ML20237L601

Forwards Response to NRC Re Violations Noted in Insp Repts 50-259/86-25,50-260/86-25 & 50-296/86-25. Corrective Actions:Physical Mounting of Control Room Emergency Ventilation Sys Train B Inspected

ML20237L601
Person / Time
Site:	Browns Ferry
Issue date:	08/14/1987
From:	Gridley R TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NUDOCS 8708200274
Download: ML20237L601 (6)

Text

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Ti .~ l TENNESSEE VALLEY AUTHORITY

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CHATTANOOGA. TENNESSEE 374o1  ;

SN 157B Lookout Place:

AUS 141987

'U.S. Nuclear Regulatory Commission ATTNt Document Control Desk Washington, D.C. 20555.-

, Gentlemen: l In the Matter of ) Docket Nos. 50-259 Tennessee Valley ~ Authority ) 50-260

.) 50-296 BROWNS FERRY NUCLEAR PLANT UNITS 1,.2,.AND 3 - NRC-0IE REGION II INSPECTION REPORT'NOS. 50-259/86-25, 50-260/86-25,' AND 50-296/86-25 RESPONSE TO NRC  ;

POSITION.ON SUPPLEMENTAL RESPONSE TO VIOLATION 2.C .j i

Enclosed is TVA's reply to G. G. Zech's June ~ 16, 1987 letter to S. A. White f which requested.an analysis in regard to an item contained in Inspection l Report Nos. 50-259/86-25, 50-260/86-25, and 50-296/86-25 regarding the seismicity of the mounting configuration utilized for the Control Room }

Emergency Ventilation System skid, train B.

1 For the purpose of clarification, the original statement of violation and TVA's March 2, 1987 supplemental response is included with our reply to'the . l.

NRC-stated position'in the June 16, 1987 letter.

.i Enclosure 1 contains our reply to the NRC position. Enclosure 2 contains the '

commitments made in this response. If you have any questions, please  ;

telephone M.'J. May at (205) 729-3566. 1 I

To the best of my knowledge, I declare the statements contained here!.n are complete and true. {

Very truly yours, I i

TENNESSEE EY AUTHORITY  !

R. Gridley, D rector Nuclear Safe y and Licenqing Enclosures cc: See page 2

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0i gB2OO274g7ogj4 G ADOCK 05000259 '\

PDR i

An Equal Opportunity Employer N: .

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-e f i U.S. Nuclear Regulatory Connission j QQ jf jg cc (Enclosures):

Mr. G. G. Zech, Assistant Director Regional Inspections Orlice of Special Projects U.S.' Nuclear Regulatory Commission i Region II.

101 Marietta St., NW, Suite 2900 l Atlanta, Georgia 30323 l

Mr. J. A. Zwolinski, Assistant Director i for Projects . i Office of Special Projects

.U.S. Nuclear Regulatory Commission' 4350 East West Highway EWW 322 Bethesda, Maryland 20814 Browns. Ferry Resident Inspector j Browns Ferry Nuclear Plant P.O. Box 311 i Athens, Alabama 35611 l i

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ENCLOSURE 1 i I

.NRC POSITION RESPONSE i NRC INSPECTION REPORT NOS. j 50-259/86-25, 50-260/86-25,~50-296/86-25  ;

LETTER FROM G. G. ZECH'To S. A.. WHITE DATED JUNE 16, 1987 {

BROWNS FERRY NUCLEAR-PLANT (BFN) i Item-2.c ORIGINAL' VIOLATION 10 CFR"50, Appendix B, Criterion V, requires that activities affecting quality shall be. prescribed by documented instructions, procedures, or drawings of a i type appropriate to the circumstances and shall be' accomplished in accordance -l' with those instructions,Lprocedures, or drawings.

contrary to the above, there is no documented instruction, procedure, or drawing which prescribes the anchoring details of the control room emergency ventilation system (CREVS)-filter train and blower assembly. The train A l and B assemblies are mounted differently with train B cantilevered off its j

anchoring pad. -Since no anchoring details could be located, the installed configuration represents an unanalyzed condition.

This is a Severity Level IV Violation.(Supplement I) and is applicable to all units..

Item 2:e'(TVA's March 2. 1987 Supplemental Response) ,

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.In' response to;the Atomic Energy Commission's FSAR. questions dated March 25, ,

1971, TVA addressed the conformance of 10 CFR.50, Appendix B, in relation.to i specific:BFN systems.: The response to question D.3. detailed in the FSAR, Amendment 31, stated exception to criteriaLIV,? XVII, and XVIII as they relate to the control' room air conditioning system, of which CREVS is a part. This ,

is due to the fact that Appendix B came.into being after some components of i

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BFN were already installed.  ;

- Since an exception was taken to 10 CFR 50, Appendix B, Criteria XVII, Quality '

Assurance Records for fabrication, installation, and examination, complete .l quality control or quality assurance documentation was not required to be .

maintained for this equipment, and thus, the anchoring details could not be l retrieved in this case.

