ML19290E676

Responds to NRC 800107 Ltr Re Violations Noted in IE Insp Repts 50-518/79-24,50-519/79-24,50-520/79-24 & 50-521/79-24. Corrective Actions:Alternative QC Method Will Be Used to Insure Highest Std of Electrodes

ML19290E676
Person / Time
Site:	Hartsville
Issue date:	01/18/1980
From:	Mills L TENNESSEE VALLEY AUTHORITY
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML19290E674	List: ML19290E676
References
NUDOCS 8003140368
Download: ML19290E676 (3)

Text

TENNESSEE VALLEY AUTHORITY

, CH ATT ANOOG A. TENNESSEE 374G1 400 Chestnut Street Tower I!

January 18, 1980 C 2 C- r'

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C3 dm Mr. James P. O'Reilly, Director Office of Inspection and Enforcement E

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U.S. Nuclear Regulatory Commission -

Region II - Suite 3100 CA N

101 Marietta Street Atlanta, Georgia 303P5

Dear Mr. O'Reilly:

Our initial response to your November 16, 1979, letter, RII:EHG 50-518/79-24, 50-519/79-24, 50-520/79-24, 50-521/79-24, was submitted to you on December 6, 1979. Enclosed is our response to J. C. Bryant's letter to H. C. Parris dated January 7, 1980, which requested a supplemental response to our December 6, 1979, letter.

If you have any questions regarding this subject, please call Jim Domer at FTS 854-2014.

Very truly yours, TENNESSEE VALLEY AUTHORITY

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L. M.

-)/k Mills, Manager Nuclear Regulation and Safety Enclosure 8 003140gg So/o .

An Equal Opportunity Employer u @ ** M

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, ENCLOSURE SUPPLEMENTAL RESPONSE TO NRC-0IE LETTER FROM C. E. MURPHY TO H. G. PARRIS DATED NOVEMBER 16, 1979 REFERENCE RII: EHG 50-518/79-24, 50-519/79-24, 50-520/79-24,-50-521/79-24 This response supplements our final response to you dated December 6, 1979, as requested by telephone by inspector E. H. Girard of your office on December 20, 1979.

Noncompliance Item - Deficiency 518/79-24-02 A. As required by Criterion V of Appendix B to 10CFR50, and as implemented by PSAR Section 17.lA.5, " Activities affecting quality shall be perscribed by documented instructions, procedures, . . .

and shall be accomplished in accordance with those instructions, procedures, . . ." TVA Procedure CEP 8.03, Revision 8, requires that the Welding Materials Issue Inspector enter heat or lot number of rod on welding material requisitions when issued.

Contrary to the above, on October 16, 1979, heat or lot numbers were not being entered on weld material requisitions at the issue station for unit Al.

This is a deficiency.

Supplemental Response Cause of Deficiency The cited requirement in CEP 8.03, Revision 8, had been overlooked by site personnel due to the changes that were made in the checklist for the QA program to reflect the method of compliance noted below.

This program change or addition was made on or abcut June 5, 1979, when CEP 9.07, Revision 0, was issued. CEP 9.07, Revision 0, Appendix A, "Fitup", card item C, allows entering of filler metal heat number or type. The site was following this procedure and had overlooked that CEP 8.03 still required heat number to be entered and had not been revised to agree with CEP 9.07.

Method of Complying with ASME Code Requirements Hartsville Nuclear Plant has elected to utilize an alternative method of control. All welding el -ctrodes other than specialty maintenance electrodes are purchased to the highest quality level requirements anticipated to be encountered in nuclear construction. The type and size of'the electrode is verified both at the time of fitup and randomly throughout the weld'ing process in order to ensure that the specified welding materials are used. This verification is documented as part of the QC inspection.

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Noncompliance Item - Infraction 518/79-24-01 B. As required by Criterion II of Appendix A to 10CFR50, and as implemented by PSAR Section 17.lA.2, "The program shall provide for. indoctrination and training of personnel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained." TVA's Procedure QCI 502RI specifies two maximum reinforcements for AWS Dl.1 welds of 1/8 inch.

Contrary to the above, On October 17, 1979, accepted weld Al PED 00038R5 had reinforcement exceeding the maximum specified. This indicates that welding and inspection personnel have not been provided indoctrination and training sufficient to assure their proficiency with regard to weld requirements.

This is an infraction.

Supplemental Response Cause of Infraction The part of weld Al PED 00038R5 is a repaired section (about 10 inches long by 1.5 inches wide) of a weld of several feet in length and 2 to 2.5 inches wide. The additional reinforcement was left on the repair area. This condition resulted from misinterpretation by the inspector,

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i.e., the reinforcement on the repair was considered as separate and not additive to that already existing on the original weld.

The inspector involved in this infraction had been retrained in visual weld inspection before this occurrence as a result of the containment anchor bolt chair problem previously reported to your officq. But the situation of a weld added within the area of another larger weld wre not specifically discussed in the retraining.

All inspectors are n aware of the proper application of the reinforcement criteria.

In addition, all welders and welding foremen are scheduled to attend a welder training program beginning February 1980. The program will include indoctrination in AWS/ASME welding requirements.

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