ML20004F785

Responds to NRC 810126 Ltr Re Violations Noted in IE Insp Repts 50-327/80-43 & 50-328/80-21.Corrective Actions:Memo Issued to Employees Clarifying Requirements for Preparation, Review,Approval & Issue of Hydrostatic Testing Procedures

ML20004F785
Person / Time
Site:	Sequoyah
Issue date:	02/27/1981
From:	Mills L TENNESSEE VALLEY AUTHORITY
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20004F783	List: ML20004F785 ML20004F786
References
NUDOCS 8106220360
Download: ML20004F785 (7)

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TENNESSEE VALLEY .AUTMC3;T2.' - - "

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., .e s cco4. m mres:: ; .m 9 400 Chestnut Street Tower II February 27,11981,3  ? U2 *, b Mr. James P. O'Reilly, Director Office of Inspection and Enforcement L.S. Nuclear Regulatory Consnission Region. II - Suite 3100 101 Marietta Street Atla:!ta, Georgia 30303

Dear Mr. O'Reilly:

SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 - NRC-0IE REGION II INSPECTION REPORT -

50-327/80-43, 50-328/80 RESPONSE TO VIOLATIONS The subject inspection report dated January 26, 1981, citeo TVA with one Severity Level IV and one Severity Level V Violation in accordance with 10 CFR 2.201. A letter documenting your approval of the seven-day extension to the response deadline was submitted February 20, 1981.

Enclosed is our response to these violations.

If you have any questions, please get in touch with D. L. Lambert at FTS 857-2581.

Very truly.yours, TENNESSEE VALLEY AUTHORITY l &

L. M. Mills, Manager Nuclear Regulation and Safety Enclosure cc: Mr. Victor Stelle, Director (Enclosure)

Office of Inspection and Enforcement U.S. Nuclear Reguls. tory Commission Washington, DC 20555 8106220'

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[p-ENCLOSURE SEQUOYAH NUCLEAR PLANT UNIT 2

- RESPONSE TO VIOLATIONS 328/80-21-01 AND 328/80-21-02 Violation 328/80-21-01 10CF350, Appendix B, Criterion VI, Document Contho'l requires thaU procedures which prescribe activities affecting quality shall be reviewed for adequacy and approved by authorized personnel before use.

Contrary to the above, documents were not controlled in that on November 4,1980, -during the cold hydrostatic' test of the reactor coolant system, the procedure in use entitled NReactor Coolant -System Unit 2 Cold Hydrostatic Coordination Plan 68-2" had been preparedland

-implemented .by the engineers conducting the test' and had not been -

independently reviewed and approved by authorized personnel. 4 Admission or Denial of Alleged Violation The failure to review the test procedure, as described in the subject violation, ' occurred as stated.

Reason for Violati+1 The' violation occurred as a result of failure of project personnel to prepare,' review, approve, and issue the test procedure as a supplement to L

Sequoyah Inspection Instruction (II) No. 41, " Hydrostatic Test of Piping Systets." Instead, the procedure was prepared and issued as a Coordination

Plan with acceptance criteria to be in accordance with II-41. As a result, the review and approvals it would have received as an II-41 supplement were bypassed.

Corrective Action Taken and Results Achieved

,- Further testing aas stopped and not resumed until the test procedure had been- revised, reviewed, approved, and issued as a supplement to II-41. In addition to the management and QA reviews required for the procedure as an II-41 supplement, the procedure was also reviewed and j approved by the Division of Nuclear Power before issuance.

I Steps Taken to Avoid Further Recurrence

- A memorandum has been issued to responsible project employees clarifying the requirements for preparation, review, approval, and issue of hydrostatic testing procedures.

