ML18038B598
| ML18038B598 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 01/12/1996 |
| From: | Machon R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9601170342 | |
| Download: ML18038B598 (16) | |
Text
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
CCESSION NBR:9601170342 DOC.DATE: 96/01/12 NOTARIZED:
NO DOCKET ACIL: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 MACHON,R.D.
Tennessee Valley Authority RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Forwards response to NRC 951215 ltr re violations noted in insp repts 50-259/95-57,50-260/95-57
& 50-296/95-57 on 951002-1117.Corrective actions:revised subject DCA corrected weld to comply w/drawing.
DISTRIBUTION CODE:
ZEOID COPIES RECEIVED'LTRl ENCL
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SIRE'ITLE:
General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:
RECIPIENT ID CODE/NAME PD2-3-PD INTERNAL: ACRS AEOD/SPD/RAB DEDRO NRR/DISP/PIPB NRR/DRPM/PECB NUDOCS-ABSTRACT OGC/HDS3 EXTERNAL: LITCO BRYCEPJ H
NRC PDR COPIES LTTR ENCL 1
1 2
2 1
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1 RECIPIENT ID CODE/NAME WILLIAMS,J.
AEOD/DEIB ILE CEN NRR DRCH/HHFB NRR/DRPM/PERB OE DIR RGN2 FILE 01 NOAC COPIES LTTR ENCL 1
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1 NOTE TO ALL "RIDS" RECIPIENTSI PLEASE HELP US TO REDUCE WASTE!
CONTACT THE DOCUMENT CONTROL DESK, ROOM OWFN 5D-5(EXT. 415-2083)
TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
TOTAL NUMBER OF COPIES REQUIRED:
LTTR 20 ENCL 20
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Tennessee Valtey Authority. Post ONce Box 2000. Decatur, Atabama 35609.2000 R. D. (Rick) Machon Vce President, Browns Ferry Nuctear Plant January 12, 1996 U.S. Nuclear Regulatory Commission ATTN:
Document Control'esk 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 'XNSPECTXON REPORT (ZR) 50-259~
50-260~
50-296/95 REPLY TO NOTICE OF VZOLATZON (NOV)
This letter provides our reply to the subject NOV transmitted by letter from Albert F. Gibson, NRC, to Oliver D. Kingsley, TVA, dated December 15, 1995.
This NOV involved a violation with five examples for failure to properly carry out design requirements.
TVA admits this violation.
In the cover letter forwarding the violation, NRC notes that this vi;olation is similar to previous violations cited in NRC letters dated May 5, 1995 (IR 95-15, NOV 95-15-01) and October 12, 1995 (IR'5-52, NOV 95-52-02).
NRC also requested that TVA address the common causes associated with the three violations and describe any actions taken or planned to improve the effectiveness of TVA's program to implement modifications.
TVA agrees that these violations are similar in that they involve structural modifications for 'Unit 3 recovery and resulted from personnel errors.
TVA also recognizes the significance of these violations and the need to ensure that an effective program exists to implement plant modifications.
170O VO 960ii70342 960ii2 PDR ADOCK 05000259 8
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U.S. Nuclear Regulatory Commission Page 2
January 12, 1996 TVA has reviewed the three violations and the circumstances surrounding them and has not identified any common causes.
For example, as noted in the enclosure to this letter, NOV 95-57-01 involves three examples of poor installation practices (i.e., hardware installed incorrectly) and two examples of deficient drawings as a result of using non-standard design practices.
While one of the previous two violations involved a drawing error (NOV 95-15-01, Example 1), neither of these previous violations were caused by poor installation practices.
Additionally, in TVA s response to NOV. 95-52-02, TVA specifically noted that the incident identified in that violation was a unique incident.
TVA believes that an acceptable program for issuing and implementing design changes exists at BFN.
The design changes involved in these three violations were large, complex changes needed for the recovery of Unit 3.
Similar changes will not be needed in the future due to the operational status of BFN Units 2 and 3.
- Instead, future design changes will be smaller and less complex.
Also, any nonstandard design output will be accompanied by specific installation instructions to preclude errors-due to this cause.
Consequently, TVA believes that no further actions are necessary.
The enclosure provides our response to the NOV.
There are no commitments contained in this letter. If you have any questions regarding this reply, please contact Pedro Salas at (205) 729-2636.
Sincerely, R.
D achon Enclosure cc:
See page 3
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U.S. Nuclear Regulatory Commission Page 3
January 12, 1996 Enclosure cc (Enclosure).:
Mr. Mark S. Lesser, 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 AUTHORZTY BROWNS FERRY NUCLEAR PLANT (BFN)
UNZTS l.g 2p AND 3 ZNSPECTZON REPORT NUMBER. 50-259'0-260~
50-296/95-57
'REPLY TO NOTZCE OF VZOLATZON (NOV)
RESTATEMENT OF THE VZOLATZON "During an NRC inspection conducted on October 2 through November 17,
- 1995, a violation of NRC requirements was identified.
Xn accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below:
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.
