ML18033B217

Responds to NRC 900130 Ltr Re Violations Noted in Insp Repts 50-259/89-57,50-260/89-57 & 50-296/89-57.Corrective Action: Personnel Involved W/Removal of Existing Supports Have Been Counseled in Requirements for Procedural Adherence

ML18033B217
Person / Time
Site:	Browns Ferry
Issue date:	03/16/1990
From:	Medford M TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9003230156
Download: ML18033B217 (12)

Text

ACCELERATED DISHUBUTION DEMONSHRATIQN SYSTHM

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REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ESSION NBR:9003230156 DOC.DATE: 90/03/16 NOTARIZED: NO DOCKET g FACIL:50-259 Browns Ferry Nuclear Power Station, Unit 1, Tennessee 05000259 50-260 Browns Ferry Nuclear Power Station, Unit 2, Tennessee 05000260 50-296 Browns Ferry Nuclear Power Station, Unit, 3, Tennessee 05000296 AUTH. NAME AUTHOR AFFILIATION MEDFORD,M.O. Tennessee Valley Authority R RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Responds to NRC 900130 ltr re violations noted in Insp Repts 50 259/89 57150 260/89 57 & 50 296/89 57 CODE: IE01D COPIES RECEIVED:LTR ENCL

'ISTRIBUTION SIZE:

TITLE: General (50 Dkt)-Insp Rept/Notice of Vi lation Response NOTES:1 Copy each to: B.Wilson,D.M.Crutchfield,B.D.Liaw,S.Black 05000259 A

R. Pierson, 1 Copy each to: S.Black,D.M.Crutchfield,B.D.Liaw, 05000260 R. Pierson,B.Wilson 1 Copy each to: S. Black,D.M.Crutchfield,B.D.Liaw, 05000296 R. Pierson,B.Wilson S

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD 1 1 ROSS,T. 1 1 RNAL: ACRS 2 2 AEOD 1 1 AEOD/DEIIB 1 1 AEOD/TPAD 1 1 DEDRO 1 1 NRR SHANKMAN,S 1 1 NRR/DLPQ/LPEB10 1 1 NRR/DOEA DIR 11 1 1 NRR/DREP/PEPB9D 1 1 NRR/DREP/PRPB11 2 2 NRR/DRIS/DIR ,1 1 NRR/DST/DIR 8E2 1 1 NRR/PMAS/ILRB12 1 1 STRACT 1 1 OGC/HDS2 1 1 REG FILE 02 1 1 RES MORISSEAU,D 1 1 RGN ILE 01 1 1 R EXTERNAL: LPDR 1 1 NRC PDR 1 1 NSIC 1 1 NOTES: 5 5

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D NOTE TO ALL "RIDS" RECIPIERIS:

S PLEASE HELP US TO REDUCE WASTEl CONTACT THE.DOCUMENT CGNTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISIRIBUTION OTAL NUMBER OF COPIES REQUIRED: LTTR 30 ENCL -30

TENNESSEE VALLEY AUTHORITY CHATTANOOGA. TENNESSEE 37401 6N 38A Lookout Place MAR 16 1989 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Nashington, D.C. 20555 Gentlemen:

In the Matter of Docket Nos. 50-259-Tennessee Valley Authority 50-260 50-296 BRONNS FERRY NUCLEAR PLANT (BFN) UNITS .1, 2, 3, NRC INSPECTION REPORT NOS.

50-259/89-57, 50-260/89-57, 50-296/89-57 RESPONSE TO NOTICE OF VIOLATION This letter provides TVA's response to the notice of violation transmitted by letter from B. A. Nil'son to O. D. Kingsley, 3r., dated January 30, 1990. The violation involves support deviations from the documented requirements, despite Quality Control verification and acceptance.

TVA admits the violation and concludes that this incident was caused by personnel error. The appropriate correctiv'ctions have been taken and required commitments are listed in Enclosure 2. Enclosure 1 provides background information and TVA's response to NRC concerns raised in the subject report. On March 2, 1990, a telephone call was made to Hilliam S. Little of your staff to extend the due date of this response to March 16, 1990.

If you have any questions, please telephone Patrick P. Carier at (205) 729-3570.

