ML20040C136
| ML20040C136 | |
| Person / Time | |
|---|---|
| Site: | Hartsville  |
| Issue date: | 12/29/1981 |
| From: | Mills L TENNESSEE VALLEY AUTHORITY |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20040C129 | List: |
| References | |
| NUDOCS 8201270302 | |
| Download: ML20040C136 (3) | |
Text
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TENNESSEE VALLEY AU,TSOMlVSiD,.:-
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CH ATTANOOG A, TENNESSEE 3740'l 400 Chestnut Street Tower II n B. Og B2 JM14 December 29, 1981
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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 response to H. C. Lewis' November 17, 1981 letter to H. G. Parris transmitting Inspection Report Nos. 50-518/81-18,
-519/81-18, -520/81-18, and -521/81-18 regarding activities at our Hartsville Nuclear Plant which appeared to have been in violation of NRC regulations. We have enclosed our response to Appendix A, Notice of Violation. A 14-day extension was discussed with and approved by NRC-0IE Inspector F. S. Cantrell on December 10, 1981.
If you have any questions, please call Jim Docer at FTS 858-2725.
To the best of my knowledge, I declare the statements contained herein arc complete and true.
Very truly yours, TENNESSEE VALLEY AUTHORITY
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L. M. Mills, Manager Nuclear Regulation and Safety Enclosure 8201270302 820118 DR ADOCK 05000518 PDR l
An Ecual Ocportuitty Empf oyer l
ENCLOSURE RESPONSE TO NRC-0IE LETTER
'FROM R. C. LEWIS TO H. G. PARRIS DATED NOVEMBER 17, 1981
(
Reference:
Report Nos. 50-518/81-18, 50-519/81-18, 50-520/81-18, 50-521/81-18)
This report responds to the Notice of Violation described in Appendix A of the OIS inspection report referanced above. This is the final report on the subject noncompliance.
Noncompliance Item - Severity Level VI - Violation 518/81-18-02 10CFR50, Appendix B, Criterion XIII as implemented by PSAR Section
- 17.1A.13 requires measures be established to control the storage and preservation of material and equipment in accordance with work and inspection instruction to prevent damage or deterioraticn.
Contrary to the above, on October 29, 1981, measures were not established for preservation of equipment in that no preventative maintenance procedures were in effect for a residual heat removal pump which was in long-term storage.
This is a Severity Level VI Violation (Supplement II.F).
Response
1.
Admission or Denial of the Alleged Violation TVA admits the violation occurred as stated.
2.
The Reasons for the Violation Items requiring preventive maintenance are entered in the preventive maintenance computer program (PREVENT) from receiving reports obtained from the Warehouse Services Unit. The pump in question was nonconformed on receipt delaying the receiving report. When the report was processed, the pump was not entered in the PREVENT program. Due to the length of time since receipt, we cannot determine if the report was properly routed and incorrectly handled or if routing was improper.
3 Corrective Steps Taken and Results Achieved The specified preventive maintenance requirements stated that (1) protective coverings are intact, (2) there are no signs of loose
. flaky rust, and (3) the pump shaft is rotated. These were to be performed monthly, quarterly, and semiannually, respectively. These requirements for the RHR pumps have been reevaluated and as
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. a result will be changed to require quarterly preventive maintenance consisting of a visual inspection to verify that (1) the item is stored in its original condition, (2) protective covers and seals are in place, (3) coatings, preservatives, and lubricants are present, (4) physical damage has not occurred, (5) the item is generally clean, and (6) water has not accumulated. This decision is based on the design of the pump, storage level requirements, and vendor recommendations. The shaft is fabricated from noncorrosive alloy steel eliminating the need for an inspection for rust.
The pump body is carbon steel with manufacturer's recommended storage level of Level C, i.e. indoor storage with no heat or humidity control. TVA has chosen to place these items in Level B storage which includes heat controls. As a result, the temperature controlled storage greatly reduces the possibility of detrimental rust. The pump bearings are water lubricated and can be damaged by shaft rotation. Therefore, failure to perform the required preventive maintenance did not adversely affect the pump.
4.
Corrective Steps Taken to Avoid Further Noncompliance All involved personnel have been reminded of the importance of properly routing receiving reports so that items will be included in the PREVENT program.
5.
Date When Full Compliance Will Be Achieved Full compliance will be a hieved by January 29, 1982.