ML20093F278
| ML20093F278 | |
| Person / Time | |
|---|---|
| Site: | Bellefonte  |
| Issue date: | 02/10/1984 |
| From: | Mills L TENNESSEE VALLEY AUTHORITY |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20093F216 | List: |
| References | |
| NUDOCS 8407180313 | |
| Download: ML20093F278 (5) | |
Text
{{#Wiki_filter:i TENNESSEE VALLEY AUTHORITY (dWh'e"[t20hItr"eTtTcheYE February 10, 1984 U.S. Nuclear Regulatorggr[rgM1otA 8 * ] l 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 - 50-438/83-31-01, 50-439/83-31 MAINTENANCE COVERS ON SOLID STATE CABINETS, 50-438/83-31 ORIENTATION OF ASCO SCLEN0ID VALVES This letter is in response to R. C. Lewis' letter dated January 4,1984, report numbers 50-438/83-31, 50-439/83-31 concerning activities at the Bellefonte Nuclear Plant which appeared to have been in violation of NRC regulations. Enclosed is our response to the citations. As discussed with NRC-0IE Inspector P. E. Fredrickson on January 13, 1984, TVA will submit our response to the programmatic aspects of the violations by March 5,1984. A one-week extension for the submittal of this msponse was also discussed with Inspector Fredrickson on February 1,1984. 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 am complete and true. Very truly yours, TENNESSEE VALLEY AUTHORITY M1 - L L. M. Mills, Manager Nuclear Licensing Enclosure cc (Enclosure): Mr. Richard C. DeYoung, Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Records Center Institute of Nuclear Power Operations 1100 Circle 75 Parkway, Suite 1500 Atlanta, Georgia 30339 8407180313 840404 {DRADOCK05000 g ~
1 ENCLOSURE BELLEFONTE NUCLEAR PLANT UNITS 1 AND C RESPONSE TO SEVERITY LEVEL IV VIOLATION 50-438/83-31-01, 50-439/83-31-01 MAINTENANCE COVERS ON SOLID STATE CABINETS Description of Deficiency 10 CFR 50, Appendix B, Criterion XIII and the accepted QA Program (TVA-TR75-1A, Revision 5) Section 17.1.13 require that measures shall be established to control the handling and storage of material and equipment in accordance with work and i,nspection instructions to prevent damage or deterioration and, when necessary for particular products, that special environments, such as temperature levels, shall be specified and provided. BNP QCP,-1 3, Revision 4, requires the Responsible Engineering Unit to stipulate the environmental conditions mquired during the installation of solid state equipment after reviewing vendors mar als for the requirements. Consolidated Control Corporation, for solid state equipment procumd under Contract No. 85550, states that the equipment is mted for a temperature environment of 50 - 104 4 with a normal temperature of 75 4. Contrary to the above, special temperatum environments were not ~ provided in that on November 8,1983 solid state control cabinets in train A and B instrument rooms were found to be energized with their heat dissipation louvers covered and the metal exterior of the cabinet very hot to the touch and exceeding the 1044 maximum temperatum. TVA ResDonse Admission or Denial of the Alleaed Violation TVA denies the violation occurred as stated. The plastic covers in question were installed to prevent dirt and dust from construction sotivities from entering the cabinets in accordance with vendor requirements. These covers actually had slits cut in them at the top and were also open at other locations at the top. In addition, the penetrations opening into the bottom of the cabinets allow some passage of air. Therefore, them was in fact some convoetive cooling occurring at the time the inspector identified the problem. Although the technical manual states that the solid state control system (SSCS) cabinets are designed to function continuously in a 50-104 4 envirorument, the temperature limits wem modified through Contract Change No. 41 on September 1,1981 to inomase the range to 50-1200F. The upper limit (1200F. environment) is the ambient temperature limit around the cabinet, which implies the cabinet interior and surface would exceed 1204 when the ambient temperatum is near the limit. Discussions with the vendor have revealed that the components subject to damage due to high temperature are the integrated circuit (IC) chips Wiich are acceptable to 1604. .s. ~< I f s [" -j r i
