ML20086T911
| ML20086T911 | |
| Person / Time | |
|---|---|
| Site: | Bellefonte  |
| Issue date: | 12/13/1983 |
| From: | Mills L TENNESSEE VALLEY AUTHORITY |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8403070089 | |
| Download: ML20086T911 (2) | |
Text
- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
I.
r-7 o
o
, TENNESSEE VALLEY AUTHORITY CH ATTANOOGA, TENNESSEE 374ol 400 Ches nut Street Tower II g ? \\ ' 7.
December 13, 1983 U.S. Nuclear Regu'latory 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 - REVISED RESPONSE TO VIOLATION
- 438/83-23 HVAC DUCTWORK SUPPORTS TVA had originauy responded to R. C. Lewis' letter dated October 5,1983, report numbers 50-438/83-23, 50-439/83-23 concerning activities at the Bellefonte Nuclear Plant which appeared to have been in violation of NRC regulations by our letter dated November 3,1983 Enclosed is our revised response to violation 50-438/83-23-05.
If you have any qusstions concerning this ruatter, 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 oc:
Mr. Richard C. DeYoung, Directet- (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 Atlanta, Georgia 30339 8403070089 831213 gDRADOCK 05000438 PDR
)
l 1983-TVA SOTH ANNIVERSARY An Equal Opportunity Employer y [d/
W i
~ _ _ _ _ _ _ _ _ _ _ _ _
e' ENCLOSURE BELLEFONTE NUCLEAR PLANT UNIT $
REVISED RESPONSE TO SEVERITY LEVEL V VIOLATION 50-438/83-23-05 HVAC DUCTWORK SUPPORTS Description of Defiency 10 CFR 50, Appendix B, Criterion V and the accepted QA Program (TVA-TR-75-1 A, Revision 5) section 17.1 A.5 require that activities affecting quality be accomplished in accordance with drawings. Process Specification V0.C.I.I (a), Paragraph 3.7.3 states the follcuing part:
" Members distorted by welding may be straightened by mechanical means or by carefully supervised application of a limited amount of localized heat."
TVA's Bellefonte Quality Control Procedure BNP-QCP-10.4, Rev. 9, Paragraph 5.2 states the following: " Engineering and inspection unit representatives initiate QCIRs and NCRs, ensure identification of nonconforming items, and verify completed corrective ac tion."
Contrary to the above, the resident inspector noted that the ironworker craft had beaten and straightened (via sledge hammer) several HVAC supports. These supports were heated without any direct measurements. In addition, both mechanical QC and engineering personnel were aware of these activities; however, a QCIR or NCR was not generated. Also the ironworkers had not been trained in Bellefonte's Quality Control Procedure BNP-QCP-6.7 which they were using to perform the work (Unit 1).
TVA Response 1.
Admission or Denial of the Alleged Violation Since this violation addresses three factors which contributed to the violation, this response will address these items individually.
1.
TVA admits the portion of the violation occurred as 9tated with regard to the failure to properly train the ironworkers in QCP-6.7 (HVAC Duct Work Installation).
2.
TVA denies the portion of the violation occurred as stated with regard to the method of straightening used on the cited supports.
Reason: The existing provisions within the procedures currently approved allow the use of the sledge hammers and the heat application methods described in the violation. The limited amount of heat required to straighten the hangers was applied using normal construction practices by a qualified craftsman who has the job training an experience necessary to observe and control this d
process. The Process Specification delineates that a dull red color may be achieved during heat application and TVA feels that this guidance is adequate for its craftsmen.
.