ML18025B654
| ML18025B654 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 09/04/1981 |
| From: | Mills L TENNESSEE VALLEY AUTHORITY |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML18025B652 | List: |
| References | |
| IEB-79-14, NUDOCS 8109240573 | |
| Download: ML18025B654 (10) | |
Text
TENNESSEE VALLEYAUTHORITY CHATTANOOGA, TENNESSEE 37401 400 Chestnut Street Tower II September 4,
1981 in o
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Mr. James P. O'Reilly, Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Region II - Suite 3100 101 Marietta Street Atlanta, Georgia 30303
Dear Mr. O'Reilly:
This is, in response to R.
C. Lewis'uly 22, 1981 letter to H. G. Parris, Report Nos. 50-259/81-16,
-260/81-16, and -296/81-16, concerning activities at the Browns Ferry Nuclear Plant which appeared to violate NRC requirements.
Enclosed is our response to Appendix A, Notice of Violation.
An extension of the original response date was discussed with F.'. Cantrell of your staff on August 18, 1981. 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
. M. ills, M nager Nuclear Regulation and Safety Enclosure
( 810/240573 8109'DR ADQCK 05000259
,Q.'DR'n Equal Opportunity Employer
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ENCLOSURE
RESPONSE
NRC INSPECTION REPORT NOS.
50-259/81-16, 50-260/81-16, AND 50-296/81-16 R.
C. LEHIS'ULY 22, 1981 TO H. G.
PARRIS Item A
10 CFR 50, Appendix B, Criterion V as implemented by TVA Topical Report TVA TR 75-01 paragraph 17.2.5 requires activities affecting quality be accomplished in accordance with procedures.
TVA Process Specification 1.C.1.2.(b),
dated 2/1/81, paragraph 9.8 and 15.1 require welders to remove arc strikes and slag from welds and adjacent base material.
TVA Process Specification 3.M.5.1.(d), dated 3/21/79, paragraph B.1 requires welding inspectors to assure that all welds and adjacent base material are free of avc stvikes, weld spatter and slag.
Paragraph B.O of 3.M.5.1.(d) requires welding inspectors to inspect all applicable welds for compliance to drawing weld size requirements.
Contrary to the above, on June 24, 1981, activities affecting quality were not accomplished in accordance with procedures in that the following were noted on completed and accepted welds on torus modification catwalk knee braces:
1.
Numerous are strikes.
2.
A large amount of weld splatter.
3.
Several welds with adhering slag.
The reinforcing fillet on a groove weld was approximately 1/16-inch under size.
This is a Severity Level V Violation (Supplement I.E).
1.
Admission or Denial of the Alle ed Violation TVA admits the violation occurred as stated.
2.
Reasons for the Violation if Admitted The weld inspections for the first two knee brace assemblies weve scheduled to be performed upon completion of the entire subassembly.
At this time, however, placement of some parts made visual access to certain welds very difficult. This violation occurred when an inspector inadvertently overlooked deficient welds in this relatively inaccessible area.
3.
Corrective Ste s Which Have Been Taken and Results Achieved All welds performed and inspected by the Power Service Shops on the unit 1, cycle 4 torus modification have been r einspected.
Deficient welds were repaired to meet applicable requirements.
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Corrective Ste s Which Will be Taken to Avoid Further Violations On June 25,
- 1981, QA management at the Power Service Shops reinstructed QC inspectors on weld S.nspection techniques and acceptance criteria.
Managers observed inspectors performing weld inspections to ensure they understood the applicable requirements.
Additionally, the weld inspection sequence was changed to provide for in-process inspection of the subject welds immediately upon their completion while they were more accessible.
5.
Date When Full Com lienee Will be Achieved TVA is now in full compliance.
Item B 10 CFR 50, Appendix B, Criterion IX as implemented by TVA Topical Report TVA 75-01 paragraph 17.2.9 requires measures be established to assure special processes, including nondestructive testing are controlled.
TVA procedure NPT-NC-1, RevS. sion 1 paragraph 4.2 requires masking material be removed prior to liquid penetrant (PT) application.