Very truly.yours, TENNESSEE VALLEY AUTHORITY Hark 0. Hedford, Vice President Nuclear Technology and Licensing Enclosures cc: See page 2 S'00323015~ P0031g P>

PDR ADOCK 0.000259 9 PDC An Equai Opportunity Empioyer

U.S. Nuclear Regulatory Commission MAR 16 19SO cc (Enclosures):

Ms. S. C. Black, Assistant Director for Projects TVA Projects Di,vision U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Mr. B. A. Wilson, Assistant Director for Inspection Programs TVA Projects Division U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 NRC Resident Inspector Browns Ferry Nuclear Plant Route 12, Box 637 Athens, Alabama 35609-2000

ENCLOSURE 1

' RESPONSE NRC INSPECTION REPORT NOS. 50-259/89-57, 50-260/89-57, 50-296/89-57 Letter From B. A. Nilson to 0. D. Kingsley, Jr.

Dated January 30, 1990 10 CFR 50, Appendix B, Criteria V, requires in part that activities affecting quality shall be accomplished in accordance with documented instructions, procedures, or drawings. TVA Browns Ferry Nuclear Plant Procedure No.

SNEC-005, Rev. 4, "Pipe Support Nalkdown Procedure," General Construction Specification G-43, Design Drawings, and Nork Plan No. 2449-89 require:

(1) the walkdown inspectors to verify the field conditions against the latest as-built drawings or to generate new drawings based on field conditions if no drawing exits; (2) construction to be within tolerances; and (3) Quality Control (QC) inspectors to verify the finished work based on the design drawings.

Contrary to the above, during the inspe"tion of December 4-8, 1989, 7 of 27 Quality Assurance-accepted pipe supports were found with deviations from the documented requirements.

1. Support 2-47B452H0226 was found to have a 6-inch long, extra weld in back of the angle connection at elevation looking south and a 2 'nch length of fillet weld undersized'/16-inch at the connection between an angle and an existing beam.

2. Supports 2-47B452H0234 and 1-478450S0032 were found to have no stakes for nut locking devices.

3. Three previou~ly existing supports 2-47B400S0128, 2-478400S0129, and 2-47B455H0073, were not removed from field per drawing requirements.

4. Support 1-478450R0012 was found to have gaps, caused by warpage, of up to 1/4-inch between the slide plates while the drawing allowed no gaps.

This is a Severity Level IV violation.

l. Admission or Denial of the Alle ed Violation (or Findin )

TVA admits that the violation occurred in that some of the identified deviations did not have appropriate dispositions in place prior to workplan signoff and QC verification.

2. Reasons for the Violation (or Findin ) if Admitted Each of the identified deviations will be discussed separately.

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Item 1 Su ort 2-478452H0226 Drawing N4882-001 Revision 0, did not require any modifications in the area where the undersized and extra weld conditions exist. Consequently, modifications signoff and QC verification did not address these weld items, nor were they intended to extend their review beyond the scope of the performed modification.

The 6-inch extra weld in question is called out on sheet two of the subject. support drawings. This weld was also recorded by the 79-14 walkdown. Accordingly, it is not considered an extra weld.

As a result of this inspection concern, both welds were inspected and found to be undersized by as much as 1/8-inch for a portion of the as-constructed length. Subsequent evaluation has documented support acceptability as installed. The walkdown packages and calculations will be revised to reflect this as-constructed configuration by March 16, 1990.

To confirm that this deficiency is an isolated case, a comprehensive review of quality surveillances, audits, and training/qualifications was performed. Extensive quality surveillance verifications have been conducted by both TVA and NRC on SNEC as-built. walkdowns, including weld measurements, with no generic concerns or findings associated with w.ld sizing. Verification of training and qualification records for all

,walkdown personnel, including those who performed the subject walkdown, were included in these TVA surveys with no findings.

For further verification of weld measurement reliability, several key SNEC walkdown personnel were consulted as to the actual weld measurement techniques typically used. The consistent, approach was to examine the entire weld for minimum size, remove any slag necessary to make a clear determination, and conservatively identify the weld size as the smallest size measured.

It can be concluded, based on the proven success and accuracy of the as-built programs and the numerous third-party verifications by quality surveillances and inspections, that this is indeed an isolated case which does not impact the adequacy of the affected support structure and in no way diminishes the reliability of the overall program.

