (2) the reason for the violation if admitted, (3) the

! corrective steps which have been taken and the results achieved (4) the corrective steps which will be taken to avoid further violations, and

' (5) the date when full compliance will be achieved. Where good cause is t shown, consideration will be given to extending the response time, i

FOR THE NUCLEAR REGULATORY COMMIS$10N ,

Frank R. McCoy, Assistant Ofrector for TVA Inspection Programs TVA Projects Division Office of Special Projects Dated at Atlanta, Georgia this nEday of September 19SS