ML20062H919

Responds to NRC Re Violations Noted in IE Insp Repts 50-438/82-12 & 50-439/82-12.Corrective Actions:Sys Will Be Flushed in Accordance W/Procedures Until ANSI Acceptance Criteria Are Satisfied

ML20062H919
Person / Time
Site:	Bellefonte
Issue date:	06/21/1982
From:	Mills L TENNESSEE VALLEY AUTHORITY
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20062H902	List: IR 05000438/1982012 ML20062H900 ML20062H919 ML20062H937 ML20062H945
References
NUDOCS 8208160210
Download: ML20062H919 (3)

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U.S. Nuclear Regulatory Conunission Region II 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 50-438/82-12 TOOL AND MATERIAL CONTROL This is in response to F. J. Long's letter dated May 21, 1982, report numbers 50-438/82-12, 50-439/82-12, concerning activities at the Bellefonte Nuclear Plant which appeared to have been in viclation 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 Iqy knowledge, I declare the statements contained herein are complete and true.

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

Office of Inspection and Enforcement l U.S. Nuclear Regulatory Conur.ission Washington, DC 20555 l

l 8208160210 820809 PDR ADOCK 05000438 ,,s t c v 1, <

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ENCLOSURE BELLEFONTE NUCLEAR PLANT UNIT 1 -

• RESPONSE TO SEVERITY LEVEL V VIOLATION 50-438/82-12-11 TOOL AND MATERIAL CONTROL Description of Deficiency --

10 CFR 50, Appendix B, criterion V and Tennessee Valley Authority (TVA)

Final Safety Analysis Report, Section 17.1A.5 requires that activities affecting quality be accomplished in accordance with procedures and drawings.

Bellefonte Quality Control Procedure BNP-QCP-6.16, Rev. O, " Cleanliness Control During Piping System Installation" states:

Paragraph 6.1 -

Prior to installation the crafts shall clean all piping material for those systems specified for cleaning per CONST Specification N4M-891.

Paragraph 6.2 -

After cleaning the crafts shall maintain cleanliness control of system by ensuring that all openings on piping materials and equipment are sealed or capped at all times when work is not in progress.

BNP-QCP-7.9, Rev. 8, "Fitup & Cleanliness" states:

Paragraph 6.3.1 (B) -

The responsible craft foreman has assured that the piping interior is clean ,

in accordance with the criteria of Field Construction Procedure (FCP) 6.1.2 and indicate such by signing the back of the fitup cards. '

Contrary to the above, during the past several months numerous proof of cleanliness flushes have been performed on safety-related systems. During these flushes, numerous tools / materials were obtained from inside these systems indicating that these systems were not constructed in a clean condition.

Admission or Denial of the Alleged Violation TVA admits the violation occurred as stated.

Reason for the Violation The violation occurred as the result of failure to follow the procedure BNP-QCP-6.16, governing the installation cleanliness and maintenance of piping systems, by various craftsmen who evidently placed the material / tools in the system or failed to adequately seal the system after cleaning. An additional contributing factor to the violation existed because in some cases the responsible steamfitter craft foremen were not performing i adequate inspection of the piping interior cleanliness as required by BNP-QCP-7.9 and BNP-FCP-6.1.2.

. Page 2 Corrective Action Taken and Results Achieved It is our opinion that most of the contaminants cited were introduced into these systems before November 1980 (issuance of procedure BNP-QCP-6.16 RO,

" Cleanliness Control During Piping System Installation"). Therefore, actions which TVA has taken since November 1980 to alert crafts to the necessity and requirement of cleanliness in the piping systems would only be reflected in future proof of cleanliness tests. Discussions with QC inspectors have indicated that crafts have improved their performance in maintaining the piping systems in a clean condition and adhering to the requirements of BNP-QCP 6.16. TVA recognizes that it is undesirable to construct a system in an unclean condition. However, ANSI N45.2.1 (Cleaning of Fluid System and Components) states that the installation process represents an opportunity for the introduction of contaminants into clean system piping components regardless of the control imposed to minimize contamination. Therefore, cleanliness flushes are employed to remove any contamination that may have inadvertently been introduced to the system. All systems cited, in addition to all other safety-related systems requiring cleanliness control, will be cleaned in accordance with the applicable procedures by performing proof of cleanliness flushes. The systems will be flushed according to these procedures until the acceptance criteria of ANSI are satisfied.

Steps Taken to Avoid Further Violations All steamfitter craftsmen, including the foremen, have been reinstructed in the necessity of proper cleaning and maintenance of piping system components. The reinstruction was performed by issuance of a memorandum from the steamfitter craft superintendent, which stated that any individual caught in violation of the requirements of BNP-QCP6.16 would receive appropriate disciplinary action. The memorandum was issued May 20, 1982.

Date of Full Compliance Full compliance for the cited systems will be achieved upon certification that they have been cleaned to their proper level of cleanliness, which TVA expects by June 1, 1983 Other safety-related systems will be in compliance after certification of cleanliness which will occur before preoperational testing of each system.