ML18038B529

Forwards Response to NRC Re Violations Noted in Insp Repts 50-259/95-52,50-260/95-52 & 50-296/95-52.C/As: Issued Memo to Remind AA Approvers That Prior to Signing Approval Fdcn Preparers Should Be Involved in Comments

ML18038B529
Person / Time
Site:	Browns Ferry
Issue date:	11/09/1995
From:	Machon R TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9511130221
Download: ML18038B529 (12)

Text

PRZORXTY 3.

(ACCELERATED RIDS PROCESSING)'EGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ESSION NBR:9511130221 DOC.DATE: 95/11/09 NOTARIZED: NO ACIL: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.

MACHON,R.D.

Tennessee Valley. Authority RECIP.NAME RECIPIENT,AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Forwards response to NRC 951012 ltr re violations noted in insp rept 50-259,260

& 296/95-52.Corrective actions:util

.issued memo to remind AA approvers that prior to signing approval FDCN preparers should be involved in comments.

DISTRXBUTION CODE: IEOlD COPIES RECEIVED:LTR ENCL +

SIZE:

TITLE: General (50 Dkt)-Insp Rept/Notice of Vio ation MR sponse NOTES:

DOCKET' 05000259

,P, 05000260 05000296 RECIPIENT ID CODE/NAME PD2-3-PD COPIES RECIPIENT LTTR ENCL ID CODE/NAME 1

1 WILLIAMS,J.

COPIES "LTTR ENCL 1

1 INTERNAL: ACRS AEOD/SPD/RAB DEDRO NRR/DISP/PIPB NRR/DRPM/PECB'E.DIR RGN2 FILE 01 2

1 1

1 1

1 1

2 AEOD/DEIB 1

AEOD/WXC~

1 ( FILE CENQEQ7 1

NRR/DRCH/HHFB 1

'NUDOCS-ABSTRACT 1

OGC/HDS3 1

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D EXTERNAL: LITCO BRYCE,J H NRC.PDR 1

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NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE!

CONTACT THE DOCUMENT CONTROL,

DESK, ROOM OWFN 5DS (415-2083)

TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

OTAL NUMBER OF COPIES REQUIRED:

LTTR 19 ENCL 19

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Tennessee Valley Authority, Post Oftce Box 2000, Decatur, Alabaina 35609-2000 R. D. (Rick) Machon Vice President. Browns Ferry Nucfear Plant NOV OS gg U.S. Nuclear Regulatory Commission ATTN:

Document Control Desk Washington, D.C.

20555 10 CFR 2

Appendix C

Gentlemen:

In the Matter of Tennessee Valley Authority Docket Nos.

50-259 50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN) - NRC INSPECTION REPORT 50-259~

50-260~

50-296/95 REPLY TO NOTICE OF VIOLATION (NOV)

This letter provides our reply to the subject NOV transmitted by letter from C. A. Casto, NRC, to Oliver D. Kingsley,

TVA, dated October 12, 1995.

This NOV involved a personnel error that resulted in a failure to install two welds in accordance with an approved field design change notice.

TVA admits the violation.

The enclosure provides our response to the NOV.

There are no commitments in this letter. If you have any questions regarding this reply, please contact Pedro Salas at (205) 729-2636.

Sincerely, R.

D.

chon Site ice President Enclosure cc:

See page 2

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U.S. Nuclear Regulatory Commission Page 2

November 9, 1995 Enclosure cc (Enclosure):

Mr. Mark S. Lesser, Acting Branch Chief U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 NRC Resident InsPector Browns Ferry Nuclear Plant 10833 Shaw Road

Athens, Alabama 35611 Mr. J.

