ML040970536
| ML040970536 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 04/06/2004 |
| From: | Casto C Division of Reactor Safety II |
| To: | Scalice J Tennessee Valley Authority |
| References | |
| EA-04-063 IR-04-011 | |
| Download: ML040970536 (20) | |
See also: IR 05000259/2004011
Text
April 6, 2004
Tennessee Valley Authority
ATTN: Mr. J. A. Scalice
Chief Nuclear Officer and
Executive Vice President
6A Lookout Place
1101 Market Street
Chattanooga, TN 37402-2801
SUBJECT:
BROWNS FERRY NUCLEAR PLANT UNIT 1 RECOVERY - NRC INSPECTION
REPORT NO. 05000259/2004011
Dear Mr. Scalice:
On February 13, 2004, the U.S. Nuclear Regulatory Commission (NRC) completed an
inspection associated with recovery activities at your Browns Ferry 1 reactor facility. The
enclosed report documents the results of this inspection which were discussed on March 25,
2004, with Mr. Jon Rupert of your staff.
This inspection was an examination of activities conducted under your license as they relate to
safety and compliance with the Commissions rules and regulations and with the conditions of
your license. Within these areas, the inspection consisted of selected examinations of records,
documents, discussion with NRC staff, and interviews with licensee personnel.
This report documents an apparent violation which is being considered for escalated
enforcement action in accordance with the General Statement of Policy and Procedure for
NRC Enforcement Actions (Enforcement Policy), NUREG-1600. The current Enforcement
Policy is included on the NRCs Web site at www.nrc.gov; select What We Do, Enforcement,
then Enforcement Policy. The apparent violation involved deficiencies in your quality
assurance program related to the Long Term Torus Integrity Program, and concerns the failure
to ensure compliance with instructions, procedures, and drawings, and to conduct adequate
oversight of torus repair activities, which resulted in multiple examples of omitted repairs. Since
the NRC has not made a final determination in this matter, no Notice of Violation is being issued
for this inspection finding at this time. In addition, please be advised that the number and
characterization of the apparent violation described in the enclosed inspection report may
change as a result of further NRC review.
2
An open predecisional enforcement conference to discuss this apparent violation will be
scheduled at a future date. The NRC will contact you regarding this date. The decision to hold
a predecisional enforcement conference does not mean that the NRC has determined that a
violation has occurred or that enforcement action will be taken. This conference is being held
to obtain information to assist the NRC in making an enforcement decision. This may include
information to determine whether a violation occurred, information to determine the
significance of a violation, information related to the identification of a violation, and information
related to any corrective actions taken or planned. The conference will provide an opportunity
for you to provide your perspective on these matters and any other information that you believe
the NRC should take into consideration in making an enforcement decision.
You will be advised by separate correspondence of the results of our deliberations on this
matter. No response regarding the apparent violation is required at this time.
In accordance with 10 CFR 2.390 of the NRCs "Rules of Practice," a copy of this letter and its
enclosure will be available electronically for public inspection in the NRC Public Document
Room or from the Publicly Available Records (PARS) component of NRCs document system
(ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-
rm/adams.html (the Public Electronic Reading Room).
Sincerely,
\\\\RA by Harold O. Christensen Acting For\\\\
Charles A. Casto, Director
Division of Reactor Safety
Docket No. 50-259
License No. DPR-33
Enclosure:
Inspection Report No. 05000259/2004011
cc w/encl:
Karl W. Singer
Senior Vice President
Nuclear Operations
Tennessee Valley Authority
Electronic Mail Distribution
James E. Maddox, Vice President
Engineering and Technical Services
Tennessee Valley Authority
Electronic Mail Distribution
cc contd - See page 3
3
cc contd
Ashok S. Bhatnagar
Site Vice President
Browns Ferry Nuclear Plant
Tennessee Valley Authority
Electronic Mail Distribution
General Counsel
Tennessee Valley Authority
Electronic Mail Distribution
Michael J. Fecht, Acting General Manager
Nuclear Assurance
Tennessee Valley Authority
Electronic Mail Distribution
Michael D. Skaggs, Plant Manager
Browns Ferry Nuclear Plant
Tennessee Valley Authority
Electronic Mail Distribution
Mark J. Burzynski, Manager
Nuclear Licensing
Tennessee Valley Authority
Electronic Mail Distribution
Timothy E. Abney, Manager
Licensing and Industry Affairs
Browns Ferry Nuclear Plant
Tennessee Valley Authority
Electronic Mail Distribution
State Health Officer
Alabama Dept. of Public Health
RSA Tower - Administration
Suite 1552
P. O. Box 303017
Montgomery, AL 36130-3017
Chairman
Limestone County Commission
310 West Washington Street
Athens, AL 35611
cc contd - See page 4
4
cc contd
Jon R. Rupert, Vice President
Browns Ferry Unit 1 Restart
Browns Ferry Nuclear Plant
Tennessee Valley Authority
P. O. Box 2000
Decatur, AL 35609
