IR 05000438/1982023
| ML20027E684 | |
| Person / Time | |
|---|---|
| Site: | Bellefonte  |
| Issue date: | 08/18/1982 |
| From: | Economos N, Girard E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20027E597 | List: |
| References | |
| 50-438-82-23, 50-439-82-23, NUDOCS 8211150610 | |
| Download: ML20027E684 (10) | |
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[n ur UNITED STATES
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NUCLEAR REGULATORY COMMISSION REGION ll y
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101 MARIETTA ST N.W suite 3100
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ATLANTA. GEORGIA 30303
~..... o Report Nos. 50-438/82-23 and 50-439/82-23 Licensee:
Tennessee Valley Authority 500A Chestnut Street Chattanooga, TN 37401 Facility Name: Bellefonte Docket Nos. 50-438 and 50-439 License Nos. CPPR-122 and CPPR-123 Inspection at Bellefonte site near Scottsboro, Alabama
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8 M 8.2-Inspector:_E. H. Gi r ~rd Dat'e Signed Approved by:
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N. Ebonohto's, Acting Section Chief Da'te/igned
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Engineering Inspection Branch Division of Engineering and Technical Programs SUMMARY Inspection on July 19-23, 1982 Areas Inspected This routine, unannounced inspection involved 41 inspector-hours on site in the areas of licensee action on previous enforcement matters and licensee identified items (10 CFR 50.55(e) items).
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Results Three violations were found in the two areas inspected (Failure to Document Deficiency, paragraph 3.b; Failure to Follow Procedures for Planning and Performing Inspections and for Controlling Inspection Documentation, paragraph l
3.c; and Inadequate Investigation of Generic Aspects, and Failure to Identify Cause for Significant Deficiencies, paragraph 6.d).
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REPORT DETAILS
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1.
Persons Contacted Licensee Employees
- W. R. Dahnke, Bellefonte Construction (BLN CONST), Project Manager
- F. Gilbert, BLN CONST, Construction Engineer
- D. Smith, BLN CONST, Assistant Construction Engineer
- H. Johnson, BLN CONST, Welding Engineering Unit (WEU) Supervisor
- K. Lawless, BLN CONST, WEU Assistant Supervisor
- F. L. Moses, BLN CONST, Mechanical Engineering Unit Supervisor
- P. C. Mann, BLN CONST, Engineering Management Assistant
- J. Worthy, Division of Engineering Design, Licensing Engineer R. Shell, Nuclear Licensing Staff, Pressurized Water Reactor Section Supervisor Gary Adkins, BLN CONST, WEU Engineering Associate J. Guthrie, BLN CONST, WEU Supervisor of Welding QC K. Tucker, BLN CONST, WEU Group Leader A. Loomey, BLN CONST, WEU Group Leader Other licensee employees contacted included construction craftsmen and foremen, QC inspectors, and office personnel.
NRC Resident Inspector J. D. Wilcox
- Attended exit interview 2.
Exit Interview The inspection scope and findings were summarized on July 23, 1982, with those persons indicated in paragraph 1 above. The licensee was informed of the inspection findings listed below.
The project manager questioned the validity of two of the three violations described by the inspector; but stated that he wished to wait until he had received the inspection report and had an opportunity to review the matter further before offering any formal dissenting comments.
I Inspector Followup Item (IFI), 438, 439/82-23-01, Piping Cleanliness on Valve Reinstallation, Paragraph 3.a.
Violation, 438, 439/82-23-02, Failure to Document Deficiency, Paragraph 3.b.
Violation, 438, 439/82-23-03, Failure to Follow Procedures for Planning and Performing Inspections and for Controlling Inspection Documentation, Paragraph 3.c.
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Violation, 438, 439/82-23-04, Inadequate investigation of generic aspects and failure to identify cause for significant deficiencies, paragraph 6.d.
3.
Licensee Action on Previous Enforcement Matters a.
(Closed) Violation (438/82-11-01): Installed Piping Cleanliness. This violation involved the licensee's failure to comply with procedural requirements to keep piping openings closed to maintain system clean-liness. A valve had been left open and foreign materials had entered the piping through the opening.
