ML20071L585

Addl Response to NRC Re Violations Noted in IE Insp Repts 50-438/83-02 & 50-439/83-02.Item 8 of Noncompliance in Area of Flushing & Hydrostatic Testing & Related Procedures Disputed

ML20071L585
Person / Time
Site:	Bellefonte
Issue date:	04/18/1983
From:	Mills L TENNESSEE VALLEY AUTHORITY
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20071L555	List: ML20071L585 ML20071L621
References
NUDOCS 8305270597
Download: ML20071L585 (3)

Text

v 6

TENNESSEE VALLEY AUTHORITY c pg ,,,

CH ATTANOOG A TENNESSEE 374ol -

l

~v. . ,. 4 ,

400 Chestnut Street Tower II , ,

April 18, 1983 0021 P il 01 U.S. Nuclear Regulatory Conunission Region II Attn: Mr. James P. O'Reilly, 3egional Administrator 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30303

Dear Mr. O'Reilly:

BELLEFONTE NUCLEAR PLANT UNITS 1 AND 2 - RESPONSE TO VIOLATION 50-438/83-02-04, INADEQUATE CONSTRUCTION OPERATING INSTRUCTIONS This is in response to D. M. Verrelli's letter dated February 25, 1983, report numbers 50-438/83-02, 50-439/83-02 concerning activities at the Bellefonte Nuclear Plant which appeared to have been in violation of NRC regulations. The response to this violation was delayed. This delay and request for extension was communicated to Paul Fredrickson (NRC-0IE RII) by telephone on March 30, 1983 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

\ >

. M. M ^

L. M. Mills, nager Nuclear Licensing Enclosure cc: Mr. Richard C. DeYoung, Director (Enclosure)

Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C. 20555 B305270597 830429 PDR 0 ADDCK 05000438 PDR An Equal Opportunity Employer

ENCLOSURE BELLFONTE NUCLEAR PLANT UNIT 1 RESPONSE TO SEVERITY LEVEL V VIOLATION 438/83-02-04 INADEQUATE CONSTRUCTION OPERATING INSTRUCTIONS 10 CFR 50, Appendix B, Criterion V and the accepted QA Program (TVA-TR75-1A, Revision 5) Section 17.1A.5 require that activities affecting quality be accomplished in accordance with procedures and that these procedures include appropriate quantitative acceptance criteria.

TVA's Quality Assurance Program Policy (QAPPS) Rev.-2, Paragraph 3 states the following: " Instructions, procedures, or drawings shall include appropriate quantitative acceptance criteria."

Also, the licensee's accepted QA Program commits to Regulatory Guide 1.116-1976 which endorses ANSI N45.2.8-1975. Section 2.9 of this standard requires that procedural engineering limitations for installation, inspection and test procedures include the enEi neering limitations and requirements from manufacturers' instruction manuals.'

Contrary to the above, procedures do not include appropriate acceptance criteria and requirements in that four construction operating instructions (1KE-01,1NV-01,1NV-02 and 1NV-03) do not include all of the quantitative requirements, i.e., precautions and limits, which are specified in vendor's technical documents Weir Pumps Limited Publication No. PSP 126 and Babcock and Wilcox (B&W) Technical Document No. 67-1003781-001. (Unit 1)

Response

Admission or Denial of the Alleged Violation TVA denies the alleged violation.

Although we recognize that we have had programmatic problems in the area of a

flushing and hydrostatic testing of safety-related systems which relate to content and review of procedures for those activities, we do not consider this l area to be similarly affected for the reasons cited below:

A. With regard to the specific finding that construction operating instructions (COI) 1NV-901, 1NV-02 and 1NV-03 do not contain the following requirement from the B&W Technical Document: " Ensure that the suction valve and bypass orifice isolation valves are open prior to startup . . . NOTE: Due to close internal tolerances, operation of this pump without suction for even a few seconds will destroy the pump l

internals." TVA has the following response:

1 1.Section III. Precautions, paragraph D, of the referenced I COIs states: " Ensure that the suction valve is open prior to startup. NOTE: Due to close internal tolerances, operation of this pump without suction for even a few seconds will destroy the pump internals."

d .

• 2. Tha requir: ment that tha "byptco orifica icolttion velvas ara open prior to startup" would normally be ensured by the inclusion of the proper alignment of the bypass line in the valve alignment checklist. At the time the referenced COIs were prepared, verbal agreement was obtained from the site B&W representative to operate the pumps with the bypass isolation valves closed. Subsequent to pump operations under this verbal agreement, additional concern for system overpressurization and pump "deadheading" was raised. TVA asked B&W for written approval to operate the pumps with the bypass isolated and B&W refused. (Further pump operation will be conducted with proper orifice isolation valve alignment.)

B. With regard to the specific finding that COI IKE-01 does not contain the seven periodic inspections and adjustments from the "

Weir Pump Limited Publication, TVA has the following response:

The pump running checks are highly conservative vendor reconsendations which may not be absolute requirements in every application of a similar Weir pump. TVA's Division of Engineering Design (EN DES) reviews vendor manuals and provides equipment operating requirements via its system design as shcwn on design drawings, i.e., pump pressures and motor current and bearing temperatures are monitored by EN DES required instrumentation. This instrumentation is documented as being available for service through the Operating Release Procedure BNP-QCP-9 1. Observation of these EN DES provided instrument readouts / alarms is a normal operating practice. Such recommen-dations as checking for leaks or excessive vibration are also a part of normal operating practices.

TVA does agree that some vendor recommendations are essential, ,

but feels that they have been met through current EN DES normal operating practices and the Operating Release procedures.

Therefore, the additional requirements in COIs are not needed. ,

C. With regard to the generic requirement that procedures include .

" appropriate quantitative acceptance criteria," TVA, feels that acceptance criteria are required in situations wherei.e., an during acceptable / unacceptable determination can be made, inspection and tests. COIs are not part of the TVA construction testing or inspection program and contain no inspection or

- -testing requirements but only operating instructions. Therefore,

,e we feel that quantitative acceptance cannot be supplied to COIs.

D. With regard to the ANSI requirement that " procedural engineering limitations for installation, inspection and test procedures include the engineering limitations and requirements from manufacturers' instruction manuals," as stated above, COIs are not used for installation, inspection or testing.

,. #_ , ~ . _ , - . - _ _ _ . _ _ _ _ _ _ . , . _ - - _ _ , _ _ . _ . _ . , . _ _ _ _ . - _ _ _ _ . . _ .- , __