ML19318A522

Responds to NRC 800501 Ltr Re Violations Noted in IE Insp Repts 50-327/80-14 & 50-328/80-08.Corrective Actions: Surveillance Instruction 114 Will Be Revised to Require Examination of Class 2 Pressure Retaining Bolting

ML19318A522
Person / Time
Site:	Sequoyah
Issue date:	05/23/1980
From:	Mills L TENNESSEE VALLEY AUTHORITY
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML19318A513	List: ML19318A522
References
NUDOCS 8006230267
Download: ML19318A522 (3)

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6, TENNESSEE VALLEY AUTHORITY

\ CH ATTANOOGA, TENNESSEE 374o1 400 Chestnut Street Tower II May 23,-1980 't U .' 3 J Mr. James P. O'Reilly, Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Region II - Suite 3100 101 Marietta Street Atlanta, Georgia 30303

Dear Mr. O'Reilly:

SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 - NRC-0IE REGION II LETTER RII:LDZ 50-327/80-14 AND 50-328/80 INSPECTION REPORT -

RESPONSE TO DEFICIENCIES The subject letter dated May 1,1980, cited TVA with two deficiencies in accordance with 10 CFR 2.201. Enclosed is our response to those deficiencies.

If you have any questions concerning this matter, please get in touch with D. L. Lambert at FTS 854-2581.

Very truly yours, TENNESSEE VALLEY AUTHORITY

. d. Mills,

. k nager Nuclear Regulation and Safety Enclosure cc: Mr. Victor Stello, Jr., Director (Enclosure)'

Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, DC 20555 8 00 623 0$?.

An Equal Opportunity Employer OFFICIAL COPY

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ENCLOSURE i

SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 RESPONSE TO INSPECTION REPORT Deficiency 327/80-14-01 and 328/80-08-01 As required by 10 CFR 50, Appendix B, Criterion V, as implemented by the FSAR, paragraph 17.lA.5 requires, in part, " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accor-dance with these instructions, procedures,...." ASME Boiler and Pressure Vessel Code,Section XI, Article lWB-2000 and IWC-2000 specify areas and extent of examinations to be performed during preservice and inservice inspections.

Contrary to the above, TVA's preservice/ inservice program, procedure SI-ll4, Rev. 9, does not require visual inspection of flange ligaments between threaded stud holes as required by Category C-D of Table IWC-2520, nor does SI-ll4, Rev. 9 specify the amount of square area required to be visually inspected of six patches of the interior clad surfaces of reactor vessels.

Category B-I-l of Table IWB-2500 requires 36 square inches per patch.

Additionally, SI-ll4, Rev. 9 does not specify the schedule for unit 2 inservice inspection.

Corrective Action TVA has taken steps to revise Surveillance Instruction 114 (SI-ll4) to require examination of Class 2 pressure-retaining bolting in accordance -

with the 1977 edition, summer 1978 addenda of Section XI for units 1 and

2. A request for relief was transmitted to L. S. Rubenstein by L. M.

Mills' letter dated hay 5, 1980, which addressed examination requirements.

The requirement to examine 36 square inches in the reactor vessel interior and closure head is being restated in SI-ll4 in a more specific manner and has been completed on unit 1 and will be done on unit 2.

Tables A and B of SI-ll4, which indicate sample size and frequency of examination, were listed for scheduling unit 1 inservice inspections.

Unit 2 preservice examinations are done to an approved scan plan which l identifies required inspection procedures, calibration blocks, reference l drawings, and code categories. SI-ll4 will be revised to address the scan i plans. At the completion of unit 2 baseline, new corrected unit specific piping isometric drawings and tables will be made for future inservice inspections.

Date of Full Compliance The changes to SI-114 required for examination of pressure retaining bolting and the reactor vessel interior clad surfaces will be made by July 19,80 and implemented as required.

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A Deficiency 328/80-08-03 As required by 10 CFR 50, Appendix B, Criterion XVII, as implemented by the FSAR, paragraph 17.lA.17 requires in part, " Sufficient records shall be maintained to furnish evidence of activities affecting quality.

The records shall include at least the following:...results of reviews, inspection, tests... The records shall also include closely-related data such as qualifications of personnel, procedures...." American Society for Nondestructive Testing Recommended Practice No. SNT-TC-1A, paragraph 8.5.2.c (which is invoked by the FSAR, paragraph 17.lB.9 and by the TVA procedure SI-114), specifies that for practical examina-tion, ten different checkpoints requiring understanding of tt at variables and procedural requirements should be included in the practical examina-tion; and paragraph 9.6.1.f specifies that personnel records of certified individuals should describe the practical test object.

Contrary to the above, TVA's practical examination form TVA 6780B (PP-8-77) does not include ten checkpoints that are related to the examiner candidate's proficiency or understanding of the test requirements; nor do the personnel records describe the test piece that was tested by the examiner candidate.

This is a deficiency against CPPR-73 only.

Corrective Action TVA is in the process of evaluating the practical portion of the certification test given to its NDE examiners. New practical examination forms are being made to clarify the practical examination and to identify the samples used for testing.

Date of Full Compliance These revisions and modifications are expected to be completed by July 1980.

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