ML20151Q892
| ML20151Q892 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 04/20/1988 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8804270164 | |
| Download: ML20151Q892 (6) | |
Text
s TENNESSEE VALLtlY AUTHORITY CHATTANOOGA, TENNESSEE 37401 SN 1578 Lookout Place APR 201988 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C.
20555 Gentlemen:
In the Matter of
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Docket Nos. 50-327 Tennessee Valley Aut.hority
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50-328 SEQUOYAH NUCLEAR PLANT (SQN) - NRC INSPECTION REPORT NOS. 50-327/87-18 AND 50-328/87 SUPPLEMENTAL RESPONSE TO NOTICE OF VIOLATION NOS.
50-327/87-18-01 AND 50-328/87-18-01 Enclosed is TVA's response to S. D. Ebneter's letter to S. A. White dated March 18, 1988, that requested resubmittal of the response for example 8 of the Notice of Violation 50-327, AND 50-328/87-18-01. provides TVA's resubmittal of the response to example 8. contains a list of commitments contained in this submittal.
If you have any questions, please telephone M. R. Harding at (615) 870-6422.
Very truly yours, TENN S EV AUTHORITY
. G idley, Dir ctor Nuclear Licens ng and Regulatory Affairs Enclosures cc: See page 2 l
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DR An Equal Opportunity Employer
. U.S. Nuclear Regulatory Commission
/(pl}gQ]ggg cc (Enclosures):
Mr. K. P. Barr, Acting Assistant Director for Inspection Programs TVA Projects Division U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NH, Suite 2900 Atlanta, Georgia 30323 Mr. G. G. Zech, Assistant Director for Projects TVA Projects Division U.S. Nuclear Regulatory Commission One White Flint, North i
11555 Rockville Pike Rockville, Maryland 20852 Sequoyah Resident Inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy Daisy, Tennessee 37579 1
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ENCLOSURE 1 ViolatMn 50-327,
?8/87-18-01 "Criterion XI of 10 CFR 50 Appendi 8, as implemented by TVA Nucle,r 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, i
Criterion XI requires that the test program be performed in accordance with written test procedures which incorporate applicable requirements and acceptance limits; that the test procedures include provisions for assuring j
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 casas 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.
1 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 TVA to resubmit a response to example 8 and discuss "... long term corrective action and program improvement with regard to the extent with which you apply skill of the craft for work activities...."
This request is based on their analysis as follows:
"However, we do not concur with your con:lusion that removai and l
reinstallation of the bolted flange would mat require any special work instructions or verification and would be within the skill of the craft.
Sequoyah Maintenance Instruction (MI)-6.15, ' General Procedure, Tightening Bolted Joints,' is applicable to this installation and would provide for 1
configuraticn and radiological controls and documentation of proper assembly.
He note that the work request for performance of the verification disassembly / reassembly on the flanged joint specified the work to be done in accordance with MI-6.15.
He also note that the joint was found to have a fastener (nut) missing, which resulted in the performance of additional inspections on the three othe. boric acid transfer pumps.
In addition, we consider that the need for (or performance of) disassembly of instrument lines and maintenance / repair activities such as removal of line blockages should be formally documented.
The fact that nc 'special work instructions' are required or that craft personnel have the training or skills needed to perform an activity does not eliminate the necessity of controlling and documenting work activities on safety related hardware as required by 10 CFR 50, Appendix B.
For example, removal of boric acid crystals on this contaminated system 1
could require additional radiological controls and the lack of documentation for breaking of additional tubing joints would probably result in no post assembly leakage check."
. TVA Resconse Admission or Denial of the Alleged Violation TVA admits the violation.
Reason for the Violation As previously stated in TVA's response dated January 26, 1988, "... TVA researched maintenance activities 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." TVA can only conclude that, at some ttJe, unauthorized work was performed.
In addition, during the performance of the work request to ensure proper installation and doct, mentation, it was discovered that one fastener (nut) was missing.
The reason for the missing nut was inappropriate work practices and inattention to detall during performance of work on this component.
Corrective Steps That Have Been Taken TVA has replaced the missing fastener (nut).
