ML20215L775
| ML20215L775 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 05/07/1987 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8705120369 | |
| Download: ML20215L775 (6) | |
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TENNESSEE VALLEY AUTHORITY CH ATTANOOGA. TENNESSEE 37401 SN 157B Lookout Place WAY 071987 U.S. Nuclear Regulatory Comission ATTN:- Document Control Desk Washington', D.C.
20555
. Gentlemen:
In the Matter of
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Docket Nos. 50-259
' Tennessee Valley Authority'
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50-160 50-296 BROWNS FERRY NUCLEAR PLANT (BFN) UNITS 1, 2. AND 3 - NRC OIE REGION II INSPECTION REPORT NOS. 50-259/87-11, 50-260/87-11, AND 50-296/87-11 RESPONSE TO VIOLATION Enclosed is TVA's response to'the letter from G. G. Zech to S. A. White dated March 30, 1987, transmitting IE Inspection Report Nos. 50-259/87-11, 50-260/87-11, and 50-296/87-11 which cited TVA with one Severity. Level IV and one Severity Level V Violation for BFN.
Please refer any questions or coments to M. J. May, BFN Site Licensing, at (205) 729-3566.
To the best of my knowledge, I declare the statements contained herein are complete and true.
Very truly yours, TENNESSEE LEY AUTHORITY R. Gridley, Di ector Nuclear Safet and Licensing Enclosures cc: See page 2 5120369 870507 ADOCK 05000259 g
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An Equal Opportunity Employer
. U.S. Regulatory Commission SY 0710-cc (Enclosures):
Mr. G. G. Zech, Assistant Director for Inspection Programs.-
Division of TVA Projects Office of Special Projects U.S. Nuclear Regulatory Commission
-Region II 101 Marietta St...NW, Suite 2900 Atlanta, Georgia 30323 Browns Ferry Resident Inspector Browns Ferry Nuclear Plant P.O. Box 311 Athens, Alabama 35611
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RESPONSE
NRC INSPECTION REPORT NOS.
50-259/87-11, 50-260/87-11 AND 50-296/87-11 LETTER FROM G. G.~ZECH TO S. A. WHITE DATED NARCH 30, 1987 Violation'A 10 CFR 50, Appendix B, Criterion VIII, as implemented by Topical Report TVA-TR75-1A,-Section 17.2.8, requires that adequate measures be provided to assure the control and identification of materials and therefore prevent the use of incorrect or defective materials.
Contrary to the above, on February 25, 1987, the NRC inspector determined that
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the licensee's measures did not assure the control and identification of'wel!
consumables in that the heat number of weld material issued on 575 Control No.
5686-11900 had not been identified. Also, 575 Control No._7386-00585, voided by warehouse personnel, was used by tool rooms as a valid' referencing number when issuing welding material for use in the field.
This is a Severity Level IV Violation (Supplement I).
1.
Admission or Denial of the Alleged Violation (or Finding)
TVA admits the violation.
'2.
Reasons For the Violations (or-Finding) if Admitted After the material has been accepted by receipt inspection, TVA uses a form TVA 575 in-house for obtaining and trancferring materials. The form TVA 575 requires appropriate information be recorded to maintain traceability.
On the subject form TVA 575 No. 5686-11900 which did not specifically identify the heat / lot number of the material' issued, an employee inadvertently failed to record a heat / lot number on the form. This was a personnel error.
The form TVA 575 Control No. 7386-00585 was volded by warehouse personnel because of an inventory control error, and proper administrative functions did not take place to notify all personnel affected.
Identical l
welding materials were maintained in maintenance support inventories, modification support inventories, and direct charge noninventory accounts.
The reviewed form TVA 575 was initially issued to an incorrect inventory account but was later corrected.
... 3.
Corrective Steps Which Have Been Taken and Results Achieved
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Research has determined that the weld rods issued under TVA Form 575 ENo. 5686-11900 could only have been from two heat / lot numbers. We have concluded that both heat / lot numbers are traceable.
To ensure
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traceability for TVA Form 575 Control No. 7386-00585, an attachment was added to the file copy of the' subject TVA Form 575.
