ML18025B631
| ML18025B631 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 08/17/1981 |
| From: | Mills L TENNESSEE VALLEY AUTHORITY |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML18025B630 | List: |
| References | |
| NUDOCS 8109090425 | |
| Download: ML18025B631 (14) | |
Text
0 TENNESSEE VALLEYAUTHORIT>Y<~ p~( f CHATTANOOGA, TE~NESsEE 374ot 400 Chestnut Street Tower II Bl r'~r;2~
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August 17, 1981 Mr. James P. O'Reilly, Direct;or Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Region II - Suite 3100 101 Marietta Str eet Atlanta, Georgia 30303
Dear Mr. O'Reilly:
This is in response to R.
C. Lewis'uly 14, 1981 letter to H. G. Parris, Repor t Nos. 50-259/81-13,
-260/81-13, and -296/81-13, concerning activities at the Browns Ferry Nuclear Plant which appeared to violate NRC requirements.
Enclosed is our response to Appendix A, Notice of Violation, and Appendix B, Notice of Deviation.
As discussed with F. S. Cantrell of your staff on August 13,
- 1981, TVA was granted a four-day extension on the filing of this response.
If you have any questions, please call Jim Domer at FTS 857-2014.
To the best of my knowledge, I declare the statements contained herein are complete and true.
Very truly yours, TENNESSEE VALLEY AUTHORITY Enclosure M. Mi ls, nag r Nuclear Regulation and Safety 8109090425 8l0831 PDR ADOCK 05000259
, 8 PDR An Equal Opportunity Employer
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I ENCLOSURE
RESPONSE
TO R.
C. LE!~IS'ETTER TO H. G.
PARRIS DATED JULY 14, 1981 INSPECTION REPORT NOS.
50-259/81-13, 50-? 60/81-13, AND 50-296/81-13 Violation A 10 CFR 50, Appendix B, Criterion VI, as implemented by Topical Report TR75-1A, requires that measures be established to assure that procedural documents and changes thereto for activities affecting quality be distributed to and used at the locations where the activities are performed.
Contrary to the above, on May 19,
- 1981, measures had not been established to assure that procedural documents (and changes thereto) for activities affecting quality were distributed to and used at the locations where the activities are performed in that document control procedures did not assure that proper revisions of procedures for safety related weld nondestructive examinations were distributed to and used at the work locations.
This is a Sever ity Level V Violation (Supplement II.E).
Admission or Denial of the Alleged Violation 2.
TVA admits the violation occurred as stated.
Reason for the Violation if Admitted Controlled copies of NDE procedures were available at the plant site for use by users, but the only controlled copy was in the plant superintendent's office.
This practice dates from a period of time when the plant staff was much smaller and more centrally located.
At this time, the one controlled copy in the plant superintendent's office was adequate.
3.
Corrective Ste s 1lhich Have Been Taken and Results Achieved For the time being, inspectors will continue using the superintendent's copy of NDE procedures.
These inspectors were instructed on June 10, 1981 by the QA supervisor about where the controlled procedures were located and about their responsibility to refer to these procedures.
4.
Corrective Steps Mhich Mill be Taken to Avoid Further Violation The OOAM will be revised to state that division procedures used to perform work must be readily available to the user.
Practices will he changed to provide controlled copies of division procedures to using organizations through the plant DCC.
5.
Date 3Jhen Full Com liance Hill be Achieved The OQAM will be revised by October 15, 1981.
The new practices regarding distribution of controlled division procedures will be complete by January 1, 1982.,
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Violation B 10 CFR 50, Appendix B, Criterion V, as implemented by TVA Topical Report TR75-1A, requires that activities affecting cuality be prescribed by instructions, procedures or drawings. and that the activities be accomplished in accordance with these instructions, procedures or drawings.,
( 1)
Procedure BF.-45 R6 requires penetrant examination of socket welds ig safety-related piping.
Morkplan 8476 R2 provides instructions for
- assembly, welding and inspection of safety-related Emergency Equipment Cooling Mater system hypochlorite injection piping which includes slip on flange welds (considered socket welds).
The workplan implements BF-45 requirements providing instructions as to which welds require penetration examination.
