ML20046C372

Responds to NRC Re Violations Noted in Insp Repts 50-327/93-24 & 50-328/93-24.C/As:licensee Has Established Site Technical Programs & Performance Organization as Single Owner for ASME Section XI Program at Plant

ML20046C372
Person / Time
Site:	Sequoyah
Issue date:	08/06/1993
From:	Fenech R TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9308100200
Download: ML20046C372 (4)

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Tennessee Valley Aumonty. Post Othce Box 2000. Soddy-Daisy. Tennessee 37379-2000 1

l Robert A. Fenech j

Vice Presdent, Sequoyah F4acioar Plant l

August 6, 1993 i

l U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 3

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Gent 1emen*

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In the Matter of

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Docket Nos. 50-327 Tennessee Valley Authority

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50-328 4

1 SEQUOYAH NUCLEAR PLANT (SQN) - NRC INSPECTION REPORT NOS. 50-327,

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328/93 REPLY TO NOTICE OF VIOLATION (NOV) 50-327, 328/93-26 Enclosed is TVA's reply to Caudie A. Julian's letter to Mark C. Medford dated July 7, 1993, which transmitted the subject NOV.

The violation involves the failure to perform a suitability evaluation for the

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like-f or-like replacement of the steam generator /feedwater cracked piping j

components and use of Appendix D of Site Standard Practice (SSP) 6.9, i

" Repair / Replacement of ASME Section XI Components."

l If you have any questions concerning this submittal, please telephone J. W. Proffitt at (615) 843-6651.

Sincerely, l

Robert A. Fenech Enclosure I

cc: See page 2

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. Q@hp 9308100200 930906 PDR ADDCK 05000327 10 PDR

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e U.S. Nuclear Regulatory Commission Page 2 August 6, 1993 i

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cc (Enclosure):

Mr. D. E. LaBarge, Project Manager U.S. Nuclear Regulatory Commission One White Flint, North l

11555 Rockville Pike l

I Rockville, Maryland-20852-2739 NRC Resident Inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy-Daisy,. Tennessee 37379-3624 Regional Administrator U.S. Nuclear Regulatory Commission l

Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323-2711 3

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. ENCLOSURE RESPONSE'TO NRC INSPECTION REPORT l

NOS.~50-327/93-24 AND 50-328/93-24 i

CAL'DLE A. JULI AN'S LETTER TO MARK 0. MEDFORD l

DATED JULY 7, 1993 l

r Violation 50-327, 328/93-24 l

l "10 CFR 50.55a (g) requires in part, that. 'Throughout the service life l

of a boiling or pressurized water-cooled nuclear power facility, components

....must meet the requirements set forth in Section XI of editions of the ASME Boiler and Pressure Vessel Code......'

ASME Section XI, Paragraph IWA-7220, requires that, prior to authorizing the

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installation of a replacement, the owner shall conduct an evaluation of the suitability of the replacement.

If the replacement is because of a i

failure, the cause of the failure shall be considered and, if the cause of the failure appears to be a design deficiency, the specification for j

the replacement shall reflect appropriate corrective provisions.

i "10 CFR 50, Appendix B, Criterion V, requires in part, that, ' Activities affecting quality shall be prescribed by documented instructions, j

procedures, and drawings of a type appropriate to the circumstances and i

shall be accomplished in accordance with these instructions....'

Paragraph 3.4 of Site Standard Practice SSP-6.9, Repair / Replacement of l

ASME Section XI Components, requires that a suitability evaluation be performed using Appendix D Replacement Checklist.

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" Contrary to the above, on June 15, 1993, it was determined that, for replacement of steam generator feedwater cracked piping components in

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1992:

(1) The suitability evaluation was inadequate in that it did not provide evaluation of suitability for operations with the 'like for like' replacement materials (the components were found to be cracked again during the current outage), and (2) For Unit 2, Appendix D to Procedure SSP-6.9 was not used.

I "This is a Severity Level IV Violation (Supplement I)."

Reason for the Violation 3

The reason for the violatien was that the Repair and Replacement Program j

was inadequate in that it did not require that a suitability evaluation be performed. Based.on industry information and experience', it was j

' determined in 1988 that the feedwater nozzles would require replacement' in the future. The replacement specified in 1988 did not adequately consider the impact of long-term auxiliary feedwater operation in-Mode 3.

Replacement of the elbows and transition pieces was. initiated.in 1988 before the failure' occurred and without the metallurgical failure analysis for the like-for-like material-change.

Since there.was no failure and the original material had performed adequately for several years, a suitability analysis was not performed at that time.

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Appendix D of SSP-6.9 consists of two pages.

Page 1 is " Repair Planning Checklist" and page 2 is " Replacement Planning Checklist." Four-l completed copies of Appendix D, page 1 were in the records. Therefore, the wrong form was utilized for the replacement activity.

Corrective Actions That Have Been Taken and the Results Achieved f

A suitability evaluation was performed and the caterial was determined to t

be acceptable for at least one fuel cycle.

i Mode 3 operating procedures have been evaluated and determined to be appropriate for minimizing stratification flow conditions. Auxiliary

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feedwater usage is being monitored to establish trigger points to perform 7

nondestructive examination for cracks.

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TVA has established the site Technical Programs and Performance organization as the single owner for the American Society of Mechanical I

Engineers (ASME) Section X1' program at Sequoyah. The establishment of responsibilities and objectives has been completed. The Technical Programs and Performance organization will assure that adequate i

suitability evaluations are conducted when repairs or replacements are l

made on components covered by ASME Section XI.

i SSP-6.9 has been revised to require that a suitability evaluation be l

performed and be approved by the ASME Section XI Coordinator or the

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cognizant engineer, f

Corrective Steps That Will be Taken to Avoid Future Violations l

i The actions that have been taken are adequate to prevent future j

occurrences of this type problem.

1 Date When Full _ Compliance Will be Achieved j

TVA is in full compliance.

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