F. Williams, Project Manager U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852

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ENCLOSURE TENNESSEE VALLEY AUTHORXTY BROWNS FERRY NUCLEAR PLANT (BFN)

UNITS 1g 2q AND 3 XNSPECTXON REPORT NUMBER 50-259'0-260'0-296/95-52 REPLY TO NOTZCE OF VZOLATZON (NOV)

RESTATEMENT OF THE VZOLATXON "10 CFR 50, Appendix B, Criterion V, requires that activities affecting quality shall be prescribed by instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures or drawings.

Paragraph 6.1.1 of Modifications and Addition Instruction MAI-3.9, Installation of Cable Tray Supports and Cable Tray Covers, requires that cable tray supports be fabricated and installed according to the applicable design documents.

Contrary to the above, flare level welds on the vertical interfaces of bill of material item numbers three and four.for support number 319092-15-B1102-38 were not completed as required by drawing number DCA W17473-300 and DCN F26704A AA-04.

This is a Severity Level IV violation (Supplement I) (Applicable for Unit.3 only)."

TVAiS REPLY TO THE VZOLATION Reason For The Violation This violation was due to personnel error as a result of a poorly coordinated field design change.

The support connection between items 3 and 4 was originally designed and fabricated with a two-sided fillet weld.

Following original installation, additional modifications were needed to attach the cable tray.

Consequently, the night-shift field engineer initiated FDCN 26104A to add the attachment structure for the cable tray.

This attachment structure was indicated on both the support assembly drawing and a section view of a portion of the support.

Because there were no authorized FDCN approvers on the night shift, the approval of this FDCN was rolled to the day-shift field engineer.

When the day-shift field engineer reviewed the FDCN, he determined that the additional flare bevel welds should be added.

However, rather than adding these welds to the section view, he added them to the support

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assembly drawing.

Additionally, the day-shift field engineer wrote "Requested changes are approved" on the FDCNg but did not indicate that the additional flare bevel welds were added.

Subsequently, when the night-shift field engineer received the approved FDCN, he did not note the addition of the flare bevel welds.

Instead, based on the day-shift field engineer's notation, the night-shift field engineer assumed that the changes he recommended were approved with no additions.

After the FDCN was approved, the night-shift field engineer prepared the appropriate modification implementation documentation (e.g.,

work plan, weld data sheets) for the cable tray support.

However, because the field engineer was unaware of the addition of the flare bevel welds, he failed to ensure that these welds were incorporated into the documentation.

Consequently, the cable tray support was installed in the field without the flare bevel welds.

Following installation of the support, modifications work plan closure personnel reviewed the installation documentation and the corresponding design output documents.

However, these individuals failed to identify that the cable tray support had not been installed in accordance with the FDCN.

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Corrective Actions Taken And Results Achieved TVA reviewed the design calculation (without the additional flare bevel welds) for this support and determined the existing tray loading would not jeopardize the structural integrity of the support.

However, based on anticipated future cable tray loading, TVA installed the flare bevel welds.

Since the field engineers and modifications closure personnel involved in this event are no longer employed at BFN, personnel corrective actions were not taken.

TVA issued a memorandum to remind AA approvers that prior to signing approval to an AA-FDCN, it is their responsibility to ensure that FDCN preparers are involved in and are aware of any comments or additions required by the AA approver.

TVA also discussed this event with the modifications work plan closure personnel and reminded them that it is their responsibility to ensure that modifications are installed in accordance with design documents.

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Corrective Ste s That Have Been Or Will Be Taken To Avoid Further Violations TVA believes that this problem with the review and approval of the FDCN is a unique incident.

Consequently, TVA believes that no further actions are necessary.

Nevertheless, a statistical sample of cable tray supports E-2

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installed in DCNs W17473 and W17720'ill be walked down to verify that welds shown on the support configuration control drawings are installed in the field.

Date When Pull Com liance Wi.ll Be Achieved TVA is in full compliance for this event.

TVA plans to complete the walkdown by December 15, 1995.~

'hese two DCNs were large cable tray support modifications, and installed the majority of new cable tray supports for Unit 3 recovery.

2 This is not a regulatory commitment.

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