ML20212P552
| ML20212P552 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 03/09/1987 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | Grace J NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8703160150 | |
| Download: ML20212P552 (6) | |
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TENNESSEE VALLEY AUTHORITY CH ATTANOOGA. TENNESSEE 37401
' 5N 157B Lookout Place MAR U91987 U.S. Nuclear Regulatory Commission ATTW: Document Control Desk Office of Nuclear Reactor Regulation Washington, D.C.
20555 Attention:
Dr. J. Nelson Grace 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 UNITS 1, 2. AND 3 - NRC-0IE REGION II INSPECTION REPORT NOS. 50-259/87-01, 50-260/87-01, AND 50-296/87-01 RESPONSE TO VIOLATION Enclosed is our response to the letter from K. P. Barr to S. A. White dated February 5, 1987, transmitting IE Inspection Report Nos. 50-259/87-01, 50-260/87-01, and 50-296/87-01 which cited TVA with two Severity Level V Violations for our Browns Ferry Nuclear Plant.
If you have any questions, please get in touch with M. J. May at (205) 729-3566.
To the best of my knowledge, I declare the statements contained herein are complete and true.
Very truly yours, TENNESSEE VALLEY AUTHORITY R. L. Gridley, Director Nuclear Safet and Licensing Enclosure ec: See page 2 l
8703160150 870309 PDR ADOCK 05000259 f
G PDR g i An Equal Opportunity Employer
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'*. U.S. Nuclear Regulatory Comission cc (Enclosure):
Mr. G. E. Gears Browns Ferry Project Manager U.S. Nuclear Regulatory Comission-7920 Norfolk Avenue Bethesda, Maryland 20814 Mr. G. G. Zech, Director TVA Projects U.S. Nuclear Regulatory Comission 101 Marietta St., NW, Suite 2900 Atlanta, Georgia 30323 Browns Ferry Resident Inspector-Browns Ferry Nuclear Plant Route 2, P.O. Box 311 Athens, Alabama 35611 e
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RESPONSE
NRC INSPECTION REPORT NOS.
50-259/87-01, 50-260/87-01, AND 50-296/87-01 LETTER FROM K. P. BARR TO S. A. WHITE DATED FEBRUARY 5,1987 Violation A 10 CFR 50, Appendix B,' Criterion IV, as implemented by Topical Report TVA-TR75-1A, Section 17.2.4, requires measures which assure that procurement documents for materials incorporate requirements which assure that the material is of adequate quality.
Contrary to the above, the licensee's measures did not assure that procurement documents for recirculation system welding materials incorporated requirements specified by-drawing 47A2408R1. This drawing, through reference to drawing 47A1408, paragraph 4.2.5, specifies that the delta ferrite content of all stainless steel welding material "shall be determined in accordance eith the magnetic instrument option of NB-2400 using type A or C instruments" and that "the minimum delta ferrite content shall be 8 ferrite number." These quality requirements were not incorporated into the purchase requisitions for recirculation system welding materials as described below.
Purchase requisition 87PBF-376995 for stainlesa steel welding wire, j
Type 308L, failed to require delta ferrite determination by magnetic method.
Purchase requisition 87PBF-376996 for stainless steel consumable welding inserts, IN308L, failed to require either that delta ferrite be determined by magnetic method or the minimum delta ferrite number of 8.
This is a Severity Level V Violation.
1.
Admission or Denial of the Violation TVA admits the violation.
2.
Reasons for the Violation if Admitted The originator of these purchase requisitions for welding materials was not aware of the originator's responsibilities as delineated in TVA's Nuclear Quality Assurance Manual (NQAM). The NQAM states that the l
originator is to identify required tests, inspections, and examinations and to determine quality assurance requirements as originally specified in the Division of Nuclear Engineering (DNE) procurement documents.
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.. A TVA purchase specification which incorporated the requirements of drawing 47A2408R1 already existed for the material ordered on requisition 87PBF-376995. This specification had not been incorporated into the Division Procedures Manual (DPM) so that an outdated purchase specification was attached to the requisition. This specification has since been incorporated into the DPM.
No TVA purchase specification existed for the consumable inserts ordered on requisition 87PBF-376996.
3.
Corrective Steps Which Have Been Taken and Results Achieved The manufacturer has supplied certifications for the material delta ferrite content measured by magnetic instrument for both requisitions.
The material on both requisitions has been dispositioned by Site Quality Assurance.
A purchase specification for consumable inserts, which incorporates the requirements of drawing 47A2408R1, has been issued by DNE.
A procedure to control welding and brazing filler material was issued subsequent to this violation as part of a program to control welding activities at BFN.
The procurement section of this procedure directs the originator to the appropriate section of the NQAM.
The group which updates the DPM has recently become part of the same organization (DNE) as the group which issues purchase specifications.
They are on the distribution list for all new purchase specifications.
This will ensure that new purchase specifications are incorporated into the DPM soon after issue.
4.
Corrective Steps Which Will Be Taken to Avoid Further Violations BFN modifications engineers involved in the recirculation pipe replacement project will receive training on their responsibility as a purchase requisition originator.
5.
Date When Full Compliance Will Be Achieved Full compliance will be achieved by April 1, 1987.
. Violation B 10 CFR 50. Appendix B, Criterion V, as implemented by Topical Report TVA-TR75-1A, Section 17.2.5, requires activities affecting quality to be prescribed and performed in accordance with documented instructions.
Contrary to the above, compressed gas cylinders were not stored in accordance with instructions described in TVA Fire Protection Program Plan, Procedure No.
FPP-01 requires that:
- Cylinders when stored inside shall not be located near exits, stairways, or in areas normally used or intended for the safe exit of people.
- Compressed gas cylinders shall be secured in an upright position - 3/4 of the cylinder height from the floor by wire, chain, or other suitable means.
- Valve protection caps shall be in place whenever the cylinder is not connected for use.
On January 7-9, 1987, the following examples were found where compressed gas cylinders were stored contrary to the above requirements.
(1) Five cylinders intended for use in welding recirculation system piping were stored inside the reactor building near the exit path.
The cylinders were only loosely secured by a single fiber rope draped around the valves at the tops of the cylinders.
At least four of the valves were not in use and did not have their valve protection caps in place.
(2) One gas cylinder stored outside in the enclosed Power Stores yard was uncapped and unsecured.
The improper storage represents a hazard to safety related equipment and structures and to essential personnel.
This is a Severity Level V Violation.
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1.
Admission or Denial of the Violation TVA admits the violation.
2.
Reasons for the Violation if Admitted There was a lack of management attention to the issue, handling, and use l
of compressed gas cylinders. There was no policy to ensure l
accountability and responsibility in the use of compressed gas cylinders.
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. 3.
Corrective Steps Which Have Been Taken and Results Achieved The six compressed gas cylinders noted in the violation have been brought into compliance with the TVA Fire Protection Program Plan, Procedure No. FPP-01.
Plant management has been informed of the continuing problem with gas cylinders and has formed a committee which has drafted a procedure to address the problem.
Daily audits are paying special attention to compressed gas cylinder storage.
Deficiencies found are being corrected immediately.
4.
Corrective Steps Which Will Be Taken to Avoid Further Violations The procedure mentioned above will be issued to provide accountability for cylindere, identify the responsible supervisor for each cylinder, and address the overall issuing, handling, and use of compressed gas cylinders.
5.
Date When Full Compliance Will Be Achieved Full compliance will be achieved by June 1, 1987.
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