The licensee's letter of response admitted the deficiency, but stated that the valve had been left open to observe the valve internal leakage during a flush, that this was documented, and that they would, in practice, assure satisfactory cleanliness of the piping when reinstallation of the valve internals was performed.
The inspector noted that a readily removable cover could have been installed over the valve opening to limit introduction of foreign materials when flushing and observation for leakage was not in progress.
The licensee's corrective action, as stated in their letter of response dated July 8,1982, was to inspect and clean the open valve and adjacent piping; place a temporary flexible cover over the valve to minimize the introduction of further contaminants; and add the valve to their Inspection, Storage and Preventive Maintenance Program (ISPMP) to provide assurance that inspections will be performed to confirm covering of the valve opening. The licensee also identified one other valve in Unit I and two in Unit 2 for which they stated they would apply the same disposition. To prevent recurrence, the licensee stated that they reinstructed their personnel regarding cleanliness protection requirements.
The licensee's response letter has been reviewed and determined acceptable by Region II.
The inspector reviewed the licensee's actions, as stated in the response letter and described above, with the site Engineering Management Assistant responsible for NRC items.
The inspector examined the valves described in the response letter for proper protection of openings and verified their addition to the ISPMP.
The inspector concluded that the actions described in the letter of response had been implemented and that the violation can be closed.
The inspector indicated, however, that he intended to verify that proper cleanliness of the pipe was assured when the subject valves were reinstalled. The inspector informed the licensee that this followup action would be identified as IFI 438,439/82-23-01, Piping Cleanliness on Valve Reinstallation.
b.
(Closed) Unresolved Item (438, 439/82-05-01): Installation of Locking Devices.
This item documented the inspector's finding that locking devices on the main steam isolation valve (MSIV) stem guide nuts were not properly installed. The inspector informed Mechanical Engineering Unit engineering personnel of the condition on March 4, 1982. At that time these personnel agreed to document the condition, for further evaluation, on Quality Control Investigation Report (QCIR) 13,146. The licensee stated that QCIR 13,146 had already been prepared, based on a
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concern reported from their Hartsville plant that locking devices were not installed on MSIVs. The inspector informed the licensee (during inspection 438, 439/82-05) that they apparently misunderstood the problem at the Hartsville site, as Region II inspectors had checked the MSIVs there and found that the locking devices were improperly installed rather than " missing".
This had been identified as unresolved item 518/81-11-01 for the Hartsville site.
On July 18, 1982, the inspector fcand that the licensee had not docu-mented the improperly installed locking devices on the Bellefonte MSIVs and that no apparent action had been taken to investigate or correct the reported deficiency.
QC procedure BNP-QCP-10.26, R4, Quality Control Investigation Report, requires that such deficiencies be promptly recorded on a QCIR when they are identified. The licensee's failure to document the deficient locking device installation as required by Procedure BNP-QCP-10.26, R4, is a violation of 10 CFR 50, Appendix B, Criterion V, as implemented by FSAR Section 17.1A.S. This violation was reported to the licensee as item 438,439/82-23-02, Failure to Document Deficiency.
c.
(Closed) Unresolved Item (438, 439/82-11-02): PT and Visual Examina-tion of Ground Weld.
This item documented the inspector's concern, identified on April 29, 1982, that reports could not be located for required visual and penetrant (PT) examinations of the inside diameter (ID) of a ground pressurizer surge line weld (on both units) and that the examinations might have been bypassed.
The inspector noted that the line was already installed on both Units 1 and 2 and that if the examinations had not already been performed their completion would be very difficult, as their was no longer any ready access to the ID's of the welds. Instructions describing the required sequence of operations to grind and examine the subject weld and install the line containing the weld were prescribed on MEU Sequence Control Chart (SCC) INC-M223 for Unit I and 2NC-M224 for Unit 2.
These SCCs referred to Welding Enginerring Unit (WEU) SCCs INC-W-002 and 2NC-W-003 for welding exa-mination and inspection related operations. The MEU SCCs sequenced the examinations of the ground weld to come immediately after the grinding and before subsequent welding of the lines to the pressurizer, such that the ground welds would be readily accessible for the examinations.
