ML20216H743
| ML20216H743 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 06/23/1987 |
| From: | Domer J TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8707010551 | |
| Download: ML20216H743 (6) | |
Text
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I p y ;.h. N ENNESSEE VALLEY AUTHORITY CHATTANOOGA. TENNESSEE 374of SN 157B Lookout Place
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JUN 281987 I
LU.S.iNuclear Regulatory Commission.
ATTN: cDocument Control Desk Washington, D.C.
20555.
- Gentlemen:
In'the Matter.of
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Docket Nos. 50-259 Tennessee. Valley Authority.-
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50-260 i
50-296 1
BROWNS FERRY NUCLEAR PLANT (BFN) UNITS I, 2, AND 3 - NRC-0IE REGION II l
. INSPECTION REPORT 50-259/86-22, 50-260/86-22,.50-296/86 SUPPLEMENTAL-
' RESPONSE
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, Enclosed is information in. addition to TVA's supplemental. response to G. G. Zech's. July 28 and August-8, 1986 letters to S. A. White transmitting IE-l Inspection Report Nos. 50-259/86-22, 50-260/86-22, and 50-296/86-22 for our j
LBrowns Ferry Nuclear Plant'which cited TVA with one Severity Level IV.
' Violation. The supplemental response dated October 30, 1986, was a status report on the application of Specification G-38, Cable Installation, and l
Specification G-40, Conduit Installation..to maintenance and modification 1
activities on existing cable and conduit installations.
Subsequent to the submission of the supplemental response, reviews.of.a Watts-Bar employee concern'for applicability to BFN has prompted us to revise ~some information in that response. The added information appears on page'four of-this submittal.
The-original response'and first supplement have also been included for continuity.
Please refer any questions or comments to M. J. May, BFN Site Licensin5, 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
- Prtht.
J. A. Domer, Assistant Director Nuclear Safety and Licensing Enclosure ec:
see page 2 7010551 970$p3 G.
ADOCK 05000259
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0 PDR l
An Equal Opportunity Emp; oyer j
'U.S. Nuclear Regulatory Commission
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cc (Enclosure):
'Mr. G. G. Zech Assistant Director.
Regional' Inspections Division'of TVA Projects Office-of Special Projects' U.S.l Nuclear-Regulatory Commission Region II.
'101 Marietta St., NW, Suite 2900 Atlanta, Georgia 30323 j
Browns Ferry Resident Inspector Browns. Ferry Nuclear Plant P.O. Box 311 Athens,. Alabama ~ 35611 Mr. J. A. Zwolinski,. Assistant Director for Projects Division. of'TVA Projects Office of'Special Projects U.S. Nuclear Regulatory Commission 4350 East West Highway.
EWW 322 Bethesda, Maryland '20814 9
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l SUPPLEMENTAL RESPONSE NRC INSPECTION REPORT NOS.
50-259/86-22, 50-260/86-22, AND 50-296/86-22 GARY G. ZECH'S LETTERS TO S. A. WHITE DATED JULY 28 AND AUGUST 8, 1986 Item 1 10 CFR 50, Appendix B Criterion III requires that measures shall be i
established to assure applicable regulatory requirements and the design basis i
are met. These measures shall include provisions to assure that appropriate quality standards are specified and included in design documents and that deviations from such standards are controlled.
j Contrary to the above, this requirement was not met from January 15 - June 16, 1986, in that newly implemented standards for control of installation of insulated cables (TVA General Specification 38) were not specified for use on facility design modifications in progress prior to January 15, 1986.
The TVA Office of Engineering implemented the new cable installation criteria of General Specification 38, revision 7, at all TVA facilities with the exception
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of Browns Ferry (BFN) as of January 15, 1986.
General Specification 38 was issued for all TVA sites to have insulated cable installations done consistently at all TVA nuclear plants and to bring TVA's cable installation practices up to a level consistent with current industry practice. General Specification 38, revision 7, was issued on January 15, 1986, for all future modifications at Browns Ferry. From January 15, 1986 to June 16, 1986 (inspection date) the licensee did not implement the cable installation specification G-38 at BFN although this corrective action was deamed necessary
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at all other TVA facilities to meet cable installation standards.
This is a Severity Level IV violation (Suppleme.nt I).
Our initial submittal dated September 17, 1986, is repeated below and the supplemental response for item 4, " Corrective Steps Which Will Be Taken to Avoid Further Violations," follows.
Initial Submittal l
1.
Admission or Denial of the Alleged Violation We admit that the violation occurred as stated.
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2.
Reasons for the Violation l
1 All insulated cables installed at BFN before January 15, 1986, were l
installed to Construction Specification G-4, Cable Installation. TVA management decided that some modifications in process would be finished under Specifications G-3, Conduit Installation, and G-4, Cable Installation, instead of using the new specifications G-38, Cable 1
Installation, and G-40, Conduit Installation.
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, The use of G-38 cable installation often requires the.use of its companion specification for conduit installation, G-40.
Many modifications in progress for unit 2 would have to be redesigned and/or reconstructed in accordance with G-40 in order for a successful G-38 installation to proceed.
Since the G-38 terminology, " future modifications," was subject to interpretation, it was decided that certain modifications in process would be finished under the old specification.
Therefore, the following implementation strategy for the orderly transition to the G-38 and G-40 specifications at BFN was chosen:
l a.
Utilize G-3 and G-4 to complete remaining unit 2 outage work for which designs had been issued before January 15, 1986.
b.
Incorporate G-38 and G-40 requirements into unit 2 outage work for which designs had been issued on or after January 15, 1986.
c.