Robert G. Jones, Restart Manager
Browns Ferry Unit 1 Restart
Browns Ferry Nuclear Plant
Tennessee Valley Authority
P. O. Box 2000
Decatur, AL 35609
Enclosure
U. S. NUCLEAR REGULATORY COMMISSION
REGION II
Docket No:
50-259
License No:
Report No:
Licensee:
Tennessee Valley Authority
Facility:
Browns Ferry Nuclear Plant, Unit 1
Location:
Corner of Shaw and Nuclear Plant Roads
Athens, AL 35611
Dates:
January 26 - 30, 2004 and February 9 - 13, 2004
Inspectors:
J. Lenahan, Senior Reactor Inspector
R. Chou, Reactor Inspector
W. Bearden, Senior Resident Inspector
Approved by:
Mark S. Lesser, Chief
Engineering Branch 2
Division of Reactor Safety
Enclosure
EXECUTIVE SUMMARY
Browns Ferry Nuclear Plant, Unit 1
NRC Inspection Report 05000259/2004-011
The inspection included observation and review of recovery activities related to Drywell Steel
Platform and Long Term Torus Integrity Programs. The inspection program for the Unit 1
Restart Program is described in NRC Inspection Manual Chapter 2509.
Engineering
No violations or deviations were identified as a result of review of the drywell steel platform
program. (Section E1.1)
An apparent violation was identified for deficiencies in the Quality Assurance Program related to
the Long Term Torus Integrity Program, involving the failure to ensure compliance with
instructions, procedures, and drawings, and to conduct adequate oversight of repair activities,
which resulted in multiple examples of omitted repairs. (Section E1.2)
The licensees corrective actions to address the apparent violation described in Section E1.2
appear to be comprehensive. (Section E1.3)
A noncited violation was identified for failure to accurately measure welds during walkdowns.
(Section E1.2)
A noncited violation was identified for inadequate basis for accepting an undersized weld.
(Section E1.2)
Enclosure
REPORT DETAILS
III. Engineering
E1
Conduct of Engineering
E1.1
Drywell Steel Platforms
a.
Inspection Scope
During investigations performed in the 1980s by the licensee and NRC related to restart
of Unit 2, numerous deficiencies were identified in design and construction of safety-
related structural steel platforms. These included cracking of clip angles which connect
structural members, failure to construct the platforms in accordance with design
documents, deficiencies in welding (primarily undersized fillet welds), seismic design
issues, and configuration management issues ( ie, failure to control addition of more
loads to platforms).
The licensees commitments for resolution of issues associated with the drywell
structural steel platforms are stated in TVA letter dated December 13, 2002, Subject:
Browns Ferry Nuclear Plant - Unit 1 - Regulatory Framework for the Restart of Unit 1.
The letter references previous commitments for restart of Units 1 and 3 stated in a letter
dated July 10, 1991, Subject: Regulatory Framework for the Restart of Units 1 and 3,
and NRC approval of the licensees plans in a letter dated April 1, 1992. Design criteria
for design and seismic qualification of the drywell structural steel platforms were
submitted to NRC in TVA letters dated June 12, 1991, June 13, 1991, and February 6,
1992. Acceptance of the licensees design criteria for the structural steel platforms by
NRC is documented in a Safety Evaluation Report dated July 13, 1992, Subject: Design
Criteria for Lower Drywell Steel Platforms and Miscellaneous Steel. The inspectors
reviewed design drawings, installation procedures, work orders, and quality records for
installation of the new structural steel for the Elevation 584 drywell platforms.
b.
Observations and Findings
The Unit 1 drywell structural steel platforms have been redesigned to correct the
deficiencies. The majority of the original structural steel members were removed and
are being replaced. The modified structural platforms are intended to meet current
design criteria and have a design margin for addition of future loads, if necessary. The
inspectors reviewed TVA Engineering Specifications G-29 and G-89, and TVA
procedures MAI-5.2, MAI-5.9, NDE N-VT-3, and NDE N-VT-6 which specify the
requirements for welding and installation of structural steel. The inspectors also
reviewed DCN 51019 and work orders issued to implement modifications to the
Elevation 584 drywell structural steel and verified that information from field walkdowns
and design drawings were correctly translated into work instructions. Documents
examined included work control instructions, including quality control (QC) holdpoints,
weld maps, instructions and location sketches to control installation of new structural
steel bolts, and weld travelers. The inspectors examined selected modifications to the
Unit 1 elevation 584 drywell structural steel frames and platforms between azimuth 351
2
Enclosure
and 60 to verify that modifications were completed in accordance with Quality
Assurance (QA) documentation, which included the work order packages, design
drawings, and documents contained in the Design Change Notices (DCN). During the
walkdown inspection, the inspectors verified the following attributes complied with the
requirements shown on the design drawings: member sizes, configuration, weld sizes,
type, and length, connection details, and verification of correct type bolts in existing
connections.
c.
