ML18032A465
| ML18032A465 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 07/29/1987 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| 5N-157B, NUDOCS 8708060081 | |
| Download: ML18032A465 (9) | |
Text
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR: 8708060081 DOC. DATE: 87/07/2'V NOTARIZED:
NO DOCKET FACIL: 50-259 Drowns Ferry Nuclear Poeer Station>
Unit 1>
Tennessee 05000259 50-260 Brains Ferry Nuclear Power Station>
Unit 2>
. 05000260 50-296 Brogans Ferry Nuclear Power Station>
Unit 3.
Tennessee 05000296 AUTH. NAME AUTHOR AFFILIATION GRIDLEY> R.
Tennessee Valley Authority RECIP. NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
'L
SUBJECT:
Responds to NRC ltr re violations noted in Insp Repts 50-259/86-09> 50-260/86-09
& 50-296/86-09.
C or r e ctive a c tion s:
all fire barriers considered nonfunctional
& fire detectors verified operable
& mill be checked semiannually.
DISTRIBUTION CODE:
IE01D COPIES RECEIVED: LTR ENCL SIZE:
TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES: Zeolinski 3 cg.
1 cg ea to:
Axelrad> Ebneter> S. Richardson>
Liam> Q. Zech
> OI > OIA.
Zeolinski 3 cg. icy ea to:
Axelrad> Ebneter> S. Richardson>
Liam> G. Zech> OI> OIA.
Zeolinski 3 cg. icy ea to:
Axelrad> Ebneter> S. Richardson.
Liam> G. Zech> OI> OIA.
0500025%'5000260 0500026 RECIPIENT ID CODE/NAME PD STANG> J ERNAL:
ACRS DEDRO NRR/DOEA DIR NRR/DREP/RPB NRR/PMAS/ ILRB OGC/HDS2 RES DEPY GI EXTERNAL:
LPDR NSIC NOTES:
COP IES LTTR ENCL 1
1 2
2 2
2 1
1 2
2 1
1 1
1 1
1 1
1 12 12 REC IP IENT ID CODE/NAME GEARS> G AEOD NRR MORISSEAU> D NRR/DREP/EPB NRR/DRIS DIR 0
LIEBERMAN>J EG IL RGN2 FILE 01 NRC PDR COPIES LTTR ENCL 2
2 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
TOTAL NUMBER OF COPIES REQUIRED:
LTTR 36 ENCL 36
TENNESSEE VALLEYAUTHORITY CHATTANOOGA. TENNESSEE 37401 5N 157B Lookout Place JUL R9 1987 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C.
20555 In the Matter of Tennessee Valley Authority Docket Nos. 50-259 50-260 50-296 BROWNS FERRY NUCLEAR PLANT UNIT 1, 2, AND 3 NRC OIE INSPECTION REPORT NOS.
50-259/86-09, 50-260/86-09, AND 50-296/86-09 SUPPLEMENTAL RESPONSE TO VIOLATION This letter is to provide a revised schedule for the completion of the fire barrier penetrations upgrade discussed in our letter dated January 29, 1987.
In our response to the violation, TVA committed to have the fire barrier modification and the. associated surveillance instruction completed by July 16, 1987.
A large portion of this work was being performed by a TVA contractor.
TVA has subsequently decided to complete the project using TVA engineering and modification personnel.
This change in responsibility will require a schedule extension.
Enclosure 1 provides TVA's revised response which reflects the new completion date.
Enclosure 2 provides a list of TVA's revised commitments.
The contents of this letter were discussed with Al Ignatonis in a telephone conference call on July 14, 1987.
TVA agreed to provide a revised response by July 28, 1987, and was subsequently extended to August 10, 1987, in a conference call on July 27, 1987, with M. P; Brown.
If you have any questions, please get in touch with M. J.
May, Site Licensing.
To the best of my knowledge, I declare,the statements contained herein are complete and true.
/
Very truly yours, TENNESSEE VALLEY AUTHORITY R.
- ridley, irector Nuclear Saf y and Licensing Enclosures cc:
See page 2
t 8708060081 870729 PDR ADOCK 05000259 8
PDR An Equal Opportunity Employer PAo
U. S. Nuclear Regulatory Commission JUL 29 1887 cc (Enclosures):
Mr. G.
G. Zech, Assistant Director Regional Inspections Division of TVA Projects Office of Special Projects U.S. Nuclear Regulatory Commission Region II 101 Marietta St.,
NW, Suite 2900 Atlanta, Georgia 30323 Browns Ferry Resident Inspector Browns Ferry Nuclear Plant P.O.
Box 311
- Athens, Alabama 35611 Mr. J.
A. Zwolinski, Assistant Director for Projects Division of TVA Projects Office of Special Projects U.S. Nuclear Regulatory Commission 4350 East West Highway EWW 322
- Bethesda, Maryland 20814
Item 2 ENCLOSURE 1 SUPPLEMENTAL RESPONSE TO NRC INSPECTION REPORT NOS. 50-259/86-09, 50-260/86-09, AND 50-296/86-09 DATED JULY 21, 1987 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 by performance of a visual inspection of the affected fire barrier penetration prior to restoring a fire barrier to functional status following repairs or maintenance.
Contrary to the above, surveillance procedures have not been provided for the piping penetration of the required fire barriers.
Surveillance inspection 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).
Ori inal Res onse 1.
Admission or Denial of the Alle ed Violati.on
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TVA admits to the violation as stated.
2.
Reasons for the Violation The violation occurred because of a misinterpretation of the Technical Specifications (TS).
The terminology used in TS-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.
Revised Res onse 3.
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 considexed 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.
An hourly roving fire watch has been established to check the safety-related areas adjacent to fire zone boundaries in order to meet the technical specifications requirements for compensatory measures.
This fire watch has been in effect since December 16, 1985 and will continue to be in effect until the appropriate surveillance instructions are approved for use.
A large portion of the penetration work was being performed by a TVA contractor.
TVA has subsequently decided to complete the project using TVA engineering and modifications personnel.
TVA's Division of Nuclear Engineering will now be designing and selecting acceptable fire-rated seals for all required fire barrier penetrations.
4.
Corrective Ste s Which Will Be Taken to Avoid Further Violations The surveillance instructions will be written,and approved to support the technical specifications section 4.11.E.
requirement of visual inspection every 18 months.
In order to support completion of the surveillance instructions, piping penetrations required by the fire protection program will be inspected,
- sealed, and corrective actions performed as necessary to insure the fire barriers are qualified.
This physical work is presently expected to be completed by December 1, 1987, and the surveillance instructions should be ready by January 10, 1988.
Since the above-mentioned corrective actions will be accomplished under an approved quality assurance
- program, TVA will take credit for completion of this work to meet the technical specification requirement for visual inspection.
5.
Date of Full Co lienee Full compliance is scheduled to be completed by March 10, 1988.
This date reflects to post work review and required approvals necessary for Engineering Change Notice closure.
ENCLOSURE 2 LIST OF COMMITMENTS MADE IN ENCLOSURE 1
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1.
The physical work necessary to support completion of the surveillance instructions will be completed by December 1, 1987.
2.
The surveillance instructions will be written and approved to support the technical specification section 4.11.E requirements by January 10, 1988.
3.
Full compliance is scheduled to be completed by March 10, 1988.