ML18031A678
| ML18031A678 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 07/31/1986 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8608110434 | |
| Download: ML18031A678 (8) | |
Text
TENNESSEE VALLEYAUTHORITY CHATTANOOGA. TENNESSEE 37401 5N 157B Lookout Place JUL 51 I86 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,
-260/85-26, 296/85-2 UPDATED RESPONSE By J.
A. Domer's letter to you dated June 14,
- 1985, we submitted our response to Browns Ferry report 85-26.
A revised response to part 4 was submitted by J.
A. Domer's letter to you dated July 3, 1985.
Enclosed is a revised response to parts 3, 4, and 5 of the subject violation.
This revision is submitted to reflect the shift in our work priorities to unit 2, our training
- plans, and the corrective actions taken.
If you have any questions, please get in touch with M. J.
May at (205) 729-3566.
To the best of my knowledge, I declare the statements contained herein are complete and true.
Very truly yours, TENNESSEE VALLEY AUTHORITY R.
G dudley, Di ector Nuclear Safety and Licensing Enclosure cc:
Mr. James Taylor, Director (Enclosure)
Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C.
20555 8608110434 0731 PDR ADOCK 05000259 8
86 PDR An Equal Opportunity Employer
1'
REVISED RESPONSE NRC INSPECTION REPORT NOS.
50-259/85-26,'0-260/85-26, AND 50-296/85-26 ROGER D. WALKER'S LETTER TO H. G.
PARRIS DATED MAY 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 dxawings.
BFN Modifications and Additions Instruction (MAI) 23 contains the following requirements:
Paragraph 6.1.1 requires that manufacturer's recommended installation procedures shall be followed.
Paxagxaph 6.1.6 requires that all threaded fasteners shall be provided with locking devices.
Paragraph 6.4.2 requires that component standaxd supports shall be within the range of support adjustment and that full thread engagement of all parts must be maintained.
Paragraph 7.3 requix'es 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 thxeaded connections are installed snug plus 1/4 turn with full thread engagement and locking,devices.
Contxary 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:
l.
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 manufactuxer'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 thxee bolts that were used for the pipe clamp installation was noted.
3.
Unit 3, RHR-support No. R-62, Rev.
2, drawing called for a 5/16" all around weld was not achievable, actual weld was 1/4" on two sides.
A lack of thread engagement fox 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.
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).
3.
Corrective Ste s Which Have Been Taken and Results Achieved MAI-23 has been revised and expanded to include additional vendor information and to more clearly define detailed acceptance criteria Eor pipe support installation.
A third party reinspection of unit 2 supports is in progress per Special Mechanical Maintenance Instruction (SMMI) 14.4.1.3-L, which includes additional detail instruction Eor reinspections.
This reinspection includes control rod drive piping and external and internal torus attachments and hangers.
The reinspection teams consist of an engineer from the Office of Engineering (OE),
a steamfitter, and a
QC inspector.
Retraining was accomplished with all QC inspectors who were needed to inspect pipe supports.
To date, approximately 850 of 936 reinspections have been completed on unit 2 by the reinspection teams.
Where a difference exists between the installed support and design drawing, the support will either be repaired in accordance with the design drawing or appropriate measures will be taken to revise all documentation associated with the support.
In such instances, an analysis will be performed by OE, iE necessary, to determine if an unqualified configuration has existed.
All deficiencies with regard to the pipe supports Eor units 1 and 3 will be resolved consistent with the program in place for unit 2.
With regard to the specific supports addressed in the violation (item 1),
the following corrective actions have been'aken:
A.
Unit 1, RHR support R-108:
The snubber bolt conn'ections have been tightened, and the threads were staked on the pipe clamp bolt with the single nut in place.
Staking threads were performed in lieu of double nut installation and is allowed by design documents.
B.
Unit 1, core spray H-83: All deficiencies noted in the violation have been corrected.
C.
Unit 3, RHR R-62:
An analysis has been performed to justify the existing 1/4" weld in place of the drawing specified 5/16" weld.
The drawing is being revised to show 1/4".
The u-bolt nut's thread engagement deficiency was corrected.
D.
Unit 3, RHR R-11:
The deficiency specified in the violation has been corrected.
E.
Unit 3, RHR R-105:
The fillet welds were performed, and the threads were staked on the pipe clamp bolt with the single nut in place.
Staking threads was performed in lieu of double nut installation and is allowed by design documents.
4.
Corrective Ste s Which Will Be Taken to Avoid Further Violations Training will be performed for necessary craft and engineering personnel who work on pipe supports and torus attachments.
Training will be administered by modifications personnel using a lesson plan and will consist of:
(1) lessons learned from the discrepancies found by the third party inspections, and (2) the requirements of MAI-23.
New personnel will also receive this training prior to their involvement with these activities.
5.
Date When Full Com liance Will Be Achieved All reinspection and analysis will be completed prior to respective star tups of units 1, 2, and 3.
The training program will be in place by August 1, 1986, and as personnel are added to the reinspection activities, they will receive documented training.
f'I