ML19325D665
| ML19325D665 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 10/20/1989 |
| From: | Medford M TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8910250267 | |
| Download: ML19325D665 (3) | |
Text
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c TENNESSEE VALLEY AUTHORITY CHATTANOOGA. TENNESSEE 37401 e
6N 38A Lookout Place OCT 201989 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Hashington, D.C.
20555 Gentlemen:
In the Matter of
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Docket Nos. 50-327 Tennessee Valley Authority
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50-328 SEQUOYAH NUCLEAR PLANT (SQN) UNITS 1 AND 2 - INSPECTION REPORT (IR)
WOS, 50-327, 328/88 REQUEST FOR ADDITIONAL INFORMATION CONCERNING TVA'S DENIAL OF NOTICE OF VIOLATION 88-09-02 l
This letter responds to a verbal request by G. A. Belisle, NRC, to supply additional information concerning TVA's handling of Ingmcess Quality Assurance documentation as it relates to TVA's denial of Violation 88-09-02 1
dated July 1, 1988.
Enclosed is TVA's response to questions raised during the telephone conversation on August 9, 1989, between NRC and TVA.
If you have any questions concerning this submittal, please telephone N. A. Cooper at (615) 843-6651.
Very truly yours, IENNESSEE VALLEY AUTHORITY
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Mark O. Medford, Vice President and Nuclear Technical Director Enclosure cc (Enclosure):
Ms. S. C. Black, Assistant Olrector i
for Projects TVA Projects Division U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike l
Rockville, Maryland 20852 Mr. B. A. Wilson, Assistant Director k
oo for Inspection Programs 28 TVA Projects Division So U.S. Nuclear Regulatory Commission t
Region Il c'$w 101 Marietta Street, NW, Suite 2900 8
gg Atlanta, Georgia 30323 i
rvA NRC Resident Inspector fgD Sequoyah Nuclear Plant f
d 2600 Igou Fer'y Road I
Soddy Daisy. Tenne nee 37379 ll An Equal Opportunity Employer
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ENCLOSURE 1 RESPONSE TO NRC'S VERBAL REQUEST FOR ADDITIONAL INFORMATION REGARDING VIOLATION RESPONSE 89-09-02 IN-PROCESS QUALITY ASSURANCE (QA) DOCUMENTATION
References:
1.
K. P. Barr's letter to TVA dated May 17, 1988, " Notice of Violation (NRC Inspection Report Nos. 50-327/88-09 and 50-328/88-09)"
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2..
TVA letter to NRC dated July 1, 1988, "Sequoyah Nuclear Plant (SON) Units 1 and 2 - NRC Inspection Report Nos. 50-327/88-09 L
and 50-328/88 Response to Notice of Violations Nos. 50-327, 50-328/88-09-01 and -02" f
3.
Telephone conversations on July 26, 1989, and August 9, 1989, between G. A. Belisle (NRC) and TVA l
In the initial response (Reference 2) to the subject notice of violation (NOV) f (Reference 1), TVA dented the violation based on the fact that the documents e
in question were QA documents, not QA records.
Several references were listed that supported this position.
However, TVA recognized that it was to TVA's advantage to afford certain documents, which were destined to become QA records, a degree of protection in handling and storage because of the difficulty of reconstructing and/or replacing them.
TVA considered this l
action to be an enhancement to the records program.
Accordingly, SQN revised l
. Administrative Instruction (AI) 7, " Controlling and Processing Records," to include a section for in-process QA records. A revision to the Nuclear Quality Assurance Manual (NQAM), Part III, Section 4.1 (incorporated in Nuclear Power Standard (NPSTD) 5.9.80), included a section on storage for in-process QA records.
TVA surveyed the list of documents that are designated to become QA records when completed.
The only documents that TVA Joelieves should receive additional or special handling and storage treatment because of difficulty of replacing or recreating are workplans (WPs), work requests, and surveillance instruction (sis).
The aforementioned procedures effectively control the handling and storage of these documents'.
The effective l
implementation of these prc,cedures will correct and prevent recurrence of i
problems such as outlined by the alleged violation.
Ouring the exchange of facts and philosophy in the two telephone conversations (Reference 3), the following three concerns were expressed by Mr. Belisle and are responded to by TVA as follows:
1.
This issue has repeatedly been reviewed, and each time attention has been narrowly focused on a new type document, i.e., procurement documents, preoperational test documents, sis, and now WPs.
L. E. Martin, TVA, responded to this concern by stating that, as previously reported in the original response, TVA has identified the documents that need special handling and storage.
However, an additional and formal request would be made to the appropriate organizations to identify those in-process QA documents in their cognizance that needed special considerations.
This would provide additional assurance that in-process QA documents would be handled consistently TVA-wide.
The response to Mr. Martin's request only identified five additional documents, all relating to operator training records.
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2.
NRC is concerned with TVA's inconsistency in handling in-process QA documents from one organization to another.
c At present, controls for in-process QA documentation are contained in NPS10 5.9.80.
At SQN, in-process QA documents, other than those described in AI-7, will be handled "at risk," 1.e., no special protection.
To
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evaluate consistency, SQN Site QA monitors activities and conducts surveys J
of the implementation of these upper-tier procedural requirements.
Inconsistencies and deviations to procedures controlling in-process QA l
documentation will be identified and appropriately dispositioned utilizing TVA's corrective action program.
3.
NRC is concerned with TVA's failure to take prompt corrective action in addressing the problem when it was first identifled in Corrective Action Report (CAR) CAR-86-04-024.
CAR-86-04-024 was initiated on May 12, 1986; however, in-process QA l
documents were not included in the original scope of the concern or corrective action. On December 22, 1986, the scope was expanded to include in-process QA documents.
In the corrective action of the CAR, it was discovered that two storage areas were identified as being unac eptable because of transient fire loading surveys. On September 29, 1988, fire surveys were completed; the two areas previously mentioned had been corrected. On October 21, 1988, the corrective action r
for CAR-86-04-024 was verified as complete and acceptable; the CAR was closed. Given the magnitude and complexity of the work involved to correct the problem and the efforts extended toward plant restart, SQN does not consider that an inordinate amount of time was spent to identify deficiencies, expand the scope, train personnel, transfer and/or rearrange areas and equipment, and verify that all the actions described in the CAR were complete.
In summary, SQN has surveyed the appropriate organizations and identifled those documents that should be afforded special handling and storage protection con.mensurate with the difficulty to reproduce, recreate, or retrieve the data or information.
SQN is now implementing requirements for handling in-process QA documentation in AI-7.
All other documents destined to become QA records will be handled on an at-risk basis.
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