Date of Full Compliance The -revised test precedure was issued on November 7,1980, and we are imw in full compliance. l 1

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Violation 328/80-21-02 10 CFR 50, Appendix B, Criterion V, requires that activities affecting quality shall be conducted in accordance with writtan procedures. The implementing procedure for tha unit 2 hydrostatic test, Reactor Coolant System Unit 2 Cold Hydrostatic Coordination Plan 68-2, requires that a valve lineup be completed as required by Appendix E, hold orders be placed on boundary valves, add cheTmicals prior tb increasingtemperatureabove15gdegreesF.,chemicalanalysisbe confirmed at 600 and 1000 lb/in , personnel access be limited to the reactor building, a relief valve be installed on the discharge of the positive displacement pump, and that communications be established between the reactor coolant area, the charging pumps room and the control room.

Contrary to the above, activities affecting quality were not conducted in accordance with the unit 2 reactor coolant system hydrostatic test procedure ir. progress on govember 4,1980, in that with the system pressurized to 1000 lb/in , the following prerequisites had not been met:

1. A relief valve was not installed at the discharge of the positive displacement pump as required by Section h.3.4.

2. A valve lineup check sheet- had not been ' completed and hold orders had not been placed on bcundary valves as required by Section 7.5.6. The inspectors observed a sampling of approximately ten valves and found five not positioned in accordance with Appendix E.

3 Reactor Coolant temperature was increased above 150 degrees F prior to adding lithium hydroxide to the system as required by Sections 7.4.2 and 7.5.1.

4. Reactor coolant was not sampled ang daemistry requirements verified at the 600 and 1000 lb/in pressure plateaus as required by Sections 7.6.2 and 7.7.3

5. Measures were not taken to limit personnel access to the reactor building to only those persons involved in the hydrostatic test as required by Section 4.1.14.

6. Direct communications were not estaolished between the reactor coolant area, the charging pump rooms, and the control room as required by Section 4.1.12.

Item 1 Admission or Denial of Alleged Violation The relief valve was not in the configuration required by Section 4.3.4 of the test procedure at the time of the NRC inspection. The valve was installed at the specified 2ccation at the start of the test. However, at the time of the inspector's observation, the valve had been isolated and removed to correct leakage that had developed.

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The centrifugal charging pump was being used to pressurize the system at this time, and there was no danger of exceeding the relief valve.

setpoint. The relief valve was reinstalled in the specified location beforeoperation-oftheposjtivedisplacementpumpforpressurizing the system above 1500 lb/in ..

Item 2 Admission or Denial of Alleged Violation The violation occurred as stated.

- Reason for Violation

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The test procedure restriction against pressurizing above 600 lb/in until the valve linup had been verified was based on not overpressuring the low pressure portions of the system. After the low' pressure portions of the system nad been isolateg in accordance with Appendix E, pressure was increased to 1000 lb/in concurrent with completing the remainder of. the valve lineup.

Corrective Action Taken and Results Achieved Further testing was stopped and a complete valve realignment was made and documented before resumption of testing.

Steps Taken to Avoid Further Recurrence All test employees have been reinstructed in the necessity to adhere to procedural requirements.

Date of Full Compliance We were in full compliance on November 9,1980, following resumption of testing. -

. Item 3

' Admission or Denial of Alleged Violation The violation occurred as described.

Reason for Violation The failure to add lithium hydroxide to the reactor coolant system before exceedini; 150 F occurred through oversight.

Corrective Action Taken and Results Achieved Lithium hydroxide was added to the reactor coolant system immediately upon recognition of the oversight. The .ddition was made approximately 2-1/2 hours after an RCS temperature of 150 F was first achfeved. The highest RCS temperature reached during this period was 166 F. '

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Steps Taken'to Avoid Further Recurrence Allibest employees have been reinstructed to adhere' to procedural requirements.

Date of Full' Compliance We were in full compliance with the resumption of testing on November 8, 1980.

.q Item 4 Admission or Denial'or' Alleged Violation There2 w s a failure to verify the chemistry require =ent at the 600 lb/in . plateau as stated; however, reactor coolant _ samples were taken as required, agd the chemistry. requirement was verified as required at the 1000 lb/in plateau.

