ML20082K013
| ML20082K013 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 04/13/1995 |
| From: | Machon R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9504190037 | |
| Download: ML20082K013 (7) | |
Text
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i Tennessee Vaney Authonty, Post Office Box 2000, Decatur, Alabama ?EY2000 R. D. (Rick) Machon Vce President, Browns Ferry Nuclear Ptant f
April 13, 1995 U.S.
Nuclear Regulatory Commission 10 CFR 2 i
ATTN:
Document Control Desk Appendix C Washington, D.C.
20555 Gentlemen:
In the Matter Of
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Docket Nos. 50-259 Tennessee Valley Authority
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50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN) - NRC INSPECTION REPORT 50-259, 50-260, 50-296/95 REPLY TO NOTICE OF VIOLATION (NOV)
This letter provides our reply to the subject NOV transmitted by letter from Charles A.
Casto, NRC, to Oliver D. Kingsley, TVA, dated March 16, 1995.
The NOV involved installation of a pipe support with a different model spring can than that specified by the appropriate work documents.
The event documented in this NOV involved improper implementation of Unit 3 workplans.
TVA has recently established an Incident Investigation (II) team to address the broader scope aspects of other events involving improper j
implementation of Unit 3 workplans/ procedures.
This II team is led by our Independent Review and Analysis Group, and is l
responsible for reviewing these events to identify any common l
cause factors, and determine appropriate corrective actions, as necessary.
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PDR l;
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4 Nuclear Regulatory Commission Page 2 April 13, 1995 1 provides the response to the NOV.
describes the commitments contained in this response.
If you have any questions regarding this reply, please.
contact Pedro Salas at (205) 729-2636.
i Sincerely, i
/
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-s R. D.
chon Site Vice President Enclosure cc (Enclosure):
Mr. Mark S. Lesser, Acting Branch Chief l
U.S.
Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323
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NRC Resident Inspector Browns Ferry Nuclear Plant Route 12, Box 637 Athens, Alabama 35611 i
Mr. J.
F. Williams, Project Manager r
U.S. Nuclear Regulatory Commission 3
One White Flint, North 11555 Rockville Pike i
Rockville, Maryland 20852 i
Mr.
E. V.
Imbro, NRR/RSIB U.S.
Nuclear Regulatory Commission one White Flint, North 11555 Rockville Plaza 1
Rockville, Maryland 20852 i
Mr.
E. J.
Leeds, NRR/DRPW U.S. Nuclear Regulatory Commission One White Flint, North 115555 Rockville Pike Rockville, Maryland 20852
s ENCLOSURE 1 TENNESSEE VALLEY AUTHORITY 4
BROWNS FERRY NUCLEAR PLANT (BFN)
REPLY TO NOTICE OF VIOLATION (NOV)
INSPECTION REPORT NUMBER 50-250, 50-260, 50-296/95-03 RESTATENENT OF THE VIOLATION During an NRC inspection conducted on January 9-13, January i
1 30 - February 3, and February 13-17, 1995, a violation of NRC requirements was identified.
In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the violation is listed below:
d 10 CFR, Appendix B, Criteria X, requires in part that examinations, measurements or tests of materials or i
products processed shall be performed for each work operation where necessary to assure quality.
- TVA, Browns Ferry Nuclear plant procedure No. MAI-4.2A, Revision 17, Modification and Addition Instruction, requires that:
1 6.2.2.7 Configuration i
Visually verify the support has been installed / modified in accordance with the drawing and the latest FCR's/FDCN's.
7.1 QA Record Data Sheet 1 - Piping / Tubing Support Installation Data Sheet (to be signed off as verification).
j Contrary to the above, during the inspection of January, 9-13, 1995 support 3-47B452-3035 was found to be installed with a different model spring can than that shown on the drawing.
The construction foreman and QC inspector had signed off in Data Sheet 1 that this modification was completed as required by drawings on March 31, 1994.
This is a Severity level IV Violation (Supplement I).
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'. TVA's ReDlv to the Violation i
1.
Backcround Information On July 20, 1993, Work Plan (WP)-3857-93 was approved.
This WP was issued based on the requirements specified by Design Change Authorization (DCA) W17701-455 R001.
As originally issued, this DCA specified installation of a Bergen Patterson (BP) 3100-19 Type C, spring can pipe support.
A Field Design Change Notice (FDCN) for the DCA was issued on October 4, 1993.
Since the work i
was not scheduled to be performed, the FDCN was not added to the WP.
The FDCN changed the spring can pipe l
support model number from BP 3100-19 Type C, to a BP 1
l 3200-19 Type C.
