ML20148R398

Provides Addl Response to Violation Examples 8 & 9 from Insp Repts 50-327/87-18 & 50-328/87-18.Corrective Actions: Violation of Improper Work Practices Denied Due to Removal & Reinstallation of Flange Considered Skill of Craft

ML20148R398
Person / Time
Site:	Sequoyah
Issue date:	01/26/1988
From:	Gridley R TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NUDOCS 8802020168
Download: ML20148R398 (6)

Text

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.e TENNESSEE VALLEY AUTHORITY CHATTANOOGA. TENNESSEE 374o1 SN 157B Lookout Place JAN 26 FJ88

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

In the Matter of ) Docket Nos. 50-327 Tennessee Valley Authority ) 50-328 SEQUOYAH NUCLEAR PLANT (SQN) NRC INSPECTION REPORT NOS. 50-327/87-18 AND 50-328/d7 SUPPI.EMENTAL RESPONSE TO NOTICE OF VIOLATION NOS.

50-327/87-18-01 AND 50-328/87-18-01 Enclosed is my response to S. D. Richardson's letter to S. A. White dated December 9, 1987, that requested an additional response to examples 8 and 9 of Notice of Violation 50-327, -328/87-18-01. The delay in the submittal of this response was discussed in a telephone conversation on January 4, 1988, between C. B. Kirk, of the SQN Site Licensing Staff, and F. R. McCoy, NRC.

Enclosure 1 provides our supplemental response for these examples.

If you have any questions, please telephone M. R. Harding at 615/870-6422.

Very truly yours, TENNESSEE VA EY AUTHORITY R. ridley, D ector Nuclear Licensing and Regulatory Affairs Enclosure cc: See page 2 880126 G CK 05000327 PDR An Equal Opportunity Ernployer /

U.S. Nuclear Regulat.ory Commission JAN 261988 cc (Enclosure):

Me. K. P. Barr, Acting Assistant Director for Inspection Programs TVA Projects Division Office of Special Projects U.S. Nuclear Regulatory Commission Region II 101 Marletta Street, NW, Suite 2900 Atlanta, Georgia 30323 Mr. G. G. Zech, Assistant Director for Projects TVA Projects Division Office of Special Projects U.S. Nuclear Regulatory Commission Mail Stop 7R23 7920 Norfolk Avenue Bethesda, Maryland 20814 Sequoyah Resident Inspector Sequoyah Nuclear Plant 2600 Igou Ferry. Road Soddy Daisy, Tennessee 37379 l

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ENCLOSURE p -

Violation 50-327. -328/87-18-01 "criterion XI of 10 CFR 50 Appendix B, as implemented by TVA Nuclear Quality Assurance Manual (NQAM), Section 2.11, requires that a test program be established and conducted to assure that structures, systems and components will perform satisfactorily in service. In order to accomplish that goal, Celterion XI requires that the test program be performed in accordance with written test procedures which incorporate applicable requirements and acceptance limits; that the test peccedures include provisions for assuring all test prerequisites have been met and adequate test instrumentation is available and used; and that the test results are documented and evaluated to assure that test requirements have been met.

Contrary to the above, the NRC inspectors identified cases in which the licensee failed to ensure that test procedures and instructions contained the necessary requirements, that tests were performed in accordance with procedure requirements, and that test results were properly documented and evaluated.

These include the following examples (section numbers refer to the body of the report). . . .

Example 8 "Work activities, including disassembly and reassembly of a bolted flange and other joints and cleanout of instrument tubing, were performed without work instructions, inspections, or second party verification of joint makeup (Section 5.a.5)."

NRC requested that TVA recespond to this violation and address the following three concerns:

"1. While TVA claims that no evidence could be found that instrument personnel removed or rebolted the flange, the inspector observed the flange disassembled, has reinspected the installation and verified that the flange has been reassenbled and is covered with insulation. Since this flange is considered a portion of critical structures, systems, and components equipment, skill of the craft is considered an unacceptable method for complying with the requirements of 10 CPR 50 Appendix B.

2. As indicated in the report the associated tubing lines had been clogged with crystalized boric acid, and were subsequently cleaned out by craftsmen. However, no investigation was initiated to determine the cause, extent or possible adverso impact of this material upon the tubing lines.

3. The first and second-party verification mentioned in the TVA response is limited to confirming existence of the gauge and does not address tightness of joints or component fitup."

TVA Supplemental Response TVA denies the violation occurred es stated.

Basis for Denial This example states there was improper control of work activities involving the removal of boric acid crystals from instrument tubing associated with the installation of a test pressure gauge on the 2A-A boric acid transfer pump (BATP). The inspection report stated that ". . . the instrument mechanic had to do extensive cleanout of boric acid crystals from the instrument tubing.

This involved the ' rodding' of tubing, and disassembly of additional tubing joints and of a bolted flange. None of the additional activities were described on any work requests associated with the test or gauge installation / removal process, and no inspections or second party verifications of joint makeup were performed."