Conclusions
No violations or deviations were identified.
E1.2
Long Term Torus Integrity Program (IP 62002, 37551)
a.
Inspection Scope
The inspectors reviewed the licensees program to identify and correct deficiencies in
installation of the torus integrity modifications which had been completed in the early
1980's under Engineering Change Notice (ECN) P-0093. The deficiencies included
undersized welds, missing welds, excessive restraint gaps, and installation/ fabrication
configurations differing from the modification design drawing requirements. The
licensees commitments for resolution of issues associated with the torus are stated in
TVA letter dated December 13, 2002, Subject: Browns Ferry Nuclear Plant - Unit 1 -
Regulatory Framework for the Restart of Unit 1. The licensee issued PER 03-017339 to
document and correct the deficiencies. Details of the repairs are shown in Work Orders
03-017394-001 through 03-017339-016 and in sketches (Deficiency Fix Requests)
referenced in the PER. The inspectors reviewed the following documents: drawings
which show results of walkdown inspections to determine existing as-built conditions for
the work completed under ECN P-0093, PER 03-017339, calculations which evaluated
the existing conditions, and the work orders issued to implement corrective actions. The
inspectors also performed walkdown inspections of the torus to evaluate the completed
repairs, and reviewed QA/QC records documenting completion and inspection of the
repairs.
b.
Observations and Findings
Review of Torus Walkdowns to Document Existing Conditions
Walkdown inspections were performed by licensees contract engineering (Bechtel)
personnel to document the as-built condition and configuration of the torus integrity
modifications installed under ECN P-0093. The results of the walkdowns were
documented on walkdown drawings. The inspectors reviewed TVA procedure WI-BFN-
0-CEB-02, Walkdown Instructions for Seismic Issues (Civil), which specified the
requirements for performance of the walkdown. The inspectors, accompanied by
walkdown personnel, independently examined selected attributes of various structural
steel members and piping in the torus to determine weld size, type, and length and
3
Enclosure
compared these dimensions to those shown on the torus walkdown drawings. The
inspectors identified four welds of approximately 40 examined which were incorrectly
measured by the licensees walkdown team. One was 1/8" undersized, while the
remaining three were 1/16" undersized.
10 CFR 50, Appendix B, Criteria V, Instructions, Procedures, and Drawings, in part,
states that activities affecting quality shall be prescribed by documented instructions,
procedures, or drawings of a type appropriate to the circumstances and shall be
accomplished in accordance with these instructions, procedures, or drawings. Section
8.2, Welding, of Procedure WI-BFN-0-CEB-02, Walkdown Instruction for Seismic Issues
(Civil), in part, has a requirement to measure and record fillet weld size. Section 8.2.2.1,
Fillet Weld Size Acceptance Criteria, of the same procedure, in part, states that a fillet
weld size shall be permitted to be less than the size recorded by 1/16-inch for 1/4 of the
length of the weld. Contrary to the above, on January 29, 2004, walkdown drawings of
several structural steel members were not appropriate, in that, they contained incorrect
weld sizes. These walkdown drawings were used to evaluate the as-built condition for
acceptability or modifications. This violation is being treated as an NCV, consistent with
Section VI.A of the NRC Enforcement Policy and will be identified as a Severity Level IV
Non-Cited Violation (NCV) 50-259/2004-011-01, Failure to Accurately Measure Welds
During Walkdowns. The licensee initiated PER 04-000671 on January 29, 2004, to
document and disposition this issue.
Review of Engineering Evaluation of Discrepancies
After the walkdown drawings were completed, licensee engineers compared the as-built
walkdown data to the original torus integrity modification ECN P-0093 drawings and
identified discrepancies between the design requirements and the measured as-built
conditions. Engineering calculations were issued to evaluate the discrepancies.
Generally welds which were undersized by 1/16" were found to be acceptable, and
welds which were undersized by more than 1/16" were identified for repair to restore the
design margin. Welds requiring repair were identified on sketches (Deficiency Fix
Requests) referenced in PER 03-017394.
