ML20058G624

Responds to NRC Re Violations Noted in IE Insp Repts 50-438/82-11 & 50-439/82-11.Corrective Action: Temporary Flexible Plastic Cover Placed Over Valve to Minimize Entrance of Addl Contaminants to Sys

ML20058G624
Person / Time
Site:	Bellefonte
Issue date:	07/08/1982
From:	Mills L TENNESSEE VALLEY AUTHORITY
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20058G579	List: IR 05000438/1982011 ML20058G574 ML20058G599 ML20058G624 ML20058G641 ML20058G654
References
NUDOCS 8208030378
Download: ML20058G624 (3)

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TENNESSEE VALLEY AUTHORITY CH ATTANOOGA. TENNESSEC , ,,

400 Chestnut Street Tower'II"#** '

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'U.S. Nuclear Regulatory Commission Region II y

Attn: Mr. James P. O'Reilly, Regional Administrator 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303

Dear Mr. O'Reilly:

BELLEFONTE NUCLEAR PLANT UNIT 1 - RESPONSE TO VIOLATION 50-438/82-11-01 INSTALLED PIPING CLEANLINESS This is in response to R. C. Lewis' letter dated June 3, 1982, report numbers 50-438/82-11, 50-439/82-11, concerning activities at the Bellefonte Nuclear Plant which appeared to have been in violation of NRC regulations. Enclosed is our response to the citation.

If you have any questions concerning this matter, please get in touch with R. H. Shell at FTS 858-2688.

To the best of my knowledge, I declare the statements contained herein are complete and true.

Very truly yours, TENNESSEE VALLEY AUTHORITY L. M. Mills, Manager Nuolear Licensing Enclosure oc: Mr. Richard C. DeYoung,. Director (Enclosure)

Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, DC 20555 f

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An Equal Opportunity Employe*

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ENCLOSURL BELLEFONTE NUCLEAR PLANT UNIi 1/  %

i RESPONSE TO SEVERITY LEVEL IV VIOLATION 50-438/82-11-01 INSTALLED PIPING CLEANLINESS <

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10 CFR 50, Appendix B, Criterion V, as implemenf,ed by FSAR Seation ~

17.1A.5, requires that activities affecting quality be prescribed and '

accomplished 1% accordance with documented procedures or instructions.

Bellefonte procedure QCP 6.16 RO requires that openings on piping

materials and equipment be sealed or capped to maintain cleinlir.ess.

'(' ,f i Contrary to the,aboar>; ' piping installed in the, core flooding system was e .

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not adequatiely sealed or cipped 'to assure maintenance of cleanliness in </

that on April 27, 1982, the valve adjacent to weld 1NLoo35'in the core

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flooding system was ,open'and dirt an$ debris had enteied'the ,t ( /

piping through the opening.

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AdmissionorDenial'hrtheAlle\ ged Violation

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( , ,/ i; TVA admits the violation occurred as stated. i-t '( I '

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' )[I ,9 Reason for the Violation' '

The violation occurred because proper prot _ection,had'not been maintained ig to prevent the entrence of contaminants into the Tsystem through the open valve. -It should be noted, however, that BLN CONST engineering personnel II

intended-to keep theivalve top seal plate off'the valve to allow observation of water leakage past the temporarily closed valve seat -

during performance of construction flushing operations. _ The monitoring of the leakage was absolutely necessary to provide pertinent information j

,j to flushing personnel during performance of the flushea. According to af Bellefonte quality cor. trol procedure BNP-QCP-10.8, a Temporary >

Installation and Omission Control Form, had been initiated to indicate f that the valve was open in temporary .$ tate and that reinstallation and cleaning of the valve. internals and adja' cent piping would be performed upon completion of the flushing operat; ions. In addition, the i configuration of the device used to block the valve closed prcHbited use of a temporary cap to. completely seal the valve top. (

Corrective Action Taken and Resulta Achieved "k

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The valve body and accessible adjacent piping was inspected for any contaminatien and any found was removed. A temporary flexible plastic l cover _ has been placed o,ver the valvo_to minimize the entrance of y additiona1 contaminants to the system and to maintain tha present level of cleanliness.! Also, this valve 1has been added,to the Inspection, <

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l Storage and Preventative Mainter.nce a (ISPM) Program to provide additional

assurance that inspections will'be performed to confirm that the v'alve '

remains protected. Thin' disposition is uniquely applicable to the i referenced valve, a, simi'.ar valve oiunit 1,aad two similar valves on unit' 2. These four valv 3s' are the only ,va' be blocked open during flushing operations.ges which TVA anticipates must l

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' e e g e Steps Taken to_ Avoid Further Violations BLN CONST Mechanical Engineering Unit (MEU) and Startup, Testing and Coordination Unit (STCU) personnel have been informed of the necessity of maintaining protection on valves and equipment that are in a temporary state during flushing activities. In addition, all steam fitter craftsmen have been reinstructed in the necessity of proper cleaning and maintenance of piping system components. The remaining three valves will also be included in the ISPM Program.

Date of Full Compliance Full compliance was achieved on April 28, 1982 at which time the valve and adjacent piping was cleaned and protected.

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