ML20106C409

Responds to NRC Re Violations Noted in Insp Repts 50-438/84-15 & 50-439/84-15.Alleged Violation Re Failure to Follow Procedure for Inspecting for Floor Penetrations Denied

ML20106C409
Person / Time
Site:	Bellefonte
Issue date:	09/19/1984
From:	Mills L TENNESSEE VALLEY AUTHORITY
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20106C402	List: ML20106C409
References
NUDOCS 8410240155
Download: ML20106C409 (2)

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i TENNESSEE VALLEY AUTHORITY CH ATTANOOGA, TENNESSEE 37401 400 Chestnut Street Tower II b

U.S. Nuclear Regulatory Commission 84 SEP3e&teP 3". h '984 Region II Attn: Mr. James P. O'Reilly, Regianal Administrator 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323

Dear Mr. O'Reilly:

BELLEFONTE NUCLEAR PLANT UNIT 1 - RESPONSE TO VIOLATION 50-438/84-15 FAILURE TO FOLLOW PROCEDURE FOR INSPECTING FOR FLOOR PENEIRATIONS This is in response to D. M. Verrelli's letter dated August 23, 1984, report numbers 50-438/84-15, 50-439/84-15 concerning activities at the Bellefonte Nuclear Plant which appeared to have been in violation of NRC regulations. Enclosed is our response to the citation.

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 ot' 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 8410240155 841005 PDR ADOCK 05000438 G PDR An Equal Opportunity Employer

• ENCLOSURE BELLEFONTE NUCLEAR PLANT UNIT 1 RESPONSE TO SEVERITY LEVEL V VIOLATION 50-438/84-15-01 FAILURE TO FOLLOW PROCEDURE FOR INSPECTING FOR FLOOR PENL7 RATIONS Description of Deficiency 10 CFR 50,- Appendix B, ' Criterion V, as implemented by Bellefonte FSAR Section-17, paragraph 17.1 A.5, requires that activities affecting quality be accomplished in accordance with documented procedures and drawings.

Bellefonte quality control procedure (QCP) 6.1, paragraph-6.1, requires the i

responsible Mechanical Engineering Unit representative to inspect embedded sleeves and piping during and after the installation activity for general conformance with detailed design drawings. Drawing No. 3AW-0594-PT-07, Rev.

9, shows the location of floor penetrations (sleeves).

Contrary to the above, activities affecting quality were not accomplished in accordance with QCP-6.1 and drawing 3AW-0594-PT-07 Rev. 9 in that four floor penetrations required by the drawing were not added in two concrete pours, card Nos. 9281 and 9385, and these pours were accepted by the Mechanical Engineering Unit.

TVA Response Admission or Denial of the Alleged Violation TVA denies the alleged violation. The violation references drawing 3AWO594-PT-07, Rev. 9, as the controlling document which specified the mark Nos.1551 and 1552 sleeves. The mark Nos.1551 and 1552 sleeves were added to the mechanical sleeve tables on December 23, 1978, upon issue of 3AWO594-PT-07, Rev. 7. The concrete inspection records were signed on August 26 and October 10, 1977. The embedded piping and sleeves were properly inspected in accordance with Bellefonte QCP-6.1.

This alleged violation resulted from an additional review of unresolved item 50-438/81-11-02, " Floor Penetration." The initial concern identified in the l unresolved item involved core drilled holes being made in the concrete floor slab in lieu of pipe sleeves, which were specified in drawing 3AWO594-PT-07, i

Rev. 9.

i The installation of the core drilled holes was accomplished in accordance

! with approved procedures. TVA's Office of Engineering (OE) approval of the core drilled holes was obtained by initiation of field change requests (FCRs) 0-1786, 0-1836 and 0-2014, which were written to revise the Auxiliary Building concrete drawing (4AWO322-X1-3). The actual drilling was authorized by work releases 2251 and 5033 A subsequent investigatien by OE regarding the sealing of penetrations identified the need to install sleeves around the core drilled holes. FCR M-5103 was initiated to authorize the revised sleeve installation. The drawing has been revised as specified by FCR M-5103, the sleeves have been installed, and FCR M-5103 has been closed.

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