ML18037A989
| ML18037A989 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 07/17/1994 |
| From: | Machon R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9407250230 | |
| Download: ML18037A989 (16) | |
Text
VH.j.MH.j.'.'Y 1 (ACCELERATED RIDS PROCESSING)
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
CESSXON NBR:9407250230 DOC.DATE: 94/07/17 NOTARIZED: NO FACIL:50-260 Browns Ferry Nuclear Power Station, Unit 2, Tennessee AUTH.NAME AUTHOR AFFILIATION MACHON,R.D.
Tennessee Valley Authority RECIP.NAME RECIPIENT AFFILIATION Document, Control Branch (Document Control Desk)
DOCKET 05000260
SUBJECT:
Responds to NRC 940606 ltr re violation noted in insp rept 50-260/94-09.Corrective actions:TVA performed
& submitted to NRC,engineering evaluation of potential adverse consequences of misapplied coating on T-quenchers for listed events.
DISTRIBUTION CODE:
IE01D COPIES RECEIVED LTR ENCL SIZE TITLE: General (50 Dkt)-Xnsp Rept/Notice of Violation Response NOTES:
RECIPIENT ID CODE/NAME PD2-4-PD INTERNAL: ACRS AEOD/DSP/ROAB AEOD/TTC NRR/DORS/OEAB NRR/PMAS/IRCB-E REG FIL 02
~FILE 01 EXTERNAL EGGG/BRYCE iJ H
NSIC COPIES LTTR ENCL 1
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1 RECIPIENT ID CODE/NAME TRIMBLE,D AEOD/DEXB AEOD/DSP/TPAB DEDRO NRR/DRCH/HHFB NUDOCS-ABSTRACT OGC/HDS3 RES/HFB NRC PDR COPIES LTTR ENCL 1
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1 NOTE TO ALL"RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE! CONTACTTHE DOCUMENTCONTROL DESK, ROOM Pl-37 (EXT. 504-2083 ) TO ELIMINATEYOUR NAMEFROM DISTRIBUTIONLISTS FOR DOCUMENTS YOU DON'T NEED!
TAL NUMBER OF COPIES REQUIRED:
LTTR 21 ENCL 21
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Tennessee ValfeyAuthority. Post Office Box 2000, Decatur, Alabama 35609-2000 R. D. (RiCk) Ma0hoft Vice President, Browns Ferry Nuclear Plant July 17, 1994 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C.
20555 Gentleman:
In the Matter of Tennessee Valley Authority 10 CFR 2 Appendix C
Docket No. 50-259 50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN) - REPLY TO NOTICE OF VIOLATION (NOV) REGARDING INAPPROPRIATE T-QUENCHER COATING (NRC INSPECTION REPORT 50-260/94-09)
On June 6,
- 1994, NRC issued Inspection Report 94-09 that identified an apparent violation relating to corrective action for a misapplied coating on the suppression chamber T-quenchers.
NRC concerns relative to the inspection findings were also discussed in an Enforcement Conference held on June 14, 1994.
On June 23,
- 1994, NRC issued a
NOV for the misapplication of protective coatings on BFN Unit 2.
Enclosure 1 provides TVA's "Reply to the Notice of Violation" (10 CFR 2.201).
Enclosure 2 contains a summary of the commitments made in the reply.
If you have any questions regarding this re'ply, please telephone Pedro Salas, Manager of Site Licensing at (205) 729-2636.
Sincerely, R.
D.
chon Site Vice President PAB 1E-BFN Enclosures cc:
See page 2
trr407250230 9407l7 PDR ADDCK 05000'260 D
0 e
U.S. Nuclear Regulatory Commission Page 2
July 17, 1994 Enclosures cc (Enclosures):
Mark S. Lesser, Section Chief U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900
- Atlanta, Georgia 30323 NRC Resident Inspector Browns Ferry Nuclear Plant Route 12, Box 637
- Athens, Alabama 35611 Mr. J.
F. Williams, Project Manager U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Mr. D.
C. Trimble, Project Manager U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockvi1le, Maryland 20852
44 II 14
ENCLOSURE TENNESSEE VALLEY AUTHORITY BROGANS FERRY NUCLEAR PLANT (BFN)
REPLY TO NOTICE OF VIOLATION (NOV)
INSPECTION REPORT NUMBER 50-260/94 09 RESTATEMENT OF VZOLATION "During the Nuclear Regulatory Commission (NRC) inspection conducted on April 16, May 17,
- 1994, a violation of NRC requirements was identified.
Zn accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions,<<
10 CFR Part 2, Appendix C, the violation is listed below:
10 CFR 50, Appendix B, Criterion XVI, Corrective Action, requires that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.
In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.
The identification of the significant condition adverse to quality, the cause of the condition, and the corrective action taken shall be documented and reported to appropriate levels of management.
Contrary to the above, as of April 21, 1994, the licensee failed to assure that a condition adverse to quality was promptly identified and corrected, in that an unqualified coating that had been misapplied to the safety relief valve discharge quenchers stainless steel piping in 1982 was found to be inadequate as a result of coatings inspections conducted from 1983-1986.
Nevertheless, this condition was not adequately corrected during these inspections, or during the establishment of the containment coatings program in the Nuclear Performance Plan, or during system return to service for Unit 2 restart in May 1991.
As a result, the adverse condition persisted until identified on April 21, 1994.
A subsequent licensee analysis indicated that 123.2 ft~ of unqualified coating could contribute to emergency core cooling system strainer blockage.
This amount, added to the existing 78 ft, exceeded the 157 ft total allowed for unqualified coatings for Unit 2 operation.