The inspectors reviewed walkdown packages WDP-BFN-1-CEB-303-TOR-12 and TOR-
20 through TOR-23, and WDP-BFN-1-CEB-001-02-03 which documented the results of
the as-built torus integrity modifications. The inspectors compared the walkdown data to
the ECN P-0093 drawings to determine if fillet welds, which were identified during the
walkdowns to be undersized by more than 1/8 inch were identified as needing to be
repaired on the Deficiency Fix Request sketches under PER 03-017339-000. Specific
weld details examined were those shown on sketches 4, 5, 6, 31, and 36. The
inspectors reviewed calculation number CDQ1-303-2003-2196, Torus Integrity-Review
of Walkdown Packages, to determine if the discrepancies identified during the
walkdowns were properly evaluated. Review of the calculation for disposition of welds
which were determined by the licensees walkdown team to be 1/16" undersized,
disclosed the following justification to accept as-is: The size of the fillet weld is found to
be undersized by 1/16 for the bottom stiffener. By engineering judgement this
4
Enclosure
discrepancy is accepted as it is too small to be measured accurately. This statement
does not provide sufficient technical basis for accepting the undersized welds.
10 CFR 50, Appendix B, Criteria V, Instructions, Procedures, and Drawings, in part,
states that activities affecting quality shall be prescribed by documented instructions,
procedures, or drawings of a type appropriate to the circumstances and shall be
accomplished in accordance with these instructions, procedures, or drawings.
Paragraph 3.2.2 I of TVA procedure NEDP-2, Design Calculation Process Control,
requires that technical justification and basis for engineering judgement be provided in
the calculation. Contrary to the above, on January 29, 2004, technical justification and
basis in calculation CDQ1-303-2003-2196 was not sufficient to accept an undersized
weld on the bottom stiffener. This violation is being treated as an NCV, consistent with
Section VI.A of the NRC Enforcement Policy and will be identified as a Severity Level IV
Non-Cited Violation (NCV) 50-259/2004-011-02, Inadequate Basis for Accepting
Undersized Weld. The licensee initiated PER 04-000656 on January 29, 2004, to
document and disposition this issue.
Following concerns raised by the inspectors regarding several repair issues discussed in
subsequent paragraphs, an engineering review was initiated by Bechtel engineers. The
objective of the review was to verify that discrepancies identified during the torus
walkdowns performed in summer/fall 2003 were adequately evaluated in the design
calculations and that discrepancies requiring repair were included in engineering output
documents (Deficiency Fix Request sketches). This review identified errors which
resulted in approximately 50 required repairs which had either not been evaluated or
incorporated on the Deficiency Fix Request sketches, or the repairs were shown at the
incorrect locations.
10 CFR 50, Appendix B, Criteria V, Instructions, Procedures, and Drawings, in part,
states that activities affecting quality shall be prescribed by documented instructions,
procedures, or drawings of a type appropriate to the circumstances and shall be
accomplished in accordance with these instructions, procedures, or drawings. Section
3.I.1 of TVA procedure NEDP-5, Design Documents Review, requires the preparer of
design documents to provide an adequate and accurate solution for the problem,
provide a quality product, and ensure that the design documents are complete. Section
3.1.2 of Procedure NEDP-5 requires the Checker (design verifier) to verify the design
documents are adequate, complete and accurate. The failure to evaluate or incorporate
numerous deficient welds into Deficiency Fix Requests sketches is identified as the first
example of Apparent Violation (AV) 50-259/2004-011-03.
Review of Repairs to Undersized/Missing Torus Welds
The inspectors examined selected repairs to the torus to determine if the repairs had
been completed in accordance with the corrective actions specified in PER 03-017339-
000 and the referenced drawings (Deficiency Fix Requests). Work orders, containing
weld data sheets, were generated to repair welds that were identified in the Deficiency
Fix Requests. During the walkdown inspection, the inspectors examined weld sizes,
type, and length and compared these attributes to the requirements shown on the
5
Enclosure
sketches and in the work order instructions. The inspectors found that some welds had
not been repaired as specified on the repair sketches, although the work order
documentation, specifically weld maps and data sheets, indicated the welds had been
repaired by craft personnel and had been inspected and accepted by QC personnel.
These included the following eight welds on the main steam relief valve vent piping
supports: weld number MS-1-WO 03017394016-008 in work order 03-017394-016,
weld numbers PCI-1-WO 03017394002-029 and -30 in work order 03-017394-002, and
weld numbers PCI-1-002-004, -005, and -006, and MS-1-WO 03017394006-047 and -
048 in work order 03-017394-006. The inspectors concluded that repairs were
completed at the incorrect locations for the above welds, and the welds which were
designated for repair had not been corrected by the craft as required by the instructions
and drawings in the work orders, and as documented.