The attachment cross references both the initial and final TVA Form 575 control number, therefore, the document package can be retrieved via the automated records management system.
Before this review by NRC, BFN initiated Corrective Action Reports (CARS) to identify similar problems related to material. traceability and maintenance of appropriate records. This Quality Assurance review resulted in CARS which have been adequately dispositioned by the Browns Ferry Power Stores Section.
The adverse conditions stated in these CARS can be summarized into the following three categories:
1.
Several TVA Form 575 control numbers were changed after issuance without notifying the material requestor.
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2.
Several issues were made without adequate information entered on the TVA Form 575 (personnel errors).
3.
Several contract files did not contain the required supporting documentation for the weld rods issued.
Power Stores has initiated the following actions and controls to correct the above. discrepancies.
Standard Practice BF 16.11 was revised to include a'second-party verification and approval of critical systems, structures, and components (CSSC) materials before issue. Therefore, the TVA Form 575 is reviewed for completeness by the quality managers organization.
Power Stores Section Instruction Letter 1.31 has been issued to establish a method of notifying the originator of a TVA Form 575 when a control number has been changed.
Acceptable electrodes in storage have been placed into one inventory to minimize the chances of a TVA Form 575 control number being inadvertently assigned.
Before issue, weld rods will have an "OK-To-Issue" tag affixed to the box or container and the tag signed by a quality control inspector.
Power Stores personnel responsible for issuing materials have been informed of these types of problems and discussions have been held on the proper issuance of CSSC welding materials per the new and revised procedures.
. 4.
Corrective Steps Which Will Be Taken to Avoid Further Violations (or Findings)
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All actions have been completed.
5.
Date When Full Compliance Will Be Achieved Full compliance has been achieved.
Violation B Paragraph (a)(1) of 10 CFR 50.55(a) requires that structures and components be fabricated to quality standards commensurate with the importance of the safety function. ASME Code Section IX, 1980 edition, paragraph QW200.4 states in part that a welding procedure qualified in combination with other processes shall be qualified for the deposited weld metal thickness range for each of the processes to be used.
Contrary to the above, on February 24, 1987, combination weld procedure qualification records (PQRs), GT-SM88-0-2 and GT-SM88-0-1, did not specify the amount of weld metal deposited by each of the weld processes used; and, therefore, it was not possible to verify the limits of qualification with each specific process.
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This is a Severity Level V Violation (Supplement I).
1.
Admission or Denial of the Alleged Violation (or Finding)
TVA denies the violation.
2.
Reasons For the Denial IVA complied with ASME Section IX Code in effect at the time the PQRs were qualified, therefore, no violation exists. The two PQRs in question are GT-SM-88-01, qualified on September 18, 1970, and GT-SM-88-02, qualified on June 24, 1974.
Deposit thicknesses were not recorded since both Section IX's in effect for these years of qualification did not require the recording of deposited thickness for individual processes, used in combination, to satisfy procedure qualification.
In the 1980 Edition of Section IX, Summer 1980 Addenda, paragraph QW2004 came into existence. This paragraph required the recording of weld metal deposited thickness ranges. However, paragraph QW 100.3 of the 1980 l
Edition of Section IX, Winter 1981 Addenda recognized that welding procedure requirements that were acceptable in past years, were not necessarily negated by the issuance of a new Edition or Addenda. Also, the paragraph permits the use of welding procedure qualifications which meet the requirements of the 1962 or later Editions of the Code for production welding. This allows TVA to employ the procedures qualified to codes earlier than the 1980 Edition of Section IX, Winter 1981 Addenda.
. Furthermore, TVA's method of controlling weld metal deposit thickness is through the use of the General Welding Procedure, P.S.I.M.1.2 (ASME and ANSI). This procedure is used to qualify the welding procedure specification (i.e., generating the pQR). Within the General Welding Procedure, specifically section 17.0, paragraph 17.1, weld metal thickness deposited for multipass welding is defined.
This paragraph allows maximum deposit of 3/8 inch and a minimum deposit of at least two layers. TVA's engineering believes this type of control is adequate to support weld metal deposit thickness for procedures that were qualified when deposit thickness was not of consideration.
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