ML18031A933
| ML18031A933 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 10/30/1986 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8611040460 | |
| Download: ML18031A933 (10) | |
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TENNESSEE VALLEYAUTHORITY CHATTANOOGA. TENNESSEE 37401 SN 157B Lookout glace pm:
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'OCTAD 886 U.S. Nuclear Regulatory Commission Region II Attn:
Dr. J. Nelson Grace, Regional Administrator 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323
Dear Dr. Grace:
BROWNS FERRY NUCLEAR PLANT UNITS 1, 2, AND 3 NRC-OIE REGION II INSPECTION REPORT 50-259/86-22, 50-260/86-22, 50- 96/8 -22 SUPPLEMENTAL RESPONSE Enclosed is our supplemental response-to G.
G. Zech's July 28 and August 8, 1986 letters to S. A. White transmitting IE Inspection Report Nos. 50-259/86-22, 50-260/86-22, and 50-296/86-22 for our Browns Ferry Nuclear Plant which cited TVA with one Severity Level IV Violation.
Our initial submittal to the Severity Level IV Violation dated September 17, 1986 stated that a status report would be submitted by October 30, 1986.
This supplemental response is a status report on the application of Specification G-38, "Cable Installation" and Specification G-40, "Conduit Installation," to maintenance and modification activities on existing cable and conduit installations.
If you have any questions, please get in touch with M. J.
May at (205) 729-3566.
To the best of my knowledge, I declare the statements contained herein are complete and true.
Very truly yours, TENNESSEE VALLEY AUTHORITY Enclosure cc (Enclosure):-
Mr. James Taylor, Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Mr. G.
G. Zech, Director TVA Projects U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 R.. Gr dley, Direc or Nuclear Safety an Licensing Sb110%04b0 Sb1030 PDR
- DOCK 05000259' PDR An Equal Opportunity Employer
I
SUPPLEMENTAL RESPONSE NRCINSPECTION REPORT NOS.
50-259/86-22, 50-260/86-22, AND 50-296/86-22 GARY G.
ZECH'S LETTERS TO S. A. WHITE DATED JULY 28 AND AUGUST 8, 1986 Item 1 10 CFR 50, Appendix B, Criterion III requires that measures shall be established to assure applicable regulatory requirements and the design basis are met.
These measures shall include provisions to assure that appropriate quality standards are specified and included in design documents and that deviations from such standards are controlled.
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g at all other TVA facilities to meet cable installatio This is a Severity Level IV violation (Supplement I).
Contrary to the above, this requirement was not met from January 15 June 16, 1986, in that newly implemented standards for control of installation of insulated cables (TVA General Specification 38) were not. specified for use on facility design modifications in progress prior to January 15, 1986.
'The TVA Office of Engineering implemented the new cable installation criteria of General Specification 38, revision 7, at all TVA facilities with the.exception of Browns Ferry (BFN) as of January 15, 1986.
General Specification 38 was issued for all TVA sites to have insulated cable installations done consistently at, all TVA nuclear plants and to bring TVA's cable installation practices up to a level consistent with current industry practice.
General Specification 38, revision,7, was issued on January 15, 1986 to June 16, 1986 (inspection date) the licensee did not implement the cable installation s ecification G-38 at BFN althou h this corrective action was deemed necessary n standards.
Our initial submittal dated September 17, 1986 is repeated below and the supplemental response for item 4, "Corrective Steps Which Will Be Taken to Avoid Further Violations," follows.
Initial Submittal 1.
Admission or Denial of the Alle ed Violation We admit that the violation occurred as stated.
2.
Reasons for the Violation All insulated cables installed at BFN before January 15,
- 1986, were installed to Construction Specification G-4, Cable Installation.
TVA management decided that some modifications in process would be finished under Specifications G-3, Conduit Installation, and G-4, Cable Installation, instead of using the new Specifications G-38, Cable Installation, and G-40, Conduit Installation.
The use of G-38 cable installation often requires the use of its companion specification for conduit installation, G-40.
Hany modifications in progress for unit 2 would have to be redesigned and/or reconstructed in accordance with G-40 in order for a successful G-38 installation to proceed.