The licensee assigned a team of two quality control personnel to reinspect the supports
and determine the existing weld sizes to confirm the weld issues discussed above. The
licensees team reinspected the welds listed above in work order 03-017394-006 (shown
on Deficiency Fix Request Sketch 31) for the stiffener plates on the main steam vent
pipe in Bay 6. The inspectors reviewed the results from the field inspections and
identified discrepancies in the re-measured weld sizes. In addition, based on reviewing
weld data sheets and the weld maps in the work order package, and comparing the
existing conditions in the torus with the work order documents, it appeared that some
welds were either not repaired, or the repairs were completed at the incorrect locations.
Examination by the licensee of additional welds in bays 2, 3 and 16 and documentation
in the corresponding work orders disclosed that several additional welds were either not
repaired, or the specified repairs were completed in incorrect locations. However, the
work order documentation (weld data sheets) indicated the required repairs had been
completed.
The inspectors raised a concern that a significant problem appeared to be the inability of
personnel to correctly reference their orientation in the torus to the location of a specific
weld as depicted on a drawing, and to correctly interpret drawing requirements.
Licensee personnel had identified similar problems during November, 2003, resulting in
work being performed at the incorrect locations. These problems were documented and
disposed in PER numbers 03-022390-000, 03-022683-000, 03-022702-000, and 03-
023354-000. The licensee initiated a review to verify that repairs had been made in the
correct location. As a result of this review, approximately 20 additional welds were
found to have been made at the incorrect location. The failure to perform numerous
repairs on the correct welds is identified a second example of Apparent Violation 50-
259/2004-011-03.
TVA procedure number N-VT-6, Visual Inspection of Structural Welds Using the Criteria
of NCIG-01, requires quality control inspectors to perform an independent inspection of
completed work activities important to safety. A requirement of the inspection procedure
is independent verification the work was performed at the correct location. QC
inspection personnel failed to independently verify that welds designated as weld
numbers MS-1-WO 03017394016-008 in work order 03-017394-016, weld numbers
PCI-1-WO 03017394002-029 and -30 in work order 03-017394-002, and weld numbers
6
Enclosure
PCI-1-002-004, -005, and -006, and MS-1-WO 03017394006-047 and -048 in work
order 03-017394-006 were completed at the correct location. The deficient welds at
these locations identified in the discrepancies described under PER 03-017394
remained uncorrected. The licensee initiated PER numbers 04-000655 and 04-000705
to document and disposition these issues. The failure of QC to independently verify the
correct locations for numerous weld repairs is identified as a third example of Apparent
Violation 50-259/2004-011-03.
Further review of documents by the inspectors in Work Order 03-017394-006 disclosed
that weld data sheets had not been prepared for six welds shown on the Deficiency Fix
Request sketches. Consequentially, these welds had not been repaired. Paragraph 3.2
of TVA procedure MMDP-1, Maintenance Management System, requires work orders to
be developed to a level of detail appropriate for the circumstances which addresses the
aspects of the work, including the scope of the work and work instructions. When
approved procedures are available to cover all or part of the scope of work, MMDP-1
requires that the work order specify that work is to be performed in accordance with the
approved procedures. TVA procedure MMDP-10, Controlling Welding, Brazing, and
Soldering Processes, specifies the requirements for control of welding activities.
Section 3.3 of MMDP-10 requires work implementing documents and weld data sheets
be prepared and included in the work order for all welding activities. Paragraph 3.8.1 of
TVA procedure MMDP-1 requires independent/technical review of the work order to
insure the work order contains detailed work steps to perform the required work prior to
approval and implementation of the work orders. Work implementing documents and
weld data sheets for six welds which required restoration to the sizes shown on
Deficiency Fix Request, Sketch Number 31, referenced in PER 03-017339, were
omitted from Work Order 030017394-006. The omission was not identified when
performing the independent technical quality review. As a result, repairs to the deficient
welds at these locations were not performed. The licensees followup review of this
concern identified approximately 30 more examples where welds requiring repairs were
omitted from the work order, and therefore not performed. The omission of numerous
welds requiring repair from work orders is identified as the fourth example of Apparent
Violation 50-259/2004-011-03.
c.
