ML20101T284

Responds to NRC Re Violations Noted in Insp Repts 50-438/84-22 & 50-439/84-22.Corrective Actions:Assemblies Placed on Curbing & Damaged Closures Replaced

ML20101T284
Person / Time
Site:	Bellefonte
Issue date:	11/30/1984
From:	Hufham J TENNESSEE VALLEY AUTHORITY
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20101T269	List: ML20101T284
References
NUDOCS 8502060084
Download: ML20101T284 (4)

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TENNESSEE VALLEY AUTHO,RITY - < - -

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CHATTANOOGA. TENNE *SSEE(,s74ol g ,

400 Chestnut Street Tower II

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, U.S. Nuclear Regulatory Comunission 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 PLANT UNIT 1 - RESPONSE TO VIOLATION 50-438/84-22-01, 50-439/84-22 FAILURE TO ESTABLISH ADEQUATE CONTROLS FOR STORAGE AND PRESERVATION OF PIPING ASSEMBLIES This is in msponse to D. M. Verrelli's letter dated October 31, 198 4,

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report . numbers 50-438/84-22, 50-439/84-22 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 act knowledge, I declare the statements contained hemin are complete and true.

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Very truly yours, TENNESSEE VALLEY AUTHORITY J W. t MManager ensi e Regulations Enclosure cc: Mr. Richard C. DeYoung, Director (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 i

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An Equal Opportunity Employer

ENCLOSURE BELLEFONTE NUCLEAR PLANT UNITS 1 AND 2 RESPONSE TO SEVERITY LEVEL V VIOLATION

. 50-438/84-22-01, 50-439/84-22-01 FAILURE TO ESTABLISH ADEQUATE CONTROLS FOR STORAGE AND PRESERVATION OF PIPING ASSEMBLIES Description of Deficiencies 10 CFR 50, Appendix B, Criterion XIII as implemented by FSAR Section

17.A.1.13, requires that measures be established to control the storage and preservation of materials and equipment to prevent damage or deterioration.

As implemented by the TVA QA program, ANSI N45.2.2-1972, " Packaging, Shipping, Receiving, Storage and Handling of Items fbe Nuclear Power Plants '

(During the Construction Phase)," paragraph Nos. 2.7.4(9) and 6.1.2(4),

require piping assemblies to be stored upon curbing to avoid trapping water. ANSI N45.2.2, paragraph 6.4.2 and Appendix A.3.5.2(2)(b), require items in storage to have caps, covers, plugs or other closures intact and that tape be impervious to water and not subject to cracking cr drying out if exposed to sunlight, heat or cold. ANSI N45.2.2, Appendix A.3 5.2(3),

as amended by Regulatory Guide (RG) 1.38, paragraph C.2.d, requires tape to

be colored to contrast with materials on which ~ they are used.

j Contrary to the above, adequate measures had not been established to control the storage and preservation of piping materials in that the following was noted:

- Approximately 10 examples of safety-related assemblies off curbing and in contact with the ground.

- Approximately 40 examples of missing, damaged, or deteriorated

! closures on piping assemblies.

- The approved tape for use on austenitic materials is silver gray in color, close to the color of austenitic stainless steel.

TVA Response t

This violation will be addressed in two parts: (A) improper storage conditions and (B) color of tape used in stainless steel.

A. Improper Storage Cor.ditions

1. Admission or Denial of the Alleged Violation l

} TVA admits the violation occurred as stated. j l \

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l- . 2.; R icena for ths Violation

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l Two different pipe storage areas were' identified which contained piping storage area contained some of the examples; however, the -

l' majority o r. the deficiencies were in the steamfitter-laydown yard which is located in the warehouse yard area. Bellefonte Nuclear Plant Quality Control Procedure (BNP-QCP)-1.2, " Storage,"

. implements the requirements of ANSI N45.2.2-1972 which are referenced in this violation. Inattention to detail on the part ,

of the steamfitter craft personnel was the cause of the - l

deficiencies in the reactor building piping storage area. The

!- steamfitter laydown yard contained temporary flush piping and l l permanent; ASME code piping which was designated for use in the unit

, p 2 reactor building. In September 1983, when the piping i installation activities were deferred for the unit 2 reactor.

building, this piping was collected and transferred to this storage 4 area. This area was not being used regularly and the deterioration '

) off the piping assembly closures went undetected.

j 3 Corrective Steps Taken and Result Achieved i

j Tne cited assemblies were placed on the curbing and the damaged closures were replaced with acceptable ones the same day of l identification ~ by the NRC inspector.

] 4. Corrective Steps Taken-to Avoid Further Noncompliance A memorandum was issued by the steamfitter superintendent to

reemphasize the importance of maintaining piping assemblies in i proper storage conditions and to monitor all storage areas

! regularly regardless of the frequency of use-of these areas. In i addition, the steamfitter superintendent has made formal l assignments to each assistant steamfitter superintendent for

responsibility of mnitoring the storage areas around the

{ powerhouse and in the laydown yard.

1 5. Date When Full Compliance will be Achieved

~TVA is in full compliance.

$ B. Color of Tape Used on Stainless Steel l

I 1. Admission or Denial of Alleged Violation I l

i. TVA denies that the tape used on austenitic stainless steel

! constitutes a violation.

i l 2. Reasons for Denial of Alleged Violation i

j In 1980, TVA reviewed RG 138 and ANSI N45.2.2 and judged that J

TVA was in compliance. ANSI N45.2.2 states that "the extent to which the individual requirements of this standard shall i

apply will depend upon the nature and scope of. the work to be performed and the importance of the ites or service involved."

i RG 138 further states that "This guideline (ANSI N45.2.2) t I ,,<a k

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ststaa thnt tap;a should ba brightly color:d to precluda thdir loss into a systc2. In licu of this guidslins, tapts should ba color:d

. ~ to contrast with the materials on which - they are used." During the 1980 review, TVA reviewed the requirement that tapes " contrast with the materials on which they are used" and concluded that grey duct tape contrasted sufficiently with materials on which they are used to be readily visible arri to oreclude their loss into a system.

In addition, TVA's specifications for external cleanliness mquire the removal of all tapes before system operation for those systems with temperatum greater than 2000F. Also, all systems are flushed before operation to verify that the systems are free of all

, foreign objects.

The' current TVA controls on d2ct tapes and system cleanliness are adequate to pmelude the loss of duct tape into a system. -

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