a m 7r.. r, '- x c,..o - .. s Although tas'tsmp;;ruture of tha.cabir.et suz face could hava-exceeded 10ricp ~ duo to t.hp GlEctrically gengrated h7.st trapped by the covers, there is rb tbsoluts waf 'of dctsrmining t.ho-cabinst internal and surface tempsratures at the time ni'. (he inspectidn. - However, T7A nas performed a simulation of this "' - 'cendition D civaring a cabinet'in unit 2 operating it for 20 hours, then taking tempsra'DAie measurementiat variou.s locations. The location of the s mep'$uring thermocouple and the corresponding temperature measured appear e n below? AN,' Location Temperature s 1. 1.ir temperat re bet'.rten cir uit 105.20F boards inside cabinet.. .n
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y '2. Surface temperathre on muinet. 103.7 F + - 3.' $1r temperat6re nesi 'bcards at' top of 101 90F ,N - Sabinet. s, Based on the abovi ~ data, TVA does notlbelieve that the vendor requirements for a 1200F maxi:mim environ' ment were violated. TVA believes that existing conditions, eveFwith the plastic covering in place, allowed sufficient heat transfer to met thesintent of the 1200F envir;onment limit while protecting the equipment' from' dontandnation. - Additionally, no erratic or spurious .. operatiorror component fhilures"in the SSCS cabinets have been identified N which would suggest. contponent. damage due to excessive temperatures. m
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BELLEFONTE NUCLEAR PLANT UNIT 1 RESPONSE TO SEVERITY LEVEL IV VIOLATION 50-438/83-31-02 ORIENTATION OF ASCO SOLENOID VALVES Description of Deficiency 9 10 CFR 50, Appendix B, Criterion V, and the accepted QA program (TVA-TR75-1A, revision 5), Section 17.1 5, requires that activities affecting quality be prescribed and accomplished in accordance with procedures and drawings and ~ that these procedures and drawings include appropriate quantitative and qualitative acceptance criteria. ASCO 3-and 4-way solenoid valve catalog No. NP-1 states that the Model No. 206-380 solenoid valve must be mounted with the solenoid vertical and upright. Contrary to the above, activities affecting quality were not prescribed and accomplished in accordance with procedures and drawings containing appropriate acceptance criteria, in that the ASCO solenoid orientation requirement is not described in any Bellefonte installation and inspection procedure or drawing and, in that the operators on containment isolation valves INV-IFSV-152 and INV-IFSV-140, were mounted in a position that oriented the model No. 206-380 solenoid in a horizontal position. 1. Admission or Denial of Alleged Violation TVA admits the violation occurred as stated. 2. Reason for the Violation TVA failed to require from the vendor specific information regarding orientation limitations on the affected valves. 3 Corrective Steps Which Have Been Taken and the Results Achieved Vendor documentation for pneumatic control valves with safety-related pilot solenoids was researched to idettify all valves using solenoids which have orientation limitations. When the potential problem valves were identified, the mechanical piping drawings were reviewed for control I valve (and consequently solenoid valve) orientation. Upon elimination of those installed correctly, the resulting list identified all valves with unacceptable installations. An engineering change notice -(ECN) will be prepared to revise all the vendor drawings for the unacceptable installations to reflect correct solenoid orientation. After completion of the design work, the affected-valves will be properly oriented by TVA's Division of Construction (CONST). 4. Corrective Steps Which Will Be Taken to Avoid Further Violations TVA is in the process of preparing its response to the programmatic aspects of this violation as requested in the transmittal letter. l-L L:~ ~ ' % Od e i c
d 5. Dats wh?n Full Complianca Will Ba Achirved I ~ TVA will proparly crient all affected valvss by August 1, 198 5. Actions taken to avoid further violations will be addressed by the progrannatic response to be supplied by March 5,1984. t e %e i 9 4 ? e 4 1 J .4 y ,wr ew .--,e, . w g w-w,e + - =}}