ML20077B029
| ML20077B029 | |
| Person / Time | |
|---|---|
| Site: | Bellefonte  |
| Issue date: | 06/27/1983 |
| From: | Mills L TENNESSEE VALLEY AUTHORITY |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20077B022 | List: |
| References | |
| NUDOCS 8307220526 | |
| Download: ML20077B029 (7) | |
Text
.
4
.g TENNESSEE VALLEY AUTd5Pf9ATP.EGON 'I CH ATTANOOGA. TENNESSEC NdO be 400 Chestnut Street Tower II 3""$37JUPP91 A 8 : 10 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 50-438/83-11-01, 50-439/83-11-01, INADEQUATE QC INSPECTOR EDUCATION AND EXPERIENCE REQUIREMENTS 438/83-11-02, 50-439/83-11-02, INADEQUATE STORAGE AND PROTECTION OF EQUIPMENT IN-PLACE 438/83-11 DISPOSITION OF NONCONFORMANCES This is in response to R. C. Lewis' letter dated May 27, 1983, report numbers 50-438/83-11, 50-439/83-11 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 concerninb 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, hanager Nuclear Licensing Enclosure cc: Mr. Richard C. DeYoung, Director (Enclosure)
Office of Inspection and Enforcement
.U.S. Nuclear Regulatory Comission Washington, D.C.
20555 8307220526 830712 PDR ADOCK 05000438 o
PDR An Equal Opportunity Employer
' l ENCLOSURE BELLEFONTE NUCLEAR PLANT UNITS 1 AND 2 RESPONSE TO SEVERITY LEVEL IV VIOLATION 50-438/83-11-01, 50-439/83-11-01 INADEQUATE QC INSPECTOR EDUCATION EXPERIENCE REQUIREMENTS Description of Deficiency TVA's response dated August 27,.1981, to NRR Generic Letter 81-01 states the licensee's current program is in compliance with Regulatory Position C.6 of Regulatory Guide 1.58, R1.
In accordance with position C.6 if no exception is taken to the education and experience requirements specified therein and in ANSI 45.2.6-1978, these requirements will be followed.
Contrary to the above, on August 29, 1981, TVA's implementing procedure BNP-QCP-10.29, R3, did not define the education and experience requiremenis as specified by ANSI N45.2.6-1978 as modified by Regulatory Guide 1.58, R1 nor does the current revision (Revision 4) of this procedure contain the experience levels equivalent to the subject standard and guide.
Admission or Denial of the Alleged Violation TVA denies the violation occurred as stated.
Position C.6 of Regulatory Guide 1.58, Revision 1, requires that "in addition to the recommendations listed under Section 3 5 of ANSI N45.2.6-1978 for level I, II, and III personnel, the candidate should be a high school graduate or have earned the General Education Development (GED) equivalent of a high school diploma." Revision 4 of Bellefonte BNP-QCP-10.29 does comply with the education requirements stated in position C.6 of Regulatory Guide 1.58, Revision 1 (i.e., BNP-QCP-10.29, Revision 4, requires that all personnel shall have a high school or equivalent education which will be evaluated by the personnel office). TVA took exception to the education and experience requirements discussed in our August 27, 1981, response to generic letter 81-01. Inasmuch as TVA elected to use capability testing, as discussed in ANSI N45.2.6-1978, Section 2.2, in lieu of education and experience requirements, there was no need to define education and experience requirements in BNP-QCP-10.29 Our intention to use the capability opticn was stated in our response to NRC Generic Letter 81-01 in which TVA said in regard to Regulatory Position C.10 of Regulatory Guide 1.58, R1:
"We determine initial capability for the following criterion as defined in our procedure: the candidate's education, experience, training, examination and/or capability demonstration. On-the-job participation in the work discipline is required of all candidates."
TVA reiterated our position in our remarks concerning Regulatory Guide 1.58 in Table 17.1 A-4C of TVA Topical Report TVA-TR75-1, R5.
'~..:..
7
.=.
