IR 05000259/1986025
| ML20210D928 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 01/26/1987 |
| From: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | White S TENNESSEE VALLEY AUTHORITY |
| References | |
| NUDOCS 8702100193 | |
| Download: ML20210D928 (4) | |
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( +' o @.ci A JAN261987 Tennessee Valley Authority ATTN: Mr. S. A. White Manager of Nuclear Power 6N 38A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Gentlemen:
SUBJECT: REPORT NOS. 50-259/86-25, 50-260/86-25, AND 50-296/86-25 Thank you for your response of October 16, 1986, to our Notice of Violation issued on September 11, 1986, concerning activities conducted at your Browns Ferry facilit We have evaluated your response and found that it meets the requirements of 10 CFR 2.201. We will examine the implementation of your corrective actions to correct Violations 1 and 2.b., during future inspection After careful consideration of the basis for your denial of Violation 2.c.,
we agree with your position from the view point of Quality Assurance records retrieval problem onl The subject equipment was installed prior to 10 CFR Part 50, Appendix B becoming effective and consequently some of the component installation details are not retrievabl However, you have not adequately demonstrated in your response that the actual as-built equipment configuration is seismically qualified. Our reasons are presented in the enclosure to the letter. Therefore, please submit a supplemental response to this office within 30 days of the date of this lette Also, clarification and a supplemental response is required to your reply to Violation 2.a. For corrective action, you have stated that the Fire Protection Group is initiating a procedure to perform special air testing at selective locations on all critical structures, systems, and components preaction sprinkler systems to verify open flow paths. Further, this test will verify flow through selected header sections and their associated branch lines. However, the Licensee Event Report 50-296/86006 covering information on the same subject states that a 30 percent random sample of branch lines of the preaction sprinkler systems was verified for open flow path. The LER provides a quantitative response and it is not clear to us if it is consistent with the former informa-tion. Please provide clarification. In addition, provide justification for not performing a 100 percent inspection of the preactive sprinklers. If a certain sample size was indeed selected for inspection, then provide the basis for its selection and why it was considered adequate to insure no flow blockage. You are requested to respond to this item within 30 days of the date of this lette The response directed by this letter is not subject to the ciearance procedure of the Office of Management and Budget issued under the Paperwork Reduction Act, PL 96-51 g2QO O
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.s-Tennessee Valley Authority 2 JAN261987 We appreciate your cooperation in this matte
Sincerely, J. Nelson Grace Regional Administrator Enclosure:
Staff Comments on Denial of Violation 2 cc w/ enc 1:
H. P. Pomrehn, Site Director Browns Ferry Nuclear Plant R. L. Lewis, Plant Manager R. L. Gridley, Director Nuclear Safety and Licensing R. W. Cantrell, Acting Director Nuclear Engineering M. J. May, Site Licensing Manager bec w/ enc 1:
J. N. Grace, RII H. R. Denton, NRR H. L. Thompson, NRR J. M. Taylor, IE B. B. Hayes, 01 S. R. Connelly, 01A G. E. Gears, NRR M. Grotenhuis, NRR K. P. Barr, RII NRC Resident Inspector Document Control Desk State of Alabama
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ENCLOSURE STAFF COMMENTS ON DENIAL OF VIOLATION TVA's response to the violation concerning lack of documented instruction, procedure, or drawing which prescribes the anchoring details of the control room emergency ventilation system (CREVS) filter train and blower assembly was evaluated. The primary reason for this violation was the inspector's concern to detemine whether or not the CREV filter train and blower assembly was properly installed to withstand the effects of seismic conditions. As mentioned in the NRC Inspection Report Nos.60-259, 260, 296/86-25, the CREV Train B unit is mourted differently than the CREV Train A unit and it appears to be improperly mounte This was the reason for the request of CREV installation drawings specifying correct anchoring detail TVA was unable to retrieve the QA records for CREV installation. TVA's reason for this is that 10 CFR Part 50, Appendix B came into being after some of the components of Browns Ferry facility were already installed, and TVA took excep-tion to Appendix B criteria IV, XVII, and XVIII as stated in a response to AEC question D.3, detailed in the FSAR, Amendment 31. While we agree with TVA's position on the QA documentation issue we do not have the assurance nor accept TVA's current response in demonstrating the CREV unit's ' ability to maintain integrity during and after a seismic even In the early AEC questioning period, TVA's response to an AEC question was as follows:
"The systems have been designed, fabricated and erected to the same codes, standards, criteria and practices that would have otherwise been required except that QA documentation is not available."
Furthermore, TVA has stated in the FSAR (Chapter 10.12) that the CREV units (Emergency Pressurization System per the FSAR) are seismically qualifie With regard to the seismic question, the licensee used their Division of Nuclear Engineering (DNE) for support in determining the CREV units seismic qualifica-tion. The NRC obtained a copy of the DNE evaluation and learned that the evalua-tion process is generic and intended to apply to all electrical equipment. The evaluation methodology is judged to be unacceptable because it had been shown to be faulty over the last several years. For example, the equipment evaluated by TVA in 1981-1982, and judged to be acceptable, has been found to be unacceptable in 1985 and 1986. This includes battery racks, control room panels, RPS instrument racks, and hydraulic control uni These findings compromised the validity of conclusions drawn from the TVA activities associated with IE Notice (IEN) 80-21, Anchorage and Support of Safety-Related Electrical Equipmen Furthermore, DNE's use of the Seismic Qualification Utilities Group (SQUG) report related to the NRC's resolution of Unresolved Safety Issue A-46 concerning seismic qualification of equipment is not fully appropriate to this case. The referenced 50VG/A-46 report is too general and it provides no infomation or
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specific guidelines on acceptable anchoring of components such as the CREV units, even on another component similarity basi In sumary, TVA's DNE evaluation does not directly address the adequacy of the CREV units anchoring configuration and provides no assurance that the as-built anchoring configuration can withstand the effects of seismic conditions.