ML18036B160
| ML18036B160 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 02/10/1993 |
| From: | Zeringue O TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9302180124 | |
| Download: ML18036B160 (9) | |
Text
ACCELERATED DOCUMENT DISTRIBVTIONSYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RXDS)
CCESSION NBR:9302180124 DOC.DATE: 93/02/10 NOTARIZED: NO DOCKET AC"L:50-259 Browns Ferry Nuclear Power Station, Unit 1, Tennessee 05000259 50-260 Browns Ferry Nuclear Power Station, Unit 2, Tennessee 05000260 50-296 Browns Ferry Nuclear Power Station, Unit 3, Tennessee 05000296 AUTH.NAME AUTHOR AFFILIATION ZERINGUE,O.J.
Tennessee Valley Authority RECIP.NAME RECIPIENT AFFILIATION
" Document Control, Branch (Document Control Desk,)
SUBJECT:
Responds to NRC 930112 ltr re violations noted in Insp,Repts 50-259/92-43,50-260/92-43
& 50-296/92-43 on 921214-18.
Corrective actions:GE stopped all field work activities on weld overlays a developed DCN checklist.
DISTRIBUTION CODE:
IE01D COPIES RECEIVED:LTR ENCL SIZE:
TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:
RECIPIENT ID CODE/NAME HEBDON,F WILLIAMS,J.
INTERNAL: ACRS AEOD/DEIB AEOD/TTC NRR MORISSEAUgD NRR/DLPQ/LPEB10 NRR/DREP/PEPB9H NRR/PMAS/ILPB 2 NUDOCS-ABSTRACT OGC/HDS3 RGN2 FILE 01 EXTERNAL: EG&G/BRYCE,J.H.
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RECIPIENT ID CODE/NAME ROSS,T.
AEOD AEOD/DSP/TPAB DEDRO NRR/DLPQ/LHFBPT NRR/DOEA/OEAB NRR/PMAS/ILPB 1 NRR/PMAS/ILRB12 OE~D1'R EG FILE 02 NRC PDR COPIES LTTR ENCL 1,
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1 NOTE TO ALL"RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 504-2065) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
TOTAL NUMBER OF COPIES REQUIRED:
LTTR 26 ENCL 26
Tennessee Valley Authoray, Post Otlce Embox 2000, Decatur, Alabama 35609 2000 0- J. "Ike" Zeringue Vice President Browrts Ferry Nuclear Plant FEB 1o 1993 U.S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D.C.
20555 Gentlemen; In the Matter of Tennessee Valley Authority P
Docket Nos.
50-259 50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN) NRC INSPECTION REPORT 50-259, 50-260, 296/92-43 REPLY TO NOTICE OF'VIOLATION (NOV)
This letter provides TVA's reply to the NOV transmitted by letter from C. A. Julian to M. 0. Medford dated January 12, 1993.
In this letter, NRC cited TVA with a violation for failure t'o follow an approved procedure.
Specifically, NRC stated that "The violation is of concern because certain administrative/p'rocedural requirements specified by the controlling specification=on weld overlay on recirculation piping were not adhered to by the contractor or TVA engineering.
This oversight resulted in the omission of a significant engineering review which was to be performed prior to the start of production welding.".
It should be noted that TVA Engineering had performed a review of the weld overlay work activity, including the method of welder qualifications, prior to the start of production welding.
The requirement that was not met by the vendor was an administrative requirement to document the results of this review on a report to TVA.
- TVA considers, the corrective actions taken resolves this issue.
Specifically, the implementation of the Design Change Notice requirements checklist form, that has been incorporated into the design change
- process, is adequate to prevent recurrence.-
Additionally, both TVA and NRC concluded that the oversight identified by this violation did not affect the quality of the welding performed in the weld overlay activity.
'V302lB0124 930210 PDR ADOCK 0500025'P 8
)8(l
Cl
U.S. Nuclear Regulatory Commission FEB ip 1993 The enclosure to this letter is TVA's "Reply to the Notice of Violation" (10-CFR 2.201). If you have any questions regarding this reply, please telephone G.
