ML20148Q710
| ML20148Q710 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 04/08/1988 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8804130246 | |
| Download: ML20148Q710 (6) | |
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TENNESSEE VALLEY AUTHORITY CHATTANOOGA. TENNESSEE 37401 5N 157B Lookout Place APR 081988 J
U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Hashington, D.C.
20555 Gentlemen:
In the Matter of
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Docket Nos. 50-259 Tennessee Valley Authority
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50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN) - UNITS 1, 2, AND 3 - NRC INSPECTION REPORT NOS. 50-259/87-46, 50-260/87-46, AND 50-296/87-46, - RESPONSF TO NOTICE OF VIOLATION This letter provides TVA's response to your letter from K. P. Barr to S. A. White dated February 26, 1988, which transnitted tne subject report.
The report cited TVA with a violation of technical specifications. prcvides TVA's response to the violation. orovides a list of commitments. An extension to the due date for this response to April 10, 1988, was agreed to by A. Ignatonis of your staff on April 1, 1988.
If you have any questions, please telephone Carroll McFall at (205) 729-2046.
Very truly yours, TENNESSEE LLEY AUTHORITY 1
R. Gridley, 1 rector Nuclear Licensing and
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Regulatory Affairs Enclosures cc: See page 2 8804130246 880408 0
PDR ADOCK 05000259
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An Equal ooportunity Employer
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- U.S. Nucidar Regulatory Commission
/lPil 081988 cc (Enclosures):
Mr. G. G. Zech, Assistant Director for Projects TVA Projects Division U.S. Nuclear Regulatory Commission f
One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Mr. K. P. Barr, Acting Assistant Director for Inspection Programs TVA Projects Division U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Browns Ferry Resident Inspector Browns Ferry Nuclear Plant Route 12, P.O. Box 637 Athens, Alabama 35611 l
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ENCLOSURE 1
RESPONSE
NRC INSPECTION REPORT NOS. 50-259/87-46, 50-260/87-46, AND 50-296/87-46 LETTER FROM K. P. BARR TO S. A. WHITE DATED FEBRUARY 26, 1988 Violation Technical specification (TS) 4.7.B.2.a recuires that halogenated hydro-carbon (freon) removal efficiency of the standby gas treatment system (SGTS) be demonstrated to be greater than or equal to 99% by the test methods of the American National Standards Institute (ANSI) N510-1975 following significant painting, fire or chemical release in a zone communicating with the system.
Contrary to the above, the test performed on SGTS train 8 November 25, 1987, to satisfy this requirement following a fire in the unit 2 drywell did not comply with ANSI N510-1975 in the following examples:
Example 1 The freon gas generator output was not held to 2 20% of the preset value as specified in step 12.4.3 of AGSI N510-1975.
1.
Admission or Denial of the Alleged Violation TVA admits this example of the violation.
2.
Reasons For the Violations A review of past revisions to technical instruction 178 which implemented the technical specification 4.7.8.2.a testing requirements revealed that the requirement to maintain the freon gas generator output to within
+ 20 percent of the preset value was erroneously deleted in 1985.
3.
Corrective Steps Which Have Been Taken and Results Achieved SGTS system train B was declared inoperable on December 7, 1987.
Technical instruction 178 was revised to require that the freon gas generator output be maintained within i 20 percent of the preset value. A retest of train B was started on December 8 and completed on December 10, 1987.
Test results indicated satisfactory filter installation.
A review of the procedures for testing high efficiency particulate air (HEPA) and charcoal filters was performed to ensure all ANSI N510-1975 requirements are being satisfied.
It was determined from this reviev that minor procedural changes are necessary to better document compliance with the ANSI N510-1975 requirements.
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Corrective Steps Which Hill Be Taken to Avoid Further Violations TVA management has alr0ady recognized that there is a generic problem with deficient surveillance instructions. A surveillance instruction upgrade program is currently underway at 8FN as described in the TVA Nuclear Performance Plan Volume 3, Section 2.5.0.
The upgraded sur.'e111ance instructions for HEPA ar.d charcoal filter testing will be issued under that program by June 17, 1988. As part of the upgrade, technical instruction 17B will be incorporated into the surveillance instructions along with the minor procedural changes necessary to better document compliance with ANSI N510-1975.
5.
Date When Full Compliance Will Be Achieved June 17, 1988 2
Exampic 2 The upstream concentration of freon tracer gas was not limited to 20 ppm as specified in step 12.4.3 of ANSI N510-1975.
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Admission or Denial of the Alleged Violation TVA admits this example of tha violation.
2.
Reasons For the Violation A review of past revisions to technical instruction 17B which implemented the technical specification 4.7.8.2.a testing requirements revealed that the recommendation to maintain the upstream concentration of freon tracer gas to no more than 20 ppm was erroneously deleted in 1985.
3.
Corrective Steps Which_Have Been Taken and Results Achieved Technical instruction 17B was revised to add the recommendation to C
maintain the upstream concentration of freon tracer gas to no more than 20 ppm.
i When compliance with the requirements of ANSI N510-1975 was questioned following the November 25, 1987 testing, the test equipment vendor was contacted for clarification. He stated that the recommendation in ANSI N510-1975, paragraph 12.4.3 was based on the limitations of test equipment at that time.
Gas chromatographs were used to measure tracer gas breakthrough in the 1975 timeframe.
Upstream and downstream tracer gas concentrations could not be taken simultaneously.
If an upstream concentration of greater than 20 ppm was used, it could cause tracer gas breakthrough to occur too quickly so that the downstream concentration could not be accurately determined.
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The halide detectors now in use, however, read upstream and downstream concentrations simultaneously.
The accuracy of downstream readings is no longer dependent on upstream concentrations within the limitation of the detectors.
4.
Corrective Steps Which Will Be Taken to Avoid Further Violations For the reasons stated above, on future tests the 20 ppm upstream concentration limitation will be considered as a recommendation which can only be exceeded with the approval of the cognizant plant engineer responsible for performance and review of this SI.
The upgraded surveillance instructions for HEPA and charcoal filter testing, which will be issued by June 17, 1988, will clarify the allowable upstream concentration of freon tracer gas in order to prevent confusion over this matter in the future.
5.
Date When Full Compliance Will Be Achieved June 17, 1988 1
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ENCLOSURE 2 NRC INSPECTION REPORT NOS. 50-259/87-46, 50-260/87-46, AND 50-296/87-46 LETTER FROM K. P. BARR TO S. A. WHITE DATED FEBRUARY 26, 1988 LIST OF COMMITMENTS 1.
Technical instruction 178 was revised to require that the freon gas generator output be maintained within 2 20 percent of the preset value and to add the recommendation to maintain upstream tracer gas concentration to no more than 20 ppm.
2.
The upgraded surveillance instructions for HEPA and charcoal filter testing will be issued by June 17, 1988. As part of this upgrade, technical instruction 178 will be incorporated into the survelliance instructions, minor procedural changes necessary to better document compliance with ANSI N510-1975 will be made, and the allowable upstream concentration of freon tracer gas will be clarified.
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