ML20041F761
| ML20041F761 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 02/22/1982 |
| From: | Mills L TENNESSEE VALLEY AUTHORITY |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20041F747 | List: |
| References | |
| NUDOCS 8203170391 | |
| Download: ML20041F761 (5) | |
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s TENNESSEE VALLEY AUTHORITY CH ATTANOOGA. TENNESSEN 87dOtlI C rl 400 Chestnut Street Tower II?!E' 3 a, February j ((1 QlS P3 28 U.S. Nuclear Regulatory Coinnission Region II ATTN: James P. O'Reilly, Regional Administrator 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303
Dear Mr. O'Reilly:
This is in response to R. C. Lewis' January 12, 1982 letter to H. G. Parris, Report Nos. 50-259/81-36, -260/81-36, and -296/81-36, concerning activities at the Browns Ferry Nuclear Plant which appeared to violate NRC requirements. Enclosed is our response to Appendix A, Notice of Violation. If you have any questions, please call Jim Domer at FTS 858-2725.
To the best of my knowledge, I declare the statements contained herein-are complete and true.
Very truly yours, TENNESSEE VALLEY AUTHORITY L.
. Mills, Mnager Nuclear Regulation and Safety Enclosure 9203170391 820309 PDR ADOCK 05000259 Q
PDR An Equal Opportunity Employer
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ENCLOSURE RESPONSE - NRC INSPECTION REPORT NOS.
50-259/81-36, 50-260/81-36, AND 50-296/81-36 R. C. LEWIS' LETTER TO H. G. PARRIS DATED JANUARY 12, 1982 tem A - (259/81-36-06 and 296/81-36-06) 10 CFR 50.55a(g) requires the licensee to comply with the requirements of' ASME Section XI.
ASME Section XI requires the preparation of specified inservice inspection reports which must be maintained as plant records and must be filed with the NRC within 90 days of completion of each inservice inspection.
Contrary to the above noted requirements, the specificd incervics inspection reports were apparently not prepared, maintained as records, or furnished to the NRC within the required 90 days for inservice inspections performed during the following plant outage dates for Units 1 and 3:
Unit 1 - Outages of 9/13/77 to 1/15/78 and 1/3/80 to 3/22/80 Unit 3 - Outages of 9/8/78 to 11/25/78 and 11/23/80 to 1/18/81 This is a Severity Level V Violation (Supplement II.E.).
This applies to Units 1 and 3 only.
1.
Admission or Denial of the Alleged Violation TVA admits the violation occurred as stated.
2.
Reasons for the Violation if Admitted Adequate administrative controls and responsibilities for preparing the in-service inspection reports had not been established.
3 Corrective Steps Which Have Been Taken and Results Achieved The nondestructive examination reports as required by Article IWA-6340 of Section XI of the ASME Code which were not available have been prepared. The reports will be submitted to NRC and a copy will be maintained at the plant site by March 31, 1982.
4.
Corrective Steps Which Will Be Taken To Avoid Further Violations a.
An administrative program for complying with Article IWA-6000 Records and Reports, of Section XI of the ASME Code is in the process of being written.
b.
A quality assurance procedure is being prepared and will be implemented in the Nuclear Operational Quality Assurance Manual (N-0QAM) by June 1982.
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-2 c.
A special training program is presently being prepared which will educate both central office and plant personnel relative to what records and reports are required by code. This training program should be completely implemented by June 1982.
d.
A quality assurance engineer at the plant will be assigned to ensure implementation of ASME Code of Section XI, Records and Reports, by August 1982.
5.
Date When Full Compliance Will Be Achieved We will be in full compliance by August 1982 when programs and procedures are fully implemented.
Item B - (259/81-36-03, 260/81-36-03, 296/81-36-03) 10 CFR 50, Appendix B, Criterion V, as implemented by the Topical Report, TVA TR 75-01 paragraph 17.2.5, requires the licensee to prescribe activities affecting quality in documented instructions, procedures or drawings which include appropriate acceptance criteria for determining that the activities have been satisfactorily accomplished.
Contrary to the above, the licensee did not have a work or inspection document to prescribe the means of installing, securing, and inspecting the necessary locking devices on the main steam isolation valves locking plate fasteners.
This is a Severity Level V Violation (Supplement II.E).
1.
Admission or Denial of the Alleged Violation TVA admits the violation occurred as stated.