Item 2 Su orts 2-47B452H0234 and 1-47B450S0032 The identified staking problem on support 2-47B452H0234 was outside the scope of the modifications performed. Drawing H4882-009 Revision 0, did not include the portion of the support where the missing stake was identified. No,modifications or inspections were therefore required.

The staking of nuts for locking devices was not a requirement during the original design of BFN and does not require retrofitting for existing installations. As no modification has occurred to this support portion since original installation, the identified condition is acceptable.

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The unstaked condition on support 1-47B450S0032 was originally inspected and rejected by a QC inspector on October 14, 1989 (QC Inspection Report M8930421). The rejection was evaluated and dispositioned to stake the nut in question. The *subsequent staking was verified as complete by a QC inspector and accepted on Oc liber 15, 1989. During the December NRC inspection, the support was again found to be unstaked. TVA has initiated an investigation to determine the root cause of this incident.

The support has once again been properly staked.

Item 3

. Su orts 2-470400S0128 2-478400S0129 and 2-478455H0073 The subject supports were not removed as required by the approved work instructions. The Modifications and QC personnel misinterpreted the workplan instructions for removing these supports. This condition is a personnel error because of inattention to detail. As a the data sheets were determined to be confusing and misleading contributing'actor, because of a typographical error. The data sheets were revised during the NRC inspection and the subject supports subsequently remove.l. The new revision in effect will ensure that personnel involved sign for the removal of'xisting supports.

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t 00 0 The observed 1/4-inch gap was due to weld draw. The Level II inspector and field engineer observed that the plates were in contact as required by the specified "0" gap on the drawing. In response to the inspector's concern, QC asked for a confirmation of acceptability of this configuration on this specific support. Nuclear Engineering confirmed that the existing configuration met the design intent. Therefore, this confirms the inspector's and the field engineer's interpretation of the drawing requiren .nts.

3. Corrective Ste s Hhich Have Been Taken and Results Achieved Supports 2-47B452H0226, 2-47B452H0234, and 1-478450R0012 require no further corrective actions. Appropriate disposition of identified

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deviation~ exists, and workplan signoff and QC verification correctly reflected the scope of the performed modification.

TVA has initiated an investigation of the stake nut condition on support 47B450S0032 to determine root cause.

For supports 2-478400S0128, 'elements 2-47B400S0129, and 2-47B455H0073:

o Data sheets associated with the removal of existing sup~ irts have been revised to clearly specify the required action.

o Personnel involved with the removal of existing supports have been counseled in the reqi for procedural adherence and attention to detail.

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o The qualifications and capabilities of QC personnel involved in this incident have been evaluated for adeq~.acy.

o The Modifications Group has established a required reading list for all* craft personnel performing quality-related activities.

4. Corrective Ste s Which Will Be Taken To Avoid Future Violations (Or

~Flndln s)

In addition to the actions described above, the Modifications Group and QC Department are performing walkdowns of in-process Engineering Change Notices and Drawing Change Notices to ensure that no other conditions exist as identified in -the NRC violation. Engineering will review and disposition items identified during this review as they are identified.

This effort will be performed in parallel with the 79-14/02 modifications program.

Support modifications specifically requiring the removal of existing structures will be reverified for all completed 79-14/02 supports. This effort will be finished April 2, 1990.

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5. Date When Full Com liance Will be Achieved Full compliance will be achieved upon completion of the overall 79-14/02 modifications program.

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ENCLOSURE 2 LIST OF COMMITMENTS RESPONSE TO VIOLATION 89-57-01 P

1. The walkdown packages and calculations for support 2-47B452H0226 will be revised to reflect the as-constructed configuration by March 16, 1990.

2. Support modifications requiring the removal of existing structures will be reverified for all completed 79-14/02 supports. This effort will be finished April 2, 1990.

3. The Modifications group and QC department are performing walkdowns of in-process Engineering Change Notices (ECNs) and Drawing Ch,;nge Notices (DCNs) to ensure that no other conditions exist as identified in the NRC violation. This effort will be performed in parallel with the 79-14/02 modifications effort. TVA will review and disposition the items identified during the walkdown of in process ECNs and DCNs by the completion of the 79-14/02 modifications effort.

4. The QC investigation of the stake nut condition on support 1-47B450S0032 will be completed by March 23, 1990 0415k/8