ML20150B880
| ML20150B880 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 07/06/1988 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8807120225 | |
| Download: ML20150B880 (4) | |
Text
,
'i
,p.
, 8=.
TENNESSEE VALLEY AUTHORITY CH ATTANOOG A TENNESSEE 37401 SN 1578 Lookout Place JUL 061988
'U.S. Nuclear Regulatory Commission AITN:
Documer.t Control Desk Washington, D.C.
20555 Gentlemen:
In the Matter of
)
Docket Nos. 50-327 Tennessee Valley Authority
)
50-328 SEQUOYAH NUCLEAR PLANT (SQN) - NUCLEAR REGULATORY COMMISSION (NRC) INSPECTION REPORT NOS. 50-327/88-07 AND 50-328/88 RESPONSE TO INSPECTION FOR PIECE
. PARTS PROCUREMENT FOLLOH-UP Enclosed is TVA's response to S. D. Richardson's letter to S. A. White dated April 13, 1988, that requested TVA to respond in writing about how TVA plans to ensure, through inspections and inspection documentation, that' commercial-grade parts are adequately dedicated for use in safety-related systems.
This response was discussed with George T. Hubbard, of your staff, on May 27, 1988.
If you have any questions, please telephone J. D. Ziegler at (615) 751-8077.
Very truly yours, TENNESSEE VALLEY AUTHORITY l
l R. G idley, D1 ector Nuclear Lit.ensing and Regulatory Affairs Enclosure cc: See paga 2 8807120225 880706 ',
'J F '
DR ADOCK 0500 I
1 An Equal Opportunity Ernployer
^
,; ' ' ap.
U.S. Nuclear Regulatory Commission ggg cc (Enclosure):
Ms~. S. C. Black Assistant Director for Projects TVA Projects Division
-U.S. Nuclear Regulatory Commission
-One White Flint, North 11555 Rockville Pike s
Rockville, Maryland 20852-Mr F. R. McCoy, Assistant Director for Inspection Programs TVA Projects' Division U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Sequoyah Resident Inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy Daisy, Tennessee 37379 i
+
x ENCLOSURE Durtrig the inspection, TVA concurred with the NRC position that the licensee should have objective evidence available that demonstrates that critical characteristics have been met and that the critical characteristics identified -
in dedication packages should be verified for compliance during receipt inspection or verifled by other appropriate means and be adequately documented to support the conclusions.
The two basic questions set forth by the NRC' inspectors were:
1.
Should thread gages, six-inch pocket rules, fillet weld gages, tape measures, etc., be considered controlled and calibrated measuring and test equipment (M&TE); and, if so, why were they not so indicated on the inspection report?
2.
Can objective evidence that all dimensional inspections have been made be provided without documenting the actual as-found dimensions "or even a listing of the dimensions to be verified" for each inspection on the inspection report?
TVA's responses to these two basic questions are as follows:
'l.
The Quality Engineering Materials Unit has previously and will continue to maintain and control devices such as thread gages, weld gages, tape measures, and pocket rules (in addition to the calibrated measuring and test equipment [M&TE]) for use durlog receipt inspection activities.
These measuring devices, although not considered M&TE (as defined by the Nuclear Quality Assurance Manual), haven been provided with identification by type of device.
This identification by type will be documented on the inspection report as an enhancement to the existing program.
2.
Objective evidence of completion of dimensional inspections required by the dedication package has been provided by the quality control inspector's signoff on the inspection report.
To enhance this process, a checklist will be initiated and utilized when five or more measurements are to be inspected on each item. This checklist will provide assurance that each measurement for the more involved inspections has been completed and will be used as support data during review and final signoff of the inspection report.
The checklist will be discarded after completion of the inspection report and will not be maintained as a qu-lity assurance record. Any specific measurements that are found to be out of tolerance will continue to be documented on the inspection report.
.?
.,,w
-2 a
~
In addition to the two basic questions presented by the NRC, four other items were' identified concerning inspection documentation with respect to dedication
~
. packages. These. items have been' addressed as follows:
3.
Documentation shall include the number of items inspected - Provisions
-have been implemented requiring the number of units inspected for each contract item to be recorded on.the inspection report form.
4.
Documentation should include inspector criteria (i.e., dimensions with
_ tolerances) - The detailed inspection criteria required to ensure that commercial-grade items are adequately dedicated for use in safety-related systems are documented.in the dedication package prepared by the Contract Engineering Group for that item.
To comply with this requirement, the inspection report has been revised to require recording the dedication package number and attachment number that documents the dedication inspection criteria (including'the dimensions measured) used for the item being received.
5.
Documentation should include the i sector's name - The inspector's signature.is required on the inspection report form.
6.
Documentation should include the status of the item (i.e., acceptable /
unacceptable) - Each contract item inspected is recorded on the inspection report form as either satisfactory or unsatisfactory. Unsatisfactory item deficiencies are recorded on the inspection report form. Unsatisfactory items are tagged, segregated, and controlled in accordance with nonconforming item procedures.
As of the date of this letter, all of the procedural enhancements identified in items 1, 2, 3, and 4 are fully implemented.
Items 5 and 6 were elements of the original program.
In conclusion, our. existing program and the enhancements described above should meet or exceed TVA commitments and normal industry practice.
7
.