ML20237A499
| ML20237A499 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 12/09/1987 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8712150045 | |
| Download: ML20237A499 (5) | |
Text
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e TENNESSEE VALLEY AUTHORITY CH ATTANOOG A, TENN ESSFC 374o1 SN 157B Lookout Place Df!B 091887 U.S. Nuclear Regulatory Commission ATTN:
Document 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
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50-296 BROWNS FERRY NUCLEAR PLANT (BFN) UNITS 1, 2, AND 3 - NRC. INSPECTION REPORT NOS. 50-259/86-09, 50-260/86-09, AND 50-296/86-09, - SUPPLEMENTAL RESPONSE TO VIOLATION This letter provides a revised schedule for the completion of the fire barrier penetrations upgrade discussed in TVA's letter dated July 29, 1987.
Subsequent to that response, deficiencies were identified in the design program of the contractor who had originally been doing a large portion of the work. This has resulted in a scope change which will require a schedule extension. provides TVA's revised response which reflects the new completion-date. A list of commitments is provided in enclosure 2.
We do not recognize any other items described herein as commitments. An extension of the due date for this response to December 15, 1987, was agreed to in a conversation with i
A. Ignatonis on December 1, 1987.
If you have any questions, please telephone M. J. May at (205) 729-3566.
Very truly yours, TENNESSEE VALLEY AUTHORITY R. Gridley, irector Nuclear Lic sing and Regulatory Affairs Enclosures cc:
See page 2 8712150045 871209 PDR ADOCK 05000259.
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An Equal Opportunity Employer i
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. I U.S. Nuclear Regulatory Commission
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g cc (Enclosure):
Mr. G. G. Zech, Assistant Director for Projects TVA Projects Division Office of Special Projects U.S. Nuclear Regulatory Commission 4350 East-West Highway EWW 322
'Bethesda, Maryland 20814 l
Mr. K. P. Barr, Acting Assistant Director l
for Inspection Programs I
TVA Projects Division Office of Special Projects U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900
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Atlanta, Georgia 30323 Browns Ferry Resident Inspector Browns Ferry Nuclear Plant Route 2, P.O. Box 311 l
Athens, Alabama 35611 l
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ENCLOSURE 1 SUPPLEMENTAL RESPONSE NRC INSPECTION REPORT NOS.
50-259/86-09, 50-260/86-09, 50-296/86-09 LETTER FROM J. N. GRACE TO S.
A. WHITE DATED MAY 21, 1987 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 inspection 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 has identified a total of 190 piping i
l 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.
Original Response 1
1.
Admission or Denial of the Alleged Violation I
TVA admits to the violation as stated.
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2.
Reasons for the Violation The violation occurred because of a misinterpretation of the technical l
specifications.
The terminology used in technical specification 3.11.E, j
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"all fire barrier penetrations including cable penetration i
barriers, fire doors, and fire dampers
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required surveillance.
Revised Response 3.
Corrective Steps Which Have Been Taken and Results Achieved l
i Until the design evaluation of fire barriers and correction of deficiencies j
has been completed, all fire barriers are being considered as nonfunctional.
i Fire detectors near penetrations in fire zone boundaries protecting j
safety-related areas have been verified to be operable and are being checked semiannually. A roving fire watch has been established to check the safety-related areas adjacent to fire zone boundaries hourly to meet the technical specification requirements for compensatory measures, l
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., i This fire watch has been in effect since December 16, 1985 and will continue to be in effect until the physical work on fire penetration seals has been completed.
A large portion of the penetration work was being performed by a TVA contractor.
TVA subsequently decided to complete the project using TVA engineering and modifications personnel.
TVA's Division of Nuclear Engineering will now be designing and selecting acceptable fire-rated seals for all required fire barrier penetrations.
4.
Corrective Steps Which Will Be Taken to Avoid Further Violations Deficiencies in the contractor'r design program have been identified which require TVA to evaluate and reverify the design before completing the remaining engineering work and seal installation. The penetrations sealed by the contractor will be reviewed by TVA to ensure adequacy.
The surveillance instructions will be written and approved to support the technical specifications section 4.11.E. requirement of visual inspection every 18 months.
In order to support completion of the surveillance instructions, piping penetrations required by the fire protection program will be inspected, sealed, and corrective actions performed as necessary to. ensure the fire barriers are qualified. This physical work and surveillance instruction issuance will be completed by June 17, 1988.
Since the above mentioned corrective actions will be accomplished under an approved quality assurance program, TVA will take credit for completion of this work to meet the technical specification requirement for visual inspection.
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Date of Full Compliance
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l Full compliance will be achieved by August 1, 1988.
This date reflects the post-work review and required approvals necessary for Engineering Change Notice closure.
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ENCLOSURE 2 LIST OF COMMITMENTS
- 1) The physical work on the fire penetration seals and the issuance of surveillance instructions to support technical specification section 4.11.E will be completed by June 17, 1988.
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- 2) Full compliance will be achieved by August 1, 1988.
This date reflects the post work review aid required approvals necessary for Engineering change Notice closure.
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