ML20113A811

Responds to NRC Re Violations Noted in Insp Repts 50-438/84-20 & 50-439/84-20.Corrective Actions: Nonconformance Rept 3522 Written to Document Exceeding of Allowable Temp Limit of Paint Storage Warehouse

ML20113A811
Person / Time
Site:	Bellefonte
Issue date:	12/05/1984
From:	Hufham J TENNESSEE VALLEY AUTHORITY
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20113A787	List: ML20113A811
References
NUDOCS 8501210221
Download: ML20113A811 (4)

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. TENNESSEE VALLEY AUTHORITY CHATTANOOG/..- TENNESSEE 374ot 400_ Chestnut Street Tower II Dehedb' g 1984 e

U.S. Nuclear Reguldtory Commission Region II.-

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Attn: Mr. _ James P. O'Reilly, Regional Administrator l101. Marietta Street, ' NW, Suite ~ 2900 '

Atlanta, Georgia 30323

Dear Mr. O'Reilly:

BELLEFONTE NUCLEAf PLANT UNITS 1 AND 2 - RESPONSE TO VIOLATIONS -

50-438/84-20-01,439/84-20-01'- ALLOWABLE STORAGE TEMPERATURES OF PROTECTIVE

. COATINGS EXCEEDED ' AND 50-438/84-20-02,439/84-20 FAILURE TO MEET SPECIFIC 10 CFR 21 POSTING REQUIREMENTS' This letter is in response to D. M. Vercelli's letter chted November 5,

1984, report numbers 50-438/84-20, 50-439/84-20 cor.cerning activities at the Bellefonte Nuclear Plant which appeared to have been in violation of

.NRC regulations. Enclosed is our msponse to the citations.

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 herein am complete and true.

Very truly yours, TENNESSEE VALLEY AUTHORITY.

i h

J W.Hrh, Manager l

L er. sing a Regulations Enclosure

.oc (Enclosure):

Mr. Richard C. DeYoung, Director Office of Inspection and Enforcement-U.S. Nuclear' Regulatory Connission Washington, D.C.

20555 Records Center Institute of Nuclear Power Operations 1100 Circle 75 Parkway, Suite 1500 Atlanta, Georgia 30339 I

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m. a, ENCLOSURE BELLEFONTE NUCLEAR PLANT UNITS 1 AND -2 RESPONSE TO SEVERITY LEVEL V VIOLATION 50-438/84-20-01, 50-439/34-20-01 ALLOWABLE STORAGE TEMPERATURES OF PROTECTIVE COATINGS EXCEEDED

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Description of Deficiency 1

10 CFR 50, Appendix B, Criterion V, and the licensee's accepted quality assurance program (TVA-TR75-1A), Section 17.1.5, collectively aquire that activities affecting quality be prescribed by documented instructions in the form of.. -. procedures and those documented instructions are to be l

followed. Bellefonte Nuclear Plant (BLN) Quality Control Procedure (QCP) 2.4, Revision 8, Appendix B, Section 2.1.6, specifies that protective coating l'

materials shall be stored in a temperature controlled environment so that a maxima temperature of 1000F and a minimum temperature of 500F are rot i

exceed ed.

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. Contrary to-the above, during an inspection conducted.0ctober 2, 1984, at 3

.p.m. of paint storage warehouse.WC (which contained service level I coating e

materials), the inspector noted that the high-low.therinometer (ID No. T-17) in that building mad 1220F and 370F, respectively. These high-low 4

temperatures exceed allowable limits.

Response

j 1.

Admission or Denial of the Alleged Violations i

TVA admits the violation occurred as stated.

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2.

Reason for Violation i

Subsequent investigation (see item 3' below) indicates that, contrary to l

the thermometer readings, the actual warehouse temperatures did not i

exceed-specified limits. - The thermometer (ID No. T-17).in warehouse WC i

(level B storage classification) had recently been installed as a replacement. The thermometer had been recently mcalibrated at the TVA laboratory in Chattanooga to mLnimum/ maxima temperatures of 340F/

123 F and left at those readings. Vibrations during shipping from.

i Chattanooga to BLN apparently moved the readings to 370F/1220F. When.

it was installed as a replacement, the inspector did not reset the

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thermometer from its mcalibrated settings.

