ML20003F453
| ML20003F453 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 02/18/1981 |
| From: | Mills L TENNESSEE VALLEY AUTHORITY |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20003F447 | List: |
| References | |
| NUDOCS 8104210269 | |
| Download: ML20003F453 (5) | |
Text
s C
. TENNESSEE VALLEY AUTHORITY
,CH ATTANOOGA. TENNESSEE 374C1 400 Chestnut Street Tower II t
February 18, 1981 Mr. James P. O'Reilly, Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Region II - Suite 3100 101 Marietta Street Atlanta, Georgia 30303
Dear Mr. O'Reilly:
This is in response,to your letter dated January 22, 1981, which transmitted IE Investigation Report 50-260/80-34 concerning activities at Browns Ferry Nuclear Plant which appeared to be in noncompliance with NRC requirements.
If you have any questions, please call Jim Domer at FTS 857-2014.
Very truly yours, TENNESSEE VALLEY AUTHORITY
.I 1
s L. M. Mills, Manager Nuclear Regulation and Safety Subscribed a d sworn t er re me this /
day of,
1981.
JlA NotapPublic ' ~
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My Commission Expires
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Enclosure B10.4210 l
m =. _ ~..
ENCLOSURE RESPONSE TO J. P. O'REILLY'S LETTER DATED JANUARY 22, 1981, TO H. G. PARRIS BROWNS FERRY NUCLEAR PLANT
~ ~ ~ ~ ~
(50-260/80-34)
Item A h.
10 CFR 50, Appendix B, criterion V and Topical Report TVA-TR75-01, paragraph 17.2.5, require " activities affecting quality shall be prescribed by documented instruction, procedures.
and shall be accomplished in accordance with those instructions, procedures.
." Instructions documented in Part III, Section 7.2 of the Operational Quality Assurance
. Manual and in Standard Practice 7.2 of the Operational Quality Assurance Manual and in Standard Practice BF 10.3 require that a failure to comply with applicable codes or specifications be considered a noncompliance item to be reported on form BF-20 and forwarded to the QA supervisor for disposition.
Contrary to the above, on October 22, 1980, a failure to comply with code and specification requirements occurred which was not documented or submitted for proper disposition. Welding was performed on hf.gh pressure coolant injection system weld FW-9 by an unqualified welder, a violation of the applicable code (USAS B31.1.0) and specification (N73M2) requirements.
Supervision was aware of this, but failed to dc ument the noncompliance on form BF-20 and submit it for proper disposition.
This is a Severity Level V Violation (Supplement II.E).
1.
Admission or Denial of the Alleged Violation TVA sgrees to the violation.
2.
Reasons for the Violation if Admitted The corrective action report, form BF-20, was not submitted because the deficiency had been identified, corrected, and documented in the work instruction by the group initially performing the work and therefore was not at the time considered an incident resulting in a nonconforming condition.
i 3.
Corrective Steps Which Have Been Taken and Results Achieved a.
The weld was cut and remade by a qualified welder and documented in the work instruction.
b.
Subsequently, a form BF-20 was initiated to formally document the incident and its safety-related significance.
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4.
Corrective Steps Which Will Be Taken to Avoid Further Violations a.
A training session was held with all outage engineering personnel to review the subject of nonconforming conditions and specifically-the use of the corrective action report in doccmenting these conditions.
h.
b.
Training on corrective actions and conditions adverse to quality will be made a part o.f the periodic training for outage engineering and supervisory personnel.
5.
Date Full Compliance Will Be Achieved Full compliance will be achieved by April 1, 1981.
Item B 10 CFR 50, Appendix B, Criterion V and Topical Report TVA-TR75-01, paragraph 17.2.5, require " activities affecting quality shall be prescribed by documented instructions, procedures and shall be accomplished in accordance with those instructions, procedures.
." Instructions in TVA Process Specification 1.M.3.l(f) (a part of TVA Specification N73M2), require that "after welding materials have been removed from containers or. packages they shall be identifiable by_ type until consumed."
