ML20127K745

Notice of Violation from Insp on 850226-0325

ML20127K745
Person / Time
Site:	Browns Ferry
Issue date:	04/24/1985
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20127K710	List: IR 05000226/2003025 ML20127K705 ML20127K745
References
50-259-85-15, 50-260-85-15, 50-296-85-15, NUDOCS 8505220176
Download: ML20127K745 (2)

See also: IR 05000226/2003025

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ENCLOSURE 1

NOTICE OF VIOLATION

Tennessee Valley Authority

Docket Nos. 50-259, -260, and -296

Browns Ferry Units 1, 2, and 3

License Nos. DPR-33, -52, and -68

The following violations were identified during an inspection conducted on

February 26 - March 25,1985. The Severity Levels were assigned in accordance

with the NRC Enforcement Policy (10 CFR Part 2, Appendix C).

1.

Technical Specification 3.7.B.1 requires that all three trains of the Stand-

by Gas Treatment (SBGT) System be operable at all times when secondary con-

tainment integrity is required except one train may be out of service for

seven days as specified in 3.7.B.3.

Contrary to the above, this requirement was not met in that during a routine

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. tour of the normally locked SBGT room on March 8, 1985, the 480-volt circuit

breaker (2A) for the humidity control heater of SBGT "C" train was found in

the tripped condition making the

"C"

train inoperable.

Indication of this

condition existed at the back parel of Unit 2 control room where both the

"0FF" (green) and "0N" (red) ind :ating lights for the humidity control

T heaters were not illuminated and a maintenance request sticker was still

in place.next to the indicating lights.for a previously cleared maintenance

request, M.R. A-312188, for troubleshooting a previous problem with the

heater breaker on October 6,1984. The circuit breaker was replaced and

the train returned to service on March 9, 1985.

This is a Severity Level IV violation (Supplement I) and is applicable to

all units.

- 2.

Technical Specification 6.3.A.6 requires that detailed written procedures

covering surveillance and testing requirements be prepared and adhered to.

Contrary to the above, Surveillance Instruction 2 (SI-2), " Instrument Checks

and Observations," was not adhered to on March 5, 1985 in that the compari-

son of reactor water level instrument readings required by Section 2.1 was

not performed on the Units 1 or 2 level instruments.

Section 2.1 of SI-2

implements the daily reactor water level instrument checks required by

Technical Specifications 4.2.A, 4.2.B, and 4.2.F.

An instrument check is

defined in Technical Specification 1.V.4 as a qualitative determination of

operability by observation of instrument behavior during operation. This

. determination shall include, where possible, comparison of the instrument

with other independent instruments measuring the same variable.

8505220176 850424

PDR

ADOCK 05000259

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Tennessee Valley Authority

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Docket Nos. 50-259, -260, and -296

Browns Ferry Units _1, 2, and 3

License Nos. DPR-33, -52, and -68

Contrary-

to

the

above,

SI-2,

" Instrument

Checks

and Observations," was inadequately written such that it did not fully

implement the Technical Specification surveillance requirements. Technical Specifications 4.2.A, 4.2.B, and 4.2.F require daily reactor water level

instrument checks consisting of a comparison with other independent

instruments where possible.

Section 2.1 of SI-2 implements this

requirement; however, it erroneously requires comparison of instruments

which are not independent in that they share common sensing lines even

though independent level instruments were available for comparison.

SI-2

was additionally inadequate in that it did not include appropriate

quantitative or qualitative acceptance criteria for determining what

constitutes a satisfactory comparison of independent reactor water level

instruments.

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Contrary to the above, the licensee failed to adhere to Surveillance

Instruction 4.2.B-4, " Instrumentation that Initiate or Control the Core

Standby Cooling Systems (CSCS) - Drywell High Pressure (PS-64-58-E-H),"

on March 14, 1985 in that:

a.

The pneumatic calibrator was not connected to the test tee as specified

in Step 4.3 but was instead connected to a fitting which was discon-

nected in the instrument drain tubing.

b.

Pressure was not decreased below 1.2 psi as required in Step 4.5 but

was instead decreased until the applicable relay dropped out at about

1.7 psi.

This is a Severity Level IV violation (Supplement I) and is applicable to

all units.

Pursuant to 10 CFR 2.201, you are required to submit to this office within 30

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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

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for the violations if admitted; (3) the corrective steps which have been taken

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and the results achieved; (4) corrective steps which will be taken to avoid

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further violations; and (5) the date when full compliance will be achieved.

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Security or safeguards' information should be submitted as an enclosure to

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facilitate withholding it from public disclosure as required by 10 CFR 2.790(d)

or 10 CFR 73.21.

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Date:

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