This is a Severity Level IV Violation (Supplement I).>>
TVAi8 REPLY TO VIOLATION Reason For Violation The initiating event for this violation occurred over 12 years ago (1982).
There was an error in judgement by an individual to use a coating system, "that was only qualified for application on carbon steel components, on the stainless steel T-quenchers.
Inadequate questioning attitudes, coupled with design and work control weaknesses, a
fragmented TVA organization, and a lack of ownership and accountability allowed the T-quenchers to be coated without reconciliation of the safety evaluation and design drawing prohibitions against coating of stainless steel components.
In hindsight, it is TVA's position that there were no clear opportunities to identify this condition after the coating was applied.
~
The 1984 - 1985 refurbishment and subsequent inspection of the suppression chamber coatings were intended to ensure the proper adherence of the coatings, not to detect the misapplication of a qualified coating system.
~
The 1986 S.
G. Pinney Unit 1'underwater inspection report contains a one sentence reference to the observation of blistering on the Unit 2 T-quenchers after the plant had operated for one cycle.
At the time of that inspection report, it would have been reasonable to assume that the reference was to the period after the initial installation of T-quencher coating (1982), but before its refurbishment (1984).
Since the Unit 2 T-quencher coatings would have been recently refurbished at the time of the Unit 1 inspection report, there was no basis for additional investigation of the Unit 2 condition.
During the implementation of the Browns Ferry Nuclear Performance Plan (NPP)
Containment Coatings
- Program, the BFN Final Safety Analysis Report (FSAR) commitment to use American National Standards Institute (ANSI) qualified coatings for the inside containment surface was considered to have been adequately implemented.
The focus of the NPP program was on purchased components installed inside primary containment that were shipped with unqualified coatings.
The misapplication of coatings by TVA/contractors was not considered to be a problem.
Therefore, identification of the T-quencher coating problem was not within the scope of this program.
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The system return to operation reviews performed in 1991 were to verify the completion of restart issues and the resolution of known deficiencies.
The T-quencher coating problem was not a recognized deficiency at this time and was, therefore, not within the scope of this program.
Corrective Ste s That have been or Ri11 Be Taken and Results Achieved Questioning attitudes have improved since the early 1980s as evidenced by the fact that TVA self-identified the T-quencher coating condition as part of its ongoing coatings program.
Once this condition was identified, TVA promptly evaluated the issue and identified thorough corrective actions:
~
TVA performed and submitted to NRC (Reference 1) an engineering evaluation of the potential adverse consequences of the misapplied coating on the T-quenchers for the following bounding events:
Main Steam Relief Valve (MSRV) blowdown events, and large, intermediate and small break loss of coolant accidents (LOCAs).
This evaluation determined that unacceptable strainer blockage would not occur as a
result of the postulated disbonding of T-quencher coatings.
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TVA reviewed the previous underwater inspection reports and did not identify any other safety concerns.
~
The Unit 2 containment coatings log was updated to include the T-quencher coating.
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TVA will remove the misapplied coating from the T-quenchers inside the Unit 2 suppression chamber prior to restart from the next refueling outage.
The misapplied coating will be removed from the T-quenchers prior to the restart of Units 1 and 3.
~
Prior to restart from the next refueling outage, TVA will also sample other stainless steel components within the Unit 2 primary containment and take appropriate action to ensure that other similar unanalyzed coating conditions do not exist.
A similar review will also be performed prior to the restart of Units 1 and 3.
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Corrective Ste s That have been or Will Be Taken To Prevent Recurrence At the time of the initiating event for this violation (early 1980s),
organizational and personal responsibilities were not always clearly defined for corporate and site organizations.
In addition, responsibility and accountability were not always clear within TVA's nuclear engineering program and weaknesses were identified in its design control plan.
The programs implemented to define responsibilities, establish accountability, and institute a BFN Site Engineering organization were described in Sections II.1.3 and II.1.2.8 of the Browns Ferry NPP (Reference 2).
The development and implementation of an improved design control program was described in NPP Section III.2.3.
NRC review and approval of these programs is documented in NUREG-1232, Volume 3, Supplement 2, Section 4.2.1, Site Organization and Management and Section 2.1, Configuration Management
- Program, Design Baseline and Verification Program, and Design Calculations Program (Reference 3).
4 ~
Date When Pull Com liance Will Be Achieved Full compliance will be achieved on Unit 2 prior to startup from the Cycle 7 refueling outage.
REFERENCES 1.
TVA letter to NRC, dated May 20, 1994, Evaluation of T-Quencher Coating Inside the Suppression Chamber 2.
TVA letter to NRC, dated October 24,
- 1988, Browns Ferry Nuclear Plant (BFN)
Nuclear Performance Plan, Revision 2
3.
NRC letter to TVA, dated January 23,
- 1991, NUREG-1232, Volume 3, Supplement 2 - Browns Ferry, Unit 2 El-4
4 4
ENCLOSURE 2
TENNESSEE VALLEY AUTHORITY BROGANS FERRY NUCLEAR PLANT (BFN)
REPLY TO NOTICE OF VIOLATION (NOV)
INSPECTION REPORT NUMBER 50 260/94 09 COMMITMENTS 1.
TVA will remove the misapplied coating from the T-quenchers inside the Unit 2 suppression chamber prior to restart from the Cycle 7 refueling outage.
The misapplied coating will be removed from the Units 1 and 3 T-quenchers prior to their restart.
2.
Prior to restart from the Cycle 7 refueling outage, TVA will also sample other stainless steel components within the Unit 2 primary containment and take appropriate action to ensure that other similar unanalyzed coating conditions do not exist.
A similar review will also be performed on Units 1 and 3 prior to their restart.