According to the licensee, the Unit 1 PT and visual examination reports for the ground weld had not been available when the inspector requested them because the exams had been missed. Subsequent to the inspector's finding, the licensee developed special tooling and techniques and performed the required examinations from inside the pressurizer using a boroscope for viewing.
The licensee's failure to perform the inspection operations in the sequence originally specified by the SCC is a violation of BNP-QCP-10.36, ROA2, Sequence Control Chart, Section 6.1.1, which requires that the sequence specified in the SCC be followed.
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'The licensee stated that the Unit 2 examinations had not been missed, that they had been performed in the intended sequence, and that the examination reports had not been available when requested by the inspector because they had been lost after they were turned in to the Quality Control and Records Unit. The licensee's inability to provide the PT and visual examination reports for the ID examinations on the Unit 2 ground pressurizer line weld is in violation of BNP-QC'-10.7 R4, Quality Assurance Records. QCP-10.7, Section 6.5.3, requires that such records be readily retrievable.
The examiner who originally performed the examinations subsequently generated (on April 29, 1982, after the NRC inspector's finding), replacement reports for the exam-i inations.
The ori.ginal examinations were reportedly performed November 19, 1981.
In reviewing the SCCs the NRC inspector found that the MEU SCCs had not been prepared in accordance with QC Procedure BNP-QCP-10.36, ROA2, Sequence Control Chart. QCP 10.36, Section 6.1.2, requires that SCCs not originated by WEU, that involve welding and welding inspection requirements, be reviewed and approved by WEU personnel prior to issue and that the approving WEU engineer initial and date the SCC next to the preparing engineer's signature. QCP 10.36, Section 6.1.3, requires review and initialing of the SCC by QC group leaders.
MEU SCCs 1NC-M223 and 2NC-M224 did not contain the required initials signifying completion of the required reviews, a violation of the procedure requirements.
The above examples of failure to comply with procedural requirements are a violation of 10 CFR 50, Appendix B, Criterion V, as implemented by FSAR Section 17.1A.5. This violation was reported to the licensee as item 438, 439/82-23-03, Failure to Follow Procedures for Planning and Performing Inspections and for Controlling Inspection Documenta-tion.
d.
(Closed) Unresolved Item (438, 439/81-18-02): Welder Qualification
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Thickness Limits. This item was opened to document and identify for further investigation and evaluation an NRC inspector's finding that some of the licensee's welders were not properly tested to qualify them for the unlimited thickness maximum limits they had been given for combination GTAW/SMAW welding. The inspector dicussed this item with the cognizant welding engineer and reviewed the actions taken by the licensee to assure proper welder qualifications and weld quality as described in the following documents:
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Noncomformance Report 1557
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Letter from W.
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Dahnke to R. M. Hodges dated April 5,1982 (identified BLN 820405 552)
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Letter from R. M. Hodges to W. R. Dahnke dated April 26, 1982 (identified NEB 820426 251)
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Ultrasonic examination records for weld ONMMPHG0067 dated 6/30/82
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and 7/8/82
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WEU SCC IKE-W-001 All-concerns relative to this item are considered resolved.
4.
Unresolved Items Unresolved items were not identified during this inspection.
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5.
Independent Inspection Effort (92706) - Units 1 and 2 The inspector conducted a general inspection of portions of the containment and auxilliary buildings to observe activities such as material handling and control, housekeeping, welding, maintenance of identification and protection of piping, and storage.
The inspector noted no instance of significant deviation from the licensee's procedures and requirements.
6.
Licensee Identified Items (LIIs) (50.55(e)) (92700)
a.
(0 pen) LII (438, 439/80-07-06): Lack of Internal Purge on Two Welds in Chemical Addition and Boron Recovery System. The firial report for this item was submitted to Region II in c letter dated February 2,1982.
The licensee's investigation of this item involved an extensive sampling of piping welds.
