ML20209B513

Suppls 860620 Response to Violations Noted in Insp Repts 50-259/86-09,50-260/86-09 & 50-296/86-09.Corrective Actions: Piping Penetrations Required by Fire Protection Program Will Be Inspected & Sealed by 870716

ML20209B513
Person / Time
Site:	Browns Ferry
Issue date:	01/29/1987
From:	Domer J TENNESSEE VALLEY AUTHORITY
To:	Grace J NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation
References
NUDOCS 8702040063
Download: ML20209B513 (4)

Text

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TENNESSEE VALLEY AUTHORITY CHATTANOOGA. TENNESSEE 374o1 SN 157B Lookout Place JAN 291987 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Office of Nuclear Reactor Regulation Washington, D.C. 20555 Attention: Dr. J. Nelson Crace In the Matter of the ) Docket Nos. 50-259 Tennessee Valley Authority ) 50-260 50-296 BROWNS FERRY NUCLEAR PLANT UNITS 1, 2, AND 3 - NRC OIE INSPECTION REPORT NOS. 50-259/86-09, 50-260/86-09, AND 50-296/86 SUPPLEMENTAL RESPONSE TO VIOLATION Our letter dated June 20, 1986 transmitted responses to violations in Inspection Report 86-09. During investigations to fully determine the scope of corrective actions on fire barrier pipe penetrations, it became apparent that many more penetrations will require sealing and the schedule will need to be extended. Enclosed is a revised response which reflects a new completion date consistent with the revised Appendix R schedule for Browns Ferry and provides clarified details on vendor performed work.

I TVA has contracted with a penetration seal vendor to provide more accurate and detailed drawings which will meet our needs for configuration upgrade in this area of fire stop penetrations, to analyze the existing seals, and to seal all penetrations which do not have acceptable seals. This increased scope of work will affect approximately 1,000 mechanical seals instead of the 492 seals originally planned for when we submitted our initial response.

The extension of the commitment completion date and submittal of this revised report was previously discussed between M. J. May and Joe Brady of Region II on December 30, 1986.

If you have any questions, please get in touch with M. J. May at (205) 729-3566.

To the best of my knowledge, I declare the statements contained herein are complete and true.

Very truly yours, TENNESSEE VALLEY AUTHORITY 8702040063 870129 */

PDR ADOCK 05000259

• G PDR J. A. Domer, Assistant Director Nuclear Safety and Licensing Enclosure cc: See Page 2 g\

l An Equal Opportunity Employer

U.S. Nuclear Regulatory Commission Jb4N 291987 cc (Enclosures):

Mr. G. E. Gears Browns Ferry Project Manager U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue Bethesda, Maryland 20814 Mr. G. G. Zech, Director TVA Projects U.S. Nuclear Regulatory Commission 101 Marietta St., NW, Suite 2900 Atlanta, Georgia 30323 Browns Ferry Resident Inspector Browns Ferry Nuclear Plant Route 2 P.O. Box 311 Athens, Alabama 35611

SUPPLEMENTAL RESPONSE TO NRC INSPECTION REPORT NOS. 50-259/86-09, 50-260/86-09, AND 50-296/86-09 DATED MAY 21, 1986 Item 2 Technical Specification Section 6.3.A.6 requires detailed written procedures covering surveillance and testing requirements to be prepared, approved, and adhered to. Technical Specification Section 4.11.E states that each required fire barrier penetration shall be verified to be functional at least once per 18 months by a visual inspection and by performance of a visual inspection of the affected fire barrier penetration prior to restoring a fire barrier to functional status following repairs or maintenance.

Contrary to the above, surveillance procedures have not been provided for the piping penetration of the required fire barriers. Surveillance inspections of these piping penetrations have not been made since this requirement was incorporated into the Technical Specifications on November 24, 1981. On November 22, 1985, the licensee discovered an open piping penetration in a fire barrier. Subsequently, the licensee hac identified a total of 190 piping fire barrier penetrations, of which 114 were found to be deficient. In general, these deficiencies involve a small annular space around piping penetrations that had not been properly sealed. These small open penetrations are considered to have only minor safety significance.

This is a Severity Level IV violation (Supplement I).

Original Response

1. Admission or Denial of the Alleged Violation i TVA admits to the violation as stated.

2. Reasons for the Violation t

The violation occurred because of a misinterpretation of the Technical Specifications (TS). The terminology used in TS-3.11.E, e.g., " ell fire barrier penetrations including cable penetration barriers, fire doors, and

! fire dampers . . ,, " led to an incorrect assumption that only the three

! specifically listed kinds of penetrations required surveillance.

3. Corrective Steps Which Have Been Taken and Results Achieved Until the design evaluation of fire barriers and correction of deficiencies has been c~ompleted, all fire barriers are being considered as nonfunctional. Fire detectors near penetrations in fire zone boundaries protecting safety-related areas have been verified to be operable and are being checked semiannually. A roving fire watch has been escablished to check the safety-related areas adjacent to fire zone boundaries hourly.

This fire watch has been in effect since December 16, 1985, when the fire i

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barriers were declared " inoperable." TVA's Division of Nuclear Engineering is designing or selecting acceptable fire-rated seals for all required fire barrier penetrations and coordinating the seal installation by and approved vendor. A surveillance instruction has been draf ted to include inspecting required piping penetrations when the fire barrier qualification has been completed, the penetrations properly sealed, and the roving fire watch is no longer required.

Revised Response

4. Corrective Steps Which Will Be Taken to Avoid Further Violations Piping penetrations required by the fire protection program will be inspected, sealed and other corrective actions performed as necessary to ensure the fire barriers are qualified. The work is being performed by a penetration seal vendor who will update and correct TVA drawings, analyze and correct as necessary existing seals, and seal any penetrations which do not presently have seals. The work, as performed by the vendor, will be reviewed and approved by TVA and will be used by TVA for acceptable completion of the surveillance instruction required for fire protection seals. The existing surveillance instruction will be revised and updated with information supplied by the vendor. TVA will perform this surveillance at the next required periodic inspection interval stated in technical specifications.

5. Date When Full Compliance Will Be Achieved Full compliance will be achieved by July 16, 1987.

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