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The inspectors identified a finding of ver … The inspectors identified a finding of very low safety significance and associated non-cited violation of 10 CFR Part 50.55a(b)(3)(ii), for the licensees failure to adequately reestablish the design basis capability of multiple Motor Operated Valves (MOVs) after internal modifications were performed to the valves. The NRC inspectors determined that the methodology described in the TVA documentation for justifying the design-basis capability of MOVs and the specific justification prepared by TVA to reestablish the design basis capability of MOVs after undergoing internal modifications did not satisfy 10 CFR 50.55a(b)(3)(ii), and was a performance deficiency. Further, this was determined to be a programmatic issue because there were at least 12 examples of other modified MOVs where the licensee implemented its methodology that did not provide an adequate justification for the design basis capability of those MOVs that would satisfy 10 CFR 50.55a(b)(3)(ii). The NRC staff determined the finding to be more than minor because the program deficiency, if left uncorrected, could become a more significant safety concern. Specifically, by establishing a design basis MOV valve factor that TVA considered to be conservative using data from two tested valves obtained from the JOG MOV Performance Verification program without demonstrating its applicability to the Browns Ferry valves, BFN personnel might not realize that the established valve factor is the minimum value that must be used to set up MOV actuator operating parameters. The inspectors concluded this finding was associated with the Mitigating Systems Cornerstone. The inspectors determined the finding could be evaluated using the Significance Determination Process (SDP) in accordance with IMC 0609, Significance Determination Process, Attachment 0609.04, Phase 1 - Initial Screening and Characterization of findings, Table 4a for the Mitigating Systems Cornerstone. The finding screened as having very low safety significance (Green) because the finding was a design or qualification deficiency confirmed not to result in a loss of operability at this time. This finding had a cross-cutting aspect in the area of human performance, decision making, because the licensee failed to use conservative assumptions in decision making. Specifically, the licensee made modifications to multiple safety related MOVs and then reestablished their design basis capability using methods that were inconsistent with industry and NRC guidance.consistent with industry and NRC guidance.

Discovered date

23:59:59, 30 September 2011 +

Docket

05000259 +, 05000260 + and 05000296 +

Event date

23:59:59, 30 September 2011 +

Finding integer

2 +

Finding type

Non-cited violation +

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INPO aspect

DM.2 +

Identified by

NRC identified +

Inspection Manual Chapter

NRC Inspection Manual 0609 +

Inspection procedure

IP 95003 +

Inspection report

IR 05000259/2011011 +

Inspector

R Croteau +, L Lake +, E Huang +, Robert Orlikowski +, Jared Nadel + and Michael Farnan +

Modification date"Modification date" is a predefined property that corresponds to the date of the last modification of a subject and is provided by <a rel="nofollow" class="external text" href="https://www.semantic-mediawiki.org/wiki/Help:Special_properties">Semantic MediaWiki</a>.

12:57:32, 25 September 2017 +

Person