ML18031A844
| ML18031A844 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 09/17/1986 |
| From: | GRIDLEY R TENNESSEE VALLEY AUTHORITY |
| To: | GRACE J N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8610020087 | |
| Download: ML18031A844 (8) | |
See also: IR 05000259/1986022
Text
TENNESSEE VALLEY AUTHORITY cHATTANQQGA.
TENNEssEE 374ot 5B 157B Lookout P1eoe-i Q l7$86 U.S.Nuclear Regulatory
Commission
Region II Attn: Dr.J.Nelson Grace, Regional Administrator
101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Dear Dr.Grace: BROWNS FERRY NUCLEAR PLANT UNITS 1, 2, AND 3-NRC-OIE REGION II INSPECTION
REPORT 50-259/86-22,-260/86-22, 96/86-22-RESPONSE TO VIOLATION Enclosed is our response to G.G.Zech's July 28 and August 8, 1986 letters to S.A.White transmit.ting IE Inspection
Report Nos.50-259/86-22,-260/86-22, and-296/86-22
for our Browns Ferry Nuclear Plant which cited TVA with one Severity Level IV Violation.
This response was due September 8, 1986.An extension to September 22, 1986 was discussed between M.J.May and Floyd Cantrell of your staff on September 4, 1986.If you have any questions, please get in touch with M.J.May 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 R.ridley, D'rector'Nuclear Safet and Licensing, Enclosure cc: Mr.James Taylor, Director (Enclosure)
Office of Inspection
and Enforcement
U.S.Nuclear Regulatory
Commission
Washington, D.C.20555 8610020087
860'717 PDR ADOCK 05000259 8'DR An Equal Opportunity
Employer
rt
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 established
to assure applicable
regulatory
requirements
and the design basis 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.
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 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 to June 16, 1986 (inspection
date)the licensee did not implement the cable installation
specification
G-38 at BFN although this'orrective
action was deemed necessary at all other TVA facilities
to meet cable installation
standards.
This is a Severity Level IV violation (Supplement
I).1.Admission or Denial of the Alle ed Violation We admit that the violation occurred as stated.2.Reasons for the Violation ,All insulated cables installed at BFN before January 15, 1986, were installed to Construction
Specification
G-4, Cable Installation.
TVA management
decided that some modifications
in process would be finished under Specifications
G-3, Conduit.Instal'lation, and G-4, Cable Installation, instead of using the new Specifications
G-38, Cable Installation, and G-40, Conduit, Installation.
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: a.Utilize G-3 and G-4 to complete remaining unit 2 outage work Eor which designs had been issued before January 15, 1986.b.Incorporate
G-38 and G-40 requ3.rements
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 Eor the unit 2 cable replacement
activities
in the drywell.d.G-38 and G-40 would be used for the future modification
activities
on units 1 and 3 when work resumed.3.Corrective
Ste s Which Have Been Taken and Results Achieved 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 cabl'e 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
Ste s Which Will Be Taken to Avoid Further Violations
We will imp'lement
standards G-38 and G-40 Eor new cable installation.
However, both modification
and maintenance
personnel have requested 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
is performing
an evaluation
j
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'hat 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 being performed.
A status report will be submitted to the 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 b'e installed using the G-38 and G-40 revised installation
instructions.
5.Date When Full Com liance Mill Be Achieved 0 Our integrity verification
programs will be complete before restart of unit 2 at BFN.