The NRC Senior Resident Inspector has identified welds to the licensee that were omitted from the intended sampling due to an error. The licensee is determining what additional
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work may be required. A revised final report may be submitted.
This matter remains open pending the licensee's completion of their investigations, submittal of a revised final report (if required) and Region II's final review of the associated work and records.
Note:
For record purposes, this item is also identified 438, 439 CDR 80-171.
b.
(Closed) LII (438/80-20-02, 439/80-22-02):
Safety-Related Non-ASME Welding Inspections.
The final report for this item was submitted to Region II in a letter dated June 22, 1981.
The report has been reviewed and determined acceptable.
In their report, the licensee concluded that had the reported deficiency gone uncorrected it would not have adversely affected the safe operation of the plant.
The inspector discussed the item with responsible licensee representatives and reviewed documentation to verify that the corrective actions described in the report have been completed.
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c.
(Closed) LII (438, 439/81-01-03): Faulty Fillet Weld Specification.
The final report for this item was submitted to Region II in a letter dated June 22, 1982. The report has been reviewed and determined to be acceptable. The inspector discussed the item with licensee representa-tives and reviewed documentation supporting and confirming completion of the corrective action described in the final report.
Note:
For record purposes this item is also identified 438, 439 CDR 80-07.
d.
(0 pen) LII (438, 439/82-02-01): Welds by Johnson Machine Works on the Revolving Platform. The final report for this item was submitted to Region II in a letter dated March 9, 1982.
Subsequently, a revised final report was submitted to Region II in a letter dated March 28, 1982.
The report involved welds, on a vendor supplied structure, which were found to be deficient in size and quality. The report neither indicated the cause of the deficiency nor whether any consideration had been given to determining if other items supplied by the same vendor exhibited the same or related noncomforming conditions.
That is, the report did not indicate any consideration of possible generic implications.
The inspector reviewed the licensee's Noncon-forming Condition Report (NCR) 1638, which originally documented the reported condition as a significant condition and specified the disposition and corrective actions to be taken.
The inspector found that, as with the licensee's report to Region II, NCR 1638 did not identify the cause of the deficiency or indicate any investigation for generic noncomformance. The inspector asked the licensee whether other items supplied by the same vendor had been checked for proper weld size and quality and was informed that they had. The inspector subsequently examined selected welds on the seismic Category I diesel generator building missile doors supplied by the vendor and found that some did not comply with the contract (contract No. 822755) specified code and-drawing requirements for weld size and quality.
In response to a l
request from the inspector, the licensee examined welds on the seismic
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Category I secondary containment barn doors supplied by the vendor (contract No. 821476) and found similar deficiencies. The licensee
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recorded the deficient items for disposition on QCIR 23178.
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inspector noted that it appeared that he had been misinformed when told that the licensee had checked for other deficient items from the
j vendor. The licensee stated that there had apparently been a misunder-standing among their personnel which led to the inspector's being misinformed.
j The inspector reviewed the licensee's site QC procedures for investi-
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gation and documentation of nonconformances and suspected nonconfor-mances, listed below, to determine whether they specified adequate l
requirements to assure that nonconforming conditions were promptly
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identified and corrected; and that the causes of and the corrective
action for significant nonconforming conditions were identified and l
documented.
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QC Procedure BNP-QCP-10.26, R3, Quality Control Investigation Reports
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QC Procedure BNP-QCP-10.4, R8A3, Noncomforming Condition Reports In addition, the inspector discussed with licensee engineering and management personnel their understandng of their requirements for recording and investigating noncompliances.
From the review and discussion, the inspector found that:
The QC procedures do not provide specific requirements, respon-
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sibilities or guidance relative to evaluation for and identi-fication of noncompliance that is generic.
Further, licensee personnel stated they were aware of no requirements that speci-fied investigation for generic noncompliance. The licensee's failure to identify similar nonconformance in related items (same vendor), as described above, is evidence that the licensee does not have procedures or other measures which assure identification of noncompliance that is generic.
The site QC procedure which prescribes the handling of significant
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nonconformances, Procedure QCP-10.4, indicates that the cause of a significant nonconformance is to be documented on the NCR that identifies the deficiency.
