ML20005A116

Final Deficiency Rept,Originally Reported on 800904,re Const QA Audit Deficiency Concerning safety-related non-ASME Weld Insp.Qa Program Meets Intent of Commitment to ANSI N45.2.5

ML20005A116
Person / Time
Site:	Bellefonte
Issue date:	06/22/1981
From:	Mills L TENNESSEE VALLEY AUTHORITY
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
10CFR-050.55E, 10CFR-50.55E, NUDOCS 8106290408
Download: ML20005A116 (3)

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Mr. James P. O'Reilly, Director ., g* -9. -

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Office of Inspecticn and Enforcement 42  ;

U.S. Nuclear Beaulaterv Ccruission - 3P ~

Regicn II - Suite 3100' 101 Marietta Street h, 8 '

Atlanta, Georgia 30303  %

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Dear Mr. O'Reilly:

RTTIMt2TTE NUCLEAR PIAVr CNITS 1 AND 2 - CCtm2urnCN CA AUDIT DEFICIDCI SAFEIY-RELMD NCN-ASME NEED IMeu.mCN BN47-80 FINAL REPORT on September 4,1980, R. W. Wright, NBC-CIE Regicn II, was informed that the subject nonconformance was determined to be recortable in accordarre with 10 CFR 50.55(e) . 'Ihis was followed by our interim reports dated Octcber 20, 1980, March 6, and May 5, 1981. Enclosed is our final recort.

Although this deficiency was orginally written on Bellefonte, it has teen determined to be generic to all 'IVA plants under construction.

If you have any cuestices, please get in touch with D. L. Lambert at FTS 857-2581.

Very truly yours, TENtESSEE VALLEY AlumulN L. M. Mills, Manager Nuclear Regulation and Safety Enclosure ec: Mr. Victor Stello, Director (Enclosure) /

Officte of Inspection and Enforcement U.S. Nuclear Regulatory Cenmission Washington, DC 20555 s  :

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ENCIASURE BEILEETNIE MJCLEAR PLANT UNITS 1 AND 2 CONSTRUCTION AUDIT DEFICIENCY SAFETY-REIATED NCN-ASM:: WEID INSPECPION 10 CFR 50.12(e) CCNSTRUCTION OA AUDIT BN-W-80-08 FINAL REPORP Description of Deficieref ..

Contrary to the FSAR Section 17.lA.9 requirements, 'IVA's Office of .

Engineering Design and Construction (OEDC) QA Program for Control of Special -

Proc <sses does not contain written measures to ensure that safety-related weldirg receives all inspections / verifications required by Codes, standards, -

and ld CFR 50 Appendix B, cannitments. As a result, certain categories of safety-related welding, have/are not receiving the inspections required by ANSI 45.2.5-1974 to verify quality. 'Ihe required inspections not being performed include:

-Verification of welding procedure and compliance thereto

-Verification of welder qualification

-Verification of joint fit up

-Verification of correct filler metal usage Although this deficiency was originally written on Bellefonte Nuclear Plant, it has been determined to be generic to all TVA Nuclear Plants under construction.

Safety Implications TVA's review of commitments and compliance with those comnitments has been completed. This review has shown that had the deficiency remained uncorrected it could not have affected adversely the safety of operations of the plant.

Corrective Action TVA's review and evaluation of the welding program and procedures, as related to the audit deficiency BN-N-80-08 has been empleted. This evalaation was conducted in the following manner:

1. Identify the exact requirements of section 5.5 of ANSI N45.2.5 and the four items of deficiency as reported to the NBC, namely:

a. Verification of welding procedure and empliance thereto.

b. Verification of welder qualification.

c. Verification of joint fit up.

d. Verification of correct filler metal usage.  ;

2. I Identify the quality control procedures and how safety-related non-ASME i welding ard inspection are performed and documented.

3. Cmpare requirements of 1 and 2 for compliance and/or nonempliance with TVA cmmit:nents.

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l TVA's detailed review and investigation revealed the OEDC CA program is meeting the intent of our comnitment to ANSI N45.2.5. We substance of the deficiency depends on the interpretation of paragraph 1.2 (Applicability),

and paragraph 1.3 (Responsibility) of ANSI N45.2.5.

TVA fully coroplies with the abcne items la., lb., and ld. Regarding item Ic.,

it is TVA's position that the individual requirements of the standard be applied depending upon the nature and scope of the work to be performed and the importance of the item or the service involved. We specific requirements for quality control would be reflected in the drawings and specification applicable to the work to be performed. It is the intent of 'IVA that specific requirements for preweld joint fit-up inspection and documentation be called

.for in the construction drawings on a case-by-case basis as required by the engineer. However, it has been the usual 'IVA practice to require more rigorous inspection methods such as radiographic testing, ultrasonic testing, liquid penetrant examination, and dry magnetic particle examination in lieu of specifying joint fit-up inspection.

tis investigation did reveal that the design engineer's responsibility in implementing ANSI N45.2.5 needs clarification. We responsibilities of design engineers are being clarified to enphasize that item Ic. be considered and if required on a particular feature, be specified on construction drawings, in construction specifications, or procurenent specifications. tis clarification will be accmplished by issuing a memorandum by June 30, 1981 and will be incorporated into TVA's Engineering Procedures by Septenber 30, 1981.

Based on the foregoing, 'IVA considers the generic issue of cmpliance resolved.

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