ML18038B529

Forwards Response to NRC 951012 Ltr Re Violations Noted in Insp Repts 50-259/95-52,50-260/95-52 & 50-296/95-52.C/As: Issued Memo to Remind AA Approvers That Prior to Signing Approval Fdcn Preparers Should Be Involved in Comments

ML18038B529
Person / Time
Site:	Browns Ferry
Issue date:	11/09/1995
From:	MACHON R D TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9511130221
Download: ML18038B529 (12)

See also: IR 05000259/1995052

Text

PRZORXTY 3.(ACCELERATED

RIDS PROCESSING)'EGULATORY

INFORMATION

DISTRIBUTION

SYSTEM (RIDS)ESSION NBR:9511130221

DOC.DATE: 95/11/09 NOTARIZED:

NO ACIL:50-259

Browns Ferry Nuclear Power Station, Unit 1, Tennessee 50-260 Browns Ferry Nuclear Power Station, Unit 2, Tennessee 50-296 Browns Ferry Nuclear Power Station, Unit 3, Tennessee AUTH.NAME AUTHOR AFFILIATION.

MACHON,R.D.

Tennessee Valley.Authority RECIP.NAME

RECIPIENT, AFFILIATION

Document Control Branch (Document Control Desk)SUBJECT: Forwards response to NRC 951012 ltr re violations

noted in insp rept 50-259,260

&296/95-52.Corrective

actions:util.issued memo to remind AA approvers that prior to signing approval FDCN preparers should be involved in comments.DISTRXBUTION

CODE: IEOlD COPIES RECEIVED:LTR

ENCL+SIZE: TITLE: General (50 Dkt)-Insp Rept/Notice

of Vio ation MR sponse NOTES: DOCKET'05000259 ,P, 05000260 05000296 RECIPIENT ID CODE/NAME PD2-3-PD COPIES RECIPIENT LTTR ENCL ID CODE/NAME 1 1 WILLIAMS, J.COPIES"LTTR ENCL.1 1 INTERNAL: ACRS AEOD/SPD/RAB

DEDRO NRR/DISP/PIPB

NRR/DRPM/PECB'E.DIR RGN2 FILE 01 2 1 1 1 1 1 1 2 AEOD/DE IB 1 AEOD/WXC~1 (FILE CENQEQ7 1 NRR/DRCH/HHFB

1'NUDOCS-ABSTRACT

1 OGC/HDS3 1 1 1 1 1 1 1 1.1 1 1 1 1 D EXTERNAL: LITCO BRYCE,J H NRC.PDR 1 1 1 1 NOAC 1 1 N NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE!CONTACT THE DOCUMENT CONTROL, DESK, ROOM OWFN 5DS (415-2083)

TO ELIMINATE YOUR NAME FROM DISTRIBUTION

LISTS FOR DOCUMENTS YOU DON'T NEED!OTAL NUMBER OF COPIES REQUIRED: LTTR 19 ENCL 19

l il~Oi L 41~

Tennessee Valley Authority, Post Oftce Box 2000, Decatur, Alabaina 35609-2000

R.D.(Rick)Machon Vice President.

Browns Ferry Nucfear Plant NOV OS gg U.S.Nuclear Regulatory

Commission

ATTN: Document Control Desk Washington, D.C.20555 10 CFR 2 Appendix C Gentlemen:

In the Matter of Tennessee Valley Authority Docket Nos.50-259 50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN)-NRC INSPECTION

REPORT 50-259~50-260~50-296/95-52

-REPLY TO NOTICE OF VIOLATION (NOV)This letter provides our reply to the subject NOV transmitted

by letter from C.A.Casto, NRC, to Oliver D.Kingsley, TVA, dated October 12, 1995.This NOV involved a personnel error that resulted in a failure to install two welds in accordance

with an approved field design change notice.TVA admits the violation.

