ML20065F887

Forwards Revised Response to NRC Re Violations Noted in IE Insp Repts 50-438/82-12.Corrective Actions: QA Program & Procedure to Require QC Insp Before Fitup of Piping Components Revised

ML20065F887
Person / Time
Site:	Bellefonte
Issue date:	09/07/1982
From:	Mills L TENNESSEE VALLEY AUTHORITY
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20065F853	List: ML20065F887
References
NUDOCS 8210010429
Download: ML20065F887 (3)

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TENNESSEE VALLEY AUTHORITY ,

.,2 "dod*Ehes$ nut Street "

Towert[SNRC 'IIMITA,REGIONGEORGIA September 7 1982 8fSEPIO AW: hg U.S. Nuclear Regulatory Commission Region II Attn: Mr. James P. O'Reilly, Regional Administrator 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303 4

Dear Mr. O'Reilly:

BELLEFONTE NUCLEAR. PLANT UNIT 1 '- REVISED RESPONSE TO VIOLATION 50-438/82-

'12 TOOL AND MATERIAL CONTROL This is in response to F. J. Long's letter dated May 21, 1982, report numbers 50-438/82-12, 50-439/82-12, concerning activities at the Bellefonte Nuclear Plant which appeared to have been in violation of NRC regulations.

The previous response to this violation was submitted June 21, 1982. As discussed with J. D. Wilcox by telephone on June 29 and September 1, 1982, enclosed is our revised response to the citation.

If you have any questions concerning this matter, please get in touch with R. H. Shell at pts 858-2688.

To the best of my knowledge, 1 declare the statements contained herein are complete and true.

Very truly yours, TENNESSEE' VALLEY AUTHORITY i

L. M. Mills, nager Nuclear Licensing Enclosure cc: Mr. Richard C. DeYoung, Director (Enclosure)

Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, DC 20555 4

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B210010429 820917

PDR ADOCK 05000438

G PDR An Equal Opportunity Employer

ENCLOSURE BELLEFONTE NUCLEAR PLANT UNIT 1 REVISED RESPONSE TO SEVERITY LEVEL V VIOLATION 50-438/82-12-11 TOOL AND MATERIAL CONTROL Description of Deficiency 10 CFR 50, Appendix B, Criterion V and Tennessee Valley Authority (TVA)

Final Safety Analysis Report, Section 17.1 A.5 requires that activities affecting quality be accomplished in accordance with procedures and drawings.

Bellefonte Quality Control Procedure BNP-QCP-6.16, Rev. O, " Cleanliness

• Control During Piping System Installation" states:

Paragraph 6.1 -

Prior to installation the crafts shall clean all piping material for those systems specified for cleaning per CONST Specification N4M-891.

Paragraph 6.2 -

After cleaning the crafts shall maintain cleanliness control of system by ensuring that all openings on piping materials and equipment are sealed or capped at all times when work is not in progress.

BNP-QCP-7.9, Rev. 8, "Fitup & Cleanliness" states:

Paragraph 6.3 1 (B) -

The responsible craft foreman has assured that the piping inter-ior is clean in accordance with the criteria of Field Construction Procedure (FCP) 6.1.2 and indicate such by signing the back of the fitup cards.

Contrary to the above, during the past several months numerous proof of a

cleanliness flushes have been performed on safety-related systems. During these flushes, numerous tools / materials were obtained from inside these systems indicating that these systems were not constructed in a clean condition.

Admission or Denial of the Alleged Violation TVA admits the violation occurred as stated.

Reason for the Violation

' The violation occurred because of the lack of an adequate QC inspection  ;

program for piping interior cleanliness.

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Page 2 Corrective Action Taken and Results Achieved Investigations performed by TVA as the result of the violation indicate that the present program and procedure governing piping interior cleanliness inspection was not adequate mainly because of poor performance of craft personnel in following the existing procedure. TVA has decided to revise the QA program and procedure to require a QC inspection before fitup of piping components.

Steps Taken to Avoid Further Violations

,, BNP-QCP-7.9 will be revised to require a QC inspection to verify cleanliness before ritup of piping components.

Date of Full Compliance Full compliance will be achieved upon issuance of the revision to QCP-7.9 requiring QC inspection of piping interior cleanliness and corresponding certification of the QC inspectors. TVA expects to complete these actions by October 15, 1982.

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