QCP-10.4 does not assign respon-sibility for determination and entry of the cause on the NCR, however. The inspector's finding that NCR 1638 did not identify and document cause is evidence that the licensee has not esta-blished procedures or other measures to assure identification and documentation of cause for significant nonconformances. Addi-tional nonconformances examined by the inspector, which were determined significant by the licensee but for which cause was not identified on the NCR included those reported on NCRs 1312, 1315, 1350 and 3R1 (QEB).
The licensee's failure to establish measures to assure identification of generic nonconformance and to assure the identification and documentation of the cause of significant nonconformance is considered a violation of 10 CFR 50, Appendix B, Criterion XVI, as implemented by Section 17.1A.16 of the FSAR.
This violation was identified to the licensee as item 438, 439/82-23-04, Inadequate Investigation of Generic Aspects and Failure to Identify Cause for Significant Deficiencies.
LII 438, 439/82-02-01, will remain open pending Region II's verification that the full extent of the generic deficiency has been determined, its cause identified and documented, and that adequate corrective act'.cn has been taken.
Note:
For record purpose LII 438, 439/82-02-01 is also identified 438, 439 CDR 81-072.
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e.
Request for Revised or Supplemental Reports The inspector discussed the final reports submitted to Region II for several items with the licensee's Nuclear Licensing Staff Pressurized Water Reactor Section Supervisor and requested additional information needed to permit analysis and evaluation of the deficiencies and the corrective action. The inspector asked that the information requested be provided as revised or supplemental final reports.
The items discussed and information requested are as follows:
(1)
(0 pen) LII (438, 439/80-08-02): potential Defects in WKM Valves.
The inspector requested the following information:
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The cause of the deficiency
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Information regarding or an analysis of the generic implica-tions of the deficiency indicating whether additional exam-inations were considered and/or performed to assure that full extent of noncompliance was identified (2)
(0 pen) LII (438/81-15-06):
Excessive Vibrations in ERCW Pump /
Motor. This item involved two pumps which exhibited excessive vibration. The final report stated that the cause of the vibra-tion was that pump design resulted in natural frequencies too near the running speed and that the floor beneath the pump had been reworked and appeared to be a contributing factor.
The corrective action was to change the natural frequency of the pumps by adding weight.
The inspector observed the subject (weighted) pumps and observed identical pumps (without weights added) in an immediately adjacent room.
One of the unweighted pumps in the adjacent room was running and the inspector noted that it exhibited no significant vibration. Based on his obser-vation of the pumps and review of the final report on the vibra-tion deficiency the inspector requested the following information:
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Explanation of why the unweighted and apparently identical nearby pump did not exhibit excessive vibration
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The analysis used to determine and justify the weight additions to the subject pumps
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The basis for stating that the vibration experienced in the deficient pumps was due to resonant amplification Note:
For record purposes, this item is also identified 438 CDR 80-049.
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(3) (0 pen) LII (438, 439/81-18-01): Welding Valves Without Preheat and Unqualified Filler Metal.
The inspector requested the following information:
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A clearer detailed description of the deficiency than was given in the original report, including such factors as material " nominal thickness", specific requirements violated, material P No. and material carbon content
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The cause of the deficiency
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Information regarding or an anlysis of the generic implica-tions of the deficiency indicating whether examinations or data reviews were considered necessary and/or performed to assure that the full extent of noncompliance was identified Note:
For record purposes, this item is also identified 438 CDR 81-020; 439 CDR 81-021.
(4) (0 pen) LII (439/80-29-06): Atwood and Morrill Valve Deficiency.
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The inspector requested the same information as for (1) above.
(5) (0 pen) LII (438/82-09-08): Unacceptable Replacement Pump Shaft.
The inspedar requested the same information as for (1) above.
Note:
For record purposes, this item is also identified 438 CDR 82-022.
The above items will remain open pending Region II's receipt and review of the revised or supplemental reports that are to be submitted and
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examination of the items as deemed necessary in subsequent inspection.
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