ML20205M391
| ML20205M391 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 04/04/1986 |
| From: | Shell R TENNESSEE VALLEY AUTHORITY |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8604150211 | |
| Download: ML20205M391 (4) | |
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TENNESSEE VALLEY AUTHORITY SN 157B Lookout Place Y b?,] l AQ; GG April 4, 1986 U.S. Nuclear Regulatory Commission Region II ATTN:
Dr. J. Nelson Grace, Regional Administrator 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323
Dear Dr. Grace:
BROWNS FERRY NUCLEAR PLANT UNITS 1, 2, AND 3 - NRC-ole REGION II INSPECTION REPORT 50-259/86-05, 50-260/86-05, 50-296/86 RESPONSE TO VIOLATIONS Enclosed is our response to J. A. Olshinski's March 5, 1986 letter transmitting IE Inspection Report Nos. 50-259/86-05, 50-260/86-05, and 50-296/86-05 for our Browns Ferry Nuclear Plant. The transmitting letter requested an evaluation regarding Incorrect Design Specification Reference.
That evaluation is enclosed.
Regarding Unresolved Items 86-05-09 and 01, we are reviewing these items and will provide a response by April 17, 1986.
If you have any questions, please get in touch with R. E. Alsup at PTS 858-2725.
To the best of my knowledge, I declare the statements contained herein are complete and true.
Very truly yours, TENNESSEE V LLEY AUTHORITY R. H. Shell Nuclear Engineer Enclosure cc:
Mr. James Taylor, Director (Enclosure)
Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C.
20555 8604150211 860404
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PDR ADOCK 05000259 i
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An Equal Opportun:ty Employer
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RESPONSE
NRC INSPECTION REPORT NOS.
50-259/86-05, 50-260/86-05, AND 50-296/86-05 JOHN A. OLSHINSKI'S LETTER TO S. A. WHITE j
DATED MARCH 5, 1986 i
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On October 22, 1985, during a routine review of plant drawEng 730E927, Primary Containment Isolation, a copy of a document referenced on the drawing was requested from the licensee but could not be located. The document was a design specification, 22A1421, for the separation, isolation, and indenti-fication of engineered safeguards. The licensee's search for the document and discussions with General Electric representatives revealed that design specification 22A1421 was not applicable to Browns Ferry.
The correct specification was 22A2809.
Four design drawings were found to reference the incorrect specification and are listed below:
730E918 Engineered Safeguards 730E915 Reactor Protection System 730E930 Core Spray System 730E927 Primary Containment Isolation Although no Notice of Violation was issued with the subject report, an apparent violation of 10 CFR 50, Appendix B, Criterion III, failure to reference the correct design specification on design drawings, was identified. TVA was asked to provide NRC with an evaluation of the safety 4
significance of the differences noted between the correct design specification and incorrect design specification.
of this error was also requested.
~ An assessment of the generic implications TVA concurs that-four Browns Ferry Nuclear Plant design drawings referenced an incorrect design specification.
Reasons For the Violations The following chronological listing expl'ains the reason for the drawing error.
On July 19, 1968, General Electric issued generic separation criteria (draft 22A1421) for review.
On October 30, 1968, General Electric issued generic separation criteria 22A1421 revision 0 while TVA was still reviewing this draft specification.
TVA was never aware that this specification was issued.
On December 20, 1968, TVA returned their comments on the generic separation criteria (draft 22A1421) to General Electric to be resolved for Browns Ferry Nuclear Plant.
On May 7, 1969, General Electric issued Drawing 730E915-1 revision 0 for Browns Ferry with the general specification (22A1421) referenced.
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On June 5, 1969, General Electric issued Drawing 730E918-1 revision 0 for Browns Ferry with the generic specification (22A1421) referenced.
On August 18, 1969, General Electric submitted separation criteria 22A2809 revision 0 to TVA.
This criteria is a Browns Ferry unique separation criteria.
On September 22, 1969, General Electric issued Drawing 7310E927-1 revision 0 for Browns Ferry with the generic specification (22A1421) referenced.
on October 8, 1969, General Electric issued Drawing 730E930-1 revision 0 for
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Browns Ferry with the generic specification (22A1421) referenced.
I On March 25, 1970, TVA approved "with corrections noted" the TVA Browns Ferry unique separation criteria 22A2809 revision O.
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On October 19, 1970, General Electric submitted separation criteria 22A2809 revision 1 for review.
On December 1, 1970, TVA approved 22A2809 revision 1.
On June 9, 1972, General Electric submitted separation criteria 22A2809 revision 2 for review.
On September 25, 1972, TVA approved 22A2809 revision 2.
From this listing, it can be seen that General Electric issued separation criteria 22A1421 while TVA was still reviewing the draft specification and that the drawings in question were issued for Browns Ferry by General Electric referencing the generic separation specification (22A1421) during the same time period. In reviewing the drawings, TVA did not find the discrepr.ncy 1
because TVA reviewed just for interfaces, not for total content and design verification. Although TVA approved the Browns Ferry unique separation criteria and its revisions General Electric never revised their drawings to incorporate 22A2809 for Browns Ferry.
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Following discovery of this error, a reulew was undertaken to identify the differences between the design specifications and resolve the differences.
The conclusion is that each system affected by the differences in the incorrect referenced design specification 22A1421 revision 1 and the correct design specification 22A2809 revision 2 has been designed and installed consistent with the intent of design specification 22A2809 revision 2. _The integrity of separations requirements as applied to plant design has not been j
compcomised.
An engineering change notice will be written to correct the wrong design specification on the drawings identified, thus removing the potential for the wrong design specification being used in future design modifications. To
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i research this condition for its generic implications, TVA will review, as a sample, all of the conceptual drawings for the residual heat removal system including flow, elementary, and control diagrams to ensure that the design specifications identified from the drawings are the correct specifications for Browns Ferry Nuclear Plant.
Correction of the design specifications on the design drawings should be complete by June 1, 1986. The sampling program for generic implications should be complete by July 1, 1986.
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