ML18030B247
| ML18030B247 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 03/31/1986 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8604210088 | |
| Download: ML18030B247 (8) | |
Text
0 TENNESSEE VALLEYAUTHORITY 5N 157B Lookout Place OO AP), lg pP
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March 31, 1986 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 50-259/86-03, 50-260/86-03, 50-296/86-03
RESPONSE
TO VIOLATIONS Enclosed is our response to J.
A. Olshinski's February 28, 1986 letter transmitting IE Inspection Report Nos. 50-259/86-03, 50-260/86-03, and 50-296/86-03 for our Browns Ferry Nuclear Plant which cited TVA with one Severity Level VI Violation and one Severity Level V 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 t
complete and true.
Very truly yours, TENNESSEE VALLEY AUTHORITY Enclosure cc:
Mr. James Taylor, Director (Enclosure)
Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C.
20555 R.
ridley Manager of Licensing 8b04210088 860331 PDR ADOCK 05000259 6
PDR An Equal Opportunity Employer
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I
ENCLOSURE
RESPONSE
NRC INSPECTION REPORT NOS.
50-259/86-03, 50-260/86-03, AND 50-296/86-03 J. A. OLSHINSKI'S LETTER TO S. A. MHITE DATED FEBRUARY 28$
1986 Item 1 10 CFR 50 Appendix B, Criterion V, requires in part that activities affecting quality shall be prescribed by documented instructions or procedures and accomplished in accordance with these instructions or procedures.
Browns Ferry Nuclear Plant Standard Practice No. BF-14.3 requires all assigned areas to be inspected at least once a month for housekeeping requirements and documented on a Form 96.
TVA's Standard Practice No. BF-14.36 requires aerosol cans to be stored in flammable liquid storage cabinets or in an area away from all sources of heat and the area posted.
TVA's Liquid Penetrant Procedure No. N-PT-1 requires, in part, that, after final examination, the test surface shall be cleaned with an approved cleaner.
TVA's Operational Quality Assurance Manual, Part II, Section 1.2, defines housekeeping as encompassing all activities related to control of cleanliness of facilities, cleanliness of material and equipment, fire prevention, fire protection, control of access, protection of equipment, radioactive contamination control, and storage of solid radioactive waste.
Contrary to the above instructions and procedures, on January 14, 1986, the following discrepancies were observed in housekeeping:
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a:
Anti-C clothing, clean air respirators, tape and trash on floor in Unit 2 dress out, area.
b.
Trash, dirt, grinding dust, used grinding wheels and cigarette butts on floor in Unit 2 Access Room area posted as "Highly Contaminated Area,"
(condition reported to have existed for several months and also reported as deficient housekeeping
- area, but no action taken to improve conditions).
c ~
Trash on floor and platforms in Unit 2 drywall:
among items observed was partial filled can of highly flammable DUBL CHEK, Cleaner/Remover 60.
d.
Penetrant material observed on 6.inch diameter reactor water cleanup system piping, a platform below where the examination had been performed on other piping.
This is a Severity Level V violation (Supplement 1).
Admission or Denial of the Alle ed Violation TVA admits the violation.
2.
Reason for the Violation Many activities were simultaneously being conducted in the drywell by various plant groups.
There was no group specifically designated as being responsible for overall cleanliness of the drywell and dressout
'rea.
3.
Cox'rective Ste s Mhich Have Been Taken and Results Achieved The dxywell and dxessout areas have been cleaned and housekeeping deficiencies corrected.
A responsible person has been assigned to the different areas of the reactor building to coordinate the housekeeping work until a xesponsible group is designed for cleanliness activities.
4.
Corrective St s Which Will Be Taken to Avoid Further Violations Plant Standard Practice BF-14.3, "Periodic Plant and Housekeeping Inspections" is being revised to assign a responsible group to maintain cleanliness during unit outages.
This group will perform inspections to identify areas deficient in cleanliness and to immediately correct, conditions as needed.
Additionally, Site Director Standard Practice 24.2 is being, originated to control access to liquid penetrant sprays and other flammable materials.
t 5.
Date When Full Com liance Mill Be Achieved, Full compliance will be achieved on April 21,
- 1986, when the responsible group for cleanliness is fully functional.
SDSP 24.2 will be in place by April 21, 1986.
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e, 10 CFR 50, Appendix B, Criterion V, requires in part that activities affecting quality shall be prescribed by documented instructions or procedures and accomplished in accordance with these instructions or procedures.
Browns Ferry Nuclear Plant Modification'nd Addition Instruction No. BF-MAI-22 paragraph 4.0 and TVA's General Specification No. G-28, paragraph 2.4.2.2 requires that temporary attachments be completly removed and the area ground smooth and inspected by the liquid penetrant or magnetic particle methods.
Contrary to the above, on January 14, 1986, fillet welds were observed where temporary attachments have been broken off on a recirculation system spool piece between welds GR-2-54 and GR-2-55.
One fillet had been welded on the spool piece longitudinal weld seam which is contrary to Browns Ferry Workmanship practice.
Discussion with supervision in the welding department indicates that the welds had not been authorized by that department.
This is a severity Level IV violation (Supplement I).
1.
Admission or Denial of the Alle ed Violation TVA admits the violation.
2.
Reasons for the Violation The fillet welds appear to be associated with temporary construction lugs utilized during original plant construction.
Construction procedure BF-45 requires documentation of such activities, although records related to this item have not been located.
3.
Corrective Ste s Which Have Been Taken and Results Achieved A maintenance request has been written to remove the existing fillet welds by grinding in accordance with plant Standard Practice BF-6.1 and BF-6.2.
Nondestructive testing will be carried out in accordance with Quality Engineering Program Manual 1502.07 for proper visual, penetrant, and ultrasonic examinations.
s 4.
Corrective Ste s Which Will Be Taken to Avoid Further Violations The controls in place today are such that this type of violation is prevented.
Work instructions are more restrictive and now must identify critical systems, structures, and components (CSSC) work; applicable plant instructions; quality control; and post-maintenance test requirements.
Instructions requiring American Society of Mechanical Engineers,Section XI work must contain a review sheet for the Authorized Nuclear Inspector (ANI) or Authorized Nuclear Inservice Inspector (ANII) and shall be forwarded to the ANI/ANIIfor his review in accordance with Standard Practice BF-17.8.
Removal of the fillet welds and final examinations will be completed before unit 2 cycle 5.
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