(2)
Safety-related structural welding is performed to the Structural Melding Code (AMS D1.1).
This code specifies transition requirements at welds,between members of different thickness.
Contrary to the above, on May 20, 1981, activities affecting quality were not prescribed and accomplished in accordance with instructions in that:
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( 1)
Morkplan 8476 R2 required penetrant examination of slip on flange to pipe welds 1AEECM through 7AEECM (flange to pipe OD welds) but did not specify examination of the welds opposite these welds on the same flanges (flange to pipe end welds).
As a result, the examinations were not performed.
(2)
Neither the procedure for visual examination of structural welds (procedure 3.C.5.2.(b))
nor other procedures contained requirements for examination of structural welds for proper weld transitions between members of different thickness.
This is a Severity Level V Violation (Supplement II.E).
Item B.I l.
Admission or Denial of the Alleged Violation TVA admits the violation occurred as stated.
2.
Reasons for the Violation if Admitted Morkplan 8476 F2 indicates in step No.
5 that a penetrant examination would be performed on all welds using penetrant procedure N-PT-1.
Personnel performing the welding inspections were not aware that the inside flange to pipe welds existed as they were not part of the work instruction and consequently the welds were not penetrant examined.
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0 Corrective Ste s Uhich Have Been Taken and Results Achieved On May 22,
- 1981, a
. evision was made to workplan 8476 to incorporate the pipe end to flange inside diameter welds into the wor kplan.
fields 1G through 8GEKCH were added to the weld map and weld data sheets by this revision.
These welds have been penetrant tested per instructions in workplan 8476.
4.
Corrective Ste s Which Mill Be Taken to Avoid Further Violations Personnel were instructed on August 7, 1981 that in the future a more detailed review should be performed of all workplans to ensure that the work instructions are adequate as to which welds will require penetrant examination.
5.
Date
>1hen Full Compliance Milt Be Achieved Welds lG through 8GEEC~if were penetrant tested on May 24, 1981.
Item B.2 Admission or Denial of the ALLeged Violation TVA admits the violation occurred as stated.
2.
Reason for the Violation if Admitted Personnel involved with initial preparation of DPM No.
N73M2 apparently overlooked the AMS 'requirement.
3.
Corrective Steps
)1hich Have Been Taken and Results Achieved The referenced visual examination procedures are no Longer authorized for use by TVA Nuclear Power due to a revision to DPM No.
N73M2.
All NDE in the future will be performed usinp, procedures in DPM No.
N80E3.
This change was made May 21, 1981, during the first period of inspection.
The applicable procedures in DPM No.
N80E3 are being reviewed to assure inclusion of requirements for examination of weld transitions between members of different thickness.
4.
Corrective Ste s 1Jhich lliLL be Taken to Avoid Further Violations The applicable procedures in DPM No.
N80E3 will be evaluated and corrective steps made as necessary to include requirements for examination of weld transitions.
In the interim, plants will be instructed to include requirements in the workplan for examination of weld transitions in accordance with the applicable code.
5.
Date 11hen Full Compliance lJiLL Be Achieved TVA will be in full compliance on or before December 31, 1981.
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Deviation The Browns Ferry FSAR indicates that the Code applicable to the containment piping penetrations is ASME Section III ( 1q65 edition).
ASME Section III refers to ASME Section VIII for radiography on containment penetration welds.
ASME Section VIII provides fiLm density, penetr ameter, and location marker requirements for the radiography.
Contrary to the above, the examples of main steam and feedwater system piping containment penetration weld radiographs listed-below do not comply with the code film density, penetrameter and location marker requirements.
fteld Penetration Piping Svstem Urit GMS-1-36 Gh1S-1-38 GFN-1-36 GMS-2-42 GMF-2-38 GMS-3-36 X-7A X-7B X-9A X-7D X-9B X-7A Hain Steam Main Steam Feedwater Main Steam Feedwater Main Steam 1.
Admission or Denial of the ALLeged Deviation TVA admits the deviation occurred as stated.
2.
