ML20080M789

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Responds to NRC Re Violations Noted in IE Insp Repts 50-259/83-24,50-260/83-24 & 50-296/83-24.Corrective Actions:Lmt Examiners Barred from Performing Addl Intergranular Stress Corrosion Cracking Exams
ML20080M789
Person / Time
Site: Browns Ferry  Tennessee Valley Authority icon.png
Issue date: 08/24/1983
From: Mills L
TENNESSEE VALLEY AUTHORITY
To: James O'Reilly
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20080M770 List:
References
IEB-83-02, IEB-83-2, NUDOCS 8310040271
Download: ML20080M789 (3)


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1 TENNESSEE VALLEY AUTHORITY CHATTANOOGA. TENNESSEE 374o1 400 Chestnut Street Tower II

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U.S. Nuclear Regulatory Commission # d Region II $ O[I ATTN: James P. O'Reilly, Regional Administrator g o.

101 Marietta Street, NW, Suite 2900 m E' Atlanta, Georgia 30303

Dear Mr. O'Reilly:

Enclosed is our response to D. M. Verrelli's July 25, 1983 letter to H. G. Parris transmitting Inspection Report Nos. 50-259/83-24,

-260/83-24, -296/83-24 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.

Very truly yours, TENNESSEE VALLEY AUTHORITY 9

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. M. Mills, ager Nuclear Licensing Enclosure 8310040271 830914 PDR-ADOCK G

05000259 pyg 1983-TVA SOTH ANNIVERSARY An Equal Opportunity Employer

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RESPONSE - NRC INSPECTION REPORT NOS.

50-259/83-24, 50-260/83-24, AND 50-296/83-24 D. M. VERRELLI'S LETTER TO H. G. PARRIS '

DATED JULY 25, 1983 259/83-24-01 10 CFR 50, Appendix B, Criterion IX, requires that, " measures shall be established to assure that special process, including . . . non-destructive testing are controlled and accomplished by qualified personnel." In addition, Criterion XVII requires that sufficient records shall be maintalhed to furnish evidence of activities affecting quality and that the records shall also include closely-related data such as qualifications of personnel. IE Bulletin 83-02 requires that, licensees / vendors who have completed efforts to validate their UT detection capability in accordance with IE Bulletin 82-03 need not repeat this qualification effort for IE Bulletin 83-02 provided that:

. . . the UT personnel employed in the new examinations are the'same; or those having appropriate training (documented) in intergranular stress corrosion crack inspection using cracked thick-wall pipe specimens, and are under the direct supervision of Level II/III UT operators who successfully completed-the performance demonstration test. . _ . . . . . . _ . _ . . _ . _ , _ . . . . . _ . . _ . . . _ _ _ , _ _ . _ _ _ _ _ . _ ..

Contrary to the above, on June 22, 1983, LMT examiners other than those

- who ;had. completed the validation effort at Battelle Memorial Institute in Columbus, Ohio were observed examining welds on the Unit 1 recircu-lation system. Subsequent review of their qualification records did not reveal documented training on thick-wall IGSCC on a pipe specimen.

On June 23, 1983, TVA was able to provide verification of training conducted by Georgia Power for two of the three examiners involved.

This is a Severity Level V Violation (Supplem- I).

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1. Admission or Denial of the Alleged Violation l

TVA admits the violation occurred as stated.

2. Reasons for the Violation if Admitted The violation resulted from personnel error. The cognizant reviewer was aware that documented training was available on two of the LMT examiners. The verification of training on thickwall intergranular stress corrosion crack (IGSCC) on a pipe specimen for the two examiners was obtained from Southern Service.

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-2 LMT was the contractor who performed the IGSCC examinations required by IE Bulletin 82-03, Revision 1, on Browns Ferry unit 2 during the Fall 1982 outage. The third examiner who had no verifi-cation of training was an employee of LMT during that time and performed IGSCC examinations dUring the Browns Ferry unit 2 Fall 1982 outage. Therefore, it was assumed that he was qualified.

3. Corrective Steps Which Have Been Taken and the Results Achieved When it was pointed out to TVA that LMT had an individual that was not properly qualified, they were not permitted to perform additional examinations.
4. Corrective Steps Which Will be Taken to Avoid Further Violations.

Future contracts written for compliance to IE Bulletin 83-02 will require documented proficiency in detection of IGSCC in thickwall piping or alternatively qualification will be demonstrated on TVA supplied cracked samples.

5. Date When Full Compliance Will be Achieved Full compliance was achieved June 23, 1983, when LMT was not permitted to perform additional IGSCC examinations.

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