ML20076F461
| ML20076F461 | |
| Person / Time | |
|---|---|
| Site: | Bellefonte  |
| Issue date: | 05/12/1983 |
| From: | Mills L TENNESSEE VALLEY AUTHORITY |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20076F448 | List: |
| References | |
| NUDOCS 8306140125 | |
| Download: ML20076F461 (5) | |
Text
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TENNESSEE VALLEY AUTHORITY,
.qj,z g C Q p (3} A CH ATTANOOGA. TENNESSEE 374ol 400 Chestnut Street Tower II
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83 MAY 17 A 8 : 46 May 12, 1983 U.S. Nuclear Regulatory Commission Region II Attn:
Mr. James P. O'Reilly, Regional Administrator 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30303
Dear Mr. O'Reilly:
BELLEFONTE NUCLEAR PLANT UNITS 1 AND 2 - RESPONSE TO VIOLATIONS 50-438/83-05-01, 50-439/83-05-01, INCOMPLETE QC INSPECTION RECORDS -
50-438/83-05-02, 50-439/83-05-02, FAILURE TO FOLLOW PROCEDURES FOR VALVE INSPECTIONS 438/83-05-03, 50-439/83-05-03, FAILURE TO FOLLOW PROCEDURES AND DRAWINGS FOR INSPECTION OF MECHANICAL EQUIPMENT This is in response to D. M. Verrelli's letter dated April 12, 1983, report numbers 50-438/83-05, 50-439/83-05 concerning activities at the Bellefonte Nuclear Plant which appeared to have been in violation of NRC regulations. Enclosed is our response to the citations.
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, TENNESSE VALLEY AUTHORITY
. M. Mills, Manager Nuclear Licensing Enclosure cc:
Mr. Richard C. DeYoung, Director (Enclosure)
Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C.
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PDR ADOCK 05000438 O
PDR An Equal Opportunity Employer
BELLEFONTE NUCLEAR PLANT UNITS 1 AED 2 RESPONSE TO SEVERITY LEVEL V VIOLATION 50-438/83-05-01, 50-439/83-05-01 INCOMPLETE QC INSPECTION RECORDS Description of Deficiency 10 CFR 50, Appendix B, Criterion XVII, as implemented by TVA-Bellefonte FSAR Section 17, Paragraph 17.1.B.17, requires in part that sufficient records shall be maintained to furnish evidence of activities affecting quality. The records shall include data such as qualification of personnel. Bellefonte QCP 2 3, Paragraph 8.3 requires that records of personnel must be completed and maintained for previous certification and experience.
Contrary to the above, sufficient records affecting quality such as qualifications of QC personnel were not being maintained in that the records of five QC inspectors did not contain supportive documentation to past experience.
Admission or Denial of the Alleged Violation TVA admits the-violation occurred as stated.
Reason for Violation Failure of the Unit Training Officer (UT0) to make sure that all required supportive documentation (specifically, the nondestructive examination (NDE) Personnel Qualification Summary), as required by Quality Assurance Procedure (QAP) 2.3, paragraph 8.3, is prepared and placed in the individual certification records.
Corrective Steps Which Have Been Taken and the Results Achieved Upon identification of the discrepancy, an humediate search of all NDE personnel files was initiated. Upon investigation, it was discovered that eleven (11) personnel records did not contain the required NDE Personnel Qualification Summary. Quality Control Inspection Report (QCIR) No. 28,259, dated December 3, 1982, was issued with the following plan. " Complete NDE Qualification Summary for available personnel and route to Quality Control Records Unit (QCRU) for retention in NDE Certification Files." NDE Qualification Summaries were prepared and placed in the Certification Records of the affected personnel except for three (3) NDE personnel who had since left TVA's employment. The inability to prepare a NDE Qualification Summary for the three personnel who had left TVA employment does not affect the integrity of any inspections perforined by these individuals as they were certified in accordance with SNT-TC-1A recommended guidelines. QCIR No. 28,259 was completed and closed on December 6,1982.
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Corrective Steps Taken to Avoid Further_ Violation A checklist has been prepared and issued to the unit training officer, which delineates all documentation requirements for NDE personnel, as required per QAP 2 3 (now QATTP III-2), for use when processing new or transferred NDE personnel into the Welding Quality Control Unit.
Date When Full Compliance Will Be Achieged, Full compliance was achieved on December 6,1982.
Response to Severity Level V Violation - 50 438/83-05-02, 50-439/83-05-02 Failure to Follow Procedures for Valve Inspections 10 CFR 50, Appendix B, Criterion V as implemented by TVA-Bellefonte PSAR Section 17, Paragraph 17.1.B.5, requires in part that activities affecting quality be accomplished in accordance with instructions, procedures, or drawings. Bellefonte QCP 6.9, Paragraph 7.1.d requires valves to be installed with the operator in the proper direction and l
attitude as shown on the location drawing.
Contrary to the above, activities affecting quality were not being accomplished in accordance with documented instructions, procedures or drawings in that QC accepted valve Nos. 1KC-VTAC-44A and 1KC-1FCV-313A were not installed with the operator in the proper direction and attitude as shown on the location drawing.
Admission or Denial of the Alleged Violation TVA admits the violation occurred as stated.