In addition, inspections (as noted in your letter) were performed on the other three boric acid transfer pumps to ensure there were no fasteners missing. Management has stressed the importance of performing work by procedures and "attention to detail." TVA agrees that disassembly / reassembly of this flange, although considered "skill of the craft," should not have been performed without use of applicable procedures. This is evidenced by the use of MI-6.15 to perform the verification work.
TVA has reviewed the procedural ~ requirements that existed during the time '
period when this violation was identified and has determined that these requirements were vague. SQH2 has been revised to provide positive controls over skill of the craft by replacing the word "should" with "shall." The j
revised procedural requirements in SQM2 are as follows:
i "Maintenance activities which can be performed using the skills normally possessed by qualified maintenance personnel according to job classifications.
(journeyman, machinist, certified welder, etc.) may be considered
' skill-of-the-craft'.
The planner and the cognizant responsible supervisor shall be responsible for determining if the maintenance activity falls within the ' skill-of-the-craft.'
The ' skill-of-the-craft' designation is included in this instruction to provide guidelines to the maintenance staff in determining the amount of detail needed for a particular task. Maintenance activities which involves
' skill-of-tne-craft' do not require step-by-step details for the actual performance of the work. Several of the listed activities may require configuration control and QC inspection. Additional details such as material type or specifications, relay model number, and torque requirements shall be specified when required.
These maintenance activities shall be performed and documented within the MR/HR requirements of this procedure.
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Personnel performing maintenance activities as ' skill-of-the-craft' shall do l
so in strict compliance with the conditions and scope of the WR/HR.
If during l
the performance of the activity it is determined that either the scope of the l
activity has increased or the conditions are not as expected, contact the l
responsible foreman for potential replanning.
Additional planning requirements for ' skill-of-the-craft' maintenance activities are contained in section 9.3.3.
The planner shall document the vork instructions on either the HR card or an HR form, depending on the type of equipment involved and the type of i
procedures referenced in the instructions.
hrs shall refer to approved instructions such as maintenance instructions unless the maintenance to be performed involves ' skill-of-the-craft.'
For l
' skill-of-the-craft' maintenance activities, the planner shall provide instructions to direct the craftsmen in the performance of the designated work. Also, the planner shall provide the level of planning needed to ensure that the work can be correctly completed while meeting all applicable site procerfures....
The planner shall provide sufficient information in the work instruulons for activities considered within the ' skill-of-the-craft' so that the craft have effective guidance to work the job. The planner shall give special information such as torque values, clearances, alignment specifications, special inspection requirements, and part and lubrication specifications, if required.
This special Inforniation listed on the HR shall be taken from controlled manuals (per AI-23), or controlled drawings (per AI-25), or approved Field Change Requests (FCRs) and Workplans (HPs) as specified in Step l
9.3.3.7."
TVA considers the previously described procedural changes and the increased management attention adequate to resolve the concern involving I
skill-of-the-craft activities.
Corrective Steps That Will Be Taken to Avoid Further Violations All craft personnel will be instructed to perform work in accordance with approved procedures, and the importance of attention to detail will continue to be stressed.
This trainbg will be conducted during the monthly safety l
meetings.
1 In addition to the above-stated actions, SQN plans to decrease the use of skill-of-the-craft. Management considers that adequate work details should be i
provided for each task performed elther by use of a procedure or by adequately detailed information on a work request.
This planned evolution will be phased in concurrently with tne HI Enhancement Project detailed in our february 27, 1988 response to Inspection Report 50-327, -328/87-37.
This is a long-term project with an expected completion date of February 1, 1992. Any j
further updates of this planned action to delete skill of the craft will be i
submitted concurrently with the HI Enhancement Project sutmittals.
Date When Full Compliance Will Be Achieved TVA is in full compliance.
Training will be completed by June 10, !?88.
1.
Complete procedueal compliance training of craft personnel by June 10, 1988.
2.
Provide supplemental status on decreased use of skill of the craft concurrently with HI Enhancement Project submittal. Scheduled completion date is February 1, 1992.
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