On February 24, 1994 a model BP 3100-l 19 Type C spring can pipe support was staged by the 1
Materials organization under DCA W17701-455 R001 for l
installation.
In preparation to perform the scheduled work WP, a review of the WP identified that the FDCN was not added to the WP.
Therefore, on March 3, 1994, the FDCN was added to the WP.
However, the staged material was not changed to reflect the FDCN (i.e., the BP 3200-19 Type C spring can pipe support).
From March 23 through 31, 1994 the physical work needed l
to install the spring can support was performed by Unit 3 modifications craft personnel.
2.
Reason for the Violation l
This violation resulted from inattention to detail l
during the installation and subsequent Quality Control l
(QC) inspection of the spring can pipe support.
The support installed was specified by a previous revision of the design output documents DCA W17701-455 R001.
The personnel involved performed the work utilizing the previously staged material, which included the BP 3100-19 Type C, spring can pipe support.
Although the revised design output document (i.e., DCA W17701-455 R002) had been properly incorporated into the WP, the individuals performing the work did not recognize the l
change.
Consequently, they installed the incorrect l
support.
The foreman signed that the work was completed as specified by the WP without physically verifying the spring can support was the model specified by the WP drawings.
Following the installation, the QC inspector incorrectly determined that the proper support had been installed.
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The QC inspector that was involved during the installation of the spring can pipe support was interviewed regarding this issue.
The inspector indicated that he had reviewed the revised WP, and j
identified that the WP specified a BP 3200-19 Type C i
support.
However, the inspector incorrectly read the j
manufacturer's model number from the installed spring can pipe support as BP 3200-19 Type C and not a BP 3100-19 Type C.
It should be noted that both of the spring can pipe supports have similar physical characteristics.
However, the BP 3200-19 Type C is slightly longer than the BP 3100-19 Type C support to accommodate a longer stroke.
3.
Corrective Actions Taken and Results Achieved TVA generated a Problem Evaluation Report (PER) to determine the root cause and develop corrective actions.
The corrective actions taken included:
The BP 3100-19 Type C, spring can pipe support was remosad and replaced with a BP 3200-19 Type C, spring can pipe support.
TVA reviewed this event with Unit 3 modifications personnel to emphasize: (1) attention to detail, and (2) the importance of verifying that staged material is the correct material.
The QC inspector involved in the incorrect spring can support has been retrained on his responsibilities.
Additionally, the activities of the QC inspector of record were monitored and it was determined that no further actions were necessary.
" Lessons Learned" training on this event was e
conducted with other QC support inspectors.
To determine the magnitude of the problem, a sample of 60 pipe supports was randomly selected for reinspection per the applicable attributes contained in Modification and Addition Instruction
- 4.2A, "TVA-BFNP Piping / Tubing Supports."
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material identification problems were found during the reinspection effort which included various vendor supplied materials such as spring cans, sway struts, pipe clamps, snubbers, etc.
Four problems unrelated to material identification were identified and documented in a Problem Evaluation Report (PER).
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4 4.
Corrective Steps That thave been orl will Be Taken to Prevent Recurrence As noted in the previous section, this. event has been reviewed with the Unit 3 Modifications personnel.
Additionally, to ensure other affected organizations are aware of this event, the circumstances that led to this NOV will be reviewed by the appropriate Unit 2 maintenance and modifications personnel.
TVA expects to complete this action by June 15, 1995.
An Incident Investigation (II) team has been assembled to address the broader scope aspects of other events involving Unit 3 workplans/ procedures not being properly implemented.
The event described in this NOV is included in the scope of the II.
This II team is led by BFN's Independent Review and Analysis Group, and is responsible for reviewing these events to l
identify any common cause factors,.and determine appropriate corrective actions, as necessary.
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Date When full conoliance Will be Achieved Full compliance with the circumstances described in this NOV has been achieved.
TVA expects to complete the actions being taken to prevent recurrence by June 15, 1995.
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e ENCLOSURE 2 TENNESSEE VALLEY AUTHORITY 4
BROWNS FERRY NUCLEAR PLANT-(BFN)
INSPECTION REPORT NUMBER l
50-250, 50-260, 50-296/95-03 LIST OF COMMITMENTS l
In this submittal, TVA has identified several corrective actions that have been or will be taken.
Some of the actions are regulatory commitments, others are voluntary enhancements.
Identified below is the action that TVA considers a regulatory commitment.
j The circumstances surrounding this event will be reviewed by the appropriate Unit 2 maintenance and modifications personnel.
TVA expects to have this action completed by June 15, 1995.
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