2.
Reasons for the Violation if Admitted Mechanical Maintenance Instruction (MMI) 17 had a check which required seeing that locking tabs on the stem plate were bent; it was at the ti=e considered within the skills of the craft to perform this work without detailed written instructions or drawings to detail the proper method of bending a locking tab.
3 Corrective Steps Which Have Been Taken and Results Achieved Inspections have been conducted on units 1 and 2 inboard and outboard main steam isolation valve (MSIV) stem plate locking tabs ard improperly bent or missing locking tabs were corrected.
It4I-17 has been modified to include more detailed instructions for installing and bending the locking tabs along with appropriate verification signoffs.
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. 4.
Corrective Steps Which Will Be Taken To Avoid Further Violations Corrective steps related in item 3 above will also be completed on unit 3 before startup from the current refueling outage.
5.
Date When Full Compliance Will Be Achieved Full compliance will be achieved at the completion of unit 3, cycle 4 refueling outage on or about March 26, 1982.
Item C - (259/81-36-04) 10 CFR 50, Appendix B, Criterion IX, as implemented by the Topical Report, TVA TR 75-01 paragraph 17.2.9, requires the licensee to control and accomplish special processes, such as radiographic examination of welds, using qualified procedures in accordance with applicable codes.
Contrary to the above, the licensee did not control and accomplish radiographic examination of welds in accordance with their procedure (N-RT-1) and its referenced code requirements as indicated by the following examples of inadequate performance of radiographic examination steps for weld TP-1-H in a safety-related main steam tail pipe:
(1) Procedure N-RT-1 specified weld acceptance requirements which n(yessitateevaluationofradiographicallydetectedlinearindications exceeding 3/4 inch in length. Weld TP-1-H was accepted without evaluation of a 1-1/2 inch long linear indication that appeared on the film for the weld.
(2) Informed of the above radiographic indication by an NRC inspector, the licensee performed grinding on and re-radiographed a portion of the subject weld to evaluate its acceptability. However, the licensee failed to properly identify the location of the indication in accordance with means given in procedure N-RT-1, and as a result, the wrong area was evaluated and was accepted.
This is a Severity Level V Violation (Supplement II.E).
This applies to Unit 1 only.
1.
Admission or Denial of the Alleged Violation TVA admits the violation occurred as stated.
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, 2.
Reasons for the Violation if Admitted The violation cited represents two problems which must be addressed separately. The first problem is failure to either note the 1-1/2-inch long linear indication or to record an evaluation of the indication.
The only apparent reason for the failure is inspector error. Since the individual inspector involved has noted and properly evaluated much smaller indications on similar work in the past, and the indicatior in' question appears to be a satisfactory surface condition, the error is considered to be a failure to properly complete the inspection record.
The second problem is the failure to examine the correct area on a subsequent examination. The primary reason for this failure is considered to be loss of process control caused by inadequate marking of the radiograph layout due to grinding operations in adjacent weld areas.
3.
Corrective Steps Which Have Been Taken and Results Achieved The discovery of the problem after unit 1 startup precluded the reradiograph of the repaired area. A safety evaluation has been performed on the linear indication and the results were acceptable for continued operation.
This problem has been discussed with personnel of the contract radiographer, Industrial Laboratories, so they are aware of the violation. A change to this contract was issued in January 1982 to authorize backcharging the contractor for incorrect and/or incomplete work.
Presently, the only radiography underway at Browns Ferry is for the main steam relief valve (MSRV) tailpipe tees, torus hatch, and high-pressure coolant injection (HPCI) line on unit 3 Each reworked radiograph is being compared with the previous shot and a final review of all quadrants and films together is being performed.
4.
Corrective Steps Which Will Be Taken To Avoid Further Violations A procedure that will address radiography layout and grinding control will be developed for handling radiography before the next unit 1 refueling outage. Reradiograph of weld TP-1-H has been added to the short outage list; and if an outage occurs of sufficient duration, the weld will be radiographed. Otherwise, this will be scheduled for the next unit 1 refueling outage.
5.
Date When Full Compliance Will Be Achieved The radiography procedure will be completed before radiography work on the next refueling outage. Full compliance will be achieved when the radiography on the weld in question is completed. This will be no later than the end of the unit 1, cycle 5 refueling outage scheduled to end in June 1983 I