Reason for Violation An RCS sample was takeg at 600 lb/in . The pressure was subsequently increased to 1000 lb/in before the results of this sample were known.

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The sample specified to be taken at 1000 lb/in2was taken as required and -pressure was not increased until the -results were known.

Corrective Action Taken and Results Achieved 2

RCS ~ pressure was not increased after thg 1000 lb/in sample wag taken until 'the results of both the 600 lb/in sample and 1000 lb/in sample were known and verified to be satisfactory.

Steps Taken to Avoid Further Recurrence-All test employees have been reinstructed in the necessity to adhere to -

procedural requirements.

Date of Full Compliance We were in full compliance with the resumption of testing on November 8, 1980.

Item 5

- Admission or Denial of Alleged Violation The violation occurred as stated.

Reason for Violation The test director interpreted the requirement in Sectfon 4.1.14 of the test procedure to apply to pressures above 1500 lb/in .

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4 Corrective Action Taken and Results Achieved Further testing was stopped and not resumed until a uniformed guard was posted to restrict > access to only those persons authorized by the test director.1 The test director was instructed. to ensure access was

. controlled at-all pressures above atmospheric. .. .

Steps Taken to Avoid Further Recurrence All test employees have been reinstructed in the' requirements for restricting access to areas where test activities are in progress.

Date of Full Compliance We were in full compliance with the resumption of testing on November 8, 1980. -

Item 6 Admission or-Deniallof Alleged Violation The violation did not occur as stated. Provisio'ns for the . direct communication specified by Section 4.1.12 of the test procedure were made as required before the start of the test. The system consisted of battery-powered headsets connected by a combination of temporary and permanent plant wiring. Phone jacks for connecting the headsets were located in each of the specified ' areas. Test employees tock the

headsets with-them as they moved between the various locations and therefore the headsets would not have been in evidence unless test employees were at the location at the time of the inspector's-observation. Because of their small size, the phone jacks may not

- have been readily evident.

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General Responsa Relativa to Inspection Rnport 80-4'3 and 80-21

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. General Response As a result of 'the subject NRC inspection, the followup inspection, a meeting with NRC-0IE. Region II in Atlanta on November 19, 1980, and TVA's own investigation, we concur that our construction test program

_ did_ not conform to regulatory agreement and intent nor did the program

- ensure that components- and systems tested under the program were adequate for preoperational testing. In an effort to remove the concerns that developed as a result of these problems, TVA committed to perform an overall review and evaluation of the entire construction test program. This commitment was identified in an NRC confirmation of ~ concurrence letter from J. P. O'Reilly to H. G. Parris dated November 20, 1980.

The extent of the review and evaluation is much broader and comprehensive than noted in the above correspondence. The procedures and their applicability to each component or system is being reviewed by l TVA to verify that the applicable construction test meets the design requirements. Each construction test program element will be explicitly a defined with written and formal instructions issued for each eierent of the construction test program.

As a result of the construction test review, a number of changes have been identified. Where Sequoyah unit 2 construction tests have been

. completed, the test results will be reviewed and evaluated to determine if the original tests were adeq:. ate. Retests will be i conducted where neceasary. In addition, the more complex test

] - procedures for individual components or systems will require

_ additional r. view and signoff. This will include review and approval

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by TVA's Division of Engineering Design (EN DES), Division of Nuclear Power (NUC PR), and Construction QA Unit onsite. Control during testing will be formalized with shift turnover instructions and i designation of test directors for each test. All test results will be i verified and approved by the Construction Engineer with QA and NUC PR .

approval required on specific tesc results.

TVA is now satisfied that the upgraded construction test program that

' resulted from the review and evaluation process meets regulatory agreement aad intent. The improved program should ensure that tLe fabrication, erection, and installation of the component or system being tested is in accordance with the design requirements and that

the component or system is adequate for preoperational testing. While this response is specific to Sequoyah unit 2, the review and evaluation of the construction tert program is generic to all TVA nuclear units still under construction.

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