The TVA program for qualification of inspection, examination, and testing personnel for the construction phase of nuclear power plants is based on (1)
TVA hiring practices which assures employment of candidates who are high school graduates or equivalent, (2) certification by the candidate's supervisor that he possesses the necessary job skills, and (3) satisfactory completion of a written examination on the specific procedure (s) to which inspection or examination is to be performed. Section 6.3 " Qualification /
Training / Certification" of Bellefonte BNP-QCP-10.29, Revision 4, clearly delineates the process by which TVA's Division of Construction (CONST) personnel are qualified for inspection, examination and testing.
d as l
l l
l l
l l
I l
,..w.._..:.-.--.,...-.
-....., ~. - _ _ _.
.,-_m-.-._..,.
4 BELLEFONTE NUCLEAR PLANT UNITS 1 AND 2 RESPONSE TO SEVERITY LEVEL V VIOLATION 50-438/83-11-02, 50-439/83-11-02
-INADEQUATE STORAGE AND PROTECTION OF EQUIPMENT IN-PLACE Description of Deficiency
- 10 CFR 50, Appendix B, Criterion XIII and Bellefonte QCP 10.27, R6, and QCP
' 1.3, R3, require that measures be established to control the storage, cleaning, and preservation of equipment in accordance with the work and inspection instructions to prevent dama'ge or deterioration.
Contrary to the above, the in-place storage of the below listed safety-related equipment was not properly controlled:
- Contract 86163 Motor Operated Valve 1KEIFCV128A in Essential Raw Cooling Water System at location 610A05P for Unit 1.
Covered with dust beneath plastic cover, noted shaft and key corrosion. Screw missing from electrical compartment cover.
- Contract 86163 Motor operated Valve 2KEUAC128A for Unit 2.
Plastic cover partially off. Dusty all over. Shaft and key covered with dust. Screws missing from electrical compartment cover.
- Contract 86133 Auxiliary Feedwater Pump 1CAMPMPIA for Unit 1 in Auxiliary Building. Temperature gauge on pump bearing casing broken.
Flexible cable to Resistance Temperature Detector severely damaged.
(Both damaged items apparently due to nearby construction activities.) Cover partially off of motor. Motor and pump covered with dust. Oil dr ipping from pump near coupling. Trash on top of motor-pump common base.
- Contract 86133 Auxiliary Feedwater Pump 1CAMPMP3Q for Unit 1 in Auxiliary Building. Equipment covered with dust under plastic cover.
Extensive quantity of trash, loose bolts and nuts on top of common base for pump and turbine. Oil noted on the common base near hose connection.
- Contract 86133 Auxiliary Feedwater Pump 2CAMPMP3Q fc:- Unit 2 in Auxiliary Building. Area and equipment wet from dripping water.
l Plastic cover was torn and water leaked through to equipment. Dust on equipment beneath cover. Corrosion noted on common base.
Admission or Denial of the Alleged Violation TVA admits the violation occurred as stated.
l l
I Iep__
~
~
Reasons for the Violation Maintenance inspections are conducted on all safety-related equipment at intervals and to criteria. specified by the responsible engineering unit using the manufacturer's recommendations as a guide. As discussed with the NRC inspector, some of the items in question such as dirt and dust are of a judgemental nature.
However, most of the conditions such as damaged components, loose material, torn plastic, and water leaking on the equipment are definitely nonacceptable c onditions. The cause of these conditions was the failure of the craftsmen to take proper precautions to protect equipment from ongoing construction activity. Normally, these conditions would be noted and corrected at the next scheduled inspection of the equipment.
Corrective Steps Taken and Results Achieved 1.
Motor Operated Valve 1KEIFCV128A ' Equipment was cleaned and recovered with plastic. Screws are purposely not installed. This was explained to NRC inspector.
2.
Motor Operated Valve 2KEVUAC128A - Equipment was cleaned and recovered with plastic. Screws are purposely not installed. This was explained to NRC inspector.
3.
Auxiliary Feedwater Pump 1CAMPMP1A - Equipment was cleaned and recovered with plastic. QCIR 29653 was written documenting damage to equipment. QCIR 30846 was written documenting oil leak in rear bearing.-
4.
Auxiliary Feedwater Pump 1CAMPMP3Q - Equipment was cleaned and recovered with plastic.
5.
Auxiliary Feedwater Pump 2CAMPMP3Q - Equipment was cleaned and recovered with plastic.
