ML20003H219
| ML20003H219 | |
| Person / Time | |
|---|---|
| Site: | Bellefonte |
| Issue date: | 04/10/1981 |
| From: | Mills L TENNESSEE VALLEY AUTHORITY |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML110870763 | List: |
| References | |
| NUDOCS 8105050357 | |
| Download: ML20003H219 (3) | |
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TENNESSEE VALLEY AUTHORITY
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400 Chestnut Street Tower II i p114 AE: 30 April 10, 1981 Mr. Janes P. O'Reilly, Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Carission Region II - Suite 3100 101 Marietta Street Atlanta, Georgia 30303
Dear Mr. O'aeilly:
WHMtNTE NUCLEAR PIANP UNIT 2 - VIGATICE 50-439/B1-07 FAILURE TO FTIJ4W PROCEDURES WHEN INSTALLIIU THE MEGANICAL HEATING AND VENTIIATICN STRUCTURES This is in response to R. C. Iewis' letter dated March 18, 1981 report numbers 50-438/B1-07 and 50-439/B1-07, concerning activities at the dellefonte Nuclear Plant which appeared to have been in violation of NH',' regulations.
Enclosed is our response to the citation.
If you have any questions concerning this matter, please get in touch with D. L. Lambert at FTS 857-2581.
To the best of my knowledge, I declare the statements contained herein are ccmiplete and true.
Very truly yours, Tf2EESSEE VALLEY AU1BORITY
.YME L. M. Mills, Manager Nuclear Regulation and Safety Enclosure cc: Mr. Victor Stello, Jr., Director (Enclosure)
Office of Inspection and Enforcement U.S. Nuclear Regulatory Ccunission Washington, DC 20555 f/Ofo[Mb An E; :,t Croo tamty Emotover
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BE[LERNFE NUCLEAR PIJNP WIT 2 SEVERITY LEVEL V VIGATIN 1
FAIIURE TO RI.IOf Planm1RES MEN IN!rmLLING THE MECHANIChL HEkTING AIO VI!NPIIATIN STRUCIURES 50-439/91-07-01 6
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Description of Violation i
j 10 CFR 50, Appendix B, Criterion V requires that activities affecting quality shall be prescribed in documented instructions, procedures, or drawings of any type appropriate to the circuenstances and shall be acomplished in accordance with these instructions, procedures, or drawings.
Instructions, procedures, i
or drawings shall include appropriate quantitative or qualitative acceptance j
criteria for determining that inportant activities have been satisfactorily acomplished. TVA drawings 3AWO910-00-55 Ittil and 3AWO910-00-601500 l
specify in part the detail of how to fabricate the mechanical heating and ventilation system structure. These drawings include the location of welds and type / size of welds to be made.
l Contrary to the above, between February 18 and 26, 1981 the Resident Inspector identified three examples of welding performance which violate the criteria specified on TVA drawings 3AWO910-00-5515f11 and 3AWO910-00-601990.
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Admission or Denial of Alleged Violation l
The failure to follow procedures when installing the mechanical heating and ventilation structures occurred as cited in the violation. It should be noted that the correct revision level for 3AWO910-00-55 is 1, not 11, as stated in the subject OIE inspection report.
l Reason for Violation l
In the details section of the subject report, the NIC irdg-wr stated that, "Four welds were made on February 18, 1981 at elevation 686' 6" (Detail J55,J55 of TVA 3AWO910-00-55 Revision 11) without any welds specified on the above drawing" and "Several welds were made on the mechanical heating and ventilation structure which did not coincide with the weld symbols identified on TVA drawing 3AWO910-00-55, Revision 11." The reason for these deficient areas is that work was not being performed by the craft in accordance with TVA I
Division of Engineering Design (M DES) drawing (s).
In addition, the NBC ii5gwr stated that, "1he welder was performing the welds without weld cards in the immediate work area and four weld cards did not exist." Safety-related welds at Bellefonte generally are identified by engineering through the use of weld maps (isemetrics) constructed fran the weld detail requirements of M DES drawings. Each safety-related weld is assigned a weld number on the weld map and a corresponding weld card for that nianber is issued to the craft as a process control document. Pour unauthorized welds were applied to the assembly proper. No weld cards e'<1sted for these welds because they were not on the EN DES drawing. Weld cards not being in the immediate area indicates that there was improper supervisory control, i.e., the foreman over the work being performed.
Bellefonte Nuclear Plant Field Ccnstruction Procedure BNP-ECP-10.7.2, Revision 0, " Handling of APC (Weld) Cards and Weld Maps," procedurally requires review of M DES drawings against weld maps and weld cards before starting work.
In this case, the procedure was not properly followed.
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2-s Corrective Action Taken and Results Ichieved he resultant fabrication errors are being dccumented and processed for corrective action through the nonconformance reporting rystem.
The responsible craft personnel have received disciplinary action and instruction in the following areas:
1.
QA orientation and job rules 2.
Welding orientation and test 3.
3NP-EEP-10.7. 2 4.
Weld symbols mis combination of disciplinary action and instructions has created a greater awareness on behalf of both management and workers to fabricate plant features in accordance with approved prccedures, drawings, and specifications.
Steps Taken to Avoid Further Recurrence The responsible craft supervision is now providing training to'its eriplayees on a continuing basis.
Related to this violation is the February 20 Allegation Report A-017, "Possible Unauthorized Welding in the HVAC Plenum Area," which is still under investigation. Pending results of this conprehensive investigation, further recurrence control may be necessary.
If any a3ditional necessary corrective actions are identified as a result of the investigation into the allegation, TVA will expeditiously inplement them. Any deficiencies similar to those cited will also be atv,manted and processed for corrective action through the nonconformance reporting system.
Date of Ebll Canpliance TVA is in full ccurpliance.
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