TVA has reinterviewed the employees involved with the installation / removal of the test gauge. These employees maintain their belief that the bolted flange was not removed during the work activity. Looking further into the matter, TVA researched maintenance activition on this system for work activities ongoing at the time of the inspector's observations. The results to date have not identified any activity that removed or installed this flange. In order to verify installat ion practice, TVA contacted the manufacturer (Mansfield Green, a division of AMETEX) of the bolted flange (actually a diaphragm seal) and requested their requirements / recommendations for proper installation. The manufacturer's representative stated that they had no published requirements or recommendations and that there were no special installation requirements associated with the bolted connection. Thus, even if the maintenance request had specified removal of the bolted flange, no special work instructions or verification would be required. Accordingly, TVA believes that removal and reinstallation of the bolted flange, had it occurred, would be within the skill of the craft. However, to ensure proper installation and documentation, a work request will be issued and completed by February 15, 1998.

With respect to the "rodding" of the boric acid crystals from the instrument tubing, TVA disagrees with NRC's description of this activity as "extensive."

The tubing involved is short (less than eight inches) with a minimum of joints. The removal / reinstallation of this instrument tubing is not complicated nor does it require detailed work instructions. TVA instrument mechanica receive specific training on tube fitting that ensures instrument mechanics can properly install tube fittings to ensure a leakproof, mechanically sound tubing connection. This training consists of classroom training with a test as well as "hands on" practice-oriented training. This training is part of the Institute of Nuclear Power Operations approved Instrument Mechanic Training Program. TVA considers removal and reinstallation of the involved tubing are within the qualifications and experience of the instrument mechanics and are within the skill of the crafi

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To ensure more effective control of these test gauges, Surveillance Instruction (SI) 304, "Boric Acid Transfer Pumps," has been revised to delete the installation / removal of the test gauges using maintenance requests. The installation / removal of the test gauges is now under the configuration control .

of the SI. Although TVA believes "rodding" of boric acid crystals was an adequate procedure, SI-304 has also been revised to use a heat gun to clear blockage from the non-heat-traced pipe stubs before installation of the test gauges. This should preclude the need to rod the tubing to clear boric acid crystal blockage from the non-heat-traced tubing lines.

The following provides TVA's response to the specific concerns for this example identified in an NRC request for additional response in a letter from S. D. Richardson to S. A. White dated December 9, 1987.

1. As previously discussed, TVA considers that the removal and reinstallation of the bolted flange, had it occurred, are within the skill of the craft.

2. Crystallization of boric acid in non-heat-traced instrument sense lines is not an uncommon occurronce because, at the involved concentration, boric acid crystallizes below appro:<imately 140 degrees Fahrenheit. This is not an abnormal or unexpected condition and does not warrant any special investigation of the cause or extent of possible adverse impact upon the tubing line. The tubing is constructed of material suitable for boric acid service.

3. Although the second-party verification only specifically confirms the installation and removal of the test gauges, the removal, reinstallation, and rodding of the instrument tubing are properly considered .to be within the skill of the craf t with respect to component fitup or joint tightness.

Example 9 "During functional testing of diesel generator room exhaust fans, a step verifying that red lights on the fan breaker were energized was signed off, when in fact the panel lights were burned out (Section 5.c)."

NRC requested that TVA resubmit the response to this violation and address the following issue:

"TVA denies this example of the violation stating that the subject test was properly performed.

Discussions with the NRC inspector who identified this concern reaffirm that the functional test was not performed as required by test instructions, specifically, that the step which requires verification of indicating lights was signed off prior to bulbs being installed for indication. The criteria used at the time of sign off was whether the fan was running. After the sign off the inspector observed that indicating bulbs were installed and the test rerun.

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Conclusion The TVA denial of this violation is not accepted. Additional evaluation of the performance of this test,, and general test practices is required."

TVA Supplemental Response TVA denies this example of the violation occurred as stated.

Basis For Denial TVA reinterviewed the individual involved with the test. This individual reaffirmed that he did not sign off the step before relamping the indicating lights and obtaining proper indication for the test step. Nonetheless, TVA agrees that proper test performance control is required and that, if the stated example had occurred, it would be unacceptable.

TVA has established additional administrative controls on the conduct of testing. These controls were established by implementing Administrative Instruction ( AI) 47, "Conduct of Testing," which was implemented in accordance with a verbal commitment made to the NRC in the June 18, 1987 enforcement conference. The stated purpose of this instruction is to provide

". . . guidance and requirements for those personnel involved in the performance of test activities . . . ." This procedure provides specific controls on the identification and resolution of test deficiencies, requires training and biannual retraining for the test director, and requires proper briefing of the test performers by the test director. Additionally, this instruction makes the test director responsible for proper test performance and requires the test performer to follow the test instruction under the direction of the test director. This instruction also enhances test documentation in the form of a required test log. TVA believes that this instruction and its implementation adequately address the NRC's concerns with general test practices.

Because NRC acknowledges the indicating bulbs were replaced and the test rerun, TVA believes that the performance of this test has been adequately addressed.