Since the G-38 terminology, "future modifications," was subject to interpretation, it was decided that certain modifications in process would be finished under the old specification.
I Therefore, the following implementation strategy for the orderly transition to the G-38 and G-40 specifications at BFN was chosen:
a.
Utilize G-3 and G-4 to complete remaining unit 2 outage work for which designs had been issued before January 15; 1986.
b.
Incorporate G-38 and G-40 requirements into unit 2 outage work for which designs had been issued on or after January 15, 1986.
c.
G-38 and G-40 would be utilized for the unit 2 cable replacement activities in the drywell.
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d.
G-38 and G-40 would be used for the future modification activities on units 1 and 3 when work resumed.
3.
Corrective Ste s Which Have Been Taken and Results Achieved On June 18, 1986 TVA placed a hold on all cable pulling at BFN.
The order stated that the hold would be lifted for each applicable section when the following conditions were met:
a.
Site -instructions associated with cable pulling activities must be revised or new procedures written to incorporate the requirements set forth in Specifications G-38 and G-40.
b.
Site personnel involved in cable pulling activities must receive documented training in the revised site instructions.
Quality Assurance verified compliance with the hold order through the surveillance process.
4.
Corrective Ste s Which Will Be Taken to Avoid Further Violations We will implement standards G-38 and G-40 for new cable installation.
However, both modification and maintenance personnel have requested numerous engineering interpretations in applying all the requirements of G-38 and G-40 to restoration of existing cable/conduit installations.
Therefore, our Division of Nuclear Engineering (DNE) is performing an
evaluation to determine the appropriate application of G-38 and G-40 to maintenance and modification routine restoration work, in order that we may continue activities without unnecessary documentation and replacement of existing cable and conduit installations.
The evaluation will take into account the necessary installation and inspection controls.
Until that evaluation is complete and appropriate procedural controls are in
- place, any maintenance or modification restoration activity deviating from G-38 or G-40 will be justified and documented before the work being performed.
A status report will be submitted to NRC by October 30, 1986.
Several technical integrity verification programs are presently underway at BFN to demonstrate the integrity of cable installed under G-3 and G-4.
These are scheduled to be completed in the coming, months.
Preliminary results indicate that the installed cable is capable of reliable operation at several times the sidewall pressure and at lesser minimum bend radius than specified by the cable suppliers.
If any of the programs should indicate cases of inadequate cable conditions, new cable will be installed using the G-38 and G-40 revised installation instructions.
5.
Date When Full Com liance Will Be Achieved Our integrity verification programs will be complete before restart of unit 2 at BFN.
Su lemental Res onse Status Re ort Our cable pulling maintenance activities have been limited due to the need for additional procedures that are to be written to specifically address maintenance activities.
In the interim, the hold has been lifted for only those specific cable pulling maintenance activities that are able to be performed in accordance with the new modificabions implementing procedures.
These newly approved procedures are Modifications and Additions Instruction (MAI) 44, "Cable Pulling for Insulated Cables Rated Up to 15,000 Volts Units 1, 2, 3," which conforms to Specification G-38, "Cable Installation," and MAI-27, "Installation of Electrical Conduit Systems and Junction Boxes," which conforms to Specification G-40, "Conduit Installation."
Training is performed for engineers and craftsmen in the applicable procedures before accomplishing cable pulling or conduit installation activities.
The hold on cable pulling modification activities has been lifted.
Procedures MAI-44 and MAI-27, referenced
- above, have been implemented.
Training has been completed and documented for all personnel who are currently involved with the implementation of cable pulling modification activities associated with MAI-44 and MAI-27.
Training will be ongoing for additional personnel as required.
DNE has established the following requirements for restoration maintenance that will be incorporated in our next revision to Specifications G-38 and G-40:
1.
Restoration can be made such that the installation can be returned to the original, as-found condition.
2.
The repair can be made meeting all the requirements which existed at the time of installation so that the existing operability requirements, technical specification limits, and design bases are satisfied.
3.
Any nonconforming restoration is documented by a Problem Identification Report or Significant Condition Report and the corrective action resolved and implemented before restart.
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