ML20078M617
| ML20078M617 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 09/30/1983 |
| From: | Mills L TENNESSEE VALLEY AUTHORITY |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20078M597 | List: |
| References | |
| NUDOCS 8310250240 | |
| Download: ML20078M617 (4) | |
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u TENNESSEE VALLEY AUTHOREYNPO Prii D N."
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CHATTANOOGA, TENNESSEE 374ol 400 Chestnut Street Tower II 83 0ci 3 A10 : 14 September 30, 1983 U.S. Nuclear Regulatory Commission Regica II, I
ATTN: James P. O'Reilly, Regional Administrator 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30303 1
Dear Mr. O'Reilly:
Enclosed is our response to R. C. Lewis' September 1, 1983 letter to H. G. Parris transmitting Inspection Report Nos. 50-259/83-28,
-260/83-28, -296/83-28 regarding activities at our Browns Ferry Nuclear Plant which appeared to have been in violation of NRC regulations. We have enclosed 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.
1 Very truly yours, TENNESSEE VALLEY AUTHORITY L. M. Mills, Manager Nuclear Licensing Enclosure G310250240 831007 PDR ADOCK 05000259 G
PDR 1983-TVA SOTH ANNIVERSARY An Equal Opportunity Employer
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-RESPONSE - NRC INSPECTION REPORT NOS.
'50-259/83-28, 50-260/83-28, and 50-296/83-28 R. C. LEWIS' LETTER TO H. G. PARRIS DATED SEPTEMBER 1, 1963 Item A (259/83-28-01) 10 CFR 50, Appendix B, Criterion V as implemented by the Topical Report TVA TR-75-01, Paragraph 17.2.5, requires that, " activities affecting quality shall be prescribed by documented instructions, or drawings of a type appropriate to the circumstances, and shall be accomplished in accordance with these instructions, procedures or drawings." TVA's BFNP Standard Practice Proceduce No. 16.4, paragraph 2.5, requires as
- part of the receipt inspection of QA Level I items, that the QC inspector shall review and verify manufacturing documentation and material certifications of physical. properties to assure that physical properties conform to the specified requirements and that chemical and physical test reports meet these requirements. TVA's Modification and Area Instruction BF MAI 12 paragraph 1.3 states that, welding material used in the outage tool room shall be purchased from Power Stores or the ECN warehouse on TVA Form 575 and that a copy of the 575 be main-tained in the tool room as long as those rods are being issued. TVA's Modification and Area Instruction MAI 15.3, paragraph 15, states, for QAS Levels I, II, certified and significant material, a copy of the 575D with applicable control number will be supplied to the individual withdrawing the item for attachment to the applicable work document.
Contrary to the above, the licensee did not follow procedure for receiving and issuing Welding Consumables as indicated by the following examples:
(1) Two lots of Sandvik welding wire were in the tool issue room without any physical and chemical reports on site.
(2) Four lots _of welding wire were in the issue tool room without a TVA Form 575.
(3) A spool of welding wire witn a heat number that could not be supported by physical and chemical documentation was observed in NUTECH's trailer. This spool was-missing from the lot in the issue ' tool room but records did not reveal its issue, nor did the t
individual withdrawing the welding wire receive a copy of the 575 as required.
(4) Welding wire was being issued by the tool room using the purchase order number as the unique control number. The purchase order i
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. number is not unique. It covered welding wire with acceptable documentation as well as welding wire that should have been nonconformed.
This is a Severity Level IV Violation (Supplement 1).
1.
Admission or Denial of the Alleged Violation TVA admits the violation occurred as stated.
2.
Reasons for the Violation if Admitted A s'ection of the contract with NUTECH required NUTECH to supply the welding material (which includes welding wire, grinding disc, are gouging, etc., but no weld rods) but did not specify the type of welding wire to be used or adequately specify the procedure for transferring of the welding material to TVA for receipt and inspection. The contract should have required this material and certification papers to enter the plant through Power Stores which would have ensured correct paperwork and a unique control number.
Instead, the contract only required that the welding material was to be turned over to TVA for control and that certification and chemical analysis was to be supplied to the Chemical, Metallurgy, and Standards Group (CMSG) for approval.
3.
Corrective Steps Which Have Been Taken and the Results Achieved Transfer of msterial on site from NUTECH to TVA has been completed. Remaining welding material to be supplied by NUTECH will enter TVA through Power Stores. NUTECH was transferring the welding material to TVA by giving the welding material to the tool-roca for issue. NUTECH transferred welding material to TVA that had not been approved by CMSG, but this welding material was not issued for use by the toolroom until approved by CMSG and had proper certification papers. Therefore, positive control was maintained. The welding wire which was in NUTECH's trailer had been aporoved by TVA. NUTECH was holding this welding wire in the trailer so that a NRC inspector could check some of the welding material supplied by NUTECH.
4.
Corrective Steps Which Will Be Taken to Avoid Further Violations All future contracts will have the requirements for receiving material at the plant sites and material specifications to permit receipt inspection of quality assurance level material.
5.
Date When Full Compliance Will Be Achieved Full compliance has been achieved.
'. Item B (259/83-28-02) 10 CFR 50, Appandix B, Criterion IX, requires that measures shall be established to assure that special processes are controlled. TVA 4
Process Specification 4.M.1.1.(h), paragraph 3 1.2.2, requires that wire brushes used on austenitic stainless steel components or weld metal shall be austenitic stainless steel and shall not have been previously used on other.than stainless steel or high nickel alloy.
Contrary to the above, the licensee has not established any measures that can be verified to control the use of prohibited materials such as wire brushes that have been used on materials other than austenitic stainless steel or high nickel alloys.
This is a Severity Level V Violation.(Supplement 1).
1.
Admission or Denial of the Alleged Violation TVA admits the violation occurred as stated.
2.
Reasons for the Violation if Admitted TVA has considered the process specification, which is normally referenced in the work instructions, to be adequate for the performance of work. However, when wire brushes were issued, there was no method established for controlling the type of metal on which a wire brush would or had been used.
3 Corrective Steps Which Have Been Taken and the Results Achieved Wire brushes for use on austenitic stainless steel components or weld metal have been uniquely marked with red paint and are kept in separate locations from other wire brushes in the toolrooms. In addition, when issuing wire brushes, toolroom clerks request the type of metal that the brush is to be used on.
This allows properly marked brushes to be issued for stainless steel usage.
4.
Corrective Steps Which Will Be Taken To Avcid Further Violations None.
5.
Date When Full Compliance Will be Achieved i
Full compliance has been achieved.
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