ML19353A365
| ML19353A365 | |
| Person / Time | |
|---|---|
| Site: | Hartsville  |
| Issue date: | 10/27/1980 |
| From: | Mills L TENNESSEE VALLEY AUTHORITY |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML19353A358 | List: |
| References | |
| NUDOCS 8101080292 | |
| Download: ML19353A365 (3) | |
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TENNESSEE VALLEY AUTHCfRITY CH ATTANOOG A. TENNESSEE 374ol 400 Chestnut Street Tower II 7 ', -
Ochobefk7,1980 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:
TVA previously provided a response to C. E. Murphy's letter dated August 28, 1980, RII:LDZ 50-518/80-17, 50-520/80-17, on September 22, 1980. Enclosed is an additional response to the noncompliance itess, 518, 520/80-17-01 and 518, 520/80-17-02.
This additional response is being submitted as a result of a telephone conversation with A. R. Herdt and L. D. Zajac of your staff on October 14, 1980.
We have thoroughly reevaluated our initial response and continue to believe that we are not now, nor have we ever been in noncompliance with any of the applicable codes, standards, specifications, or licensing documents utilized in the construction of the Hartsville Nuclear Plants.
Although we consider that the items cited do not constitute noncompliance, we believe that these items do represent areas of possible improvement to our program.
In this regard we will be making those changes in our program which we believe will be beneficial.
TVA will continue to be responsive to suggestions from the NRC for improving our program.
If you have any additional questions or would like to discuss this matter, please call me.
Very truly yours, l
TENNESSEE VALLEY AUTHORITY b
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L. M. Mills, Manager Nuclear Regulation and Safety Enclosure l
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ENCLOSURE ADDITIONAL RESPONSE TO NRC-0IE LETTER FROM C. E. MURPHY TO H. G. PARRIS DATED AUGUST 28, 1980
==q Please reference RII: LDZ 50-518/80-17, 50-520/80-17 and our letter from L. M. Mills to J. P. O'Reilly dated September 22, 1980, responding to Infractions 518, 520/80-17-01 and 518, 520/80-17-02.
This report is an additional response to the infractions noted above and is filed to follow up on the discussion between TVA and NRC-0IE Inspectors L. D. Zajac and A. R. Herdt on October 14, 1980.
TVA has thoroughly reviewed our initial response to the Notice of Violation of the OIE inspection report and conclude that our initial response does present our final position on each of the items discussed with the additional information presented below. We are still of the opinion that the items cited in the referenced inspection report do not constitute items of noncompliance to any applicable codes, standards, or other criteria of the Hartsville Nuclear Plant.
We consider the items cited to represent areas of possible improvement to our program but, again, we feel that our program currently meets ASME requirements.
Noncompliance Item 518, 520/80-17 Additional Information TVA has thoroughly reviewed the magnetic particle testing (MT) program, especially as related'to the anchor bolt chair welds and___.
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program and who was present, along with the Authorized Nuclear ~
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interviewed the CONST Level III who implements the training
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Inspector (ANI), at the time of the MT examination cited as deficient by the OIE Inspector. In the opinion of the CONST Level III and.the _ __
ANI, the cited MT inspection met minimum ASMS requirements. The
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fact that indications were found during this MT inspection (and subsequently repaired) further supports this fosition.
In addition to our original response concerning procedure QCI-N201, our training procedures for MT which are signed by the CONST Level III include the methods of applying and removing powder and the appropriate methods of ensuring adequate coverage of the test surface.
l Furthermore, to cooperate with what we consider as NRC program imprevement suggestions, we have revised process specification 3.M.2.1 as of October 6,1980, as we indicated in our previous report on-this matter.
Noncompliance Item 518, 520/80-17 Additional Information Our rereview of the procedures shows no specific requirement for SNT-TC-1 A in visual examination methods other than for development of
" equivalent" programs, procedures, and demonstrations. We still maintain.,that the TVA program at Hartsville is equivalent to SNT-TC-1A methods. Concerning workmanship samples, we add that the training program covers definition by the instructors of acceptable and E
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unacceptable surface conditions as exhibited by the samples used in the program in a method described in QCI-N501.
Also, three examples of acceptable 3 to 1 transitions are and have been used in the training program and, as indicated to the OIE inspector at the time of the inspection, the test coupons he observed were not and are not used to illustrate this condition.
(This is specifically pointed out in the training program.)
In summary, we believe we are not now, nor have we ever been in nonconpliance with any of the applicable codes, specifications, or licensing documents committed to in construction of the Hartsville Nuclear Plant. TVA will continue to be responsive to any suggestion you or your staff may have for improving our program now or in i
the future.
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