ML20072U965

Responds to NRC Re Violations Noted in IE Insp Repts 50-438/82-33 & 50-439/82-33.Corrective Actions:Qcir 28102 & Ncr 2110 Initiated to Document Unauthorized Welding, Hangers Rejected & Replacements Fabricated

ML20072U965
Person / Time
Site:	Bellefonte
Issue date:	03/08/1983
From:	Mills L TENNESSEE VALLEY AUTHORITY
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20072U945	List: ML20072U965
References
NUDOCS 8304110477
Download: ML20072U965 (6)

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4 TENNESSEE VALLEY AUTHORIV9'RE020N '

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CH ATTANOOGA. TENNESSEE 37401 400 Chestnut Street Tower II i

March 82198310 A'd 23

, U.S. Nuclear Regulatory Comission Region II

-Attn: Mr. James P. O'Reilly, Regional Administrator 101 Marietta Street, Suite 2900 i Atlanta, Georgia 30303

Dear Mr. O'Reilly:

BELLEFONTE NUCLEAR PLANT UNITS 1 AND 2 - RESPONSE TO VIOLATIONS 50-438,50-439/82-33-02, PLUG WELDING OF ELECTRICAL CONDUIT HANGER, 50-438/82-33-03, SPENT FUEL GATE GUIDES, 50-438,50-439/82-33-01, OVERPRESSURIZATION OF THE CHEMICAL ADDITION AND BORON RECOVERY SYSTEM, AND 50-438/82-33-04, OPERATION OF SAFETY-RELATED' EQUIPMENT This is in response to R. C. Lewis' letter dated February 7, 1983, report numbers 50-438/82-33, 50-439/82-33, concerning activities at the Bellefonte

, Nuclear Plant which appeared to have been in violation of NRC regulations.

Enclosed is our response to the citations.

I 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, i Very truly yours, TENNESSEE VALLEY AUTHORITY L. M. Mills, Apnager Nuclear Licensing

( Enclosure cc: Mr. Richard C. DeYoung, Director (Enclosure)

Office of Inspection and Enforcement j' U.S. Nuclear Regulatory Comission -

l Washington, D.C. 20555

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C304110477 030317

, PDR ADDCK 05000438

O PM An Equal Opportunity Employer

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ENCLOSURE BELLEFONTE NUCLEAR PLANT UNITS 1 AND 2 RESPONSE TO SEVERITY LEVEL IV VIOLATION 50-438, 50-439/82-33-02 PLUG WELDING OF ELECTRICAL CONDUIT HANGER Description of Deficiency 10 CFR 50, Appendix B, Criterion IX and the accepted QA Program (TVA-TR75-1A, Revision 5) Section 17.1 A.9 requires that " Measures shall be established .to assure that special processes, including welding, heat treating, and nondestructive testing, are controlled and accomplished by qualified personn61 using qualified procedures in accordance with applicable codes, standards, specificatic ts, criteria, and other special requirements."

Bellefonte's Quality Control Procedure BNP-QCP-10.13, Rev. 5 requires that all welding shall be performed using qualified detailed weld procedures.

Contrary to the above, on November 29, 1982, the resident inspector noted that the electric fabrication shop had altered seismic conduit hanger (FF-486-16-MK86 SN9) without proper authorization (Unit 1 and 2).

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

Reason for the Violation The violation occurred because the craft welder knowingly failed to follow procedure BNP-QCP-10.13, Weld Procedure Assignment, which requires that all welding shall be performed using qualified detail weld procedures. The welder had been informed of the requirement during welder orientation on April 22, 1982.

Corrective Action Taken and Results Achieved QCIR 28102 and NCR 2110 were initiated to document the unauthorized welding.

The subject hangers were rejected and replacements were fabricated as described

! by the disposition of the NCR.

! Steps Taken to Avoid Further Violations Disciplinary action was taken against the welder in the form of suspension. In addition, upon return from suspension, the welder was reinstructed.in welder orientation on December 23, 1982. '

Date of Full Compliance TVA was in full compliance on January 24, 1983

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, 't l' g i s RESPONSE TO SEVERITY LEVEL IV VIOLATION 50-438/82-33-03 ( , s SPENT FUEL GATE GUIDES i

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Description of Deficiency , ()

, , .. y 10 CFR 50, Appendix B, Criterion V and the accepted QA Program-(TVAL u Revision 5) Section 17.1 A.5 require that activities affecting , quality beTR75-1A, S accomplished in accordance with procedures and drawings. ,

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b ' , mk TVA's Quality' Assurance Program Policy QAPP 3 Rev.1 states,in paya6raph B.4.the )

following: " Work shall not be started on field changes by Construction potil i receipt of oral (to be confirmed later in writing) or written 'auttiorization 1,from ' '

the design group." TVA's Quality Assurance Procedure QAP 3 1 Rev. 6 sta'tes the following in part in paragraph 2.1.A:

i the appropriate DPO representative prior to starting work. . .". Bellefonte "FCRsshallbeapprovedorauthSrizedby{

Quality Control Procedure BNP-QCP-10.2 paragraph 6.3.5 statec the following in > ,

1 part: "FCRs shall be approved by the appropriate Design Project'0rganization *, 'I before construction pertinent to the change starts." .f

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Contrary to the above, between October 8 and 15, 1982, the resident 7noted that}; j the system engineer in the mechanical engineering unit had issued a work) release '

to slot the spent fuel gate guides without receiving EN DES concurrence (FCR) as required by TVA's Procedures (Unit 1).

