ML18033B598
| ML18033B598 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 12/28/1990 |
| From: | Medford M TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9101090225 | |
| Download: ML18033B598 (19) | |
Text
" ACCELERATED DlcgRIBUTION DEMONSTRATION SYSTEM I
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ESSION NBR:9101090225 DOC.DATE: 90/12/28 NOTARIZED: NO FACIL:50-259 Browns Ferry Nuclear Power Station, Unit 1, Tennessee 50-260 Browns Ferry Nuclear Power Station, Unit 2, Tennessee 50-296 Browns Ferry Nuclear Power Station, Unit -3, Tennessee AUTH.NAME AUTHOR AFFILIATION MEDFORD,M.O.
Tennessee Valley Authority RECIP.NAME RECIPIENT AFFILIATION
=-Document Control Branch (Document Control Desk)
DOCKET Ii 05000259 05000260 05000296 R
A
- 05000259 05000260 05000296 D
NOTES:1 Copy each to: B.Wilson,S.
BLACK 1 Copy each to: S.Black,B.WILSON 1 Copy each to:
S.
Black,B.WILSON
SUBJECT:
Responds to NRC 901024 ltr re violations noted in Insp Repts 50-259/90-27,50-260/90-27
& 50-296/90-27.Corrective actions:
each individual holdpoint violation documented through condition adverse to quality rept program.
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TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response RECIPIENT ID CODE/NAME HEBDON,F RNAL: ACRS AEOD/DEIIB DEDRO NRR SHANKMAN,S NRR/DOEA/OEAB NRR/DRIS/DIR NRR/PMAS/ILRB12 OE DIR 02 EXTERNAL EG&G/BRYCE 1 J
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AEOD AEOD/TPAB NRR MORISSEAU,D NRR/DLPQ/LPEB10 NRR/DREP/PEPB9D NRR/DST/DIR SE2 NUDOCS-ABSTRACT OGC/HDS3 RGN2 FILE 01 NRC PDR COPIES LTTR ENCL 1
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iNOTE TO ALL "RIDS" RECIPIENTS:
D PLEASE HELP US TO REDUCE iYASTE! COiNTACTTHE DOCUi~'IENT CONTROL DESK, ROOi I Pl-37 (EXT. 20079) TO ELINIINATEYOUR NAliIEFROM DISTRIBUTION LISTS FOR DOCUilENTS YOU DON'T NEED!
OTAL NUMBER OF COPIES REQUIRED:
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TENNESSEE VALLEY AUTHORITY L
6A Lookout Place DE~ SS ~m U.S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D.C.
20555 Gentlemen:
In the Matter of Tennessee Valley Authority Docket Nos.
50-259 50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN) UNITS 1, 2, AND 3 NRC INSPECTION REPORT NOS. 50-259/90-27, 50-260/90-27, AND 50-296/90-27
RESPONSE
TO VIOLATION This letter provides TVA's response to the letter from B. A. Wilson to 0.
D. Kingsley, Jr.
dated October 24, 1990, which transmitted the subject report.
The report cited TVA with a violation for bypassing Quality Control (QC) holdpoints during maintenance and modification work activities.
Fourteen examples of bypassing documented QC holdpoints were identified by TVA's Site Quality organization with five examples in August 1990.
TVA admits this violation.
TVA has also included in this letter two examples of bypassed holdpoints that have occurred since August 1990.
As agreed with the NRC Resident's
- Office, this revised response will be issued by January 14, 1991.
Enclosure 1 provides TVA's response to the violation.
Enclosure 2 is a summary of the Conditions Adverse to Quality Reports identified in the inspection report, and two that occurred since Augu'st 1990.
Enclosure 3 is a listing of the commitments made in the response.
Please refer any questions concerning this submittal to Patrick P. Carier, BFN, Site Licensing (205) 729-3570.
Very truly yours, TENNESSEE VALLEY AUTHORITY
~314~p
~/~M'ark
- 0. Medford, Vice President, Nuclear Assurance, Licensing 6
Fuels Enclosures 910105022~
P01-.2;=,.
PDFi ADOCI'5000259 ti,l PDR An Equal Opportunity Employer gpss/
U.S. Nuclear Regulatory Commission cc (Enclosures):
Ms. S.
C. Black, Deputy Director
.Project Directorate II-4 U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike, Rockville, Maryland 20852 NRC Resident Inspector Browns Ferry Nuclear Plant Route 12, Box 637
- Athens, Alabama 35609-2000 Mr. Thierry M. Ross, Project Manager U., S. Nuclear Regulatory Commission Ope White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Mr. B. A. Wilson, Project Chief U.S. Nuclear Regulatory 'Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323
ENCLOSURE 1
REPLY TO NOTICE OF VIOLATION BROWNS FERRY NUCLEAR PLANT NRC INSPECTION REPORT NOS. 50-259/90-27>
50-260/90-27, and 50-296/90-27 During the NRC inspection conducted August 18 September 15,
- 1990, NRC identified a violation of regulatory requirements.
