ML18031A534

Responds to NRC 860521 Ltr Re Violations Noted in Insp Repts 50-259/86-09,50-260/86-09 & 50-296/86-09.Corrective Actions: Fire Protection Audit by Qualified Personnel Performed & Fire Watch Established

ML18031A534
Person / Time
Site:	Browns Ferry
Issue date:	06/20/1986
From:	Gridley R TENNESSEE VALLEY AUTHORITY
To:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
NUDOCS 8607070262
Download: ML18031A534 (8)

Text

TENNESSEE VALLEY AUTHORITY CHATTANOOGA. TENNESSEE 37401 5N 157B Lookout Place June 20, 1986 U.S. Nuclear Regulatory Commission Region II ATTN: Dr. J. Nelson Grace, Regional Administrator 101 Marietta Street, NH, Suite 2900 Atlanta, Georgia 30323

Dear Or. Grace:

BRONNS FERRY NUCLEAR PLANT UNITS 1 2 NRC-OIE REGION'I INSPECTION REPORT 50-259/86-09, 50-260/86-09, 50-296/86- RESPONSE TO VIOLATIONS Enclosed is our response to your May 21, 1986 letter to S. A. white transmitting IE Inspection Report Nos. 50-259/86-09, 50-260/86-09, and 50-296/86-09 for our Browns Ferry Nuclear Plant which cited TVA with two Severity Level IV Violations.

If you have any questions, please get in touch with R. E. Rogers at FTS 858-2723.

To the best of my knowledge, I declare -the statements contained herein are complete and true.

Very truly yours, TENNESSEE VA LEY AUTHORITY R. Gridley, D rector Nuclear Safety and Licensing Enclosure cc: Mr. James Taylor, Director (Enclosure)

Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Hashington,-D.C. 20555 8b070702b2 8bOb20 PDR *DOCK 05000259 ~~

8 PDR I',t An Equal Opportunity Employer

RESPONSE

TO NRC INSPECTION REPORT NOS. 50-259/86-09, 50-260/86-09, AND 50-296/86-09 DATED MAY 21, 1986 Item 1 Technical Specification Section 6.2.A.B.i requires an independent fire protection and loss prevention inspection and audit to be performed annually utilizing either qualified offsite licensee personnel or an outside fire protection firm. NRC Generic Letter 82-21 describes the general scope of the fire protection audits and identifies the composition and qualifications of the auditors.

Contrary to the above, the independent fire protection and loss prevention inspection and audit by qualified offsite fire protection licensee personnel or outside fire protection firm has not b5en performed at Browns Ferry since May 1984 is 'his a Severity Level IV violation (Supplement I),

l. Admission or Denial of the Alle ed Violation TVA admits to the violation.

2. Reasons for the Violation At the time of the audit, although- the TVA Quality Audit Branch would preferred to have qualified fire protection personnel, they did not'ave believe that fire protection engineers were ~re u>red for the annual technical specification audit. The subject audit did have a very competent audit team, and we believe,they performed an excellent audit.

The violation was caused by a shortage of available qualified resources in the Quality Audit Branch and inability to obtain the use of fire protection engineers for this specific audit time period. This was an isolated occurrence that occurred at Browns Ferry Nuclear Plant (BFN) in 1985. The fire protection audit conducted at BFN in 1984 was performed by qualified individuals as recommended in NRC Generic Letter 82-21.

3 . Corrective Ste s Which Have Been Taken and Results Achieved The audit module for scheduling and scoping this audit has been revised to specify that a qualified fire protection engineer be included on all fire protection audit teams. A triennial fire protection audit was conducted-et BFN by an independent fire protection consulting firm during April and May 1986.

4. Corrective Ste s Which Wi 11 Be Taken to Avoid Further Violations Internal TVA organizations with qualified fire protection personnel will be contacted and commitment will be obtained for utilizing their services in assisting TVA's Division of Nuclear Quality Assurance in performing future fire protection audits of TVA's nuclear plants. These organizations will be formally contacted by September 30, 1986. Firm commitments for utilization of their services during 1987 calendar year fire protection audits will be in place by December 1, 1986.

In addition to the above, contractual arrangements with external fire protection firms will be pursued. If such arrangements can be made and are found to be acceptable, th'en contractual agreements wi 11 be considered for providing fire protection expertise on future audits on an as-needed basis.

5. Date When Full Com liance Will Be Achieved Full compliance was achieved when-the -BFN:.triennial fire protection audit was completed in Hay 1986.

Item 2 Technical Specification Section 6.3.A.6 requires detailed written procedures covering surveillance and testing requirements to be prepared, approved, and adhered to. Technical Specification Section 4.11.E states that each required fire barrier penetration shall be verified to be functional at least once per 18 months by a visual inspection and prior to restoring a fire barrier to functional status following repairs or- maintenance by performance of a visual inspection of the affected fire barrier penetration.

Contrary to the above, surveillance procedures have not been provided for the piping penetration of the required fire bapriers. Surveillance inspections of these piping penetrations have not been made since this requirement was incorporated into the Technical Specifications on November 24, 1981. On November 22, 1985, the licensee discovered an open piping penetration in a fire barrier. Subsequently, the licensee has identified a total of 190 piping fire barrier penetrations of which 114 were found to be deficient. In .

general, these deficiencies involve a small annular space around piping penetrations that had not been properly sealed. These small open penetrations are considered to have only minor safety significance.

This is a Severity Level IV violation (Supplement I).

l. Admission or Denial of the Alled ed Violation TVA admits to the violation as stated.

S Rea'sons for the Violation

,2'. The violation occurred because of 'a misinterpretation of the Technical Specifications. The terminology used in the Technical Specification 3.11.E, e.g., "all fire barrier penetrations including cable penetration barriers, fire doors, and fire dampers . . .," led to an incorrect assumption that only the three specifically listed kinds of penetrations required surveillance.

Corrective Ste s Which Have Been Taken and Results Achieved Until the design evaluation of fire barriers and correction of deficiencies has been completed, all fire barriers are being considered as nonfunctional. Fire detectors near penetrations in fire zone boundaries protecting safety-related areas have been verified to be operable and are being checked semiannually. A roving fire watch has been established to check the safety-related areas adjacent to fire zone boundaries hourly.

This fire watch has been in effect since December 16, 1985, when the fire barriers were declared ."inoperabld'." .. TVA's Division of Nuclear Engineering (DNE) is designing or selecting'cceptable fire-rated seals for all required fire barrier penetrations and coordinating the seal installation. A surveillance instruction (SI) has been drafted to include inspecting required piping penetrations when the fire barrier qualification has been completed, the penetrations properly sealed, and the roving fire watch is no longer required.

4. Corrective Ste s Which Hill Be Taken to Avoid Further Violations Piping penetrations required by the fire protection program will be qualified and included in the surveillance program. They will be maintained by a maintenance crew assigned to the fire protection engineer. The roving fire watch wi 1 continue until the piping 1

penetrations have been sealed, and thesurveillance inspection program has been implemented.

5. Date When Full Com liance Hill Be Achieved The fire barrier qualification will be completed, the piping penetrations will be sealed, and the surveillance program will be implemented by December 31, 1986, or before any unit startup, whichever comes first.

S