ML19345H562
| ML19345H562 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 04/07/1981 |
| From: | Mills L TENNESSEE VALLEY AUTHORITY |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML19345H556 | List: |
| References | |
| NUDOCS 8105210262 | |
| Download: ML19345H562 (6) | |
Text
TENNESSEE VALLEY AUTHORITY (Oj cH ATTA NCOG A. TENNESSEE M4C1 400 Chestnut Street Tower II April 7, 1981
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Mr. James P. O'Reilly, Director Office of Inspection and Enforcement U.S. Nuclear ReFulatory 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 INSPECTION REPORT 50-327/80-44, 50-328/80 ADDITIONAL RESPONSE TO VIOLATIONS The subject letter dated February 6,1981, cited TVA with four violations in accordance with 10 CFR 2.201.
A response to the violations was submitted on March 4, 1981.
Enclosed are responses to these violations, as connitted in our March 4, 1981, response.
If you have any questions, please get in touch with D. L. Lambert at FTS 857-2581.
To the best -f my knowledge, I declare the statements contained herein are complete and true.
Very truly yours, TENNESSEE VALLEY AUTHORITY l
L. M. Mills, Manager Nuclear Regulation and Safety Enclosure cc:
Mr. Victor Stello, Director (Enclosure)
Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, DC 20555 81052101[,2 Q
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1 ENCLOSURE SEQUOYAH NUCLEAR PLANT REVISED RESPONSE TO VIOLATIONS Violation 80-23-01 10 CFR 50, Appendix B, Criterion XI requires that testing be identified in written test procedures which incorporate the requirements of design documents. The accepted QA program, FSAR Section 17.1. A.11 requires tests to verify the adequacy of field erection and installation. Engineering Design drawing 47W-810-74-1 specified Residual Heat gemoval (RHR) pump suction line design-2 pressure to be 600 lb/in g, hence requiring a 750 lb/in g hydrostatic test per Section 3 17.9.1 of Construction Specification No. G-29 Contrary to the above, as of November 14, 1980, the hydrostatig test of the unit 2 RHR pugp suction line was conducted'at 400 lb/in g instead of 750 lb/in g.
Admission or Denial of Alleged Violation The violation occurre l as stated.
Reason for Violation Process Specification 3.M.9.1 of TVA General Construction Specification No. _ G-29 cautions against damaging pump seals by testing at pressures in excess of the maximum pump suction pressure provided by the manufacturer. The functional description section of the vendog's manual for the RHR pump specifies a pump suction head of 400 lb/in g maximum. This was the basis for limiting ghe hydrostatic test pressure of the RHR pump suction line to 400 lb/in g.
Corrective Action Taken and Results Achieved Information subsequently received from the NSSS vendor indicated that the pump geals had a 90 percent chance of withstanding as much as a 900 lb/in g hydrostatic test. The RHR pump suction line has since been subjected to, ang has successfully passed, a hydrostatic test pressure of 750 lb/in g.
Subsequent review of other hydrostatic tests conducted at Sequoyah revealed other examples of improperly pressurized hydrostatic tests.
These were documented on nonconforming condition reports (NCR's) 2436, 2437, 2438, 2440, 2441, 2442, 2443, 2447, 2448, 2449, 2462, and~2457.
TVA submitted a final report on these items to NRC-0IE Region II dated February 3, 1981, pursuant to the requirements of 10CFR50.55(e).
Steps Taken to Avoid Further Recurrence Test personnel have been instructed to request EN DES concurrence for testing limiting components to pressures different than those specified by EN DES drawing or specifications.
2 Date of Full Compliance We were in full compliance following the retest of.the RHR pump suction line on January 24, 1981.
Violation 327/80-44-01, 328/80-23-02 10 CFR 50, Appendix B, Criterion V, requires activities affecting quality to be accomplished in accordance with appropriate procedures.
The accepted QA program, FSAR Section 17.1 A.5 states that assurance is provided that activities are accomplished in accordance with instructions. Section 2.1.2.4 of General Construction Specification G-50, Torque and Limit Switch Settings for Motor. Operated Valves, i
requires that close torque switches shall be set at the minimum position that allows the valves to perform.
Contrary to the above, as of November 14, 1980,: activities affecting quality were not accomplished in accordance with appropriate instructions in that Section 6 of S0P 103, Electrical Checkout of Motor Operated Valves, the site implementing procedure, failed to specify adjustment of close torque switches and the site Electrical Engineering Unit has made adjustments to torque switches.
Admission or Denial of Alleged Violation The violation occurred as stated.
Reason for Violat?on Instructions for adjustment of torque switches were inadvertently omitteo during the preparation of SOP 103, " Electrical Checkout of Motor Operrted Valves."
Corrective Action Taken and Results Achieved SNP Inspect. ion Instruction No. 24, Revision 3, was issued on November 24, 1980, to provide instructions for adjusting torque switches. All motor-operated valve electrical checkouts performed since that date have been accomplished using II-24.
In addition, torque and limit switch settings for motor-operated valves which were checked before the issuance of revision 3 of SNP II-24 will be rechecked before fuel load.
