ML20070B539

Submits follow-up to 940614 Enforcement Conference Re Violation for Failure to Take Time C/A to Address Use of Unqualified Coating on Unit 2 T-quenchers

ML20070B539
Person / Time
Site:	Browns Ferry
Issue date:	06/20/1994
From:	Salas P TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9406300210
Download: ML20070B539 (5)

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1 Termenee VaHe y AuthoMy Post 0+i>;e Box 2000 DecaNr A absma 3%D9 JUN 2 01994 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Gentlemen:

t In the Matter of ) Docket No. 50-260 Tennessee Valley Authority )

BROWNS FERRY NUCLEAR PLANT (BFN) - FOLLOW-UP TO ENFORCEMENT CONFERENCE REGARDING T-QUENCHER COATING On June 14, 1994, TVA and NRC met to discuss an apparent violation for failure to take timely corrective action to address the use of an unqualified coating on the Unit 2 T-quenchers. During this meeting, NRC requested that TVA review a December 23, 1991 letter to TVA from United States Senator Jim Sasser (Reference 1) in order to determine whether this letter constituted an opportunity to identify the coatings on the BFN T-quenchers. TVA has reviewed this t letter and determined that it did not constitute a reasonable opportunity to identify the misapplication of a carbon steel qualified coating system on the stainless steel BFN T-quenchers.

The December 10, 1991 letter, from Mr. Lanson R. Rogers to the Honorable Jim Sasser, which is an enclosure to Reference 1, does not identify any specific concerns with coating at BFN. Rather, Mr. Rogers' letter criticizes an American Society for Testing and Materials (ASTM) coatings committee, promotes his in-situ paint testing technology, and advocates the use of commercial grade paints in safety-related applications. Mr. Rogers then goes on to make

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U.S. Nuclear Regulatory Commission Page 2 JUN y u 1994 a general allegation that Browns Ferry was, to some degree, in violation of its own safety requirements for Level l coatings as specified in the BFN Final Safety Analysis Report (FSAR).

In order to place Mr. Rogers' letter in the proper context, it is necessary to understand the nature and type of coating initiatives that had been accomplished at BEN over the past several years. In November 1981, TVA developed a construction specificaticn for the application of a suppression chamber protective coating. A contract was '

issued in March 1983 to refurbish the coatings on the internal surface of the suppression chamber and associated components. An additional contract was issued in November 1985 to refurbish the coating in the Unit 2 drywell and vent header. These contracts were implemented on Unit 2 during the early stages of the Cycle 5 outage, which started in September 1984.

In the 1988 timeframe, when Mr. Rogers left TVA, TVA's focus had narrowed to address the coating on certain purchased components installed within primary containment. As stated in Section III.14.3 of the Browns Ferry Nuclear Performance Plan (Reference 2), the FSAR commitment to utilize coatings qualified to the requirements of the American National Standards Institute were considered to be met for the inside primary containment surface. In order to address the purchased components coating issue, TVA was implementing a program to identify, quantify, and evaluate these coatings.

The results of this program were provided to NRC in October 1989 (Reference 3). NRC approved this program in January 1991, as documented in Reference 4.

At the time of Mr. Rogers' December 10, 1991 letter, TVA had already refurbished the coatings on the inner surface of the primary containment and the components within the suppression chamber. The unqualified coating on purchased components had been identified, quantified, and evaluated. TVA had performed pre-operational reviews of the primary containment and associated systems and had returned Unit 2 to service. L

U.S. Nuclear Regulatory Commission Page 3 JUN y U 199; Therefore, in February 1992, when TVA replied to the letter from the Honorable Jim Sasser (Reference 5), TVA had considered the best information available to it at the time and concluded that no safety concerns existed with protective coatings at BEN.

In summary, Mr. Rogers' letter express no specific concerns with regards to the improper use of unqualified coatings, and certainly gave no indication of concern about the coating of surfaces that should have remained uncoated. TVA was aware of various coating issues at BFN during the 1980's timeframe i and TVA took extensive corrective actions to resolve these concerns. In view of the above, TVA does not consider Mr. Rogers' letter to contain any significant information  !

which would have provided a reasonable opportunity to specifically identify the T-quencher coating issue.

l There are no commitments contained in this letter. If you I have any questions, please telephone me at (205) 729-2636.

Sincerely D'

x Pe ro Salas .

Manager of Site Licensing cc: see page 5

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References:

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1. Letter from the Honorable Jim Sasser, United States l Senator, to TVA, dated December 23, 1991, in regards to correspondence from Lanson R. Rogers, President of Coatings and Testing Corporation

2. TVA letter to NRC, dated October 24, 1988, Browns Ferry j Nuclear Plant (B EN) - Nuclear performance Plan, i Revision 2 l

3. TVA letter to NRC, dated October 4, 1989, Containment l Coatings

4. NRC letter to TVA, dated January 23, 1991, NUREG-1232, Volume 3, Supplement 2 - Browns Ferry, Unit 2

[Section 3.7]

5. Letter from TVA to the Honorable Jim Sasser, United 1 States Senator, dated February 11, 1992, in regards to correspondence from Lanson R. Rogers, President of Coatings and Testing Corporation l

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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 Rockville, Maryland 20852