Contrary to the above, on October 30, 1980, all welding materials were not maintained identifiable by type in that two unidentified lengths of bare wire were mixed with similar appearing, but properly identified, ER-308 (stainless steel) weld wire in the issue station. The unidentified wires appeared to be carbon steel.
In addition,. instructions were not provided for control of unused bare filler wire for Cas Tungsten Arc welding and uncontrolled welding material was present on the torus.
This is a Severity Level V Violation (Supplement II.E).
i 1.
Admission or Denial of the Alleged Violation TVA agrees to the violation regarding the unidentified weld a.
rods at the issue station.
[
b.
TVA does not agree with the violation ".
. instructions were l
not provided for control of unused bare filler wire for Cas
(
Tungsten Arc welding" MAI 12 stated that "
. bare rods I
and studs should be returned at the end of each shift." This should have been adequate instructions.
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2.
Reasons for the Violation if Admitted
~a.
An investigation by tool room personnel did not determine the reasons for the two unidentified lengths of bare wire being cixed with stainless steel weld wire at the issue station; however, based on procedures for control of welding materials, these unmarked rods would not have been issued.
b.
The uncontrolled welding material on top of the' torus was a result of poor housekeeping and the failure of craftsmen to return all, unused weld material at the end of each shift as stated in MAI 12.
3..
Corrective Steps Which Have Been Taken and Results Achieved a.
The unidentified weld rods in the tool room were immediately destroyed.
b.
The area where the weld rods on the torus were found was cleaned up and the stubs disposed of.
4.
Corrective Steps Which Will Be Taken To Avoid Further Violations n.
The specific requirements in MAI 12 which state, "Any welding materials whose positive identificatinn has been lost shall be destroyed," have been discussed with tool room attendants.
b.
The requirement of MAI 12 to return all unused material at the end of each shift has and will continue to be emphasized to outage supervisors, foremen, and certified welders.
In addition, MAI 12 will be changed to require a monthly survey of work areas for proper control of welding materials and the wording ".
bare rod and stubs should'be returned" will be changed to ".
bare rods and stubs will be returned."
5.
Date When Full Compliance Will be Achieved Full compliance will be achieved on March 15, 1981.
Item C 10 CFR 50.55.a(d) and the FSAR require that high pressure coolant injection (HPCI) system piping meet the requirements of USAS B31.1.0 (1967).
Based on Figure 127.4.4.C of USAS B31.1.0 (1967), HPCI system piping oypass line fillet (socket) welds FW-1 through FW-9 (documented in TVA Browns Ferry Work Package 9883) require fillets ranging in size from about 1/4-5/16 inch.
Contrary to the above, on October 31, 1980, welds FW-1 through FW-9 were undersize an estimated 1/16-1/8 inch.
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This is a Severity Level V Violation (Supplement II. E).
E*,
l.
Admission or Denial of the Alleged Violation TVA agrees to the violation.
2.
Reasons for the Violation if Admitted a.
This condition was caused by the lack of specification of weld y,
size in the work plan; and b.
The failure of quality control personnel' performing the visual and dye penetrant examinations to verify the weld size.
i 3.
Corrective Steps Which-Have Been Taken and Results Achieved
~
a.
A corrective action report was initiated to identify the nonconformance item.
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j b.
Fillet metal was added and the welds were subsequently visually i
and dye penetrant examined and accepted. The work plan was revised to document the addition of fillet metal.
c.
Additional work plans worked during the.same refueling outage i
with similar fillet socket welds were checked and undersized l
welds were repaired in the same manner.
4.
Corrective Steps Which Will be Taken to Avoid Further Violations a.
Training was conducted with outage engineers and certified welders to review the sockat weld size requirements.
i j
b.
Plant instructions will be written so that socket veld size requirements for specific schedules and sizes of piping are included in applicable work plans.'
c.
Inspection perso$.nel have been advised as to the requirement to check size as part of the predye penetrant inspection.
t 5.
Date When Full Compliance Will be Achieved f
Full compliance will be achieved on April 1, 1981.
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