ML19208B257

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Responds to NRC 790706 Ltr Re Violations Noted in IE Insp Repts 50-518/79-12,50-519/79-12,50-520/79-12 & 50-521/79-12. Corrective actions:CEP-2.01 Deleted from Manual,Welder Terminated & SOP-34 Drafted to Define Requirements
ML19208B257
Person / Time
Site: Hartsville  Tennessee Valley Authority icon.png
Issue date: 07/31/1979
From: Mills L
TENNESSEE VALLEY AUTHORITY
To: James O'Reilly
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML19208B250 List:
References
NUDOCS 7909190421
Download: ML19208B257 (4)


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. TENNESSEE VALLEY AUTHORITY 8 CH ATTANOOGA. TENNESSEE 374ol 400 Chestnut Street Tower 11 v

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. July 31, 1979 .

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c Mr. James P. O'Reilly, Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission -

Region II - Suite 3100 ~

101 Marietta Street Atlanta, Georgia 30303

Dear Mr. O'Reilly:

Enclosed is our final response to C. E. Murphy's July 6, 1979, letter, RII:JJB 50-518/79-12, 50-519/79-12, 50-520/79-12, and 50-521/79-12, regarding activities at Hartsville Nuclear Plants A and B which appeared to have been in violation of NRC regulations.

We have reviewed the subject inspection report and find no proprietary information in the report. If you have any questions regarding this matter, please call Tish Jenkins at FTS 854-2014.

Very truly yours, TENNESSEE VALLEY AUTHORITY

. M. Mills, Manager Nuclear Regulation and Safety Enclosure

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yioim An Eaual Opportunity Employer OrggjlCOF2-

ENCLOSURE FINAL RESPONSE TO NRC-0IE LETTER FROM C. E. MURPHY TO H. G. PART N DATED JULY 6, 1979 (REFERENCE RII:JJB 50-518/79-12, 50-519/79-12, 50-520/79-12, 50-521/79-12)

This report responds to the following Notice of Violation described in appendix A of IE Inspection Report RII:JJE 50-518/79-12, 50-519/79-12, 50-520/79-12, and 50-521/79-12. This is the final report on these noncompliances.

Noncompliance Item Ceficiency 518/79-12-01, 519/79-12-01, 520/79-12-01, 521/79-12-01 A. As required by Criterion VI of Appendix B to 10CTR50 and implemented by TVA Hartsville PSAR Section 17.lA.6 Docume Control "TVA assures that QA policies, manuals, procedures, drawing;, and specifications (including changes thereto) are controlled by means of procedures. . ."

Contrary to the above, construction engineering procedure CEP-5.01 for the control of Construction Engineering Frocedures does not assure that CEP-2.01 " Construction.Engineeri.Lg Quality Assurance Program Description is updated when changes are made to other sections of the manual (e.g. , additions or deletions of procedures) .

This is a deficiency.

Response

1. Corrective Steps Taken and Results Achieved Construction Engineering Procedure CEP-2.01 was employed in early stages of the QA program development for content planning purposes.

Since this portion of the Hartsville QA Program is nearing com-pletion, the " planning function" of CEP-2.01 is now served by the CEP Manual Index. CEP-2.01 was deleted from the CEP Manual, and therefore from the QA program by memorandum dated July 10, 1979, from the Chief, QA Staff CONST to manual holders.

2. Corrective Steps Taken to Avoid Further Noncompliance Withdrawal of CEP-2.01 from the QA program will prevent further noncompliance of this type.

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. 3. Date When Full Compliance was Achieved Full compliance was achieved July 20, 1979.

Noncompliance Item Infraction 518/79-12-02 B. As required by Criterion IX of Appendix B to 10CFR50 and implemented by TVA Hartsville PSAR Section 17.lA.9 control of special processes "special processes are controlled and accomplished by qualified written procedures." The weld test shop QA orientation which is a part of the qualification of welding personnel states that the welder is to "take only one electrode at a time from the oven. . ."

Contrary to the above, on June 6,1979, a welder was observed taking a handful of electrodes from his portable electrode oven while welding on a safety-related structure. This action violated the QA terms of the welder's welder qualification.

This is an infraction.

Response

1. Corrective Steps Taken and Results Achieved In order to reinforce TVA commitment to good welding practice, the welder identified as taking more than one electrode from his oven was terminated. Removal of one electrode at a time,is good welding practice and is identified in the QA prograc as such in the welder orientation. This practice is not a written QA requirement at this time, and therefore not considered to be part of the formal QA program at the Hartsville Nuclear Plant.
2. Corrective Steps Taken to Avoid Further Noncompliance TVA has reemphasized the importance of electrode control to QC inspectors responsible for welder surveillance in accordance with standard operating procedure SOP-ll and Construction Engineering Procedure CEP-8.03. One of the functions of this surveillance is to enforce weld electrode control. This surveillance is performed on a daily basis in all areas.
3. Date When Full Compliance was Achieved Full compliance was achieved on July 30, 1979.

Noncompliance Item Infraction 518/79-12-03, 519/79-12-03, 520/79-12-03, 521/79-12-03 C. As required by Criterion V of Appendix B to 10CFR50 and implemented by TVA, Hartsville PSAR Section 17.lA.5 Instructions Procedures and Drawings, activities affecting quality are prescribed by documented instructions in the form of drawings, specifications, and procedures.

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Contrary to the above, welding control procedures do not clearly define requirements for recording of welder identification, welding filler material used or preheat temperature checks for welding oper-ations between the fitup inspection and the final visual examination of a Vb1d joint.

This is an infraction.

Response

1. Corrective Steps Taken and Results Achieved A new standard operating procedure SOP-34 has been draf ted to provide a clear definition of requirements for documentation of welding. SOP-34 addresses welder identification, welding fill-r metal used and preheat temperature checks for welding oper& tion, between the fitup inspection and the final visual examination of a weld joint.
2. Corrective Steps Taken to Avoid Further Noncompliance Implementation of SOP-34 should preclude further noncompliance.
3. Date When Full Compliance will be Achieved Full compliance will be achieved by August 1,1979.

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