ML20215G921

Responds to NRC Re Deviations Noted in Insp Repts 50-259/87-02,50-260/87-02 & 50-296/87-02.Corrective Actions: Administrative Procedures in Effect Which Do Not Allow Use of New Fuel Storage Vaults

ML20215G921
Person / Time
Site:	Browns Ferry
Issue date:	06/12/1987
From:	Domer J TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NUDOCS 8706230440
Download: ML20215G921 (6)

Text

.e TENNESSEE VALLEY AUTHORITY CH ATTANOOGA. TENNESSEE 374o1 SN 157B Lookout Place JUN 121987

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.U.S. Nuclear Regulatory Commission ATTN: Document Control' Desk Washington, D.C. 20555 Gentlemen:

In the Matter of ) Docket Nus. 50-259 Tennessee Valley Authority ) 50-260 50-296 BROWNS FERRY NUCLEAR PLANT UNITS 1, 2. AND 3 - NRC OIE INSPECTION REPORT NOS.

50-259/87-02, 50-260/87-02, AND 50-296/87-02 RESPONSE TO DEVIATION Enclosed is TVA's. response to the letter from G. G. Zech to S. A. White dated April 17, 1987, which transmitted IE Inspection Report Nos. 50-259/87-02, 50-260/87-02, and 50-296/37-02 for TVA's Browns Ferry Nuclear Plant unit.s 1, 2, and 3. This report cited TVA with two deviations. A list of commitments is provided in enclosure 2. An extenslon of the response due date till June 15, 1987 was. agreed to by A. Ignatonis.

c Please refer any questions to M. J. May, Manager of Site Licensing,-Browns Ferry Nuclear Plant, (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

)J.A.Domer,AssistantDirector Nuclear Safety and Licensing Enclosures ec: . See page 2 8706230440 870612 PDR ADOCK 05000259 An Equal Opportunity Employer

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. U.S. Nuclear Regulatory Commission n*

cc (Enclosures):

Mr. G . 'J . Zech, Assistant Director

-Reglunst Inspections Division of TVAt Projects Office'of_Special' Projects-U.S._ Nuclear Regulatory Commission Region II 101 Marietta St.,;NW,_ Suite 2900 Atlanta, Georgia 30323 Browns Ferry Resident Inspector Browns Ferry Nuclear Plant P.O. Box'311-Athens Alabama! 35611 3>.

[/*[: \ l Mr'. J. A. Zwolinski, Assistant Director L for Projects Division of TVA Projects

.' .f, Office of Special Projortu il > ') / U.S. Nuclear Regulatori *ct.af t;. ion 4350 East. West' Highway ~

EWW 322-Bethesda, Maryland 20814

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ENCLOSURE 1

RESPONSE

NRC INSPECTION REPORT NOS.

50-259/87-02, 50-260/87-02, AND 50-296/87-02 LETTER FROM C. G. ZECH TO S. A. WHITE l DATED APRIL 17, 1987 ]

l Deviation A Final Safety Analysis Report Section 10.11, Fire Protection Systems states that each unit battery room and battery board room contain drains and curbs. l These are provided to remove a minimum of 100% flow, assuming all sprinkler '

heads in one room are open and 200 gpm is being provided by hand hoses. The drains and curbs were also to be installed for preventing personnel hazard and damage to safety equipment due to battery acid spillage.

Contrary to the above, this requirement was not met in that none of the rooms have curbs installed. Units 1 and 3 battery boaed rooms do not contain drains. The engineering change notice (L-1978) that installed the drains and curbs was complated in 1978. On December 25, 1986, expandable plugs were placed in all of the rooms which do contain drains pending resolution of a possible Secondary Containment breach due to a common drain header with the reactor building floor drains.

This deviation is applicable to all three units.

1. Corrective Steps Which Have Been Taken and Results Achieved TVA's design organization reviewed this problem and analyzed the water flow into and out of the room from the fire protection systems which are in place. This review concluded that the' curbs are needed to prevent water from flooding rooms adjacent to the battery and battery board rooms.