Contrary to the above, procedures, instructions, or drawings were not implemented for installation of modifications as described below:
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Note Number 4 on Drawing number 3-47B600-2512-2, Revision 01, requires that tubing clamps be installed to ensure that the maximum unsupported tubing span with concentrated weights (i.e., unsupported valves and flow elements) does not exceed 24 inches.
Detail B on Drawing number 3-47B600-2512-1, Revision 0, requires that a structural support be provided for instrument tubing and flow elements in accordance with Detail J, Drawing 3-47E600-808.
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Tubing clamps were not installed to secure the tubing/flow element to the Detail J support on instrument panel numbers 3-LPNL -925 -674 and -675.
The unsupported tubing span exceeded 24 inches.
Drawing,number 3-47B600-2033, Revision 1, requires repair of a clamp on a 1/2 inch diameter Control Air system pipe support, designated on the drawing as support sequence number 01, to ensure a three directional restraint of the tubing is provided.
On October 3, 1995, it was observed that the clamp was not installed on support sequence number 1.
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Drawing number 3-47B600-1432, Revision 1, requires repair of an oversized hole in a control air system pipe support, designated on the drawing as support sequence number 3.
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5.
On October 5, 1995, it was observed that the oversized hole had not been repaired.
Note 2 on drawing 3-47B600-1435, Revision 0, requires the clamp halves (Bill of Materials item 4) for the pipe anchor/support for control air system pipe, support number 3-47B600-1435, to have a gap greater than zero inches after application of installation torque.
On October 5,
- 1995, a quarter inch plate was observed to have been installed between the clamp halves with a gap of zero inches.
Base Drawing number 3-48N443, DCA W17538-086, Revision 5, specifies attachment of the 3/4 inch plate (Bill of Material item 2) to the flange of the existing 12WF27 member, with a 1/4 inch fillet weld, 22 1/2 inches long at each end of the plate.
The 1/4 inch fillet welds at the ends of the plate were only approximately 12 inches in length, and not the 22 1/2 inch required by the design drawing.
This is a Severity Level IV violation (Supplement I)."
TVA S REPLY TO THE VIOLATION EXAMPLES 1 AND 5 1 ~
Reason For The Violation These examples resulted from inadequate modification drawings.
Specifically, in Example 1, design engineers who prepared the drawings did not use standard design practices for detailing supports (the support was placed on a flow diagram instead of a panel assembly drawing).
Additionally, the support was located where no structural member existed to attach the support to.
In Example 5, the design engineers who prepared the drawings did not use standard structural steel detailing practices.
As a result, the drawings became complicated and difficult to read/interpret.
Consequently, craft and QC personnel could not determine the actual final design requirements.
Contributing to this violation was a lack of a questioning attitude.
Even though the drawings were inadequate and/or difficult to read, personnel responsible for planning, installing, and verifying the modification failed to stop the work activity to verify the design requirements and determine whether the intended installation would meet/met the design requirements.
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Corrective Actions Taken And Results Achieved 3 ~
These drawings became complex as a result of many modifications that were required/installed for Unit 3 restart.
TVA does not anticipate drawings or design changes to become as complex during future outages because of the operational status of Units 2 and 3.
Furthermore, future structural steel modifications will be prepared in accordance with American Institute of Steel Construction standard detailing practices.'VA revised the subject Design Change Authorization (DCA) and corrected the weld to comply with this drawing.
TVA also reviewed an additional sixty-eight (68)
DCAs for DCN W17538 without identifying any additional deficiencies.
With respect to the lack of questioning attitude by craft personnel, no personnel corrective actions were taken because the individuals who were responsible for these deficiencies were contractor personnel and are no longer working at BFN.
Corrective Ste s That Have Been Or Will Be Taken To Avoid Further Violations No additional corrective actions are required.
Date When Full Com liance Will Be Achieved TVA is in full compliance.
TVAiS REPLY TO THE VIOLATION EXAMPLES 2-4 Reason For The Violation These examples resulted from personnel error.
Personnel responsible for installing the modifications did not install the design as required.
Additionally, personnel responsible for verifying the modification installation failed to detect these deficiencies.
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Corrective Actions Taken And Results Achieved The hardware problems identified in these examples were corrected.
Specifically, in Example 1, the tubing clamp was installed and a 3/8-inch plate was welded to the existing angle iron to provide additional tubing support.
Additionally, an FDCN was issued to clarify the drawings.
- Finally, TVA reviewed similar tubing, runs of four other flow This is not a regulatory commitment.
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meters at different locations and found them acceptable.
In Example 2, the clamp was installed.
In Example 3, the oversized hole was repaired after the washer was removed.
In Example 4, the spacer plate was removed and the clamp halves were reassembled with the proper gap.
No personnel corrective actions were taken because the individuals who were responsible for these deficiencies were contractor personnel and are no longer working at BFN.
- However, TVA management did conduct gangbox meetings with craft personnel to emphasize the need to have a questioning attitude and ensure that modifications are installed per design requirements.
Corrective Ste s That Have Been Or Mill Be Taken To'Avoid Further Violations No additional corrective actions are required.
Date Shen Full Com liance Mill Be Achieved TVA is in full compliance.
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