G-38 and G-40 would be utilized for the unit 2 cable replacement activities in the drywell, d.
G-38 and G-40 would be used for the future modifi' cation activities on units 1 and 3 when work resumed.
3.
Corrective Steps Which Have Been Taken and Results Achieved I
On June 18, 1986, TVA placed a hold on all cable pulling at BFN.
The order stated that the hold would be lifted for each applicable section when the following conditions were met:
a.
Site instructions associated with cable pulling activities must be revised or new procedures written to incorporate the requirements set forth in Specifications G-38 and G-40.
b.
Site personnel involved in cable pulling activities must receive documented training in the revised site instructions.
Quality Assurance verified compliance with the hold order through the surveillance process.
4.
Corrective Steps Which Will Be Taken to Avoid Further Violations We will implement standards G-38 and G-40 for new cable installation.
However, both modification and maintenance personnel have requested l
numerous engineering interpretations in applying all the requirements of G-38 and G-40 to restoration of existing cable / conduit installations.
Therefore, our Division of Nuclear Engineering (DNE) is performing an l
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.. evaluation to determine the appropriate application of G-38 and G-40 to maintenance and modification routine restoration work, in order that we may continue activities without unnecessary documentation and replacement of existing cable and conduit installations. The evaluation will take into account the necessary installation and inspection controls. Until that evaluation is complete and appropriate procedural controls are in place, any maintenance or modification restoration activity deviating from G-38 or G-40 will be justified and documented before the work,is performed.
A status report will be submitted to NRC by October 30, 1986.
Several technical integrity verification programs are presently underway at BFN to demonstrate the integrity of cable installed under G-3 and G-4.
These are scheduled to be completed in the coming months. Preliminary results indicate that the installed cable is capable of reliable operation at several times the sidewall pressure and at lesser minimum bend radius than specified by the cable suppliers.
If any of the programs should indicate cases of inadequate cable conditions, new cable will be installed using the G-38 and G-40 revised installation instructions.
1 5.
Date When Full Compliance Will Be Achieved Our integrity verification programs will be complete before restart of i
unit 2 at BFN.
First Supplemental Response - Status Report our cable pulling maintenance activities have been limited due to the need for additional procedures that are to be written to specifically address msintenance activities.
In the interim, the hold has been lifted for only those specific cable pulling maintenance activities that are able to be performed in accordance with the new modifications implementing procedures.
These newly approved procedures are Modifications and Additions Instruction (MAI) 44, " Cable Pulling for Insulated Cables Rated Up to 15,000 Volts - Units 1, 2, 3," which conforms to Specification G-38,
" Cable Installation," and MAI-27, " Installation of Electrical Conduit Systems and Junction Boxes," which conforms to Specification G-40,
" Conduit Installation." Training is performed for engineers and craftsmen in the applicable procedures before accomplishing cable pulling or conduit installation activities.
The hold on cable pulling modification activities has been lifted.
Procedures MAI-44 and RAI-27, referenced above, have been implemented.
Training has been completed and documented for all personnel who are currently involved with the implementation of cable pulling modification activities associated with MAI-44 and HAI-27.
Training will be ongoing for additional personnel as required.
_4 DNE has established the following requirements for restoration maintenance that will be incorporated in our next revision to Specifications G-38 and G-40:
l 1.
Restoration can be made such that the installation can be returned to the original, as-found condition.
2.
The repair can be made meeting all the requirements which existed at the time of installation so that the existing operability requirements, technical specification limits, and design bases are satisfied.
3.
Any nonconforming restoration is documented by a Problem Identification Report or Significant Condition Report and the corrective action resolved and implemented before restart.
Second Supplemental Response A Watts Bar Nuclear Plant (WBN) employee concern was identified on the subject of modifications and additions not being made in accordance with Construction Specifications. This concern was reviewed further to determine if related issues might be present at Browns Ferry Nuclear Plant (BFN). The report of this review identified several findings applying to BFN when it was forwarded to the corrective Action Program Manager, March 13, 1987.
Subsequently, the report was forwarded to BFN for determination of required corrective action to respond to the findings of the report.
At this time, two specific findings were noted that were relevant to TVA's response to violation Item 1, NRC-0IE Region II Inspection Report 50-259/86-22, 50-260/86-22, and 50-296/86-22.
These were:
"G-4 was never fully implemented in modification or maintenance procedures," and " Cable installation procedures in effect before June 18, 1986 were not totally in accordance with G-4."
These findings are in conflict with the response provided to the noted NRC Inspection Report which stated that "All insulated cables installed at BFN before January 15, 1986, were installed to Construction Specification G-4, Cable Installation."
Surveillance instructions have been regularly performed on Critical Systems, Structures, and Components (CSSC) equipment at frequencies specified by Technical Specifications.
The surveillance testing program verifies the ability of systems and subsystems to perform satisfactorily ac designed.
Thus, performing surveillance requirements is an ongoing verification of the adequacy of Class 1E cable installation. A detailed 3
review of cable failures which have occurred at TVA nuclear plants and two TVA fossil plants concluded that cable installation practices have not contributed to cable failures and that the overall failure rate of safety-related cables for fifteen years at TVA plants is within the range estimated in IEEE Standard 500-1984.
Several technical integrity verification programs are presently underway at BFN to demonstrate the integrity of installed cable.
These programs are scheduled to be completed before unit restart at Browns Ferry. Based upon Sequoyah's i
experience, TVA does not expect a significant number of cable problems to be identified by those programs.
Should any of the programs indicate inadequate cable conditions, new cable will be installed using revised installation instructions that incorporate requirements of C-38 and G-40.
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