The violation involved the bypassing of Quality Control (QC) holdpoints during maintenance and modifications work activities.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C
(1990),
the violation states:
Technical Specification (TS) Section 6.8.1, Procedures, requires that written procedures shall be established, implemented and maintained covering applicable procedures recommended in Appendix A of Regulatory Guide, 1.33, Revision 2, February 1978.
Appendix A of Regulatory Guide 1.33 includes administrative procedures and procedures for controlling repair activities of safety-related equipment.
Site Directors Standard Practice 3.11, Quality Control Inspection
- Program, Section 3.1.2.e.l requires that during work instruction preparation inspection planning will include holdpoints and notification points sufficient to provide opportunity for witness/inspection of specified activities.
SDSP-3.11, Attachment A
requires that the work activity shall not progress past the Quality Control inspection holdpoint until signed as accepted by an inspector or until the Site Quality Management or his designee's consent to continue is obtained and documented.
Contrary to the above, between January 18, 1990 and September 1,
- 1990, the requirements were not met in that fourteen examples of bypassing documented QC holdpoints were identified by the licensee's Site Quality Organization.
Five examples occurred in August 1990.
This is a Severity level IV violation (Supplement I) applicable to all three units.
TVA admits the violation.
2.
This violation occurred as a result of personnel errors.
TVA bases this conclusion on the root cause analysis performed for the resolution of each holdpoint violation.
These errors were the result of lack of attention to detail by craft personnel during implementation of workplans.
0
A contributing factor for these events was the significant amount of work being performed at BFN.
From January 1990 to August 1990 an excess of 59,000 inspections were performed.
Between March and July 1990 the average rate of bypassed QC holdpoints was two per month.
In August 1990 the number increased to five.
At that time,'VA concluded that a
potential adverse trend existed.
t'v t
v Each individual holdpoint v'iolation has been documented through the Condition Adverse to Quality Report (CAQR) program.
The corrective actions for each QC holdpoint violation were documented in a CAQR and are provided in Enclosure 2.
Also included is an assessment of impact on hardware resulting from these noncompliances.
In each instance for craft personnel who bypassed QC hold points, appropriate disciplinary actions have been taken.
Specifically, individuals have received oral warnings.
As the problem with bypassing holdpoints continued, TVA management expanded the personnel policy to include suspensions and demotions, and ultimately to termination of employment.
TVA's disciplinary policy has resulted in no individual continuing to bypass QC holdpoints following initial disciplinary action.
Additionally, the modifications manager has held discussions with modifications personnel to stress the importance of holdpoint compliance.
The following two examples of bypassed QC holdpoints have been identified since August 1990.
Example 1,
CAQR BFP 900364, which occurred on October 31, 1990.
In this example a
QC holdpoint was bypassed during breaching of Appendix R penetration for cable installation.
Example 2,
CAQR 900368, which occurred on November 3, 1990.
In this example a
QC holdpoint was bypassed during welding activities.
t
k n t
)
Nonconformances will be addressed and documented by the CAQR program.
The corrective action for bypassed holdpoints will be tracked and documented by the CAQR program.
TVA considers that the expanded disciplinary action policy has reversed the adverse trend.
Additionally, corrective actions necessary to close the two examples of bypassed QC holdpoints, CAQRs BFP900364 and BFP900368, will be implemented.
TVA considers that with implementation of the expanded disciplinary action policy, revised procedures, and tracking of bypassed holdpoints on CAQRs, TVA has programmatically achieved compliance with this violation.
Additionally, to achieve full compliance with this violation, the corrective actions necessary to close the two additional examples of bypassed QC holdpoints will be implemented.
Implementation of the corrective action will be completed prior to Unit 2 startup.
ENCLOSURE 2 0
'REPLY TO NOTICE OF VIOLATION BROWNS FERRY NUCLEAR PLANT NRC INSPECTION REPORT NOS. 50-259/90-27 50-260/90-27 and 50-296/90-27 CAQR N HB DATE RR D
DATE REP RTED DESCRIPTION F
NDIT N
RRE T VE A TI N ASSESSHENT F
HARDWAR BFP 890562P 06/28/89 06/29/89 Foreman failed to notify Personnel involved were QC of weld fitup prior to counselled.
initiation of root pass.
Based on the final visual inspection of the weld, the weld was determined.
acceptable.
BFP 890735 10/14/89 10/15/89 QC holdpoint was bypassed during installation of a penetration seal.
- 1) Seal material was removed and replaced.
- 2) Personnel involved were counselled.
The seal was evaluated and determined adequate
- however, to be conser-vative the seal was removed and replaced.
BFP 890776 11/18/89 11/18/89 Cable was lifted and removed from conduit without QC presence.
Personnel involved were counselled.
Cables were examined and determined acceptable.
BFP 890780 11/20/89 11/21/89 Melding was performed without a detailed weld procedure; no base material listed, no fitup inspection holdpoint, and qualified welders were not listed on weld data sheets.
- 1) Weld repair data sheet was issued.
- 2) Filler material control program was reviewed.
- 3) Base material was recorded on weld data sheets.
4)
Exam of weld was performed.