Reasons for the Violation TVA's Division of Construction's (CONST) Mechanical Quality Control failed to follow QCP 6.9 by inspecting and accepting valve installation without the approved drawing changes showing the new orientation of the subject valves. The new orientation resulted from a change to facilitate hanger installation. The 00NST's Mechanical Engineering Unit had verbal approval for the new orientation from the Division of Engineering Design (EN DES) but failed to follow up with an approved field change request (FCR) to have the appropriate drawing changed, as required in QCP 10.2.
Corrective Steps Which Have Been Taken and the Results Achieved QCIR 28,274 dated December 3, 1982, was initiated to document the incorrect valve orientation without FCR approval.
Nonconformance Report (NCR) 2274 dated February 23, 1983, was initiated due to the QCIR not being reviewed by the responsible CONST engineering personnel for significance within the limits of BNP-QCP-10.4. NCR 2274, identifying the incorrect valve orientation, was resolved as follows:
Field Change Request (FCR) M4626 dated February 28, 1983, was issued to accept the valve installation as installed. The FCR was approved by EN DES on March 1,1983 As a result of the incorrect valve orientation, TVA has committed to random sample 315 out of 13,964 valves previously installed and Mechanical Quality Control inspected in accordance with MIL STD 105D.
Any deficiencies identified during the sampling program, will be documented and corrected by separate NCR.
Corrective Steps Taken to Avoid Further Violation In accordance with NCR 2274, the mechanical engineering and Mechanical Quality Control inspection units are to be retrained in accordance with QCP-10.2 and 10.4.
In addition, the Mechanical Quality Control inspection unit will be retrained in accordance with QCP-6.9.
Efforts are underway to generate a standard operating procedure to evaluate inspection training effectiveness. A follow-up program will also be implemented.
Date When Full Compliance Will Be Achieved Full compliance will be achieved on August 30, 1983 Response to Severity Level V Violation 50-438/83-05-03, 50-439/83-05-03.
Fialure to Follow Procedures and Drawings for Inspection of Mechanical Equipment 10 CFR 50, Appendix B, Criterion V as implemented by TVA-Bellefonte FSAR Section 17, Paragraph 17.1.B.5, requires in part that motivities affecting quality be accomplished in accordance with instructions, procedures, or drawings. Bellefonte QCP 6 3, Paragraph 6.2.e, item 2, requires that embedded anchor bolts be tightened per EN DES requirements and various equipment drawings give the appropriate details required.
Contrary to the above, activities affecting quality were not being accomplished in accordance with documented instructions, procedures or drawings in that the foundation attachment areas of four tanks, four loose nuts were found, a washer was missing, two washers were not dimensioned per detail drawing, a neoprene pad was not installed per drawing and a clearance for the sliding end of one foundation did not meet drawing requirements.
-Admission or Denial of the Alleged Violation TTA admits the violation occurred as stated.
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~4-Reason for the Violation The responsible construction mechanical engineer inadvertently failed to properly list all applicable vendor drawings on the Sequence Control Charts (SCCs) which are utilized in installing the storage tanks. The detailed vendor drawing 5-4148 A and B, sheet 9, which delineates material and installation requirements should have been listed on the SCC. The inadvertent omission of sheet 9 resulted in the craft being unable to install the hardware correctly.
The storage tinks were inspected based upon the SCC, which did not list sheet 9 as as an applicable vendor drawing, and QCP 6.3 " Mechanical Equipment." Therefore, the tanks were accepted on July 21, 1977, based upon inadequate documentation (omission of sheet 9).
Procedures were not in place at the time the SCC was written to ensure that the inspector received all the necessary applicable documentation.
Corrective Steps Which Have Been Taken and the Results Achieved QCIR 26,916 dated December 3, 1982, was issued to document inadequato installation on tanks 1NB-MYMK-022 and 2NB-MTMK-023 The corrective action was to obtain correct mounting hardware and drawing requirements.
QCIR 26824 dated October 26, 1982, was issued to document discrepancies for tanks 1NB-MTMK-031,030 and 2NB-MTMK-032,033. The corrective action was to initiate SCCs to install material pcr the drawing, tighten the nuts, and generate an NCR to address the gaps in the supports.
NCR 2364 dated April 25, 1983, was issued to address lack of sufficient gap on foundation or sliding support on tanks 1NB-MTMK-030,031 and 2NB-MTMK-032,033. This item is presently no complete.
(Note that all the Reactor Coolant Distillant Storage Tanks were inspected in accordance with current QC requirements and any deficiencies that were uncovered noted in QCIR 26,824 and NCR 2364.)
Corrective Steps Taken to Avoid Further Violation Revisions 2 and 3 of QCP-6.3 adequately address requirements for installation and inspection; however, equipment installed and inspected under revisions 0 and 1 are suspect at this time. Mechanical Quality Control will inspect all equipment presently accepted under revisions 0 and 1 of QCP-6.3 and determine if any problems exist. Based upon the results of the investigation, further action (i.e., rework) may be necessary. Any discrepancies found will be documented and corrected by separate NCR.
Additionally, QCP 10 36 revision 0, " Sequence Control Chart" was implemented on July 30, 1981, which now require that a QC group leader perform a data review for completeness to ensure that all required inspections have been adequately performed and documented.
Date When Full Compliance Will Be Achieved Full compliance will be achieved by August 30, 1983.
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