ML20100E762
| ML20100E762 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 10/19/1984 |
| From: | Mills L TENNESSEE VALLEY AUTHORITY |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20100E730 | List: |
| References | |
| NUDOCS 8412060364 | |
| Download: ML20100E762 (4) | |
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TENNESSEE VALLEY AUTHORITY CHATTANOOG A. TENNESSEE 374ol 400 Chest Street Tower II N OCT a D : U8 October 19, 1984 U.S. Nuclear Regulatory Commission Region II-ATTN: Jartes P. O'Reilly, Regional Administrator 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323
Dear Mr. O'Reilly:
Enclosed is our response to R. C. Lewis' September 20, 1984 letter to H. G. Parris transmitting IE Inspection Report Nos. 50-259/84-31,
-260/84-31, -296/84-31 for our Browns Ferry Nuclear Plant which appeared to have been in violation of NRC regulations. We have enclosed our response to the 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
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L. M. Mills, anager Nuclear Licensing Enclosure 8412060364 841106 PDR ADOCK 05000259 G
PDR An Equal Opportunity Employer
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RESPONSE
NRC INSPECTION REPORT NOS.
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~50-259/84-31, 50-260/84-31, AND 50-296/84-31 R. C. LEWIS'S LETTER TO H. G. PARRIS DATED SEPTEMBER 20,1984 ( A02 840924 005)
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Enclosure Item l' "G0-254784-11-01 j
10 CFR 50, Appendix B, Criteria II and I, as implemented by TVA Topical li Report TVA TR-75-01, Paragraph 17.2.2 and 17 2.10 require training of personnel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained and also stipulates j
that inspections are required to be performed by individuals other than those who performed the activity being inspected.
TVA's Standard Practice BF 3.2 requires that, activities and characteristics shall be verified by using QC inspection hold points when these activities could affect the structural integrity of the reactor coolant pressure boundary components.
Examples of procedural activities and characteristics included welding activities and dimensional characteristics of materials and components.
- a.
Contrary to the above, paragraphs 8.13(a) and 8.13(b) of TVA's Weld Travelers (Special Mechanical Maintenance Instruction 14.4.1.3-1) for the overlay weld repairs on Unit 1 sweepolets, did not contain QC hold points to verify that the required dimensional measurements were taken to ensure correct weld profiles and to provide the basis for the final analysis of the completed weld. The visual measurements for these welds were taken by Weldings Services, Inc., personnel who had made the weld and were not certified to make the visual examinations.
All overlay repair welds on Unit 1 sweapolets were found to have significant dimensional errors when t
reexamined by TVA's certified QC examiners.
This is a Severity Level IV violation (Supplement 1.D.2).
1.
u=4mmion or Denial of the A11ered Violation TVA admits the alleged violation as stated.
2.
Reasons for the Violations After the in process work had started, the physical configuration of sweepolets required alternate techniques (visual mechanical) to be utilized in lieu of originally planned instructions for UT 4
measurements.
The SMMI was revised to incorporate this alternate testing by mechanical visual means but responsible engineering personnel failed to incorporate proper application of QC hold points.
This is contrary to site procedures.
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Corrective Stens Which Have Been Taken and Results Achieved
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The as-built dimensions'of: tee we' ds were"weashred and documented by QC i
inspectors.
The as-built-dimensions'were' reanalyzed and judged to be acceptable for service.
1 4.
Corrective Steos Which Will Be Taken to Avoid Further Violations Special Mechanical Maintenance Instruction 14.4.1.3-1, overlay Weld Repair For Class I Stainless Steel ~ Piping, ~will be revised to include' QC verification of dimensional measurements of completed welds.
Training will be conducted for quality assurance, and modification personnel normally involved in overlay weld repairs. The training will include requirements for independent verification of contractor activities, specification of QC hold points, and incorporation of the
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quality assurance organization in surveillance of contractor activities i
on critical system, structures and components.
1 5.
Date When Full Conoliance Will Be Achieved Full compliance -will be-achieved by November 19, 1984 when Special Maintenance Instruction 14.'4.1.3-1 will have been revised and the needed training accomplished.
4 Item 2 250/84-11-02 10CFR, Appendix B, Criterion VI, as implemented by TVA Topical Report TVA TR-75-01, paragraph 17 2.6 requires, changes to documents be reviewed and approved by the same organization that performed the original review and approval.
TVA's Standard Practice BF 3.2 also requires approval for intent changes.
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Contrary to the above, procedures were not changed and approved to provide j
a QC hold point for visual dimensional measurements when ultrasonic readings could not be obtained in accordance with paragraph 8.13(b) of the Weld Travelers (SMMI-14.4.1.3-1) for weld Nos. KR-1-20 and KR-1-42.
This is a Severity Level IV violation (Supplement I.D.2).
i 1.
Admission or Denial of the Allemed Violation TVA admits the alleged violation as stated.
2.
Reasons for the Violations Supervisory and engineering personnel failed to adequately review
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activities and implement needed instruction changes. There was a misjudgement on the part c* the cognizant engineer as he failed to recognize that the overlay dimensions taken by visual dimensional means (not ultrasonic testing) would be used for design analysis.
Also, by not recognizing the need for the visual measurements to be used for analysis, the cognizant engineer did not stop the work and initiate j
appropriate document changes.
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Corrective Steos Which Have Been Taken and Results Achieved The involved supervisor and engineering personnel were reinstructed on instruction change procedees and the need to incorporate QC hold points. The instruction was conducted during the initiation of a corrective action report concerning this event.
4.
Corrective Steos Which Will Be Taken to Avoid Further Violations Training for modifications personnel will be conducted which covers procedures to be followed to initiate instruction changes and the incorporation of QC hold points in instructions.
5.
Date When Full Comoliance Will Be Achieved Full compliance will be achieved by November 19, 1984 when the training will have been performed.
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