ML19290G598

Responds to NRC 801017 Ltr Re Violations Noted in IE Insp Rept 50-260/80-28.Corrective Actions:Preliminary & Final Liquid Penetrant Examinations Performed

ML19290G598
Person / Time
Site:	Browns Ferry
Issue date:	11/10/1980
From:	Mills L TENNESSEE VALLEY AUTHORITY
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML19290G595	List: ML19290G598
References
NUDOCS 8012180097
Download: ML19290G598 (3)

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ENCLOSURE RESPONSE TO C. E. MURPHY'S LETTER DATED OCTOBER 17, 1cSO, TO H. G. PARRIS BRO'US FERRY NUCLEAR PLANT (RII:MHG 50-260/80-?8)

Appendix A of the inspection letter identified activities which were apparently not conducted in full compliance with NRC requirements.

The following are those activities and our response.

INFRACTION As required by Criterion V of Appendix B to 10 CFR 50, and implemented by Topical Report TVA-TR75-01, Paragraph 17.2.5,

" Activities affecting quality shall be prescribed by documented instructions, procedures...and shall be accomplished in accordance with these instructions, procedures, and drawings."

(1) IX-360 of Section III of the ASPE Boiler and Pressure Vessel Code (1o68 Fdition) is identified by the FSAR as the applicable code for inservice inspection penetrant examination procedures. IX-360 requires that penetrant ,

examination procedures contain the details of the method of pre-examination cleaning.

(2) Penetrant examination procedure N-PT-1 Rev. 2 requires _

removal of paint, slag and other masking materials from the specimen surface prior to penetrant application.

(3) Penetrant examination procedure N-PT-1 Rev. 2 requires that all welds blend smoothly into the parent metal.

Contrary to the above, on September 21, 1080:

~~~

(1) Penetrant examination procedure N-PT-1 Rev. 2 did not

• contain the details of mechanical pre-examination cleaning tethods used to prepare welds for inservice inspection penetrant examinations. Also, the procedure did not prescribe the details of the method to be usad to remove couplant remaining on a weld from prior ultrasonic examination (weld TRHR-2-191).

(2) Paint and small amcunts of slag and other mas'<ina, materials were not removed from the surface of weld TRHR-2-101 prior to application of penetrant in an inservice inspection penetrant examination being conducted in accordance with procedure N-PT-1 Rev. 2.

(3) Weld TRHR-2-101 was not prepared to blend smoothly into the parent retal for a:' inservice inspection penetrant examination conducted in accordance with procedure N-PT-1 Rev. 2.

This is an infraction.

B PESPO?'SF Corracti're Stans Taken and Results Achievad Nhen a level II examiner started to examine weld TRHR-2-101, he realized that the weld was not ready to 5e liquid penatrant exanined because ultrasonic test (UT) couplant was still present on the weld.

After removing the couplant with demineralizad water, the examiner called TVA's level III examiner. The level III examiner reco:imended that a preliminary liquid penetrant examination be performed and that the results he used to determine if more surface preparation 'ias required, how much, and where. This preliminary examination was witnessed by the NRC inspector. The level II examiner failed to notify the NRC inspector that this liquid penetrant examination was only a preliminary test. This preliminary or "information test" indicated the need fer additional cleaning.

This additional cleanine removed paint soots present on the weld, as well as some small amounts of slag that were present. Weld TRHR-2-101 has been reexamined using very careful cleanine in crevice areas which may trap excess penetrant. The reexamination was performed on November 6, 1c80. .

Corrective Steos Which Will Be Taken to Avoid Further Morcemoliance Liquid Penetrant Procedure l'-PT-1, Revision 2, will be changed to address cleaninc of ultrasonic couplant with demineralized water.

Ve vill attempt to keep MRC inspectors better advised in the future as to whether the examinations they witness are only preliminary or official examinations.

Date FMen Full Comoliance Will Be Achicved Revisions to the Liquid Penetrant Proced' ire N-PT-1, Revision 2, ,

should be effective by February 1, 1081.