ML20151H982
| ML20151H982 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 04/13/1988 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8804210023 | |
| Download: ML20151H982 (7) | |
Text
_ _ _ _ _ _ _ _ _ _ _.. _ _ ___
TENNESSEE VALLEY AUTHORITY CH ATTANOOGA. TENNESSEE 37401 5N 157B Lookout Place APR 131988 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington 0.C.
20555 Gentlemen:
In the Matter of
)
Docket Nos. 50-259 Tennessee Valley Authority
)
50-260
)
50-296 BROWNS FERRY NUCLEAR PLANT (BFN) UNITS 1, 2, AND 3 - NRC INSPECTION REPORT NOS. 50-259/87-33, 50-260/87-33, AND 50-296/87 SUPPLEMENTAL RESPONSE TO NOTICE OF VIOLATION This letter provides a supplemental response to violation B (conduit sealing) which was forwarded in your letter from G. G. Zech to S. A. White dated November 19, 1987, and transmitted the subject inspection report.
TVA's original response was provided in a letter from M. J. Ray dated January 11, 1988, and committed to having the corrective actions for violation B completed by April 1, 1988. There has since been an increase in the scope of this item because of other conduits found unsealed in fire protection spray areas.
This change in scope will require the date of full compliance to be moved to October 7, 1988. provides background information and TVA's revised response to violation B.
A list of commitments is provided in enclosure 2. An extension of the response due date until April 8, 1988, was agreed to by B. Little in a telephone call on April 1, 1988.
If you have any questions, please telephone Clark J. Madden (205) 729-2049.
Very truly yours, TENNES EE EY AUTHORITY l'
R. Gridley, D ctor Nuclear Licensing and Regulatory Affairs Enclosures cc: See page 2 fgO f
\\
$$$42ggggj$$$
g, i
O An Equal Opportunity Employer J
o U.S. Nuclear Regulatory Commission g{g$$@
cc (Enclosure):
Mr. G. G. Zech, Assistant Olrector for Projects TVA Projects Division U.S. Nuclear Regulatory Connission-One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Mr. K. P. Barr, Acting Assistant Olrector for Inspection Programs TVA Projects Olvision U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Browns Ferry Residen; Inspector Browns Ferry Nuclear Plant Route 12, Box 637 Athens, Alabama 35611 d
I i
ENCLOSURE 1
RESPONSE
NRC INSPECTION REPORT NOS.
50-259/87-33, 50-260/87-33, AND 50-296/87-33 LETTER FRON G. G. ZECH TO S. A. WHITE DATED NOVEMBER 19, 1987 Violation B 10 CFR 50, Appendix B, Criterion V requires that activities affecting quality shall be accomplished in accordance with plant drawings.
Plant drawing 45B891-1 provides information on electrical conduit sealing and note four of the drawing specifies sealing around cables inside condults to keep water from entering electrical termination compartments.
Contrary to the above, this requirement was not met for the sealing of electrical conduit as required by plant drawing 458891-1. After an inadvertent initiation of the fixed spray fire protection system on August 31, 1987, two of the scram discharge instrument volume instruments (3-LE-85-45J and 3-LE-85-45L) were found full of water.
The conduit leading to the instruments was not sealed at the conduit opening leading from the respective cable tray. Conduit sealing problems were identified during a previous initiation of the fixed spray system as detailed in inspection report 86-16.
This is a Severity Level IV Violation (Supplement I).
l 1.
Admission or Denial of the Violation TVA admits the violation.
Revised Response 2.
Reason for the Violation Drawing 45B891-1 shows typical details for waterproofing and sealing of electrical equipment.
Note No. 1 on this drawing indicates that the details are to be utilized for electrical equipment defined in Appendix D of a Civil Engineering Branch (CEB) report detailing postulated pipe failure events outside containment.
Waterproofing of electrical condults around fire protection spray areas falls outside the scope of this report. The current engineering drawings do not require conduits to be l
sealed that are not included in this CEB report. The cond9tt in question l
was not included in the report findings.
Therefore, this ccndition is indicative of an engineering and not a plant modification problem.
3.
Corrective Steps Which Have Been Taken and Results Achieved After the inadvertent initiation of the fixed spray fire protection system on August 31, 1987, Maintenance Request (MR) 753469 was issued to reseal junction boxes and panels in the area of the fire protection spray.
The only conduit found not sealed was 35G-2064. A preliminary review and
fleid walkdown of some additional field installations revealed other conduits in Fire Protection spray arens as not being sealed. A Condition Adverse to Quality Report (CAQR) was written to track the resolution of the issue.