However, TVA takes exception to the floor drains not being provided. A 6 inch by 2 inch drain hole was provided in the wall between the battery room and battery board room to allow water to flow from the battery board room to the battery room floor drain for units 1 and 3 per the design drawin6s. This drain hole through the wall provides design flow equal to the floor drains provided in the adjacent rooms.

2. Corrective Steps Which Will Be Taken To Avoid Recurrence l

The curbs will be installed as presently shown on design drawings.

Since 1977/78, the modifications process has been formalized to ensure better work control and that more accurate documentation is kept on modifications done in the plant. Strict adherence to procedures has been emphasized in both the Regulatory Performance Improvement Plan and the l

Nuclear Performance Plan.

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3. Date When Full Compliance Will Be Achieved The curbs will be installed by July 15, 1987.

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Deviation B The Browns Ferry Nuclear plant Final Safety Analysis Report Section 10.2.4, New Fuel Storage, requires that each new fuel storage vault be provided with neutron dosimeters.

Contrary to the above, no neutron dosimeters were provided on any of the unit 1, 2, or 3 new fuel storage vaults. An inspection conducted on January 27, 1987, by licensee representatives and the inspector failed to locate any neutron dosimeters. It is not knowa how long this condition may have existed.

This deviation is applicable to all three units. i

1. Corrective Steps Which Have Been Taken and Results Achieved '

Administrative procedures are in effect which do not allow the use of the new fuel storage vaults (see Technical Instruction 14 for allowable fuel storage locations).

4 Furthermore TVA' believes that the last sentence of the first paragraph on {'

page 10.2-2 of our FSAR does not accurately reflect BFN's intentions for providin5 neutron dosimetry. At issue is the fact that the FSAR does not accurately reflect the neutron dosimetry requirements for the new fuel storage vault.

TVA believes that the technical and legal requirements were met and that neutron dosimetry should only be installed when new fuel is actually being stored in the new fuel storage vaults.

The following information is provided in support of this position.

The requirement for providing neutron measuring instrumentation is based on the requirements of 10 CFR 70.24. The original BFN Special Nuclear Material license applications requested and justified exemptions to this requirement. These exemptions were granted by NRC in a letter dated January 31, 1975.

A review of GE design cpecification 22A1278, TVA drawings, and design l documents for the new fuel storage vault contains no references to l permanently installed neutron monitoring instrumentation.

These facts support the idea that TVA did not intend to install permanent neutron monitoring instruments in the new fuel storage vaults but intended i to provide neutron dosimetry when the vaults were in use.

Other documentation exists which indicates that TVA questioned the applicability of the 10 CFR 70.24 exemption to the operating license of the DFN units. A request was made to NRC in 1981 to review the applicability of 10 CFR 70.24. A response was not received. In 1984, a TVA internal memorandum again questioned the applicability of the 10 CFR 70.24 exemption to the operating license.

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BFh has never used the new fuel storage vaults; this can be verified by a ,

review of fuel assembly history records, and therefore has never been l required to provide the neutron dosimeters.

2. Corrective Steps Which Will Be Taken To Avoid Recurrence l

A revision to FSAR Section 10.2.4 will be submitted in TVA's next annual FSAR update to clarify that neutron dosimeters will be provided in the new i

fuel storage vaults whenever fuel is stored there.

3. ') ate When Full Compliance Will Be Achieved The annual FSAR update will be submitted by August 1, 1987.

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. .e ENCLOSURE 2 LIST OF COMMITMENTS Deviation A Curbs will be installed on the unit battery rooms and battery board rooms by July 15, 1987.

Deviation B The new fuci storage vault will have dosimeters provided when/if fuel is to be placed in the vaults, and the FSAR will be revised to state this requirement at the next annual update, which will be submitted by August 1,1987, 1

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