Corrective Steps Taken to Avoid Further Violation Beginning with the routine inspections conducted in July 1983, a trend system will be established to report the number of unacceptable conditions by month, which will be documented on Attachment A of BNP-QCP-1 3, to.the craft supervisor responsible for that particular area. This will help the supervisor to place proper emphasis on protection and storage of in-place equipment to the craftsmen in his area when conditions indicate it is needed.
Realizing that complete elimination of problems of this sort in a construction environment is next to impossible, the trend system should indicate when the situation has been reduced to an acceptable level.
Corrective action to resolve any deficiencies by the trend program should be completed, during the first three months of the program.
Date When Full Compliance Will Be Achieved The program for trend deficiencies in the maintenance of equipment will be in place by August 1, 1983 w w: -
.~..
. x..i..
.a
~..~w
. a: a
- a a.
-. a - a -.
BELLEFONTE NUCLEAR PLANT UNITS 1 AND 2 RESPONSE TO SEVERITY LEVEL IV VIOLATION 50-438/83-11-03 DISPOSITION OF NONCONFORMANCES Description of Deficiency 10 CPR 50, Appendix B, Criterion V as implemented by Bellefonte's SAR Section 17.1A.5 requires activities affecting quality to be accomplished in accordance with instructions, procedures, or drawings. Bellefonte QCP 10.4, R8, Paragraph 4.2 requires that a Nonconforming Condition Report (NCR). be written and referred to Engineering Design (EN DES) for. disposition of items that cannot be corrected within the scope and requirements of the specification, drawing, or code.
Contrary to the above, the site encountereia misalignment of incore monitoring system piping problem which they identified in QCIR NO. 2408.
However, instead of writing an NCR on the problem as required thereby getting proper EN DES review and disposition in accordance with procedures, the site personnel conducted a dimensional study on their own and dispositioned QCIR No. 2408 by installing skewed dutchmen without.EN DES approval.
Admission or Denial of the Alleged Violation TVA admits the violation. occurred as stated.
Reasons for Violation TVA's Livision of Construction (CONST) initiated QCIR 2408 to identify the offset / mismatch of incore monitoring system piping. The original disposition of the QCIR was to request from B&W a tolerance for using the subject piping "as is" or reworking the skewed dutchman. The site B&W representative was contacted by informal memorandum, which stated that a primary concern of the skewing was the effect it would have on the insertion and withdrawal of the related incore detector assembly. B&W's site representative responded by stating that TVA should be advised of the requirements of the installation specification and/or any other requirements that pertain to thie area of work. TVA CONST had in possession B&W construction testing specification 08-1134000002-09, Incore Detector Assembly Model' DA7L-1B-1B-IT-IC-118. Pargraph 3 9, Bends, of the specification stated, "The assembly shall be capable of accepting twenty insertion / withdrawal cycles around... an "S" shaped 10 bend... without injury to junction, detectors, or assembly integrity."
The cause of the violation resulted from an erroneous interpretation by the responsible site engineer that the B&W specification in possession could be applied as installation criteria for resolution of the skewed dutchmen and would also satisfy the requirement in BNP-QCP-10.26 R1 which was in effect at the time (eliminating the necesity to initiate an NCR for EN DES disposition as an item which would be corrected within the scope and requirements of the specification).
6 I
hwA > g a ss Ab=.
we
- Josh, h
- 7 g si c.
~
me w_
=
The individual closed the QCIR based on the fact that all dutchmen did satisfy the 10 bend criteria found in the specification.
Corrective Steps Taken and Results Achieved TVA CONST initiated NCR 2352 to document the offset / mismatch of the dutchmen and to allow for EN DES review and disposition of the nonconformance. The NCR was determined significant and has been reported to the NRC under the provisions of 10 CPR 50.55(e).
Corrective Steps Taken to Avoid Further Vi6lation The erroneous interpretations, by the responsible engineering representative, that the B&W specification could be applied for resolution of the NCR, appears to be of an isolated nature. Therefore, no other action to avoid further noncompliance is deemed necessary.
Date When Full Compliance was Achieved TVA was in full compliance on May 3,1983, when NCR 2352 was issued.
h r
1 A m.', - ~ a uw.~..
. n ;- w '
,.,..--,-.-,,,-,--,~~-.n,, - ~, - >-.
.~
-