- 5) Personnel involved were counselled.
- 1) Fi tup'as accepted.
- 2) Final weld was inspected and -accepted.
4.
t l
0 CAQR NUMBE DATE CCURRED DATE P
T 0 DESCRIPTION 0
NDITION CORRE TIV A TI N ASSESSMENT F HARDWAR BFP 900001 12/25/89 01/01/90 Wel'ding per formed,wi thout
- 1) Visual inspection was fitup inspection.
performed.
- 2) Personnel involved were counselled.
Final visual inspection accepted.
BFP 900056 11/26/89 BFP 900070P 03/07/90 03/05/90 03/13/90 Measurement not taken prior to removal of temporary pipe supports.
QC holdpoints bypassed during cable pullback.
QC reinspected and found deflection within tolerance.
- 1) Worked stopped.
- 2) Condition was docu-mented.
- 3) Work plan was revised to delete inspection requirements.
Deflection was determined acceptable.
Cable was removed to allow replacement with qualified cable.
BFP 900086 03/23/90 03/25/90
- 1) Conductors were lifted without QC veri-fication.
2)
During cable termination it was discovered the termi-nation did not agree with as-constructed drawings.
Drawing discrepancy was issued.
The conduits are not class lE.
Therefore, no QC verification was required.
BFP 900090 03/26/90 03/26/90 Failure to utilize weld area removal data sheet.
- 1) Personnel involved were counselled and trained.
- 2) Weld area removal data sheet was issued.
- 3) Weld was reworked.
Final inspection accepted.
BFP 900159P 05/13/90 05/18/90 QC was not notified prior to removal of primary system valves.
Opening was covered with suitable material.
QC inspected opening; no foreign material was identified.
CAi)R NUHBER DATE RRED DATE RP TO DESCRIPTION F
NOITION RRE TIV A TI N ASSESSHENT F
HAROWAR BFP 900160P 05/19/90 05/19/90 No gC fit-up prior to welding.
- 1) Meld filler material control program was reviewed.
- 2) Welder qualification program was reviewed.
- 3) Fitup inspection on repair weld joint was rejected.
- 4) Weld joint was repaired and passed final i)C inspection.
Meld joint was determined acceptable.
BFP 900198P 06/14/90 06/14/90 Fi t-up weld hol dpoints were bypassed without notifying gC.
- 1) Pre-weld inspection was performed by responsible foreman and verified by welding engineering.
- 2) Welder ID and filler material
'recorded on weld data sheets.
- 3) Meld joint was inspected by gC and accepted.
Dispositioned acceptable.
BFP 900234P 07/12/90 07/12/90 Three examples of all bypassed gC fitup hold-points on three different welds.
- 1) Visual inspection was performed, one-weld repaired and
- accepted, two welds accepted as is.
- 2) Base material was verified correct.
- 3) Training material reviewed.
All three bypassed i)C holdpoint examples were dispositioned acceptable.
CAQR N HB DATE RRED DATE REP TED DESCRIPTION F
NDIT N
CORR TIV A T N
ASSESSHENT F
HARDMAR BFP 900285P 08/22/90 08/23/90 Appendix R fire seal penetrations were breached and repaired without QC involvement.
- 1) Independent verifi-'ation of seal instal-lation was used instead of QC inspection.
Seal was accepted as is.
BFP 900288P 08/25/90 08/25/90 QC inspection was not performed during cable pull.
- 1) Cable was pulled back and inspected for damage.
2)
QC inspected reinstal-lation.
- 3) Personnel.
involved were counselled.
Cable pull was accepted by QC.
BFP 900290P.
08/27/90 08/27/90 Holdpoints bypassed during wire (jumper) installation.
- 1) Mire was relanded.
- 2) Personnel involved were counselled.
QC accepted wire reland.
BFP 900296P 08/22/90 08/29/90 Cable pulled back (removed from conduit) without documentation.
- 1) Morkplan was revised to document and allow deletion and abandoning of spare cable.
- 2) Personnel involved were counselled.
Cable abandoned.
BFP 900299P 08/26/90 09/01/90 Piping painted QC holdpoint bypassed.
- 1) Revise workplan to delete QC holdpoint.
- 2) Personnel involved were counselled.
Accepted as is.
BFP 900364 10/31/90 BFP 900368 11/03/90 11/01/90 11/03/90 QC holdpoint bypassed during breaching of Appendix R penetration.
Bypass QC inspection during welding activity.
Open Open Open Open 0586k
ENCLOSURE 3
LIST OF COMNITMENTS NRC INSPECTION REPORT NOS. 50-259/90-27, 50-260/90-27, and 50-296/90-27 LETTER FROM B. A. WILSON 'TO 0. D. KINGSLEY, JR.
DATED OCTOBER 24, 1990 1.
Corrective actions necessary to close Condition Adverse to Quality Report (CAQR) BFP 900364 will be implemented.
This will be completed prior'to Unit 2 startup.
2.
Corrective actions necessary to clo'se CAQR BFP 900368 will be implemented.
This will be completed prior to Unit 2 startup.-