ML20209D744

Responds to NRC Re Violations in Noted Insp Repts 50-438/86-07 & 50-439/86-07.Corrective Actions: Requirements for Timely Documenting of Conditions Adverse to Quality Reviewed by Involved Supervisors

ML20209D744
Person / Time
Site:	Bellefonte
Issue date:	01/28/1987
From:	Domer J TENNESSEE VALLEY AUTHORITY
To:	Grace J NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation
References
NUDOCS 8702040540
Download: ML20209D744 (3)

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TENNESSEE VALLEY AUTHORITY CH ATTANOOGA. TENNESSEE 374o1 SN 157B Lookout Place JAN 28 887 U.S. Nuclear Regulatory Conmission Attn: Document Control Desk Office of Nuclear Reactor Regulation Washington, D.C. 20555 l

Attention: Dr. J. Nelson Grace j BELLEFONTE NUCLEAR PLANT UNITS 1 AND 2 - NRC-OIE INSPECTION REPORT NOS.

50-438/86-07 AND 50-439/86 RESPONSE TO VIOLATION Cary G. Zech's letter to S. A. White dated December 29, 1986 transmitted NRC ,

Inspection Report Nos. 50-438/86-07 and 50-439/86-07 for Bellefonte Nuclear l Plant. This report cited TVA with one violation: 50-438/86-07-01, Severity Level V. Our response to this violation is enclosed.

l If you have any questions, please get in touch with D. L. Terrill at (205) 574-8820.

To the best of my knowledge, the statements contained herein are completo and true, i

Very truly yours, ,

TENNESSEE VALLEY AUTHORITY

, .N.

J. A. Domer, Assistant Director Nuclear Safety and Licensing cc (Enclosure):

U.S. Nuclear Regulatory Commission Region II Attn: Dr. J. Nelson Grace, Regional Administrator 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Mr. G. G. Zech, Director TVA Projects U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Bellefonte Resident Inspector Bellefonte Nuclear Plant P.O. Box 2000 Hollywood, Alabama 35752

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8702040540 870128 PDR G

ADOCK 05000438 PDR..

An Equal Opportunity Employer fI 1

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. ENCLOSURE RESPONSE NRC OIE INSPECTION REPORT NOS. 50-438/86-07 AND 50-439/86-07 GARY G. ZECH'S LETTER TO S. A. WHITE DATED DECEMBER 29, 1986 Violation 50-438/86-07-01. Failure to Follow Procedure for Documenting Conditions Adverse to Quality 10 CFR 50, Appendix B, Criteria V, and the accepted QA Program (TVA-TR-75-1A, Rev. 8) Section 17.1. A.5, requires in part that activities affecting quality be prescribed by documented procedures of a type appropriate to the circumstances and shall be accomplished in accordance with these procedures.

Bellefonte Standard Practice BLA 16.1, Identification of Conditions Adverse to Quality and Corrective Actions, par. 1.0 states that documentation of conditions adverse to quality should be made promptly, within three working days after identification by plant personnel.

Contrary to the above, activities affecting quality were not being

-accomplished in accordance with documented procedures in that during the heating of a 12 inch diameter stainless steel pipe in the Spent Fuel Cooling System, the pipe became distorted and Corrective Action Report (CAR) No.

BLN-CAR-86-14 was initiated on November 14, 1986, which is 9 days after the distorted condition of the piping was identified. This exceeds the 3 days maximum allowed by BLA 16.1.

This is a Severity Level V Violation (Supplement II)

1. Admission or Denial of the Alleged Violation TVA admits the violation occurred as stated. For purposes of clarification, Bellefonte Standard Practice, BLA 16.1, Revision 14,

" Identification of Conditions Adverse to Quality and Corrective Action,"

requires documentation of conditions adverse to quality within three working days of identification and the actual time before the specified condition was documented was six working days; therefore, the requirement was exceeded by only three working days. The nine days cited above includes a weekend and a holiday.

2. Reason for the Violation The site imposed requirement that conditions adverse to quality be documented within three working days was exceeded because of indecision over identifying this condition as a condition adverse to quality.

3. Corrective Steps Taken and Results Achieved The requirements for timely documenting of conditions adverse to quality were reviewed by the involved supervisors. This review clarified the proper interpretation of conditions adverse to quality and timeliness for documenting conditions adverse to quality.

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4. Corrective Steps Taken to Avoid Further Violations The responsible supervisor and his engineering personnel will receive formal retraining on the Bellefonte Corrective Action Program.

5. Date When Full Compliance Will Be Achieved Retraining will be completed by May 1, 1987, subsequent to issuance of the new Bellefonte corrective action procedure.

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