ML20155A177
| ML20155A177 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 06/02/1988 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8806090269 | |
| Download: ML20155A177 (7) | |
Text
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TENNESSEE VALLEY AUTHORITY l
CH ATTANOOGA. TENNESSEE 374o1 SN 157B Lookout Place JUN 021988 U.S Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D.C.
20555 Centlemen:
In the Matter of
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Docket Nos. 50-259 Tennessee Valley Authority
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50-260
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50-296 BROWHS FERRY NUCLEAR PLANT (BFN) UNITS 1, 2. AND 3 - NRC INSPECTION REPORT NOS. 50-259/88-02, 50-260/88-02, AND 50-296/88-02, -- RESPONSE TO NOTICE OF VIOLATION TVA responded to the subject notice of violation on April 28, 1988. At that time, TVA requested an extension until June 3, 1988, to investigate and develop responson to twelve (12) inspector concerns. This letter transmits our plans to the twelve (12) concerns. provides TVA's response.
If you have any questions, please telephone James E. Wallace at (205) 729-2053.
Very truly yours, TENNESSEE VA
'Y AUTiiORITY
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ridley, Ditector Nuclear Licensing and Regulatory Affairs Enclosure cc:
See page 2 Y
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l 8806090269 830602
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DCD An Equal Opportunity Employer v
. U.S. Nuclear Regulatory Commission (JI N 021988 L
cc (Enclosure):
Mr. G. G. Zech, Assistant Director for Projects TVA Projects Division U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Mr. K. P. Barr, Acting Assistant Director for Inspection Programs TVA Projects Division U.S. Nuclear Regulatory Com:nission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia-30323 Browns Ferry Resident Inspector Browns Ferry Nuclear Plant Route 12, Box 637 Athens, Alabama 35611
I ENCLOSURE 1
RESPONSE
NRC INSPECTION REPORT NOS.
50-259/88-02, 50-260/88-02, 50-296/88-02 LETTER FROM K. P. BARR TO S. A. WillTE DATED MARCH 24, 1988
- 1. NRC Concern Multiple examples of craft and/or QC verifications of completed work and final inspections for modification activities subsequently found incomplete.
Examples include loose conduit fittings and condulet tight covers, electrical panel _ construction debris, and incomplete painting of weld joints.
TVA Plan Corrective actions to address tnis concern were stated in TVA's response to dotice of Violation B of this report and was provided on April 28, 1988.
In that response, we explained how our present procedures requira a final system walkdown and signature by the cognizant engineer to ensure the noted types of mistakes are found and promptly corrected prior to release of the system for service. Also, TVA committed to additional training for construction personnel.
Additionally, TVA's procedures fcr identification and correction of conditions adverse to quality (CAQ) presently ensures prompt identification and correction of similar problems.
- 2. NRC Concern Signi.ficant pipe support inspection requirements were omitted from work plans. Pipe support rework materially affected the physical integrity without provision for reinspection.
Inadequate training and experience appeared to contribute to responsible personnel not recognizing the applicability of the inspection requirements.
TVA Plan Corrective actions to address this concern were stated in TVA's response to Notice of Violation A of this report and was provided on April 28, 1988.
In that response, we explained that a final system walkdown would be conducted by Browns Ferry Nuclear Plant (BFN) engineering under another procedure (PI 87-49), "pipe Support Verification Program." TVA committed to provide additional training to the responsible engineer to more clearly depict in workplans any required inspections and associated walkdown projects.
- 3. NRC Concern An RilR pipe support was installed with misalignment exceeding procedural limits. The condition was not recognized by field installation personnel and was not subject to final inspection.
[
, TVA Plan Coreective actions to address this concern were stated in TVA's response to Notice of Violation A of this report and was provided on April 28, 1988.
In that response, we explained that a final system walkdown would be conducted by BFN engineering under another procedure (PI 87-49) "Pipe Support Verification Program." TVA committed to provide additiona1 training to the responsible engineer to more clearly depict in the workplan any required inspections and associated walkdown proje ts.
- 4. NRC Concern Design output documents failed to include necessary piping supports for HPCI valve test valves and tail pieces.
Design and field personnel failed to recognize the omission and its potential for fatigue or seismic failure.
TVA Plan The scope of ECN PO651 was to replace the HPCI valve only and permitted the test valves end call pieces to be field routed. Present practices (General Design Criteria BFN-50-C-7103) do not allow fleid routing of piping.
Additlons11y, the TVA smalb iore piping program is evaluating the adequacy of previously installed fleid routed piping.
S. NRC Concern The number and significance of EA findings to date (from relatively limited site EA surveillances and oversight activities) warrants an increase in the scrutiny available through the EA programs directed at the ECN and modification.
TVA Plan TVA notes the NRC's assessment that an increase in scrutiny available through EA program is warranted.