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(} i Admission or Denial of the Al eged Violation t. < s F . t' q TVA admits the violation occurred as stated. -

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responsible system engineer and his assistant. The system engineer discussed; /- e the problem with the appropriate design engineer and obtained informal ,  ; j concurrence to perform the modification. The assistant was directed /to issue a.f= , l work release and process-the PCR; however, he understood the engineer to say l , ' , '? l that the FCR had been processed. b N d' o As a result, the FCR was never processed.

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QCIR 30810 was written to document the performance of the modificatiobhtithot/cc ' 'O FCR-EN DES approval. FCR M-4605 was written to obtain approval for tneS * ,,

modification and add the change to the applicable drawing. ' ' ,

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,' , l Steps Taken to Avoid Further Violations

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AllMechanicalEngineeringUnitpersonnelwereretrainedinsiteQAprocedure[

l BNP-QCP-10.2, Drawing Control, by March 7, 1983 ,(

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Date of Full Compliance l s' t'

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i1 TVA was in full compliance on March 1,1983 ,

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5 RESPONSE TO SEVERITY LEVEL IV VIOLATION, 50-438,50-439/82-33-01 OVERPRESSURIZATION OF THE CHEMICAL

<>, ADDITION AND BORON RECOVERY SYSTEM  ;

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• Description of Deficiency

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? 10 CFR 50, Appendix B, Criterion V and the accepted QA Program (TVA-TR75-1A, 3

,0 ) Section 17.A.5 require that activities affecting quality be

.k,.I Revision 5 accomplished in accordance with procedures and drawings. Bellefonte Q

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/ y Control Procedure BNP-QCP-10.26 Rev. 4, paragraph 6.5 states the following:

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' the concern is deemed to be a reportable nonconformance, the ACE initiates appropriate action through the engineering unit supervisor and unit personnel 9

[' ']f f' ,q + for generation of a Nonconforming Condition Report (NCR) per BNP-QCP-10.4.

' (NOTE: the time period from the identification of a deficiency until the Construction Engineer's determination of significance on reportable 4

.nonconformances should not exceed eight (8) calendar days). If the final l' a ' disposition of the QCIR is to initiate a NCR then the QCIR may be completed at 1

ff, this time per paragraph 6.9." On October 11 and 30, 1982, the Chemical Addition Both instances are reportable

( ;and Boron Recovery System was overpressurized.

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, Contrary to.the above, activities affecting quality were not accomplished in

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V y Mccordance with procedures in that NCRs were not generated for both

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overk pressurization instances, as required by BNP-QCP-10.26, until after they

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were identified by the resident inspector on November 18, 1982.

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' TVA admits the violation occurred as stated.

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F, bN $ [The first overpressurization occurred on October 11, 1982. QCIR 26345 was

! -[( l L initiated on October 14, 1982, the unit supervisor reviewed the QCIR and i

/i[determinedittobenon-significant.

f .gt y.M j The second overpressurization occurred on October 30, 1982. QCIR 27270 was C' "

JI initiated on November 3, 1982. The assistant construction engineer reviewed the p./{' i QCIR and determined it to be non-significant.

The responsible individual Q[ y, '"Both QCIR3 were dispositioned to initiate an NCR.

considered the eight (8) calendar day time to be invalid because of this non-4

('L , (f 3 sMnificant determination and did not take innediate steps to process the NCRs.

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'3., t.m M* W I[CorrectiveActionTakenandResultsAchieved s f ; MCR 20h0 was initiated on November 12, 1982 to document the first overpressuri-

' ' NCR 2089 was initiated on j

f zation and was November 19, 1982 determined non-significant.and was determined to be significant due to th J. ~  : nature of the nonconformance in' addition to the initiation of stop work order

'O _SWOO8 on the same day.

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Steps Taken to Avoid Further Violations Based on the evaluation of flushing overpressurizations during the investigation of stop work order SWOO8, all future overpressurizations which occur during flushing operations that exceed the hydrostatic test pressure of the applicable portion of the affected system will be considered potentially significant conditions adverse to quality and processed accordingly.

Date of Full Compliance TVA was in full compliance on November 19, 1982.

RESPONSE TO SEVERITY LEVEL IV VIOLATION 50-438/82-33-04 OPERATION OF SA?ETY-RELATED EQUIPMENT Description of Deficiency 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 drawings. Also, paragraph 4.6 of ANSI N45.2.8-1975, committed to by the licensee, stated the following in part:

" Temporary use of equipment or facilities to which this standard applies that are to become part of the completed project may be desirable. Authorization of such usage shall be as provided for in the contract or by written approval from the responsible organization. Such temporary use shall not subject the equipment or system to conditions for which they were not designed.

The temporary use authorization shall include: (1) conditions of use or operation; (2) maintenance requirements; and (3) inspections and tests as ,

required to maintain operability and quality during period of temporary use of the item. When temporary use is completed, conditions of temporary use shall be evaluated to verify that the permanent plant equipment continues to satisfy the specified requirements."

Contrary to the above, between November 5 and 12, 1982, and on October 8, 1982, the resident noted that safety-related components, specifically several Essential Raw Cooling Water pumps and Borated Water Recirculation Pump 1A, in temporary use, were being operated without an approved TVA procedure or operation (Unit 1).

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

l Reason for the Violation The violation occurred because TVA did not have a QA procedure to govern the operation of safety-related equipment on a temporary basis.

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Correctiv7 Action Teken rnd R Multa Achicved BNP-QCP-9.5, Construction Operating Instruction (COI), was issued on December 17, 1982 to provide a method to be used when COIs are required during the interval between the completion of construction testing and the eventual transfer of the component to the Division of Nuclear Power.

Steps Taken to Avoid Further Violations All future operation of safety-related components that is within the scope of BNP-QCP-9 5 will require initiation of an approved COI.

' Date of Full Compliance TVA was in full compliance on December 17, 1982.

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