ML18029A635
| ML18029A635 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 06/14/1985 |
| From: | Domer J TENNESSEE VALLEY AUTHORITY |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8507110114 | |
| Download: ML18029A635 (7) | |
Text
TENNESSEE VALLEYAUTHORITY CHAT)TANOOGA. TENNESSEE 37401 400 Chestnut Street Tower II June 14, 1985 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 50-259/85-26, 50-260/85-26, 50-29 5-
RESPONSE
TO VIOLATION Enclosed is our response to R.
D. Walker's May 14, 1985 lette to H.
G. Parris transmitting IE Inspection Report Nos.
50-259 ~
50-260/85-26, and 50-296/85-26 for our Browns Ferry Nuclear which cited TVA with one Severity Level IV Violation.
If you have any questions, please get in touch with R.
E. Alsup at FTS 858-2725.
To the best of my knowledge, I declare the statements contained herein are complete and true.
Very truly yours, TENNESSEE VALLEY AUTHORITY A, Domer, Chief Nuclear Licensing Branch Enclosure cc:
Mr. James Taylor, Director (Enclosure)
Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C.
20555 0
8507iiOii4 850614 PDR aDOCK 0500aa59 8
PDR An Equal Opportunity Employer WED/
RESPONSE
NRC INSPECTION REPORT NOS.
50-259/85-26, 50-260/85-26, AND 50-296/85-26 ROGER D. WALKER'S LETTER TO H. G.
PARRIS DATED'AY 14, 1985 Enclosure 1
Item 1
10 CFR 50, Appendix B, Criterion V, requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings and shall be accomplished in accordance with these instructions, procedures and drawings.
Browns Ferry Instruction BF MAI-23 contains the following requirements:
Paragraph 6.1.1 requires that manufacturer's recommended installation procedures shall be followed.
Paragr aph 6.1.6 requires that all threaded fasteners shall be provided with locking devices.
Paragraph 6.4.2 requires that component standard supports shall be within the range of support ad)ustment and that full thread engagement of all parts must be maintained.
Paragraph 7.3 requires that for new supports, the Quality Control (QC) inspector shall verify that the general configuration is correct.
Paragraph 7.4 requires that the craft foremen and QC inspector shall verify that all threaded connections are installed snug plus 1/4 turn with full thread engagement and locking devices.
Contrary to the above, activities affecting quality were not being accomplished in accordance with documented procedures and drawings in that a field inspection of seven QC accepted pipe supports revealed five supports with deviations from the documented requirements.
As a result, these supports may not be able to perform their intended function as required by the design.
These five supports are identified below:
1.
Unit 1, residual heat removal (RHR) support No. R-108, Rev.
1, snubber bolt connections were loose.
The pipe clamp was installed with single nut instead of double nuts specified by the manufacturer's instructions.
2.
Unit 1, core spray support No. H-83, Rev. 1, configuration was incorrect in that a bolt connection was used instead of a pin connection specified by the drawing.
A lack of thread engagement for three bolts that were used for the pipe clamp installation was noted.
3.
Unit 3, RHR suppor t No. R-62, Rev. 2, drawing called for a 5/16" all around weld was not achievable, actual weld'as 1/4" on two sides.
A lack of thread engagement for four double nuts that were used for U-bolt installation was noted.
4.
Unit 3, RHR support No. R-ll, Rev.
3, the lock nut was loose for the strut installation.
Page 2
Item 1 (continued) 5.
Unit 3, RHR support No. R-105, Rev. 2, a, 3/16" fillet weld was missing at two weld attachments.
The pipe clamp was installed with a single nut without any locking devices.
The manufacturer's instructions require double nut installation.
This is a Severity Level IV violation (Supplement I).
l.
Admission or Denial of the ~Alla ed Violation TVA admits the violation occurred as stated.
2.
Reasons For the Violation Work instructions failed to include sufficient detail of manufacturer's recommended installation procedures and design drawing r equirements.
The requirements were not referenced in the instructions, and no requirements were made for independent verification of the manufacturer's suggested practice.
Requirements for locking devices, thread engagement, and double nuts were not clearly communicated, rather the skill of the craft was relied upon.
Additionally, foremen and QC were not adequately trained to inspect 'in accordance with MAI-23.
Craftsmen and QC inspectors made technical decisions instead of stopping work to request clar ifications.
3.
Corrective
~Ste s Which Have Been Taken and Results Achieved To correct deficiencies in the program, reinspection of supports is in progress per Special Mechanical Maintenance Instruction (SMMI) 14.4.1.3-L, which includes additional detail instruction for reinspections.
Teams consisting of an engineer from the Office of Engineering (OE), a steamfitten, and a
QC inspector are reexamining and repairing, as necessary, a total of 468 pipe supports on unit 3 to allow startup of that unit, Where a difference between the installed and design drawing configuration exists, the support will either be repair ed in accordance with the drawing or appropriate measures will be taken to revise all documenbation associated with the support.
In such instances, an analysis will be performed by OE, if necessary, to determine if an unqualified configuration has existed.
Unit 2 pipe supports have been reinspected by field forces.
All deficiencies with regard to the pipe supports for units 1 and 2 will be resolved consistent with the progr am in place for unit 3.
Page 3
Item 1 (continued)
'orrective
~Bte s Which Will Be Taken to Avoid Further Violations Procedures will be revised to ensure holdpoints, and acceptance criteria are more clearly defined.
Individuals responsible for the noted discrepancies will be removed from duty to receive documented training in accordance with plant procedures on corrective personnel action.
Procedure MAI-23 will be revised and all training accomplished before star tup of unit 2.
All reinspection and analysis will be completed prior to respective startups of units l, 2, and 3.
L