This violation and related CAQR have been discussed with design engineers and installation engineers.
4.
Corrective Steps Which Will be Taken to Avoid Further Violations TVA Engineering is currently evaluating the CAQR and will provide an assessment of any additional conduits which need moisture intrusion seals.
The open head deluge type fire protection valves will be removed or replaced before restart on unit 2 in association with Appendix R modifications.
Following completion of the engineering evaluation, drawing notes specifying conduits to be sealed to prevent moisture intrusion will be revised. A field walkdown will be performed as needed to identify additional conduits requiring sealing to prevent moisture intrusion.
Those conduits found not to be sealed in accordance with the revised drawing requirements will be sealed to bring them into conformance with the drawing requirements.
5.
Date When Full Compliance Will Be Achieved October 7, 1988, for unit 2.
The CAQ will also be dispositioned for units 1 and 3 before startup of those units.
[
l l
ENCLOSURE 2 NRC INSPECTION REPORT NOS.
50-259/87-33, 50-260/87-33, AND 50-296/87-33 LETTER FROM G. G. ZECH TO S. A. 1:HITE DATED NOVEMBER 19, 1987 LIST OF COMMITMENTS Violation B 1.
TVA engineering is currently evaluating the~CAQR and will provide an assessment of any additional condults which need moisture intrusion seals by June.I', 1988.
0 2.
The open head deluge-type fire protection valves will be removed or replaced before restart on unit 2 in association with Appendix R modifications.
3.
Following completion of.the engineering evaluation, drawing notes specifying conduits to be sealed to prevent moisture intrusion will be revised and issued by June 10, 1988.
4.
A field walkdown will be performed as needed to identify additional conduit requiring sealing by July 8, 1988.
5.
Those conduits found not to be sealed in accordance with the revised i
drawing requirements will be sealed to bring them into conformance with the drawing requirements. The full date of compliance will be October 7, 1988.
6.
The CAQ for Unit I will be dispositioned and corrected before its startup.
7.
The CAQ for unit 3 will be dispositioned and corrected before its startup.
i
s i.
s s3 l:e!!Gd.as a
a i
5 n
!!d Tr il
)
1.R
- s a
a
.hjp 3
a R
ieisl-l,l*i
=
1 c,a lg=
m_
.u s
abQ' mx s
t 0 - 4 I
1 ir g
m W-gi l
e er
@.._ g<a e
i 5
i- - - - - - - -o- -o s m
M 0
, 4 - -. -,
na el a
o i
i i
3 i
P g
i i
l.
g ls allll*
Ig g-e' i,"
5 g6 ggj E.
l %
j ll6e s
l l
l
'o; b.ii 45
---ca i lge i
l e
i e
o - -6 e x
Ice
.e-i i
,o n e
o ll4e e "
l l
6e D
. _l i-i - - -<5 el
" 9e i
o i
n i
i e ti el n.,y,
!- f !!v.6e 1 54 a,
l goe l
1.
f, gji i
g_
a 8
8 c5 5
l I
8
!!@lesu(eiM" ex#"
i g
w 3
E
~
!l4s,",< lglocSe !das i
m~
i r
i eg
't l
l 4e l
l !! l l
o.g
!g l""
onlny3-4e i
i i
i 9
'E lE oas as s-lg0 3
. g!4s '!
- 90t 58 g>
af
~
"5 5,S
~
, ng e
m, oc hg E
IS
?
bh5 ch0 hh$
lo si g ten su ep s ni e
e o
e p
i Bea ae=
gpc g 8a*
n en s
~
FIRE PROTECTION MAINTENANCE REQUESTS i
600--
1 TOTAL FIRE PROTECTION MR's (26 & 39) o FORECAST (P1ANNED MRs) g e
e ACTUA1 TO DATE soo--
S'..
x' 455 4.428 6
400--
O FORECAST (PLANNED MRs)
U2 S/U REQUIRED MR's (26 & 39)
E ACTUAL TO DATE 0:
..~ ~.
L11 m
NEW MR's
-8
- - 300 --
2
- O
'N.,
'X' STATUS (26) - 69
~ ~.,
'H' STATUS (26) - 74 Z
226
'M' STATUS (26) - 45
~ ~.
a
'N' STATUS (39) - 3 1
g, '
~.
'M' STATUS (39) - N/A 200--
.~ ~.
.~..~~..
i 100--
8/8 APPENDIX R WALKDOWN
.,"I'=P O
MAR 2 MAR 11 MAR 17 APR MAY JUN -- JUL AUG SEP OCT NOV y TUP DATE Data Date 3/17/88 i
i m
.