ML20082L063

Responds to NRC Re Violations Noted in IE Insp Repts 50-438/83-22 & 50-439/83-22.Corrective Actions:Repair of Welds Will Be Accomplished Per Automated Process Control Sys & Tracked by Monitoring Program

ML20082L063
Person / Time
Site:	Bellefonte
Issue date:	10/18/1983
From:	Mills L TENNESSEE VALLEY AUTHORITY
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20082L050	List: ML20082L063
References
NUDOCS 8312050396
Download: ML20082L063 (5)

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. TENNESSEE VALLEY AUTHO 1 ,

y3 CH ATTANOOG A. TENNESSEE 37401 * * 'l. > l /

400 Chestnut Street Tower II" October 18,1 y p } ; t} }

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 UNIT 1 - HESPONSE TO VIOLATIONS a 50-438/83-22 FAILURE TO FOLLOW PROCEDURE FOR WELD INSPECTION -

50-438/83-22 FAILURE TO FOLLOW PROCEDURE FOR HANGER INSPECTION This is in response to D. M. Verrelli's letter dated September 21, 1983, report numbers 50-438/83-22, 50-439/83-22 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, TENNESSEE VALLEY AUTHORITY

\

L. 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. 20555 Records Center (Enclosure)

Institute of Nuclear Power Operations 1100 circle 75 Parkway, Suite 1500 l Atlanta, Georgia 30339 I

8312050396 8 $9 PDR ADOCK 05 PDR 1983-TVA SO ANNIVERSARY An Equal Opportunity Employer

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- ENCLOSURE 4

BELLEFONTE NUCLEAR PLANT UNIT 1

. RESPONSE TO SEVERITY LEVEL V VIOLATION 50-438/83-22-01 FAILURE TO FOLLOW PROCEDURE FOR WELD INSPECTION Description of Deficiency l

10 CFR 50, Appendix B, Criterion V as laplemented by TVA-Bellefonte FSAR Section 17, paragraph 17.1.B.5, requires in part that activities affecting quality be accomplished in accordance with instruction, procedures or d rawings. Bellefonte QCP-7.5, paragraph 7.0 requires that no undersize welds are permitted for fillet welds connections. Bellefonte specification

, 3.M.S.1(e), paragraphs B.1 and B.5, requires that undercut for base material shall not exceed 1/32" and shall not encroach on the required section thickness.

Contrary to the above, activities affecting quality were not being accomplished in accordance with documented instructions, procedures or drawings in that:

1. Hanger 1KC-MPHG-0003, sheet 1, Revision 6 contains undersize welds (fillet weld) for approximately 10 percent of the perimeter at weld joint "b" and 25 percent at weld joint "c".

2. Hanger 1KE-MPHG-0745, sheet 2, Revision 7 contains excessive undercut at two corners of weld joint "b".

1. Admission or Denial of the Alleged Violation i

TVA admits the violation occurred as stated.

2. Reasons for the Violation '

The failure to follow procedure for weld inspections by the welding quality control (WQC) inspectors can be attributed to inattention to detail during performance of the inspections.

3 Corrective Steps Taken and Results Achieved Quality Control Inspection Report (QCIR) 35,796 was generated to identify the undersize fillet welds on hanger 1KC-MPHG-0003, sheet 1, Revision 6. The QCIR was dispositioned to issue repair cards. The repair cards were issued and the QCIR was closed. QCIR 35,795 was generated to identify the base material damage created by excessive grinding on the weld of 1KE-MPHG-0745, sheet 2, Revision 7. The QCIR was dispositioned to issue a repair card. The card was issued and the QCIR was closed. Repair of the welds will be accomplished in accordance with the Automated Process Control System (APC) and tracked by the weld monitoring program.

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- 4 Corractiva Staps Taken to Avnid Furthse Violations An investigation was conducted by the WQC Unit regarding performance of the three inspectors who inspected the unacceptable welds. The investigation consisted of reviewing data previously generated on visual weld examinations performed by the inspectors in the time frame of the unacceptable inspections and reinspecting a sample of accepted inspec tions. Results of the investigation revealed that the unacceptable inspections were of an isolated nature; therefore, no additional corrective steps are necessary.

5. Date When Full Compliance Will Be Achieved Repair of the deficient welds will be accomplished by December 1,'

1983 1

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. BELLEFONTE NUCLEAR PLANT UNIT 1 RESPONSE TO SEVERITY LEVEL V VIOLATION 50-438/83-22-02

, FAILURE TO FOLLOW PROCEDURE FOR HANGER INSPECTION l

Description of Deficiency 10 CFR 50,. Appendix B, Criterion V as implemented by TVA-Bellefonte FSAR Section 17, paragraph 17.1.B.5, requires in part that activities affecting quality be accomplished in accordance with instructions, procedures or d rawings. Bellefonte QCP-6.17, paragraph 6.6.5.2, requires that pipe clamps are propenly installed and tightened around the pipe. Bellefonte construction specification G-43, paragraph 2.2, requires that pipe clamps shall not be installed directly over circumferential welds when such installation can be avoided.

Contrary to the above, activities affecting quality were not being accomplished in accordance with documented instructions, procedures or drawings in that:

1. Hanger 1ND-MPHG-0591, sheet 2, Revision 3 contained two nuts on the pipe clamp bolt that were loose, which caused the connection between the pipe clamps and the sway strut to'become ineffective. As a result, the installed sway strut is not able to perform its intended function.

2. The above hanger had the pipe clamps installed directly over the circumferential weld joint.

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

2. Reasons for the Violation The cited support was inspected and accepted on March 2, 1982. After this date, the clamp portion of the hanger was loosened by unauthorized personnel. The clamp was shifted out of position and in this condition covered the weld to exhibit the condition referenced in the violation. Evidence existse gg support the fact that the clamp

, was in its correct position and met Ell orocedural requirements at the time of inspection. The stud and nut of the cited hanger were match marked with oaint at the time of inspection. Inspection performed which resulted in the violation indicated that the nut and stud did not match at that time. In addition, all QC documentation for the hanger was reviewed and no deviations were found.

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3 Corractiva Stspa Taken and Results Achieved

, QCIR 35803 was generated to document this condition. This support a will be corrected and documentation affected will be revised by completion c' this QCIR.

4. Corrective Steps Taken to Avoid Further Violations Hanger Quality Control has issued a memorandum to all inspectors to alert them to this adverse condition. This memorandum places additional importance on providing surveillance during daily activities to correct these type of deficiencies. All components .

found in unacceptable conditions will be identified by separate QCIRs and corrected.

5. Date When Full Compliance Will be Achieved Corrective action will be complete by December 1,1983 1

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