ML20210D928
| ML20210D928 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 01/26/1987 |
| From: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | White S TENNESSEE VALLEY AUTHORITY |
| References | |
| NUDOCS 8702100193 | |
| Download: ML20210D928 (4) | |
See also: IR 05000259/1986025
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JAN261987
Tennessee Valley Authority
ATTN: Mr. S. A. White
Manager of Nuclear Power
6N 38A Lookout Place
1101 Market Street
Chattanooga, TN 37402-2801
Gentlemen:
SUBJECT: REPORT NOS. 50-259/86-25, 50-260/86-25, AND 50-296/86-25
Thank you for your response of October 16, 1986, to our Notice of Violation
issued on September 11, 1986, concerning activities conducted at your Browns
Ferry facility.
We have evaluated your response and found that it meets the
requirements of 10 CFR 2.201.
We will examine the implementation of your
corrective actions to correct Violations 1 and 2.b., during future inspections.
After careful consideration of the basis for your denial of Violation 2.c.,
we agree with your position from the view point of Quality Assurance records
retrieval problem only.
The subject equipment was installed prior to
10 CFR Part 50, Appendix B becoming effective and consequently some of the
component installation details are not retrievable.
However, you have not
adequately demonstrated in your response that the actual as-built equipment
configuration is seismically qualified.
Our reasons are presented in the
enclosure to the letter.
Therefore, please submit a supplemental response to
this office within 30 days of the date of this letter.
Also, clarification and a supplemental response is required to your reply to
Violation 2.a.
For corrective action, you have stated that the Fire Protection
Group is initiating a procedure to perform special air testing at selective
locations on all critical structures, systems, and components preaction sprinkler
systems to verify open flow paths.
Further, this test will verify flow through
selected header sections and their associated branch lines.
However, the
Licensee Event Report 50-296/86006 covering information on the same subject
states that a 30 percent random sample of branch lines of the preaction sprinkler
systems was verified for open flow path.
The LER provides a quantitative
response and it is not clear to us if it is consistent with the former informa-
tion.
Please provide clarification.
In addition, provide justification for not
performing a 100 percent inspection of the preactive sprinklers.
If a certain
sample size was indeed selected for inspection, then provide the basis for its
selection and why it was considered adequate to insure no flow blockage.
You
are requested to respond to this item within 30 days of the date of this letter.
The response directed by this letter is not subject to the ciearance procedure
of the Office of Management and Budget issued under the Paperwork Reduction Act,
PL 96-511.
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JAN261987
We appreciate your cooperation in this matter.
Sincerely,
J. Nelson Grace
Regional Administrator
Enclosure:
Staff Comments on Denial
of Violation 2
cc w/ enc 1:
H. P. Pomrehn, Site Director
Browns Ferry Nuclear Plant
R. L. Lewis, Plant Manager
R. L. Gridley, Director
Nuclear Safety and Licensing
R. W. Cantrell, Acting Director
Nuclear Engineering
M. J. May, Site Licensing Manager
bec w/ enc 1:
J. N. Grace, RII
H. R. Denton, NRR
H. L. Thompson, NRR
J. M. Taylor, IE
B. B. Hayes, 01
S. R. Connelly, 01A
G. E. Gears, NRR
M. Grotenhuis, NRR
K. P. Barr, RII
NRC Resident Inspector
Document Control Desk
State of Alabama
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ENCLOSURE
STAFF COMMENTS ON DENIAL OF VIOLATION 2.c
TVA's response to the violation concerning lack of documented instruction,
procedure, or drawing which prescribes the anchoring details of the control room
emergency ventilation system (CREVS) filter train and blower assembly was
evaluated.
The primary reason for this violation was the inspector's concern to
detemine whether or not the CREV filter train and blower assembly was properly
installed to withstand the effects of seismic conditions.
As mentioned in the
NRC Inspection Report Nos.60-259, 260, 296/86-25, the CREV Train B unit is
mourted differently than the CREV Train A unit and it appears to be improperly
mounted.
This was the reason for the request of CREV installation drawings
specifying correct anchoring details.
TVA was unable to retrieve the QA records for CREV installation.
TVA's reason
for this is that 10 CFR Part 50, Appendix B came into being after some of the
components of Browns Ferry facility were already installed, and TVA took excep-
tion to Appendix B criteria IV, XVII, and XVIII as stated in a response to AEC
question D.3, detailed in the FSAR, Amendment 31.
While we agree with TVA's
position on the QA documentation issue we do not have the assurance nor accept
TVA's current response in demonstrating the CREV unit's ' ability to maintain
integrity during and after a seismic event.
In the early AEC questioning period, TVA's response to an AEC question was as
follows:
"The systems have been designed, fabricated and erected to the same codes,
standards, criteria and practices that would have otherwise been required
except that QA documentation is not available."
Furthermore, TVA has stated in the FSAR (Chapter 10.12) that the CREV units
(Emergency Pressurization System per the FSAR) are seismically qualified.
With regard to the seismic question, the licensee used their Division of Nuclear
Engineering (DNE) for support in determining the CREV units seismic qualifica-
tion. The NRC obtained a copy of the DNE evaluation and learned that the evalua-
tion process is generic and intended to apply to all electrical equipment. The
evaluation methodology is judged to be unacceptable because it had been shown to
be faulty over the last several years.
For example, the equipment evaluated by
TVA in 1981-1982, and judged to be acceptable, has been found to be unacceptable
in 1985 and 1986.
This includes battery racks, control room panels, RPS
instrument racks, and hydraulic control unit.
These findings compromised the
validity of conclusions drawn from the TVA activities associated with IE Notice
(IEN) 80-21, Anchorage and Support of Safety-Related Electrical Equipment.
Furthermore, DNE's use of the Seismic Qualification Utilities Group (SQUG) report
related to the NRC's resolution of Unresolved Safety Issue A-46 concerning
seismic qualification of equipment is not fully appropriate to this case.
The
referenced 50VG/A-46 report is too general and it provides no infomation or
. . .
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Enclosure-
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specific guidelines on acceptable anchoring of components such as the CREV units,
even on another component similarity basis.
In sumary, TVA's DNE evaluation does not directly address the adequacy of the
CREV units anchoring configuration and provides no assurance that the as-built
anchoring configuration can withstand the effects of seismic conditions.