ML20101S928
| ML20101S928 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 07/15/1992 |
| From: | Joshua Wilson TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9207200153 | |
| Download: ML20101S928 (6) | |
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July 15, 1992 y
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U.S. Nuclear Regulatory Commission ATTN: Document. Control Desk
-! Washington, D.C. 205C5 i
Gentlemen:
.In the Matter of
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Docket Nos. 50-327
-Tennersee Valley Authority
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50-328
'SEQUOYAH: NUCLEAR-plt.NT (SQN) - NRC INSPECTION REPORT NOS. 50-327,
'328/92 REPLY TO A NOTICES OF VI01ATION (NOVS) 50-327, 328/92-09-02 AND-92-09-04-~
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Enclosed is. 'IVA's response to S. D. Ebneter's letter to M. O. Medford e:
_ dated June 15, 1992, which transmitted the subject NOV3 involving deficiencies in the=in-service inspection (ISI) program. The first NOV
-. concerned; failure to follow procedures for the placement of the lead 4
.. letter "F" adjacent _to the penetrameter for radiographa which utilize a film: side penetrameter, The-second NOV pertained to failure to ensure
-:NDE program review of work orders and work authorizations, which resulted in two new welds not-being added to the ISI weld map.
If~you'have any questions concerning this submittal, please telephone v
- - M. _ A. Cooper at (615) 843-8924.
-Sincerely,
,5 A L. Wilson Enclosures l
_cc t - See~page 2~
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9207200153 920715
-PDR ADOCK 05000327 _
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lU.S.' Nuclear' Regulatory Commission Page 2 July 15, 1992-cc (Enclosures):
Mr. D. E. LaBarge, Project Manager U.S.-Nuclear Regulatory Commission One' White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 NRC Resident Inspector LSequoyah Nuclear Plant
=2600 Igou Ferry Road-Soddy-Daisy, Tennessee 37379 Mr. B. A. Wilson, Project Chief U.S. Nuclear Regalatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 s.
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Enclorura 1 L
RESPONSE TO NRC INSPECTION REPORT NOS. 50-32//92-09 AND 50-328/92-09 STEWART D. EBNETER'S LETTER TO MARK 0. MEDFORD DATED JUNE 15, 1992 Viciatinn 50-317/92-09.Q1 "10 CFR 50, Appendix b Criterion V, states in part that activities affecting quality shall be prescribed by documented instructions, procedures and drawings of a type appropriato to the circumstances and shall be accomplished in accordance with these instructions procedures and drawings. The licensee's Radiogrcphy Procedure, NRT-1, Paragraph 7.8.1, requires that a lead letter "F" be adjacent to the penetrameter.
" Contrary to tF, above, on March 28, 1992, radiographs were observed -
where the radiographer had placed the lead letter "F" on the penetrameter in the area of interest. The placement of the lead letter "F" resulted in the resolution of the essential AT hole bcing obsecred.
"This is a Severity Level IV violation (Supplement I)."
Reasan_fn.t_the liolation TVA procedure, N-RT-1, requires the lead letter "F" to De placed
" adjacent" to the penetrameter. TVA has interpreted " adjacent" to include "on top of," consistent with a 1981 American Society of Mechanical Engineers (ASME)Section V Code Interpretation V-81-13, the 1986 edition of the ASME Section XI code, and the definition of
" adjacent." Inspection Report 92-09 indicated that placement had
-" tended" to mask the inspector's resolution of the hole; however, from further review, NRC concluded that the essential 4T hole could be seen.
Therefore, there was no need to re-radiograph the associated welds as the
-required film sensativity war satisfied.
Corrective Steps That Have Been Taken and Results Achieved A temporary procedure change was issued on March 31, 1992, to clarity that the "F" may be placed on the penetrameter provided the imare of the letter does not obscure the requisite hole and the edges of the penetrameter.
Corrective Steps to be Taken to AvoiLEnttAcr Violations Corrective actions taken in the form of the procedural clarifications are considered adequate to avoid further violations.
Date When full Complian.ce Was Achiend Full compLinu e was achieved on dcrch 31, 1992, upon issuance of the temporcry ",cedure change.
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'yyslation 50-327/92-09-02 "10 CFR 50,-Appendix B Criterion V, states in.part that activities affecting_ quality shall be prescribed-by documented instructions, procedures, Lor drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures or. drawings.
" Contrary to-the above, on April 1, 1992, (In Service Inspection) ISI Repair and Replacement Procedure, SSP-6.9, did not fully designate responsibility for including the ISI personnel in the review of work orders and work authorizations. As a result, two new wolds, which had been added by Maintenance on Work Order C003957, lad not been added to the ISI weld map and, therefore, were not included in the ISI program.
"This is a-Severity Level IV violation (Supplement I)."
Reason for the Violation This. violation involved an-in-service inspection (ISI) weld map that did not reflect two welds depicted on the corresponding plant weld map.
These two welds were added during a maintenance activity.- Following the maintenance activity that added the welds, the ISI-personnel were not notified to-update the ISI. weld map.
The procedure that controls maintenance activities did not contain sufficient positive controls for ASME Section XI components.to notify Icitof. weld replacements or addition of new welds. Typically, maintenance activities do not involve the addition of new-welds; therefore, this condition was considered limited.
CntrerJ;ive Steps That Have Been_Taken and Results., Achieved A 100 percent review of the 81 total ISI weld maps versus the plant weld maps was conducted. This review was performed to ensure that the problem was isolated. Through this review,.a small number of discrepancies, such as new weld numbers for replacement welds,-were identified.- No additional missing welds were identified.
The ISI repair and repin"t.mant procedu:e has been-revised to require site ISI personnel to review all ASME Section XI work documents.
It ensures that the responsible section for notifying ISI when ISI maps are af fected by maintenance activities is clearte delineated.
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_ Cougative' Steps to be' Taken _ to Ayoid FurtheI_Y101AllDas
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The site procedure governing welding and NDE inspections will be revised
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- to provido updated information to.the ISI personnel through copies of inspection' reports for pre-serv 3ce and in-service exams. Additionally, a'-
formal qualification program for-individuals involved in planning Section-XI work will:be-established to ensure that requirements are properly.
- implemented.-
Dale When Full Compliance Was Achieved
.. Full. compliance' was achieved on June 8,1992, when the procedure governing.ISI' repairs and_ replacements was revised.
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COMM11NENTS 1.
The site procedure governing welding and NDE inspections will 5e revised by September 1,1992, to provide updated information to the in-service inspection personnel through providing copies of inspection reports for pre-service and in-service exams.
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A formal qualification program for individuals involved
'.n planning Section XI maintenance activities will be established by August 1, 1992, to ensure that requirements are properly implemented.
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