ML20106C660
| ML20106C660 | |
| Person / Time | |
|---|---|
| Site: | Bellefonte  |
| Issue date: | 08/31/1984 |
| From: | Lambert D TENNESSEE VALLEY AUTHORITY |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20106C627 | List: |
| References | |
| NUDOCS 8410240258 | |
| Download: ML20106C660 (4) | |
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TENNESTEE VALLEY AUTHORITY
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CHATTANOOGA. TENNESSEE 37401 400 Chestnut Street Tower II N SEP 7 P2:34 August 31, 1984 U.S. Nuclear Regulatory Commission Region II Attn:
Mr. James P. O'Reilly, Regional Administrator 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323
Dear Mr. O'Reilly:
BELLEFONTE NUCLEAR PLANTS UNITS 1 AND 2 - RESPONSE TO VIOLATION i
BLRD-50-438/84-12-01, BLRD-50-439/84-12 FAILURE TO FOLLOW PROCEDURES FOR HANGER INSPECTIONS This is in msponse to D. M. Verre111's lette. dated July 18, 1984,. repor t numbers 50-438/84-12, 50-439/84-12 concerning activities at the Bellefonte Nuclear Plant which appeared to have been in violation of NRC regulations.
Enclosed is our response to the citation. A two-week delay concerning the submittal of this msponse was discussed with Inspector C. A. Julian on August 17, 1984.
If you have any questions, please ge*, in touch with R. H. Shell at FTS 858-2688.
To the best of my knoweldge, I declare the statements contained herein are complete and true.
Very truly yours, TENNESSEE VALLEY AUTHORITY D. L. Lambert, Supervisor Special Projects Enclosure 00:
Mr. Richard C. DeYoung, Director (Enclosure)
Office of Inspection and Enforcement U.S. Nuolear Regulatory Commission Washington, D.C.
20555 Records Center (Enclosure)
Institute of Nuclear Power Operations 1100 Circle 75 Parkway, Suite 1500 Atlanta, Georgia 30339 8410240250 040924 PDR ADOCK 05000430 0
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BELLEFONTE NUCLEAR; PLANT i
RESPONSE TO SEVERITY LCIEL V' VIOLATION 50-438/8'l-12-01, 50-439/84-12-01 FAILURE TO POULOW PROCEDORES FOR HANGER INSPECTIONS r
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g Description of Deficiency
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4 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 doon'nented procedures. Be1.'.efonte quality control procedums (QCP) 7.5 and 6.17 provide the procedures And acceptance criteria for welding and dimensional inspections of hangersp,
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p Contrary to the above, activitier ffecting quality were not being acoceplished in accordance with QCP-7.5 and QCP-6.17 in that a reinspection of fourteen hangers myealed two hangers did notimeet the documented welding acceptance criteria, and tm other hangerd did not meet the fooumented dimensional inspection criteria.
TVA Response i
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Admission or Denial of the Allered Violation i,-
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TVA admits the violaiion occurred as stated. The violat' ion in addressed in two parts: welding inspection (A) and hanger dimensionm1' inspection (B).
An additional improoerly installed hanger was identitled in inspection report 50-438/84-13 and 50-439/84-13. The scope of this response will include the additional F. anger.
f Part ( A) 2.
Reason for th4 Violation
.i TVA has determined that the uraoceptable welds are attributable to two conditions:
(1) welders ara insectors were not equipped with the inspection tools and gauges mquired to confirm adequate weld size, and (2) welding quality control inspectors were inadequately tratnnd in the requisite visual quality control examination techniques.'
3 Correctivo Staps Taken and_Results Achieved l
The disposition of:the. oited welds was documented on February 7,1984, under nonconformance report (NCR) 1968 (also identified as constructicn deficiency report BLRD-50-438/32-49, BLRD-50-439/82-44) The scope of' tne IJCR includes all welds fabricated and inspected during the time between May 1,1980, and July 1,1981, as were the cited welds. Corrective aattons will_ include reinspection of the wstdu and rework where necessary.
Details or the corrective actions taken'4111 be included in the next 10 CFR 50.55(e) report which is scheduled for 'Dvoember 20, 1985.
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.4 Corrective Steps Taken to Avoid Further Violations TVA has provided weld inspection tools and gauges to both welders and inspectors. In addition, all welding quality control inspectors were certified in visual welding examination techniques between September and October of 1981. Results of visual inspection audits being performed on a continuing basis in accordance with Standard Operating Procedure (SOP) 716 (implemented May 14, 1981) have indicated that inspectors are accurately performing civil and mechanical weld inspections properly.
'5.
Date When Full Compliance Will Be Achieved Corrective actions on this item will be completed in accordance with the schedule established with respect to the 10 CFR 50.55(e) report.
1 Part (B) 2.
Reasons for the Violation Two basic types of discrepancies were identified in this section.
4 Investigation results have indicated that both type discrepancies are of an isolated nature. The first type involves a unique sliding support configuration which is used on a limited basis. The inadequate clearance I
which existed between the support and adjacent structure could have been 1
undetected or incorrectly calculated during the inspection process.
The second type consists of supports which utilize sway type members (e.g.,
i struts, rods and snubbers). The tolerances allowed for the sway angle are strict, which could result in errors during inspection calculations. A review of hanger quality control postinspection audit results for the period i
I from July 1983 to July 1984 indicates that only 4 of 211 reinspected supports exhibited errors involving away angle tolerances. The actual cause 1
of either type discrepancy cannot be specifically attributed to improper inspection or postinspection movement. Construction activity adjacent to nonrigid supports could cause small movements mlative to pipe or building location which would shift the components outside the allowable tolerance.
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Corrective Steps Taken and Results Achieved i
NORs 3245, 3246, and 3285 were initiated to document the incorrect installations. Corrective action will consist of mLnor configuration mwork
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to bring the supports within allowable tolerances.
4.
Corrective Steps Taken to Avoid Further Violations To support the TVA conclusion that sliding support discrepancies are isolated, all sliding supports which have received quality control inspection have been identified and reinspected to verify acceptability.
Seventy-two sliding supports were reinspected. One support was found to have insufficient clearance from an adjacent pipel however, the pipe had i
been installed after the final inspection of the sliding support and had not l
yet been inspected by piping quality control inspectors. Consequently, TVA considers the installation cited in the violation to be an isolated case.
However, to minimize the possibility of future deficiencies, hanger quality control personnel have been instructed to be aware of the unique configuration during futum inspections.
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.TVA con;id:rs tha swry cngle discrepInci';s to ba isolated bated en tha postintpectitn cudit resulta. H:wevIr, direction 2 htva been provided to hanger quality control personnel to monitor previous sway angle inspections during future adjacent inspections and normal surveillance. To prevent recurrence of any postinspection movement, a memorandum will be provided to appropriate engineering, quality control, and craft personnel from the project manager to memphasize the necessity to mintain the integrity of permanent equipment which is susceptible to postinspee6 ion damage.
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Date When Full Compliance will be Achieved TVA will be in full compliance by October 1, 19811.
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