Reasons for the Deviation if Admitted The primary cause of the stated deviation vas the inherent difficulty of radiographing these particular weldments in the field environment coupled with the less sophisticated radiographic equipment available at the time these radiographs were made (some are in excess of 10 years old).
A contributing factor was that the examinations were performed to the 1965 edition of ASME Section VIII which is less stringent than present day requirements..
3.
Corrective Steps
>lhich Have Been Taken and Results Achieved K
The subject radiographs were jointly viewed by L. D. 7ajac of USNRC and M. E. Gothard, K. A. Hastings, and R.
M. Jessee of TYA on July 23, 1981 in Atlanta, Georgia.
The results of this meeting were discussed with A. R. Herdt of USNRC before the exit and are detailed in the following paragraph.
a)
GMS-1-38 1)
The film density of the weld area is not within the density range of minus 15 or plus 305 of the penetrameter film density.
2)
The above density discrepancies vere noted using digital readout equipment which is much more sophisticated and accurate than the comparative equipment which was available when these radiographs were made.
Based on
- this, we believe that the radiographs are not out of tolerance by an excessive amount and that the quality of the welds can be accurately determined.
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0 b)
GFH-1-36 Film numbers (0-2) are in the weld area.
These numbers are immediately adjacent to the weld and as such do not preclude viewing of the weldment for acceptance.
This does not violate 1965 ASME Section VIII code requirements.
2)
Films (0-2), (2-4), (4-6),
( 16-18) are overexposed in the weld area to be evaluated.
The applicable code does not have a maximum density (i.e. overexposed) tolerance.
It was mutually agreed between TVA and HRC personnel that these radiographs were viewable and therefore acceptable.
3)
The film density of the penetrameter is unacceptable (same comment as for GMS-1-38).
c)
GHS-1-36 The film (0-2) is underexposed in the weld area to be evaluated.
Portions of this radiograph do not comply with minimum density (i.e. underexposed) requirements.
- However, by utilizing code acceptable composite viewing techniques we believe that the quality of the weld can be accurately determined.
Refer also to GNS-1-38.
2)
Same
- comment, as for GHS-1-38 3)
One-half of the backing r ing width is burned away at film markers (20-1).
After a car eful review of this segment, it was mutually agreed between TVA and HRC personnel that the backing ring was pulled away in this area.
This is an acceptable condition.
d)
GHS-2-02 The film (0-2) is overexposed in the weld area to be evaluated.
Refer to the response for GF11-1-36, (2).
2)
The required penetrameter hole is not discernable on films (18-20) and (15-18).
This radiograph was made with the source placed on the axis of the weld joint and the complete circumference was radiographed with a single exposure.
As such, only 3 uniformly spaced penetrameters are required by the applicable code.
The weldment meets this requirement.
3)
Same comment as for Gt~8-1-38.
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e)
GHS-2-38 1)
The penetrameter is in the weld area on films (A-C),
(G-I), (I-J), and (K-H).
The penetrameter extends approximately 1/8-inch over the crown of the weld.
This is in violation of the applicable
- code, but the weld root and the majority of the weldment is readily viewable and we believe that any deleterious flaws would be visible through the image of the penetrameter.
No flaws were visible and we believe this weld is acceptable.
2)
Film markers (Q-S) are in the weld area.
Refer to the response for GFW-1-36, (1).
3)
Same comment as for GHS-1-38.
f)
GPS-3-36 1)
The required penetrameter hole is not discernible on films (A-B) and (C-D).
This set of radiographs contains number 12, 15, and 17 penetrameters, and a note on the readers form specifying that supplemental ultrasonic examinations were performed.
Until we determine which penetrameter is required, the above concern cannot be addressed.
Ve expect to provide an additional report by January 1,
1982 to resolve this deviation.
2)
Same comment as for GHS-1-38 Corrective Steps Which Will Be Taken To Avoid Further Deviations Steps have been initiated to resolve the questions raised on weld GYS-3-36 and to review other typical penetration welds from Browns Ferry Nuclear Plant.
5.
Date When Full Com liance Will Be Achieved An additional report will be provided by January 1,
1982 to address item 3f of this report.
It is anticipated that the corrective actions will be completed by January 1,
1982.
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