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Corrective Steps Taken and Results Achieved Nonconformance report (NCR) 3522 was written' to document this occurrence..

' As noted in the disposition of the NCR, there. is supportive evidence that temperatures did not fall outside the specification limits as discussed l

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- An inspection of tha Public' S3fety log indiented thEt a power failure L,

htd occurred. Howevar, Lubs;quent invcstigation revoeled that this was a false indication and was the result of a blown bulb on the power failure indicator. Therefore, TVA concludes that there has been no power failure since the thermometer had been installed and that the heating system was operating properly.

- Thermometers in nine other level B warehouses with similar heating systems were read on September 28 and October 5,1984. The lowest recorded temperature was 560F and the highest was 960F which are within the specification limits given in QCP 2.4.

From the evidence detailed above, TVA concludes that the actual temperature inside warehouse WC did not exceed allowable limits and that no further corrective action is mquired.

4.

Corrective Steps Taken to Avoid Further Violations The inspector has been reinstructed to the requirements of BLN QCP 2.4, paragraph 2.16 of Appendix B.

During reinstruction, emphasis was also placed on resetting high-low readings of thermometers.

In addition to retraining the inspector, Public Safety will begin recording the temperature inside the storage area upon first indication of a power failure and immediately after the power failure is corrected.

This will be documented and forwarded to the Civil Quality Control (CQC) and the Civil Engineering Units. In additien, the CQC supervisor has been added to the call list in order that any power failures may receive follow-up.

5.

Date When Full Compliance was Achieved Full compliance was achieved on November 16, 1984.

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BELLEFONTE NUCLEAR PLANT UNITS 1 AND 2 RESPONSE TO SEVERITY LEVEL V VIOLATION 50-438/84-20-02, 50-439/84-20-02 FAILURE TO MEET SPECIFIC 10 CFR 21 POSTING REQUIREMENTS j

10 CFR 50, Appendix B, Criterion V, and the licensee's accepted quality assurance program (TVA-TR75-1A), Section 17.1.5, collectively mquire that activities affecting quality be prescribed by documented instructions in the form of... procedures and these documented instructions ere to.be followed. The Manager of Construction's memorandum to Those listed dated October 28, 1983, instructs the Bellefonte Nuclear Plant (BLN) site to post controlled copies of the attached " NOTICE TO ALL TVA EMPLOYEES," dated October 1983 (this notice. contains the posting requirements of 10 CFR 21.6),

on all official bulletin boards, and to permanently maintain them in F

. accordance with applicable document control procedures. BLN has three official bulletin boards, one' located in the nain administrative building,

'another adjacent to the cooling tower tem the trades and labor personnel enter the site, and the third located outside the personnel office which is intended to serve now hires and contract personnel.

Contrary to the above, on October 5,1984, the inspector found that only the main administrative building bulletin board was properly posted to meet the h

requirements of 10 CFR 21.6.

Neither the trades and labor nor the personnel l

office bulletin boards contained the subject October 1983 " NOTICE TO ALL TVA i

. EMPLOYEES," which was purposely written to meet the posting mquirements of l

10 CFR 21.6.

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Response

1.

Admission or Denial of the Alleged Violations 4

1 TVA admits the violation occurred as stated.

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2.

Reason for Violation Inadequate instruction.: were provided to the individual responsible for j

posting the required information on all three official bulletin boards.

The individual posted the information on the administration building bulletin.bcard but was unaware that-the information needed to be posted i

on the other two bulletin boards.

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Corrective Steps Taken and Results Achieved The subject information has been posted on the two additional bulletin boards.

4. ~ Corrective Steps Taken to Avoid Further Violations.

Specific instructions have been given to the responsible ir.dividual regarding the requirements for posting necessary information on official bulletin boards.

-5.

Date When Full Compliance was Achieved l

Fuu compliance was achieved on October 12,1984.

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