ML19345H563
| ML19345H563 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 03/04/1981 |
| From: | Mills L TENNESSEE VALLEY AUTHORITY |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML19345H556 | List: |
| References | |
| NUDOCS 8105210269 | |
| Download: ML19345H563 (5) | |
Text
- _ _ _ _ _ - _ _ _ _
TENNESSEE VALLEY AUTHCRiT' cs c,
- c e.
T NNEuz: 2 7.:c i C
400 Chestnut Street Tower II March 4, 1981
~
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 INSPECTION REPORT 50-327/80-44, 50-328/80 RESPONSE TO VIOLATIONS The subject letter dated February 6,1981, citeci TVA with four violations in accordance with 10 CFR 2.201.
Enclosed is our response to those violations.
Note that we will provide additional information on violation 50-327/80-44-03, and 50-328/80-23-04 before April 3, 1981.
If you have any questions concerning this matter, please get in touch with D. L. Lambert at FTS 857-2581.
Very truly yours, TENNESSEE VALLEY AUTHORITY M
Mdb L. M. Mills, Manager 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 8105210 26 9
ENCLOSURE SEQUOYAH NUCLEAR PLANT RESPONSE TO VIOLATIONS e
Violations 50-328/80-23-01
', Appendix B, Criterion XI re[uires that te$ ting be identified in 10 Cr written test procedures which incorporate the requirements of design documents. The acceepted CA program, FSAR Section 17.1. A.11 requires tests te verify the adequacy of field erection and installation. Engineering Design Drawing 47W-810-74-1 specified Residaal Heat Removal (RHR) pump suctica line design pressure to be 600 psig, hence requiring a 750 psig hydrostatic test per Section 317.9.1 of Construction Specification No.
G-29 Centrary to the above, as of November 14, 1980, the hydrostatic test of the Unit 2 RHR pump suction line was conducted at 400 psig instead of 750 psig.
Admission or Denial of Alleged Violation The violation occurred as stated.
Reason for Violation Process Specification 3.M.9.1 of TVA General Construction Specificaticn No. G-29 cautions against damaging pu=p seals by testing at pressures in excess of the maxi =ur. pump suction pressure provided by the manufact"rer. The functional description section of the vendor's =nnual for the RHR pump specifies a pump suction head of 400 2
lb/in s caximu=.
This was the basis.for limitin-the hydrostatic test pressure of the RHR pu=p suction line to 400 lb/in g.
Corrective Action Taken'and Results Achieved Infor:ation subsequently received from the NSSS vendor indicated that the pu=p seals had a 90 percent chance of withstanding as =uch as a 2
900 lb/in g hydrostatic test.
The RHR pu=p suction line has since been subjected to, and has successfully passed, a hydrostatic test 2
l pressure of 750 lb/in g, Steos Taken to Avoid Further Recurrence Test personel have been instructed to request EN DES concurrence for testing limiting components to pressures different than those specified by EN DES drawing or specifications.
Date of Full Compliance We were in full cc=pliance following the retest of the RHR pump suctica line on January 24, 1981.
1
- e -
Violation 327/80-44-01, 328/80-23-02 10 CFR 50,' Appendix B, Criterion V requires activities affecting quality to be acco=plished 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 0-50, Torque and Limit Switch Settings for Motor Operated Valves, requires that close torque switches shall be set at the minicum position that allows the valve 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 3 of SOP 103, Electrical Checkout of Motor Operated Valves, the site i=plementing procedure, failed to specify adjustment of close torque switches and the site Electrical Engineering Unit has =ade adjustments to torque switches.
Admission or Denial of Alleged Violation The violation occurred as stated.
~
Reason for Violation Instructions for adjust =ent of torque switches were inadvertently omitted during the preparation of S0P 103, " Electrical Checkout of Motor Opera;ed salves.
Corrective Action Taken and Results Achieved SNP Inspection Instruction No. 24, Revision 3, was issued on November 24, 1980, to provide instructions for adjusting torque switches. All motor-operated valve electrical checkout performed since that date has been accomplished using II-24.
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 that Standard C;erating Procedures receive.
Date of Full Comoliance We have been in full compliance since II-24, Revision 3, was issued on November 24, 1980.
y
t s
5 Violation 327/80-44-02, 328/80-23-03 10 CFR 50, Appendix B, Criterion XI, requiras testing to demonstrate satisfactory performance to be identified and perfor.med in accordance uith written test procedure..The accepted QA program, FSAR Section 17 1A.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 61'. piping systems.
Contrary to the above, as of November 14, 1980, tests were not identified or performed to demonstrate the' cleanlinese of instrumentation sensing lines in any safety-related systems.
Admission or Denial of Alleged iolation 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 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 Instru: tion 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.
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.
-? -
,e a
s Violation 327/80-44-03, 328/80-23-04 (Interim Response)
~
10 CFR 50, Appendix B, criterien 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 1
acromplished 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 en 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 instructionst in that an unacceptable corrective action was proposed and approved for deficiency No. 2 of Ccnstruction Quality Assurance Audit Report No. SN-G-80-07.without escalating the negotiations at the next higher level of =anagment. 'The approved corrective action allowed 30P 103, Electrical Checkout of Motor -
Operated Valves, to continue to be in effect without the required for=al review and approval of the QA Unit Supervisor.
It further allowed the continued generation, and retentien of SOP 103 records which were not identified as or meet the standards of quality assurance records.
Admission of Denial of the Alleged Violation The subject violation occurred as stated.
The Reasons for the Violation if Admitted Paragraph 2.9.H of QASP 7.1, ~ " Auditing Construction Activities,"
authorizes the lead auditoe to evaluate alternate courses of corrective action for acceptance.
In followup actions, the lead auditor concluded that the MOV program was being controlled and sufficient evider:ce was available to satisfy QA program requirements. He accepted the alternate course of corrective action, therefore, it was not deemed necessary that the audit finding be escalated to the next higher level of management for negotiations.
l However, the NRC inspector's evaluation of the project's alternate course of corrective action revealed that all QA requirements were not satisfied.
Corrective Action Taken and Results Achieved 1
TVA is continuing to evaluate this violation. Additienal information will be submitted by April 3, 1981.
Steps Taken to Avoid Further Recurrence QA unit personnel have been reinformed that should such conditions occur 'in the future wherein acceptable corrective action to an audit finding cannot be reached negotiations will continue at the next higher echelon of manage =ent.
e t
=
m-+-
,y
-,._4 4 _.
y---...
g,,p
......,,,-.....w._._._-
m