ML19353A357
| ML19353A357 | |
| Person / Time | |
|---|---|
| Site: | Hartsville  |
| Issue date: | 12/05/1980 |
| From: | Murphy C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Parris H TENNESSEE VALLEY AUTHORITY |
| Shared Package | |
| ML19353A358 | List: |
| References | |
| NUDOCS 8101080267 | |
| Download: ML19353A357 (4) | |
See also: IR 05000518/1980017
Text
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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REGION 11
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i31 MARIETT A ST., N.W., SUIT E 3100
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ATLANTA, G EORGI A 30303
5 1980
In Reply Refer To:
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Tennessee Valley Authority
ATTN:
H. G. Parris
Manager of Power
500A Chestnut Street Tower II
Chattanooga, TN 37401
Gentlemen:
Thank you for your letters of September 22, and October 27,1980, informing
us of steps you have taken to correct the items of noncompliance concerning
activities under NRC Construction Pennit Nos. CPPR-150 and CPPR-152 brought
to your attention in our letter of August 28, 1980.
We have examined your corrective actions and plans as detailed in your letter
of response. As a result of this review, the following coments are made:
1.
We do not concur with your response to infraction 518, 529/80-17-01,
" Inadequate Magnetic Particle Examination Program," for the following
reasons:
a.
(Re:
TVA letter dated October 27) Both the NRC inspector and the
TVA level III examiner witnessed the magnetic particle examination
(itT) of the anchor bolt chair weld. After the MT uas completed,
the NRC inspector identified three major discrepancies in the
examination and discussed these with the TVA level III examiner.
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The three major discrepancies discussed were:
(1) not observing
the powder formation during application; (2) vigorous blowing to
remove excess powder; and (3) inadequate overlap of the test
prods. At the time of this discussion, the TVA level III examiner
concurred with the NRC inspector.
b.
(Re:
TVA letter dated October 27) Regarding the authorized
Nuclear Inspector's position, it should be noted that during
the MT the Authorized Nuclear Inspector (ANI) assisted the MT
examiner in performing the examination. The ANI held the light
source for the examiner and assisted in the evaluation of the
test results.
It is, therefore, questionable how the ANI can
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form an objective opinion of the examination when he had a part
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1:n perfonning the examination.
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5 1980
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c.
(Re: TVA letter dated October 27 and TVA letter dated September 22)
With regard to the MT written procedure, it is agreed that the
training function is of utmost importance and that examiner
candidates learn such things as applying and removing MT powder
and the amount of overlap required for 100 percent coverage of
the test surface. However, pertinent infonnation, such as the
methods of applying and removing the MT powder, needs to be part
of the written procedure in order to reinforce the training aspects
and to make the specified methods mandatory.
In addition, examination
procedures should include all steps necessary for the accomplishment
of the examination, not just those items specified by the applicable
code. The need for additional steps is evidenced by the failure to
properly accomplish the test. The same can be said of prod overlap.
Different size pipe welds, weld preps, fittings, fillet welds,
fasteners, etc., all require a somewhat different grid pattern to
ensure 100 percent coverage.
Detailed procedures are required to
eliminate the need for an examiner to remember all this from
training, particularly when some items may not be examined very
often. The use of a field indicator to assure coverage is good
practice, however, this does not necessarily identify the dead
zone near the prods, nor is it practical to expect the examiner
to use it in the field for every prod position on complex shapes
to ensure coverage. This sort of testing is normally done in a
laboratory and the results plotted graphically and made part of
the written procedure for the examiner to follow in the field.
d.
(Re: TVA letter dated September 22) With regard to the lighting
of the test surface, NRC agrees that ASME does not specifically
require a " beam of light" to always be directed on the test surface
during testing. However, ASME does specify observation of the test
surface during application of the MT powder and it does require
adequate lighting for this observation. Since it is difficult, if
not impossible, to observe the test surface in a darkened environ-
ment, the source of light should be directed in a manner that would
permit observation of the test surface.
During the MT of the subject
welds, the light source at times was directed on top of the yoke
holders hand and did not illuminate the test surface.
e.
(Re: TVA letter dated September 22) Regarding the tests by
manometer of powder blowers used by TVA, the NRC inspector
advised the level III examiner that the test setup did not comply
with that recomended in SE-109 of ASME,Section V.
NRC agrees
that the test conducted by TVA on the manometer produced an air
pressure less than that specified as a maximum in ASME.
However,
using TVA's setup with an even larger funnel, even less air pressure
would be produced, and if the funnel was made large enough, the air
pressure from the MT bulb would have no effect at all on the water
column. Yet the same MT bulb would be used and it would discharge
the same air pressure. Therefore, TVA's argument that their
sample tests by manometer proved the MT bulbs produced less air
pressure than that specified in ASME is invalid.
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5 1980
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f.
,(Re: TVA letter dated September 22) With regard to the overlap
being sufficient because only an excavation of a weld repair
was being examined, no dissagreement exists for coverage of the
excavation. However, the excavation was on one side of the tee
weld, while the other side of the tee weld had what appeared to
be a completed weld for the entire length of the vertical member.
Furthemore, more than just one excavation was examined; both
sides of the weld joining the member in the horizontal position
were examined in addition to the opposite side of the vertical
member.
2.
We do not concur with your response to Infraction 518, 520/80-17-02,
" Inadequate qualification requirements for visual examiners,?" for the
following reasons:
a.
(Re:
TVA letter dated September 22) With regard to the three year
requalification for~ visual evaminers, the NRC inspector asked the
TVA level III examiner whether his program required a three year
requalification and he said no.
b.
(Re:
TVA letter dated September 22) With regard to the minimum of
ten check points specified for the practical examination, the NRC
inspector was advised that numerous checkpoints were used but were
not formally documented.
In your response you indicate that the
checkpoints were not formally documented. Unless fomal documen-
tation exists, accomplishment of the program cannot be verified.
c.
(Re:
TVA letter dated October 27 and TVA letter dated September 22)
With regard to workmanship samples and training / qualification samples,
information in your response is not in agreement with that provided
the NRC inspector at the time of the inspection. There were no
samples available at the time of the NRC inspection that represented
acceptable / unacceptable surface conditions of coarse ripples, grooves,
abrupt ridges and valleys.
Furthemore, during the inspection, the
NRC inspector asked 1hether the taper at the end of a counterbore
was discussed in training and if samples were available that depicted
acceptable / unacceptable transitions.
The inspector raised this
question while reviewing a pipe sample with an unacceptable taper
condition at tne end of a counterbore. The TVA level III examiner
advised the NRC inspector that this condition had not been considered
in training or qualificathn and that he had no samples specifically
depicting the condition. However, in your response dated October 27,
you state that th:n are three examples of 3-1 transitions that are
used in the training program.
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Tennessee Valley Authority
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It is pointed out that the NRC inspector described each of the infractions
in detail during the exit interview. No discussion or rebuttal of the
discrepancies described was made by TVA attendees.
In view of the a bve,
the Notice of Violation transmitted to you on August 28, 1980, remains
unchanged. Section 2.201 requires you to submit to this office a writtee
statement or explanation in reply including:
(1) corrective steps which
have been taken by you and the results achieved; (2) corrective steps which
will be taken to avoid further noncompliance; and (3) the date when full
compliance will be achieved.
We appreciate your cooperation With us.
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Sincerely,
Charles E. iiurphy, C ief
Reactor Construction and
Engineering Support Branch
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cc:
R. T. Hathcote, Project Manager
J. F. Cox, Supervisor, Suclear
Licensing Section
J. E. Wills, Project Engineer
H. N. Culver, Chief, Nuclear
Safety Review Staff
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