Conclusions
An Apparent Violation (AV) of 10CFR50 Appendix B Criterion V, with four examples,
was identified involving repairs to the torus as part of the Long Term Torus Integrity
Program:
Numerous welds of torus structures requiring repairs were not evaluated or not
incorporated in documents identifying the need for repair and therefore not
repaired
Numerous welds were found to have been made at the incorrect location
QC inspection personnel failed to independently verify that numerous welds were
completed at the correct location
Numerous welds identified for repairs were omitted from work orders, and
therefore not performed
7
Enclosure
This Apparent Violation appears to represent a deficiency in the licensees quality
assurance program related to the Long Term Torus Integrity Program, involving the
failure to ensure compliance with instructions, procedures, and drawings, and to conduct
adequate oversight of such activities, which resulted in multiple examples of omitted
repairs.
A noncited violation was identified for failure to accurately measure welds during
walkdowns.
A noncited violation was identified for inadequate basis for accepting an undersized
weld.
E1.3
Corrective Actions to Correct Deficiencies in Long Term Torus Integrity Program
a.
Inspection Scope
The inspectors performed a review of the licensees corrective actions to resolve the
problems identified by NRC in performance of the torus walkdown inspections, errors in
engineering evaluation of the discrepancies identified by the walkdowns, deficiencies in
preparation of work orders for implementation of corrective actions, and errors in
implementing and inspecting the corrective actions.
b.
Observations and Findings
An independent walkdown inspection was performed by design engineering (Bechtel)
teams to reinspect the original torus integrity modifications to verify that the as-built
conditions that were identified and documented in walkdown packages were correct.
Included in this program were all welds not modified during Unit 1 recovery activities and
those not re-inspected in response to an NRC identified violation (NCV259/2003-010-
001) for inadequate inspection of as-built pipe supports. The licensee revised the
acceptance criteria for determining fillet weld sizes. Using the revised criteria, the actual
as-built fillet weld size was recorded on the walkdown drawing. The revised criteria did
not permit recording a weld size that was undersized by 1/16-inch for up to 25 percent of
the weld length. The minimum measured weld size was recorded. The inspectors
reviewed the results of the licensees reinspection program which showed that
approximately 10 percent of the welds were indicated to be undersized. The majority of
the undersized welds were found to be 1/16" less than indicated on the original
walkdown drawings. These dimension changes were primarily due to the change in the
inspection and acceptance criteria. However approximately 90 welds were identified
which were determined to be more than 1/16" smaller than documented on the
walkdown sketches. The licensee is re-evaluating these.
A review of design calculations by Bechtel engineers was initiated verify that the
calculations were adequate to evaluate discrepancies and that the basis for engineering
judgement is adequately documented. The review intends to ascertain that calculations
adequately document and justify use-as-is discrepancies and provide a sound
8
Enclosure
technical basis for use of engineering judgement. Critical thinking will be sufficiently
documented so that any qualified individual can independently review and understand
basis for calculation conclusions. A sample of calculations in other discipline areas will
also be reviewed by Bechtel to determine extent of using engineering judgement within
the calculations as a basis for acceptability of a condition without adequately
documenting the basis of the engineering judgement.
A review of design documents [calculations and design output documents (deficiency fix
request sketches)] was completed by Bechtel engineers to verify that discrepancies
identified during the torus walkdowns performed in summer/fall 2003 were adequately
evaluated in the design calculations and that discrepancies requiring repair were
included in engineering output documents. The inspectors examined the results of the
Bechtel review. Approximately 50 welds which required repair had not been shown on
the deficiency fix request sketches.
The licensee also performed a review of work orders issued by Unit 1 recovery planners
for implementation of torus modification repair activities to verify all work activities
specified in design documents and under PER 03-017339 corrective actions were
included in the individual work orders, and that completed work was properly
documented. The independent review of the work orders was accomplished by
comparing work activities listed in work orders to those shown on design drawings and
documentation of completed work activities (e.g. weld travelers, QC records, etc) to
verify that all work listed in individual work orders was completed in accordance with
licensees QA/QC program. The results of the licensees review and types of
deficiencies identified approximately 30 additional welds which were not included in the
work order instructions.
The inspectors reviewed the results of field validation walkdown inspection by two
independent teams, one team of two QC inspectors, and another team which included a
craft foreman and a field engineer. This validation inspection included a 100 percent re-
inspection of modifications completed in the torus for PER 03-017394 during the Unit 1
recovery program, to verify work completed in accordance with design requirements and
to identify any incomplete or inadequate work. Walkdowns were performed by two
independent teams and documented on torus weld verification checklists prepared
independently by each team. The inspectors reviewed the checklists documenting the
results of the initial re-inspection walkdowns. Subsequent to the inspection the licensee
completed the process of comparing the results from the two independent walkdown
teams and reconciling the differences. A total of 122 deficiencies were identified.