D. Pierce at (205) 729-7566.
Sincerely,
,/
0.'. Zering e
Enclosure cc (Enclosure):
NRC Resident Inspector Browns Ferry Nuclear Plant Route 12, Box 637
- Athens, Alabama 35611 Mr. Thierry M. Ross, Project Manager U.S. Nuclear Regulatory Commission One 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 Tennessee Valley Authority Browns Ferry Nuclear Plant (BFN)
Reply to Notice of Violation (NOV)
Inspection Report Number 50-259 260 2 6/92-43 RESTATEMENT OF VIOLATIO "During an NRC inspection conducted on December 14-18, 1992; a violation of NRC requirements was identified.
In accordance with the "General Stateme'nt of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the violation is listed below:
Title Ten Code of Federal Regulations, Part 50 (10 CFR 50),
Appendix B, Criterion V requires activities affecting quality be accomplished in accordance with procedures.
GE Nuclear Energy Specification GE 25A5195 Rev.
0 BFN-3, Meld Overlay Recirculation and RHR Piping System Welds; requires that welder performance qualification requirements be demonstrated either by successfully fabricating a mockup or by means of an alternate method described in Paragraph 3.5.3.7 of the subject specification.
This method, which was chosen by GE to demonstrate proficiency, requires that GE prepare a formal document for TVA Engineering's review and approval prior to commencing production welding.
The document was to contain detail record(s) of weld overlay experience or recent experience in operating the same type of equipment in the same envi'ronment as a weld overlay, and as a minimum it was to contain sufficient description of the experience to allow verification that mockup requirements had been met for each situation for which relief from mockup fabrication was requested.
Contrary to the above, on December 17,
- 1992, the inspector ascertained that GE had not fully complied with requirements of paragraph 3.5.3.7 in that a formal document with detailed records of weld overlay experience using the same type equipment in the same environment had not been submitted to TVA for review and approval prior to the start of production welding.
Seven of the nine welds scheduled for weld overlay had been fabricated at the time of this finding.
This is a Severity Level IV violation (Supplement I)."
TVA RESPONSE TO THE VIOT.ATIOH 1.
Reason For Violation This violation resulted from inattention to detail.
- In accordance with internal General Electric (GE) specifications, GE had the option of performing mockup training or obtaining a waiver of the mockup training requirements by submitting documentation for TVA's engineering review and approval.
The vendor failed to submit the required documentation after determining that the mockup training option would not be used.
Prior to this event, TVA contracted with GE for the replacement of the reactor recirculation and reactor cleanup piping systems.
As part of the original contract, extensive mockup training was performed to qualify the welders working under the contract.
This mockup training was performed prior to the start of the piping system replacement.
Additionally, the original contract stated that the welders used to installed the piping systems would be used for applica'tion of weld overlays.
The, weld. overlay, work was performed as an extra work activity under the original pipe replacement contract.
Specifically, unit rates were provided in the original contract for weld overlay work performed on the piping systems being replaced.
The welding performed on the weld overlay activity is performed using the same equipment by the same welders, in the same configuration, on the same material, and in the same locations as the work performed during the pipe replacement activity.
Due to the similarity between the work performed during the pipe replacement activities and the weld overlay activities, GE failed to recognize that either mockup training or a waiver from this training was necessary for the weld overlay activity prior to performing the work.
2.
Corrective Ste s Taken and Results Achieved Upon identification of this violation th'e vendor issued a
nonconformance report (NCR) for its violation of the GE specification.
Additionally, the vendor stopped all field work activities on weld overlays until such time as the NCR could be resolved.
The vendor then assembled the detailed records, containing the expertise and experience of the personnel performing the weld overlays.
In accordance with GE Specification 25A5195 paragraph 3.5.3.7, this documentation was submitted to TVA for review and approval for waiving the mockup training requirements.
TVA reviewed the documents and approval was granted on January 7,, 1993, for the vendor to perform weld overlays without performing mockup training.
The NCR was closed and field application of weld.
overlays was permitted to resume.
3 ~
Corrective Ste s That have been or Will Be Taken To Prevent Recurrence GE has initiated the development and use of a DCN requirements checklist.
This checklist identifies the requirements 'in the DCN and provides a tracking method of accounting for completion of each requirement.
In addition, the completed checklist is then reviewed and is'approved by the Project Manager and GE's QC group.
The effective date for implementing the DCN checklist form was January 5,. 1993.
4.
Date When Full Com liance Will Be Achieved TVA considers that full compliance occurred on January 7,
- 1993, when the vendor completed the corrective action and the DCN requirements checklist was in place.