ML20082J990
| ML20082J990 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 04/13/1995 |
| From: | Machon R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9504190029 | |
| Download: ML20082J990 (5) | |
Text
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i IUA Tennessee Valley Authority, Post Office Box 2000 Decatur, Alebama 35609 l
April 13, 1995 U.
S. Nuclear Regulatory Commission 10 CFR 2 ATTN: Document Control Desk Appendix C Washington, D.C.
20555 Gentleman:
In the Matter of
)
Docket Nos.
50-259 i
l Tennessee Valley Authority
)
50-260 50-296 l
BROWNS FERRY NUCLEAR PLANT (BFN) - NRC INSPECTION REPORT 50-259, 260, 296/94 REPLY TO NOTICE OF VIOLATION (NOV)
This letter provides our reply to a NOV transmitted by letter from C.
A. Casto, NRC, to O.
D. Kingsley Jr., TVA, dated March 16, 1995.
The NOV concerns cables that were left bundled on top of the Flamemastic coating contrary to the procedural requirements.
The enclosure contains our reply to the NOV.
This letter contains no new commitments.
If you have any questions regarding this reply, please contact Pedro Salas at (205) 729-2636.
Sincerely,
/
l R.
D. Mac Site Vic resident Enclosures cc: See Page 2 l
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6 U.
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Nuclear Regulatory Commission Page 2 i
April 13 -1995 Enclosures cc (Enclosures):
E. V. Imbro, NRR/RSIB U.
S.
Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike I
Rockville, Maryland 20852 E. J.
Leeds, NRR/DRPW U. S. Nuclear Regulatory Commission One White Flint, North.
11555 Rockville Pike Rockville, Maryland 20852 Mr. Mark S.
Lesser, Acting Branch 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 l
One White Flint, North 11555 Rockville Pike Rockville, Md 20852 l
i i
J
i ENCLOSURE TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT UNITS 1, 2,
AND 3 l
l REPLY TO NOTICE OF VIOLATION INSPECTION REPORT NUMBER 50-259, 260, 296/94-35 RESTATEMENT OF VIOLATION During an NRC inspection conducted on February 13 - 17, 1995, a violation of NRC requirements was identified.
In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the violation is listed below:
Technical Specification 6.8.1-requires, in part, that written procedures be established, implemented and maintained for activities recommended in Appendix A of j
Regulatory Guide 1.33, Quality Assurance Plogram j
Requirements, Revision 2, February 1978.
Modification and Addition Instruction 3.2, Cable Pulling for Insulated Cables Rated Up to 15,000 Volts, requires low voltage cable (0-600V) installed in trays on top of Flamemastic to be spaced and not tied together to allow heat surface transfer.
Contrary to the above, on February 14, 1995, during a walkdown of the Unit 3 cable spreading room, cables were observed in tray FZ-II bundled and tied together with no spacing on top of the Flamemastic.
This is a severity Level IV violation (Supplement I).
TVA's REPLY TO VIOLATION 1
1.
Backaround The involved cables were installed by work plan (WP) 0192-90 for Design Change Notice W6852A.
This WP rerouted and replaced portions of five cables associated with a 480V control bay vent board.
This work was performed in August 1990 as part of the Unit 2' recovery activities.
l During the installation of these cables, a Quality Control (QC) inspector identified damaged insulation on one of the cables.
The cable installation was stopped, and the damaged l
cable was determined to be acceptable for installation, i
l t
L 1
]
i I
4 Subsequently, in order to facilitate installation, the J
cables were taped together into a single bundle and the cable 1with the apparent insulation damage was placed in the center of the bundle.
This was done to minimize the potential for further damage to the cable insulation.
After pulling the bundle through the conduit, the cables were then routed into cable tray FZ-II and were left unbundled in a single layer on top of the Flamemastic in the cable tray.
This was verified by the QC inspector.
Following the installation in August 1990, for undeterminate
]
reasons, these cables were again bundled together on topfof j
the Flamemastic layer using tie wraps.
At the time of this cable installation, the applicable requirements for cables installed in cable trays on top of Flamemastic were specified in Revision 7 of Modification and-Addition Instruction (MAI)-3.2.
This revision of the MAI included requirements similar to those existing in the current revision.
2.
Reason for the Violation As discussed above, the cables were initially taped together' to facilitate installation.
The QC inspector involved in the 1990 installation was interviewed regarding this event.
The inspector stated that he verified that the cables were separated in a single layer on top of the Flamemastic before he signed the QC holdpoint for cable separation and spacing.
Since August 1990, there have been no other documented cable pulling or installation activities involving cable tray l
FZ-II.
Thus, the reason for the "as found" condition of the cables (i.e., the cables were found to be bundled together l
with tie wraps) cannot be positively determined.
- However, since the revision of MAI-3.2 that was in effect at the time of this event required cables placed on top of Flamemastic to be spaced, this violation involved a failure to properly implement procedural requirements.
i 3.
Corrective Stens Taken and the Results Achieved The cables specified in the violation were unbundled and spaced in the tray in accordance with the requirements of l
MAI-3.2.
4.
Corrective Steps That thave been or1 Will be Taken to l
Prevent Recurrence l
As noted above, TVA's investigation of this event could not determine why the cables were bundled together with tie l
wraps.
TVA's investigation did determine that appropriate personnel are knowledgeable of the requirements of MAI-3.2 with respect to installing cable in trays on top of Flamemastic.
Accordingly, at this time, TVA considers that E-2 i
,i
.o no further corrective actions are necessary to prevent recurrence.
To determine the magnitude of this event, TVA will review other modifications in Units 2 and 3 which installed cables in trays on top of Flamemastic.
TVA will then perform walkdowns to determine if any of these cables are bundled.
l Any discrepancies identified will be appropriately evaluated and addressed.8 5.
Date When Full Compliance Will be Achieved Full compliance concerning the circumstances described in this violation has been achieved.
The actions to prevent recurrence are expected to be completed by July 4, 1995.
I TVA does not consider these actions to be Regulatory commitments.
The above actions are not necessary to preserve compliance with obligations.
They are measures to determine the extent of condition.
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