These were as follows: 19 with arc strikes, splatter, etc; 23 in wrong location; 14
requiring additional documentation; 14 unsatisfactory; and 52 undersized. The
inspectors considered that a reason for the majority of the undersized welds was use of
a more rigorous acceptance criteria.
9
Enclosure
c.
Conclusions
The licensee initiated a 100% review of weld repairs in the Long Term Torus Integrity
Program. The licensees corrective actions appear to be comprehensive to resolve the
problem. No additional violations or deviations were identified.
V. Management Meetings
X1
Exit Meeting Summary
On January 30 and February 13, 2004, the inspectors presented the inspection results
to Mr. Jon Rupert and other members on his staff, who acknowledged the findings. The
inspectors confirmed that proprietary information was not provided or examined during
the inspection. Additionally, on March 25, 2004, Mr. Mark S. Lesser summarized the
findings with Mr. Rupert and members of his staff via teleconference.
ATTACHMENT: SUPPLEMENTAL INFORMATION
Attachment
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee personnel
T. Abney, Licensing and Industry Affairs Manager
R. Cutsinger, Supervisory Civil Engineer
R. Drake, Unit 1 Maintenance/Modifications Manager
S. Kane, Licensing Engineer
G. Lupardus, Unit 1 Civil Design Engineer
J. Rupert, Vice-President, Unit 1 Recovery
S. Tanner, Nuclear Assurance Supervisor
J. Valante, Engineering Manager, Unit 1 Recovery
INSPECTION PROCEDURES USED
Engineering
Inspection of Structures, Passive Components, and Civil Engineering
Features at Nuclear Power Plants
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Items Opened
05000259/04-11-03
Failure to Implement Quality Assurance
Requirements Over Torus Repair Activities, Which
Resulted in Multiple Examples of Omitted Repairs
(Section E1.2)
Items Opened and Closed
05000259/04-011-01
Failure to Accurately Measure Welds During
Walkdowns (Section E1.2)
05000259/04-011-02
Inadequate Basis for Accepting Undersized Weld
(Section E1.2)
Discussed
None
Attachment
Documents Examined
TVA General Engineering Specification G-89, Requirements for Structural and
Miscellaneous Steel, Rev. 3, dated 4/26/94.
TVA General Engineering Specification G-29A, PS 0.C.1.2, Specification for Welding of
Structures Fabricated in Accordance with AISC Requirements for Buildings and
Inspected to the Criteria of NCIG-01, Rev 3, dated 7/28/99.
TVA General Engineering Specification G-29-S01, PS 4.M.4.4, ASME Section III and
Non-ASME (Including AISC, ANSI B31.1 and ANSI B31.5) Bolting Material, Rev 5,
dated 11/12/02.
Addendum 2 to Process Specification G-29-S01, 3.C.5.5, Visual Examination of Welds,
Rev 0.
MAI-1.3, General requirements for Modifications, Rev. 16, dated 9/15/03.
MAI-5.2, Bolting and Structural Connections, Rev. 14, dated 6/23/03.
MAI-5.9, Fabrication and Installation of Structural and Miscellaneous Steel, Rev. 11,
dated 6/16/03.
MMDP-1, Maintenance Management System, Rev. 6, dated 9/26/03
MMDP-10, Controlling Welding, Brazing, and Soldering Processes, Rev. 4, dated
1/15/03
NEDP-1, Design Basis and Design Document Control, Rev. 4, dated 7/9/01
NEDP-2, Design Calculation Process Control, Rev. 9, dated 7/17/03
NEDP-5, Design Document Reviews, Rev. 2, dated 7/9/01
SPP-3.1, Corrective Action Programs, Rev. 5, dated 12/18/03
SPP-9.3, Plant Modifications and Engineering Change Control, Rev. 9, dated 9/9/03
Nondestructive Examination Procedure No. N-VT-3, Visual Examination of Weld Ends,
Fit-ups, and Dimensional Examination of Weld Joints, Rev. 23, dated 1/24/03
Nondestructive Examination Procedure No. N-VT-6, Visual Examination of Structural
Welds Using the Criteria of NCIG-01, Rev. 6, dated 1/22/97
General Design Criteria Document BFN-50-C-7100, Design of Civil Structures, Rev. 13,
dated 12/20/00
TVA Nuclear Engineering Civil Design Standard DS-C1.7.1, General Anchorage to
Concrete, Rev 9, dated 8/25/99
Technical Instruction 0-TI-466, Plant Modification Related Work Order Preparation and
Processing, Rev. 1, dated 1/26/04
Drawing number 1-48E443-1, Structural Steel Drywell Floor Framing, Elev. 584 - 91/2",
Rev. 6
Drawing number 1-48E443-2, Structural Steel Drywell Floor Framing at Elev. 584 -
91/2", Azimuth 351 to 82, Rev. 6
Drawing number 1-48E443-6, Structural Steel Floor Framing at Elev. 584 - 91/2",
Sections & Details, Sheet 1, Rev. 5
Drawing number 1-48E443-7, Structural Steel Floor Framing at Elev. 584 - 91/2",
Sections & Details, Sheet 2, Rev. 5
Drawing number 1-48E443-8, Structural Steel Floor Framing at Elev. 584 - 91/2",
Sections & Details, Sheet 3, Rev. 6
Drawing number 1-48E443-12, Structural Steel Floor Framing at Elev. 584 - 91/2",
Sections & Details, Sheet 7, Rev. 2
Drawing number 1-48E443-15, Structural Steel Drywell Floor Framing, Elev. 584 -
91/2", Rev. 1
Drawing number 1-48E443-17, Structural Steel Mark and Assembly No. Listing, Elev.