The Division of Nuclear Engineering (DNE) has initiated a problem report documenting'the fact that the civil drawings do not show a design for the pads or connections for the vendor equipment. .This problem report is presently l being resolved.

TVA's BFN is identified in NUREG-1030 as one of the operating plants to be .{

reviewed to the requirements of Unresolved Safety Issue (USI) A-46. The CREVS clong with other components are contained within the scope of items that will be reviewed against the guidelines of USI A-46. l i

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< 1 The SQUG guidelines to inspect and evaluate equipment anchorages are currently  !

being reviewed by the Senior Seismic Review Advisory Panel (SSRAP); It is l anticipated that the guidelines will be approved by NRC in the fourth quarter j of 1987. When the guidelines are approved, SQUG will train utility personnel j as to how the guidelines are to be implemented, and upon completion of the l training, TVA will develop and submit to NRC a schedule for the implementation j of these guidelines. i l

The Engineering Mechanics Group (EMG), DNE, is responsible for determining the seismic acceptability of components and equipment at BFN and has received specific training relative to TVA's position on long-term seismic qualification of safety-related equipment. An EMG representative has performed a field inspection of the CREV units (both system A and system B).

Additionally, on this inspection the EMG representative was accompanied by a BFN DNE Supervisor-Civil who is actively engaged with the SQUG organization in the development of the guidelines for evaluating anchorages to resolve USI A-46. The EMG representative's conclusions follow:

After consideration of the as-installed configuration, no reason could be identified to take exception to the USI A-46 qualification position of seismic acceptability in the absence of evidence to the contrary.

The BFN DNE Supervisor-Civil is also of the opinion that these particular installations will be qualified when the guidelines are finalized after the SSRAP review.

It is TVA's position, supported by these field inspections, that because the CREV units were installed relative to existing practices for seismic installations at the time of initial construction, that there is no reason to treat the seismic reverification of these units differently from those of any other BFN system.

NRC Position on Supplemental Response (June 16. 1987)

With regard to violation 2.c., we are not fully satisfied with your supplemental response. In our judgment, there still appears to be a question regarding the adequacy of the anchorage for the train B CREVS filter / blower assembly that needs to be resolved prior to Unit 2 restart. We consider this particular item to be an outlier to the USI A-46 program. The equipment anchorage guidelines per the USI A-46 program have not been fully developed as you have stated and thus they cannot be used to qualify the existing train B CREVS unit installation for seismic acceptability. Finally, while we recognize the appropriateness of including the Browns Ferry facility under the  ;

review of Generic Letter 87-02, " Verification of Seismic Adequacy of '

Mechanical and Electrical Equipment in Operation Reactors, USI A-46," we think the mounting of equipment that may be outliers such as the subject CREVS unit, should be reviewed more quickly once the problem is identified. Therefore, we request that you provide us an analysis that demonstrates the adequacy of the existing train B CREVS filter / blower assembly mounting or propose and .

implement an acceptable anchorage modification if it becomes necessary to meet '

the seismic requirements. Your response to this item is requested within 60 days of this letter date. This is a Unit 2 restart item.

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TVA Response On July 13 and July 14, 1987, NRC Office of Special Projects personnel-inspected the physical mounting of the CREV train B skid mounting. The  !

results of this review will be made a part of Inspection Report Nos. 50-259,  !

-260, -296/87-27. t Based on information obtained in part from the field installation review, the NRC Special Projects personnel determined and stated at the NRC Exit Metil.ng f on July 14, 1987, that it would be appropriate for TVA to utilize the resolution of USI A-46 for reverifying seismicity for the CREV configuration.

Because of the determination of acceptability for utilizing the resolution of j USI A-46, it is TVA's intent to reverify the CHEV mounting seismicity at the  !

same time as other BFN systems. As required by Ceneric Letter 87-02, l

" Verification of Seismic Adequacy of Mechanical and Electrical Equipment in f Operating Reactors," TVA is presently committed to provide the implementation l schedule for the resolution of USI A-46 to NRC by December 1, 1987. )

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o ENCLOSURE 2 Commitments made in Transmittal TVA has previously committed in a formal response to Generic Letter 87-02 to provide an implementation schedule by December 1, 1987. No other commitments are made by this submittal.

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