The enclosure provides our response to the NOV.There are no commitments

in this letter.If you have any questions regarding this reply, please contact Pedro Salas at (205)729-2636.Sincerely, R.D.chon Site ice President Enclosure cc: See page 2 g QGg6g goof i(i

il

U.S.Nuclear Regulatory

Commission

Page 2 November 9, 1995 Enclosure cc (Enclosure):

Mr.Mark S.Lesser, Acting Branch Chief U.S.Nuclear Regulatory

Commission

Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 NRC Resident InsPector Browns Ferry Nuclear Plant 10833 Shaw Road Athens, Alabama 35611 Mr.J.F.Williams, Project Manager U.S.Nuclear Regulatory

Commission

One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852

1

ENCLOSURE TENNESSEE VALLEY AUTHORXTY BROWNS FERRY NUCLEAR PLANT (BFN)UNITS 1g 2q AND 3 XNSPECTXON

REPORT NUMBER 50-259'0-260'0-296/95-52

REPLY TO NOTZCE OF VZOLATZON (NOV)RESTATEMENT

OF THE VZOLATXON"10 CFR 50, Appendix B, Criterion V, requires that activities

affecting quality shall be prescribed

by instructions, procedures, or drawings of a type appropriate

to the circumstances

and shall be accomplished

in accordance

with these instructions, procedures

or drawings.Paragraph 6.1.1 of Modifications

and Addition Instruction

MAI-3.9, Installation

of Cable Tray Supports and Cable Tray Covers, requires that cable tray supports be fabricated

and installed according to the applicable

design documents.

Contrary to the above, flare level welds on the vertical interfaces

of bill of material item numbers three and four.for support number 319092-15-B1102-38

were not completed as required by drawing number DCA W17473-300

and DCN F26704A AA-04.This is a Severity Level IV violation (Supplement

I)(Applicable

for Unit.3 only)." TVAiS REPLY TO THE VZOLATION Reason For The Violation This violation was due to personnel error as a result of a poorly coordinated

field design change.The support connection

between items 3 and 4 was originally

designed and fabricated

with a two-sided fillet weld.Following original installation, additional

modifications

were needed to attach the cable tray.Consequently, the night-shift

field engineer initiated FDCN 26104A to add the attachment

structure for the cable tray.This attachment

structure was indicated on both the support assembly drawing and a section view of a portion of the support.Because there were no authorized

FDCN approvers on the night shift, the approval of this FDCN was rolled to the day-shift field engineer.When the day-shift field engineer reviewed the FDCN, he determined

that the additional

flare bevel welds should be added.However, rather than adding these welds to the section view, he added them to the support

I

assembly drawing.Additionally, the day-shift field engineer wrote"Requested

changes are approved" on the FDCNg but did not indicate that the additional

flare bevel welds were added.Subsequently, when the night-shift

field engineer received the approved FDCN, he did not note the addition of the flare bevel welds.Instead, based on the day-shift field engineer's

notation, the night-shift

field engineer assumed that the changes he recommended

were approved with no additions.

After the FDCN was approved, the night-shift

field engineer prepared the appropriate

modification

implementation

documentation (e.g., work plan, weld data sheets)for the cable tray support.However, because the field engineer was unaware of the addition of the flare bevel welds, he failed to ensure that these welds were incorporated

into the documentation.

Consequently, the cable tray support was installed in the field without the flare bevel welds.Following installation

of the support, modifications

work plan closure personnel reviewed the installation

documentation

and the corresponding

design output documents.

However, these individuals

failed to identify that the cable tray support had not been installed in accordance

with the FDCN.2~Corrective

Actions Taken And Results Achieved TVA reviewed the design calculation (without the additional

flare bevel welds)for this support and determined

the existing tray loading would not jeopardize

the structural

integrity of the support.However, based on anticipated

future cable tray loading, TVA installed the flare bevel welds.Since the field engineers and modifications

closure personnel involved in this event are no longer employed at BFN, personnel corrective

actions were not taken.TVA issued a memorandum

to remind AA approvers that prior to signing approval to an AA-FDCN, it is their responsibility

to ensure that FDCN preparers are involved in and are aware of any comments or additions required by the AA approver.TVA also discussed this event with the modifications

work plan closure personnel and reminded them that it is their responsibility

to ensure that modifications

are installed in accordance

with design documents.

3~Corrective

Ste s That Have Been Or Will Be Taken To Avoid Further Violations

TVA believes that this problem with the review and approval of the FDCN is a unique incident.Consequently, TVA believes that no further actions are necessary.

Nevertheless, a statistical

sample of cable tray supports E-2

I L I

~P~~installed in DCNs W17473 and W17720'ill

be walked down to verify that welds shown on the support configuration

control drawings are installed in the field.Date When Pull Com liance Wi.ll Be Achieved TVA is in full compliance

for this event.TVA plans to complete the walkdown by December 15, 1995.~'hese two DCNs were large cable tray support modifications, and installed the majority of new cable tray supports for Unit 3 recovery.2 This is not a regulatory

commitment.

E-3

L 4 I