ML18029A777
| ML18029A777 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 08/07/1985 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18029A776 | List: |
| References | |
| 50-259-85-36, 50-260-85-36, 50-296-85-36, NUDOCS 8508130310 | |
| Download: ML18029A777 (6) | |
See also: IR 05000621/2007026
Text
ENCLOSURE
1
II
Valley Authority
Browns Ferry 1, 2, and
3
Docket
Nos.
50-259,
260,
and
296
License
Nos.
52,
and
68
The following violations
were identified during
an
inspection
conducted
on
June
21 - July 26,
1985.
The Severity Levels were assigned
in accordance
with
the
NRC Enforcement Policy (10 CFR Part 2, Appendix C).
1.
Technical Specification 6.3.A requires
that detailed written procedures
covering the following items shall
be prepared,
approved
and adhered to:
Normal startup,
operation
and shutdown of all systems
involving nuclear
safety of the facility.
Action to
be
taken
to correct
specific
and
foreseen
potential
malfunctions of systems
or components.
Fire protection
and prevention
procedures
Contrary to the
above, this requirement
was not met for the
two examples
that follow:
a ~
The licensee failed to prepare
adequate written procedures
covering the
unit cross-connection
feature of the Residual
Heat Removal
(RHR) System
as
described
in paragraphs
4.8.6.4
and
F.7.16 of the
Final
Safety
Analysis Report
(FSAR).
This cross-connection
feature allows each unit
access
to one
RHR loop belonging to its physically adjacent unit in
order to remove
decay
heat
and residual
heat from the reactor core
and
in the event of a complete failure of the affected
unit's
emergency
core cooling systems
(ECCS).
The licensee's
existing
procedure,
Operating Instruction 74, Residual
Heat
Removal
System,
was
inadequate
in that paragraph
IV.F, Cross
Connecting
Between Units, was
limited for use
in the containment
cooling
mode only and
did not
address
the reactor
core cooling mode.
The procedure
was additionally
inadequate
in that it did not require
the bypassing
of certain
suction valve interlocks in the
RHR pump start circuitry which would
prevent
the
pumps
from starting
in the specified cross-tie
valve
lineup.
b.
The
licensee
failed to
adhere
to Operating
Instruction
26,
High
Pressure
Fire Protection
System for the required
system
valve lineup.
On
June
17,
1985,
deluge
system
drain valve
1-26-77-SD
was
found
mispositioned
to the
open position.
The master valve status checklist
in the control
room indicated the valve was shut which was contrary to
the as-found position.
9508130310
850~07
ADOCK 05000Z59
8
Valley Authority
Browns Ferry 1, 2,
and
3
Docket Nos. 50-259,
260,
and
296
License
Nos.
DPR-33, 52,
and
68
This is
a Severity Level
IV Violation (Supplement I) applicable to all three
units.
2.
Appendix
B, Criterion
V requires
that activities affecting
quality shall
be prescribed
by drawings of a type appropriate
to the circum-
stances
and shall
be accomplished
in accordance
with these
drawings.
Contrary to the above,
the requirement
was not met in that the High Pressure
Coolant Injection System torus
suction valve,
73-27,
was not electrically
connected
in accordance
with
TVA drawings
and
This is
a Severity Level
IV
violation (Supplement I) and is applicable to
Unit Three.
3.
Technical Specification 6.3.A. requires
that detailed written procedures,
including applicable
checkoff lists,
shall
be
prepared,
approved,
and
adhered
to for system operation
and corrective maintenance
which could have
an effect on the safety of the reactor.
Procedures
were not adhered
to or were inadequate
in the following examples:,
a ~
Mechanical
Maintenance
Instruction
(MMI)-28, Control
Rod
Drive
Hydraulic Unit (Repair,
Removal;"and
Replacement),
Step
6.3 requires
that
the
maintenance
request
contain
the
functional
and
post
maintenance
test requirements
as specified in the
MMI Testing Section
and that
the maintenance
foreman
ensure
these test
requirements
are
performed
and signed off.
Contrary to the
above,
MR A126652,
completed
February
20,
1985,
on
Unit 1 Control
Rod Drive Module 34-03 did not contain the functional
and
post
maintenance
test
requirements
consisting
of insertion
and
withdrawal timing. Additionally, the responsible
foreman did not ensure
the required testing
was performed
and signed off.
b.