584 -91/2", Sheet 1, Rev. 2
Drawing number 1-48E443-18, Structural Steel Mark and Assembly No. Listing, Elev.
584 -91/2", Sheet 2, Rev. 1
Drawing number 1-48E443-19, Structural Steel Mark and Assembly No. Listing, Elev.
584 -91/2", Sheet 3, Rev. 1
Drawing number 1-48E443-20, Structural Steel Mark and Assembly No. Listing, Elev.
584 -91/2", Sheet 4, Rev. 2
Drawing number 1-48W1218-7, Miscellaneous Steel Drywell - Relief Valve Vents Pipe
Supports, Rev. 13
Drawing number 1-48N1218-10, Miscellaneous Steel Drywell - Relief Valve Vents Pipe
Restraints, Rev. 9
Drawing number 1-48N1247-1, Miscellaneous Steel - Torus Ring Girder Internal
reinforcement, Rev. 0
Drawing number 1-48W1251-1, Miscellaneous Steel - Torus Walkway & Access
Platforms - El 540, Rev. 12
Drawing number 1-48W401-5, Mechanical Main Steam Relief Valve Vent Piping, Rev.
20
Drawing number 1-48W401-8, Mechanical Main Steam Relief Valve Vent Piping, Rev. 0
DCN 51019, Civil Drywell Lower Steel, EL 584
Work Order 02-008179-007, Re-install Drywell Steel Azimuth 30 to 60 Degrees on
Elevation 584.0 Per the Marked Up Drawing
Walkdown Package WDP-BFN-1-CEB-303-TOR-12, As-Built Miscellaneous Steel
Drywell Relief Valve Vent Pipe Restraints from Azimuth 0 to 90
Walkdown Package WDP-BFN-1-CEB-303-TOR-20, As-Built Miscellaneous Torus Ring
Girder Internal Reinforcement from Azimuth 0 to 90
Walkdown Package WDP-BFN-1-CEB-303-TOR-21, As-Built Miscellaneous Torus Ring
Girder Internal Reinforcement from Azimuth 90 to 180
Walkdown Package WDP-BFN-1-CEB-303-TOR-22, As-Built Miscellaneous Torus Ring
Girder Internal Reinforcement from Azimuth 180 to 270
Walkdown Package WDP-BFN-1-CEB-303-TOR-23, As-Built Miscellaneous Torus Ring
Girder Internal Reinforcement from Azimuth 270 to 0
Walkdown Instruction WI-BFN-0-GEN-01, General requirements for BFN Unit 1
Walkdowns, Rev. 1, dated 2/22/02
Walkdown Instruction WI-BFN-0-CEB-02, Walkdown Instructions for Seismic Issues
(Civil), Rev. 0, dated 3/19/02
DCN 51020, Civil Drywell Lower Steel, EL 563
DCN 51019, Civil Drywell Lower Steel, EL 584
Torus Weld Verification Check Lists, for Craft/Resident Engineer Team, and Quality
Control Team
PER 03-017339-000, Construction Discrepancies Identified in Unit 1 Torus
PER 03-022390-000, Weld Repair Performed at Incorrect Location in Bay #1 of Unit 1
Torus
PER 03-022683-000, Discrepancies Between Weld Locations Identified in the Field and
Those Shown on the Drawings in Unit 1 Torus
PER 03-022702-000, QC Inspectors Identified Three Welds which were Completed at
Incorrect Locations in Unit 1 Torus
PER 03-023354-000, QC Inspectors Identified Five Welds which were Completed at
Incorrect Locations in Unit 1 Torus
Deficiency Fix Requests, Sketches 4, 5, 6, 29, 30, 31, and 36, Corrective Actions for
PER 03-017339