ML20031F827
| ML20031F827 | |
| Person / Time | |
|---|---|
| Site: | Yellow Creek  |
| Issue date: | 09/22/1981 |
| From: | Mills L TENNESSEE VALLEY AUTHORITY |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20031F806 | List: |
| References | |
| NUDOCS 8110200460 | |
| Download: ML20031F827 (3) | |
Text
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TENNESSEE VALLEY AUTHORITY CH ATTANOOGA, TENNESSEE 374o1 400 Chestnut Street Tower II
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c September 22, 1981 Mr. Jam 3s 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:
YELLOW CREEK NUCLEAR PLANT UNIT 1 - RESPONSE TO VIOLATION 50-566/81-08 INADEQUATE MEASURES TO CONTROL PRESERVATION OF SAFETY-RELATED MATERIALS AND EQUIPMENT This is in response to R. C. Lewis' letter dated August 20, 1981, report numbers 50-566/81-08, 50-567/81-08, concerning activities at the Yellow Creek Nuclear Plant which appeared to have been in violation of NRC regulations. Enclosed is the response to the citation.
If you have any questions concernirg 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 complete and true.
]
i Very truly yours, TENNESSEE VALLEY AUTHORITY
- /l.W L. M. Mills, Manager Nuclear Regulation and Safety Er. closure cc:,Mr. Vlotor Stello, Jr., Director (Enclosure)
Office of Inspection and Enforceaient U.S. Nuclear Regulatory Commission Washington, DC 20555
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jDRADocgo 66 PDR An Equal Opportunity Employer
1 of 2 ENCLOSURE YELLOW CREEK NUCLEAR PLANT UNIT 1 RESPONSE TO VIOLATION Violation 50-566/81-08-01 10CFR50, appendix B, criterion XIII, as implemented by paragraph 17.1 A.13 of TVA topical report TVA-TR75-1, requires that measures be established to control storage and preservation of matorials and equipment to prevent damage and deterioration. TVA specification 3250 and Chicago Bridge and Iron (CBI) procedure SH9 establishes level "D" storage requirements of ANSI N45.2.2-1972 as the applicable requirements for storage and preservation of contaf.nment penetrations. For level "D" storage preservation, paragraphs 2.7, 2.7.4, 6.1.1, and 6.1.2 of ANSI N45.2.2-1972 require protection against the weather, physical damage, and to avoid trapping water.
Contrary to the above, on July 28-29, 1981, adequate measures had not been established to protect containment penetration bellows against the weather, ohysical damage, and trapped water in that:
1.
Penetration X-53 (fuel transfer penetration) was stored outdoors in the CBI construction yard in a position where water had accumulated on the unprotected internal stainless steel bellows.
2.
Penetrations X-22, X-66, X-64, X-39, X-37, and X-67, installed in the containment shell, had no protection on the internal stainless steel bellows.
Construction debris had been allowed to accumulate on the bellows.
3 Penetration X-47, installed in the containment shell, was being used for a construction access, and the internal stainless steel bellows had been protected witn tape. The tape had started to come off and is not adequate protection against physical damage.
Admission or Denial of the Alleged Violation TVA admits the violation occurred as stated.
Reasons for the Violation This violation is a result of inadequate specification of the protection requirements in the contract specification and inadequate contractor procedures for providing and maintaining the protection.
CBI has stated that penetration X-53 has been stored and protected properly but that the plastic cover had blown off during a storm. With regard to the penetrations installed in the shell, the contract specification is not sufficiently clear as to the extent of the protection which TVA wanted the contractor to provide.
CBI had interpreted their responsibility as to provide protection from the execution of their own work and not from the
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2 of 2 execution of TVA's work during their absence from the reactor building area. No protection had been provided from the weather other than that afforded by the bellows location and the shell curvature. TVA had not taken any action to provide addf.tional protective measures in the belief that CBI had left the bellows a6 quately protected.
Corrective Steps Taken and Results Achieved Upon notification of the findings cited in this violation, TVA performed a survey of the penetration bellowe in both the reactor building area and the CBI yard. In the CBI yard penetration X-53 was found as noted in finding number 1.
CBI stated that the protective cover had blown off during a storm. The water which had accumulated inside the bellows has now been removed and the cover replaced. TVA has determined that the conditions which resulted in finding number 2 are generic in that adequate protection is not provided for the bellows on any penetrations above elevation 497 feet. A course of action to bring the bellows into compliance has been established as follows:
(a) TVA and CBI will conduct a joint insp3ction of the penetration bellows installed in the shell. The scope of work necessary to being the bellows into compliance will be determined at this time.
(b) Any work required from item (a) will be performed by CBI, and the open ends of the penetrations will be covered.
(c) The covero in item (b) will initially be nylon reinforced polyethelene taped in place. TVA will fabricate sheet metal covers which will be used to replace the polyethelene as they become available.
Penetration X-47 was being used as a construction access with hoses and cable in PVC pipe passing through the penetration. This access has been relocated so as not to use a penetration with a bellows.
Corrective Steps Taken to Avoid Further Noncompliance The nylon reinforced polyethelene will prevent contaminants from entering the bellows once they have been cleaned, but it is not expected to provide sufficient protection from physical damage in the construction environment of the reactor building. The sheet metal covers discussed above will provide this protection. For the present time, the polyethelene will remain as the only protective covers on the penetration bellows in the CBI yard. These covers will be monitored and repaired or replaced with more substantial covers if such action is indicated.
Date When Full Compliance Will Be Achieved The joint inspection of the penetration bellows discussed above was completed on September 8,1981. Any cleaning or repair work and installation of the interim polyethelene covers will be completed by September 28, 1981.
Full compliance will be achieved on this date. The fabrication and installation cf sheet metal covers will be completed by October 16, 1981.