Steps to Avoid Further Recurrence Electrical checkout of motor-operated valves will be performed using SNP Inspection Instruction No. 24.
Additionally, all activities of this nature are now required to be performed in accordance with the inspection instructions which are subjected to more review and approvals than Standard Operating Procedures receive.
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3 Date of Full Ccapliance We have been in full compliance since'II-24, Revision 3, was issued on November 24, 1980.
Violation 327/80-44-02, 328/80-23-03 10 CFR 50, Appendix B, Criterion XI, requires testing to demonstrate satisfactory performance. to be identified and performed in accordance >
with written test : procedures. The accepted 'QA program, FSAR Section.
17.1 A.11 requires testing to demonstrate' the adequacy of field erection and installation. Section 1.0 of Construction Specification-N2M-892, Chemical Cleaning Instructions for Piping Systems for Sequoyah Nuclear Plant, required demineralized water cleaning of'alli piping systems.
Contrary to the above, as of November-14,.1980, tests were not identified or performed to. demonstrate the cleanliness of instrumentation sensing lines in any safety-related' systems.
Admission or Denial of Alleged Violation Our standard practice has been to perform cleanliness flushing of instrumentation sensing lines by flushing through the lines into the process piping during filling of the lines for hydrostatic testing. -
However, we did not have a written test procedure for. performing _this flushing. Therefore, with respect to the lack of a written test procedure, the violation occurred as stated.
Reason for Violation Project personnel interpreted EN DES Project Construction
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Specification N2M-892, " Chemical Cleaning Instructions for Piping Systems for Sequoyah Nuclear Plant," to apply to process piping only.
No other design requirements existed on which to base a written test procedure for cleanliness flushing of instrumentation sensing lines.
Corrective Action Taken and Results Achieved SNP Inspection Instruction No. 85, Revision 8, has been issued to provide written instructions for cleanliness flushing of instrumentation sensing lines. This instruction incorporates the requirements of Specification Revision Notice SRN-N2M-892-5 for EN DES Project Construction Specification N2M-892.
The sensing lines in question are 1/2" id and smaller and are all stainless steel. They are stored before installation in accordance with Process Specification 4.M.1.1(g) of G-29M.
Since these lines'are stainless steel and are in a clean condition when installed, the presence of corrosion products and contamination is insignifica st.
With the current method of hydrostatic testing and flushing of the instrument lines, the amount of grade A water introduced into the process piping would be much less than 1 percent of the process system volume. Since sensing lines have no flow and are only required to transmit system pressure, the two-minute flush demonstrates that the lines are not blocked. Additional acceptance criteria is not necessary to demonstrate that the lines are open.
4 Steps Taken to Avoid Further Recurrence Cleanliness flushing of instrumentation sensing lines will be performed in accordance with the written instructions in SNP.
Inspection Instruction No. 85.
Date of Full Compliance We have been in full compliance since January 15, 1981, when II-85, Revision 8, was issued.
Violation 327/80-44-03, 328/80-23-04 10 CFR 50, Appendix B, Criterion V, requires activities affecting quality to be accomplished in accordance with procedures. The accepted QA program, FSAR Section 17.1 A.5 states that assurance' is provided that activities are accomplished in accordance with instructions. Quality Assurance Staff Procedure -7.1, Auditing Construction Activities, required in Section 2 9.H that negotiations continue at the next higher echelon of management if an acceptable position on proposed corrective action to an audit finding cannot be reached.
Contrary to the above, as of November 14, 1980, activities affecting quality were not accomplished in accordance with instructions in that an unacceptable corrective action was proposed and approved for Deficiency No. 2 of Construction Quality Assurance Audit Report No.
SN-G-80-07 without escalating the negotiations at the next higher level of management. The approved corrective action allowed S0P 103, Electrical Checkout of Motor Operated Valves, to continue to be in effect without the required formal review and approval of the QA Unit Supervisor. It further allowed -the continued generation, and retention of SOP 103 records which were not identified as or meet the standards of quality assurance records.
Admission or Denial of the All'ged Violation The violation occurred as stated.
The Reasons for the Violation Paragraph 2.9.H of QASP 7.1, " Auditing Construction Activities,"
authorizes the lead auditor to evaluate alternate courses of C/A for acceptance.
In followup actions, the lead auditor concluded that the MOV program was being controlled and sufficient evidence was available to satisfy QA program requirements. He accepted the alternate course of C/A; therefore, it was not deemed necessary that the audit finding 5e escalated to the next higher level of management for negotiations.
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Corrective Action Taken and Results Achieved The site QA supervisor, on March 11, 1981, was reinstructed that should such conditions occur in the future, wherein "an acceptable position on proposed corrective action to an audit finding cannot be reached, the finding vill. be escalated to the next higher level of management for negotiations. Such conditions have not recurred as of this response.
Steps Taken to Avoid Further Recurrence A memo has been sent to all QA unit supervisors reiterating the policy of the QA Branch in regards to the acceptance of alternate courses of corrective action to audit deficiencies.
Date of Full Compliance We have been in full compliance since March 27, 1981..
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