MMI-28, Section
10.3,
and
Browns Ferry Operating Instruction (OI)-85,
Control
Rod Drive System,
Section
3.H. l.e./2.e.,
require that control
rod insertion
and withdrawal times be'48
+ 3 seconds.
co
Contrary to the above,
during control rod timing checks
on February 22,
1985,
rod withdrawal
and
insertion
times
of
41
and
53
seconds
respectively for Unit
were
accepted
as satis-
factory.
OI-85, Section 3.0.9, requires that if control rod drive water pressure
is
increased
above
normal
limits
(260
psi
greater
than
reactor
pressure)
to initially move
a rod from the fully inserted
position,
then it should
be returned
to normal
before
a rod passes
the 02 notch
position in order to prevent double notching in high rod worth regions.
Valley Authority
Browns Ferry 1, 2, and
3
Docket Nos. 50-259,
260,
and
296
License
Nos.
DPR-33, 52,
and
68
Contrary to the above,
on February
22,
1985, Unit
was withdrawn past notch position
02 with drive water pressure
approxi-
mately
50 psi
above
normal limits.
d.
Standard
Practice
17. 18 requires
a safety
evaluation of changes
to
safety
related .equipment
that
remain
following completion
of
a
maintenance
activity to provide the basis for a determination that the
change did not involve an unreviewed safety question.
Contrary to the
above,
this
requirement
was
not met in that,
when
failed open resistors
on both
High Pressure
Coolant Injection
(HPIC)
steam line drain isolation valves'73-6A
and
73-6B) soleniod"field
suppression
circuits were found during maintenance activity on March 8,
1985,
no safety evaluation
was performed to determine
the operability
of the
system
under this potentially degraded
condition.
The
resistors
were
not replaced
and
the
system
was
not evaluated
during power operation until the unit was
shutdown
on March 19,
1985.
This is
a Severity Level
IV violation (Supplement I) and is applicable
to
all units.
Appendix
B, Criterion XII requires
that
measures
shall
be
established
to assure
that
measuring
and test
equipment
(MKTE) used
in
activities
affecting quality are
pro'perly controlled,
calibrated,
and
adjusted
at specified
periods
to maintain accuracy within necessary
limits.
Part III, Section 3. 1 "of the
TVA Nuclear
Operations guality Assurance
Manual
(N-0(AM) implements
these
requirements.
Contrary to the above,
the licensee failed to adhere to the requirements
of
Part III, Section
3. 1 of the N-0(AM as indicated
by the following examples:
a.
The accountability of the, utilization of the
M&TE used
as
working
standards
by the Mechanical
Maintenance
small tool repair
and calibra-
tion shop
was
not documented
as required
by paragraph
2.3.2 of the
N-OQAM.
b.
The assigned
calibration interval for MSTE was
not adequately
based
upon
experience
available
through historical calibration
performance
records
as required
by paragraph
3.2. 1 of the
N-0(AM in the following
two examples:
( 1)
Oscilloscope
number
251425
was
found out-of-tolerance
on its last
five annual
calibrations
(ll/5/80, 10/26/81,
10/19/82,
10/21/83
and
10/19/84), yet,
each
out-of-tolerance
investigation
report
either did not address
the calibration interval or concluded that
the interval
was adequate.
(2)
Pressure
gage
number
E00895
was
found out-of-tolerance
on
two
consecutive
semi-annual
calibrations
(2/29/84
and 8/28/84), yet,
the out-of-tolerance
investigation
reports failed to address
the
Valley Authority
Browns Ferry 1, 2,
and
3
Docket Nos.
50-259,
260,
and
296
License
Nos.
52,
and
68
adequacy
of the calibration interval
as
required
by the out-of-
tolerance
notice.
This is
a Severity
Level
V Violation (Supplement I) applicable
to all
3
units.
Pursuant
to
10 CFR 2. 201,
you are required to submit to this office within 30
days of the date of this Notice,
a written statement
or explanation in reply,
including:
(1) admission
or denial
of the alleged violations;
(2) the reasons
for the violations if admitted;
(3) the corrective
steps
which have
been taken
and
the results
achieved;
(4) corrective
steps
which will be taken to avoid
further violations;
and (5) the date
when full compliance will be achieved.
Security
or safeguards
information
should
be
submitted
as
an
enclosure
to
facilitate withholding it from public disclosure
as required
or 10 CFR 73.21.
Date:
AUG
7 1985