TVA procedure NPT-1, the applicable penetrant procedure for inservice inspection, requires that any indication believed to be non-relevant be regarded as a defect and reexamined to determine whether defects are present and that linear indications greater than 1/16-inch in length be rejected.
Contrary to the above, on June 24,
- 1981, adequate measures were not established to control nondestructive testing in that:
1.
On a torus vent downcomer pipe tiebar removal site a smeared surface residue was visible after cleaning and prior to the application of penetrant.
2.
The Level II examiner for PT inspection of inservice inspection weld HS-1-H6 was not familiar with PT acceptance standards, did not have equipment available to measure indications, and accepted a relevant linear indication greater than 1/16-inch in length as being non-relevant without re-inspection.
This is a Severity Level V Violation (Supplement I.E.).
B-1 1.
Admission or Denial of the Alle ed Violation TVA admits the violation occurred as stated.
2.
Reasons for the Violations if Admitted gag - pr ~
~The QC inspector did not believe that the residue was sufficient to mask any indications that would be revealed by the'inspection.
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3.
Corrective Ste s Which Have Been Taken and Results Achieved On the weld in question the TVA inspector found an indication as part of this same inspection and rejected the weld.
The weld was subsequently
- repaired, thoroughly cleaned, inspected, and accepted.
4.
Corrective Ste s Which Will be Taken to Avoid Further Violations The quality control inspectors were reminded on June 24, 1981, that welds must be thoroughly cleaned before the application of penetrants.
5.
Date When Full Com liance Will be Achieved Full compliance was achieved on June 24, 1981.
B-2 1.
Admission or Denial of the Alle ed Violation TVA admits the violation occurred as stated.
2.
Reasons for the Violation if Admitted The examiner was hired from the Division of Construction where he used the weld acceptance criteria specified in Section III of the ASME Code.
After reporting to work for the Division of Nuclear
3.
Corrective Ste s Which Have Been Taken and the Results Achieved The examiner's qualifications were revoked until he was retrained and recertified in accordance with DPM N75C01 on July 2, 1981.
All PT examinations that he performed were reexamined and no reportable indications were found.
Corrective Ste s Which Will be Taken to Avoid Further Violations In the future all weld examiners will be trained and certified in accordance with DPM N75C01 before being permitted to perform any weld examination.
5.
Date When Full Com liance Will be Achieved Retraining and reexamination of the welds in questions were completed on July 7, 1981.
Item C
10 CFR 50.55.a.(g)(4) requires in part that, "Throughout the service life...components (including supports)...shall meet the requirements
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set forth in Section XI of editions of the ASME Boiler and Pressure Vessel Code".
Section XI of the ASME Boiler and Pressure Vessel Code requires that support settings of constant and variable spring type
- hangers, snubbers and shock absor hers be inspected and verified.
Contrary to the above, ASME Section XI requirements have not been met in that for inspections performed on spring type hangers, snubber s, and shock absorbers during previous outages and the current outage, support settings were not inspected and/or verified.
This is a Severity Level V Violation (Supplement I.E.).
1.
Admission or Denial of the Alle ed Violation TVA admits the violation occurred as stated.
2.
Reasons for the Violation if Admitted The Division of Nuclear Power (NUC PR) has recorded field settings in the past but has not had any design acceptance allowance standards for comparison.
We are currently in the process of obtaining acceptance standards from the Division of Engineering Design (EN DES).
3.
Corrective Ste s Which Have Been Taken and Results Achieved NUC. PR has requested EN DES to provide the field settings obtained for IE Bulletin 79-14 for use in verification of hanger settings on an interim basis (until the analysis for IE Bulletin 79-14 is
- completed.,
reference L. M. Mills'etter to J.
P. O'Reilly dated June 18, 198l).
Corrective Ste s Which Will be Taken to Avoid Further Violations When the analysis for IE Bulletin 79-14 is complete, the hanger settings will be included in the Browns Ferry ISI program.
On an interim basis the field settings will be used for verification.
5.
Date When Full Com liance Will be Achieved Interim hanger settings will be obtained from EN DES for verification during ISI by October 16, 1981.
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