The Engineering Assurance Oversight Review Team is reviewing current design modifications to ensure the Transitional Change Control Program is effective and the changes are technically adequate.
The Oversight Review Team reviewed ECNs which were completed after the design baseline walkdowns were completed and before the Transitional Change Control Program (i.e. procedure PI 86-03 implemented for ECH preparation) was initiated.
The baseline program is reviewing the noted ECHs, therefore, no additional EA review of these ECNs is required since EA is continually monitoring the baseline program activities for adequacy and effectiveness.
- 6. NRC Concern Post modification test control was found weak in several areas. Post modification testing administered by workplan did not provide for sufficient notification of the Shift Engineer, including one example wherein a test was delayed for three weeks without subsequent protest notification.
In a second example, a hydrostatic test was conducted prior to disposition and repair of weld (NDE) defects.
'T TVA Plan TVA disagrees that Modification personnel did not notify Operations personnel while perfor.ning the hydrostatic test. This notification was documented on September 6, 1987 at 6:10 p.m.
in the unit 2 reactor operator's log, and an assistant unit operator was assigned to assist the hydrostatic test.
TVA agrees that a hydro test was performed prematurely. Procedures have been revised to require that all nondestructive examinations be completo l
and signed off before ary hydrostatic test begins.
- 7. URC Concern An unreviewed safety quention determination (USQD) found that the design issued by ECN could result in system misoperation outside the bases of the safety analysis (spurious valve operation).
The ECNs P0651 and P0652 have not been revised and the installation is mechanical field complete with no further action to date.
TVA Plan The corrective action to resolve Significant Condition Report (SCR) BFN MEB 8502 is ECN P7037. ECU P7037 implements the removal of the air source from testable check valve FCV-73-45 by installation of a quick-disconnect type coupling.
The closure process of ECU P7037 will assure that appropriate corrective action is complete, and spurious valve operation will not occur.
- 8. NRC Concern The large number of modifications will necessitate a proportionately large number of pi'ocedure revisions. Specific procedure impacts are largely unidentified and detailed planning for specific procedure changes is not yet in place.
TVA Plan Modification workplans have been reviewed for specific procedure revisions and the necessary changes are put into a modification data base.
This data base is being used to ensure appropriate proceduro changes are identified to the section responsible for affected procedures.
It is estimated that only 10-20 percent of the modification workplans will affect procedure revisions.
Hodification field completions are occurring continuously and work plans are being processed at that time.
This workplan closeout process includes identification to responsible organizations of needed procedure revisions.
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- 9.,NRC Concern Piping and cable tray support design required numerous Field Change Requests indicating that more predesign and preconstruction attention to existing conditions should be exercised. This trend appeared to be improving during this inspection.
TVA Plan Piping and cable tray support designs required numerous field change requests for frequent material substitution due to an absence of constructability walkdowns. Current TVA practices require a completed design package including intermediate design reviews and constructability walkdowns.
These walkdowns have contributed to reduce the number of field et.ange r.
- 10. NRC Coptucy Weakn=ssec in administration of work packages including improper cross reftcencing (DCR and ECN to workplan, workplan to workplan, workplan to test, etc.) leading to potential misapplication of references; inappropriate work plan steps; failure to provide reference drawings for work cleps; failure to include inspection, painting, etc., steps in workplans.
TVA PLqn G,eneral weaknesses which existed in workplan administration are being resolved by the several improvements in the workplan process. New procedures for workplan writing, handling, and control are nos in place.
Modification procedures (Site Director's Standard Practices: 8.1 "plant Modification and design change approval", and 8.4 "Modification Workplans") have been revised and expanded. Modification and Addition Instructions (HAIs) have been expanded to provide better instructions for modification work.
A computer aid program is being developed to assist responsible engineers to write a more uniform workplan package.
In addition, extensive training on the upgraded procedures is being provided to modification personnel.
- 11. NRC Concern Weakness in the completion of nuclear Storeroom Requisitions for the proper entry of quality requirements with the potential for issuance of unqualified material.
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EncloIure 1
-S-TVA Plan
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The inadequate nuclear storeroom regulsitions were attributed to human error. Training of Modifications personnel in the proper completion of requisition forms is required for modification work. Modifications is scheduling all necessary personnel to attend an existing Division of Nuclear Training instruction course on the completion of the requisition forms.
- 12. NRC Concent Nuclear Performance Plon, Volume III, Appendix D, lists ECUS required to be completed prior to unit 2, cycle 5 restart but does not currently list backlog ECNs required to be closed by Appendix A and Section 11.2.
TVA Plan All modifications, including ECNs for unit 2 startup, are currently being tracked by the Modification Planning and Scheduling section. TVA action plans are to ensure the closure of the modification planning and scheduling unit 2 cycle 5 backlog items, i
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