ML20151R654
| ML20151R654 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 04/08/1988 |
| From: | Baker E, Hubbard G, Pierson R NRC OFFICE OF SPECIAL PROJECTS |
| To: | |
| Shared Package | |
| ML20151R600 | List: |
| References | |
| 50-327-88-07, 50-327-88-7, 50-328-88-07, 50-328-88-7, NUDOCS 8804280057 | |
| Download: ML20151R654 (15) | |
See also: IR 05000327/1988007
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UNITED STATES NUCLEAR REGULATORY COMMISSION
OFFICE OF SPECIAL PROJECTS
TVA PROJECTS DIVISION
Report Nos.: 50-327/88-07 and 50-328/88-07
Docket Nos.:
50-327 and 50-328
Licensee Nos.:
Licensee:
Tennessee Valley Authority
6N 38A Lookout Place
1101 Market Place
Chattanooga, Tennessee 37402-2801
Inspection Conducted: January 25-29, 1988
Inspectors:
MP 7'
George T. Hubbard
Date
Inspection Team Leader
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Edward T. Baker
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Senior Reactor Engineer
Approved by:
M
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Robert C. Pierson, Chifef
D' ate
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Plant Systems Branch
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8804280057 800413
ADOCK 05000327
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INSFECTION REPORT NO. 50-327,328/88-07 INPUT
INSPECTION SUMMARY
Inspection on January 25-29, 1988 (Inspection Report Nos.: 50-327/88-07 and
50-328/88-07).
Areas Inspected: Announced follow-up inspection to review the licensee's
corrective actions relative to findings identified in NRC Inspection Reports
50-327,328/86-61 and 50-327,328/87-40.
The Safety Systems Outage Modification
(Installation) Inspection (SS0MI) findings (identified in NRC Inspection
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Reports 50-327,328/86-68) that remained open following the 87-40 inspection
were not evaluated during this inspection.
Results: The inspection determined that TVA/SQN has implemented a program to
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correct procurement deficiencies identified in Inspection Report 86-61 and
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87-40. While the NRC has observed improvements in TVA's procurement of
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purchased parts due to their corrective actions, this inspection determined
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that SQN was still procuring comercial grade purchased parts without adequate
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dedication of the parts for use in safety-related applications. One apparent
violation and one inspection fol. low-up item were identified during the
inspection.
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Items Remaining Open from Previous Inspection Reports:
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Inspection Report 50-327,328/87-40:
Unresolved Item:
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1.
Adequacy of Seismic Evaluations of Replacement
50-327/87-40-01;
Parts for Seismically Qualified Equipment
50-328/87-40-02
New Items:
Apparent Violation:
1.
Failure to Take Adequate Corrective Action
50-327/88-07-01;
and Follow Procedures Relative to Dedication
60-328/88-07-01
of Commercial Grade Items for use in
Safety-related Applications
Inspection Follow-up Item:
1.
Documentation of Receipt Inspection Activities'
50-327/88-07-02;
for Comercial Grade Items
50-328/88-07-02
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1.0 PERSONS CONTACTED
1.1 Tennessee Valley Authority (TVA)
- S. Bargerstock, Supervisor, Contract Engineerivig Group (CEG)
- J. Zeigler, Licensing
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- G. A. Roberts Supervisor, Power Stores
- R. B. Constable, Quality Assurance (QA) Engineer
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- M. L. Crane, Assistant Material Manager
- J. M. Fontenot, Supervisor, CEG
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- G. C. Wilkerson, Sequoyah (SQN) Purchasing Representative
- D. Scheide, Licensing Engineer
- J. H. Sullivan, Supervisor, Plant Operations Review Staff (PORS)
- C. McWherter, Materials Manager
- T. E. Spink, Replacement Items Project (RIP), Project Manager
- J. R. Watson, Supervisor, QA Materials
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- L. E. Martin, Site Quality Manager
- J. L. Hamilton, Quality Er.gineering Manager
- S. A. Abu-Yousif Technical Support
'*P. R. Wallace, Site Director's Office
- G. B. Kirk, Complianc'e Licqnsing Manager
D. L. Paul, Project Manager, Project Managers Staff
J. Wheeler, Assistant Manager, Nuclear Maintenance Division
D. Mack, Engineer, RIP
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T. Chiles, Materials Manager
F. Campbell, Licensing
B. Peavyhouse
M. Bishop, EA Engineer
1.2 Consultant
J. Ferguson, Senior Engineer, Impell
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2.0 BACKGROUND
In September 1986, an inspection of Sequoyah's (SQN) procurement activi-
ties was performed and documented in Inspection Report 50-327,328/86-61
(86-61).
In response to this inspection, TVA developed the Replacement
Items Program, created the Materials Management organization, reinserted
engineering into the procurement cycle, established a corporate level
Maintenance Manager, and initiated major revisions to the procedures
governing procurement, receipt inspection, and engineering evaluation of
replacement items.
In July 1987, the NRC reviewed TVA's activities to
correct the problems identified in 86-61 and documented the results in
Inspection Report 50-327,328/87-40(87-40).
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3.0 SCOPE
This inspection was a follow-up to the 87-40 inspection and focused on
procurement related findings remaining open following that inspection.
One finding of the 87-40 inspection concerning(the Fifth Vital Battery)
Room was reviewed.
SSOMI inspection findings Report 50-327,118/86-68
that were still open following the 87-40 report were not reviewed during
this inspection.
4.0 FOLLOW-UP OF INSPECTION REPORT 50-327,328/86-61 OPEN ITEMS
4.1 Potential Enforcement Findings
50-327/86-61-01 and 50-328/86-61-01 (Closed).
Failure to take
adequate corrective action in procurement of safety-related equipment
and storage and retrieval of QA records.
In the 87-40 Inspec' ion Report, this finding remained open pending a
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decision regarding enforcement.
Based on NRC review of this 86-61
finding and its similarity to the apparent violation identified
during this inspection and discussed in paragraph 5.2.2.1 of this
report, this finding i,s closed.
4.2 Procurement Implementation items
Paragraph 6.b.3 of report (Closed).
Normal f.eed breaker to reactor
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vent board 28-8 (2-BDC-201-JQ-P).
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Paragraph 6.b.4 of report (Closed). Auxiliary relay in 6.9KV
shutdown logic relay cabinet 2A-A (2-PNLB-202-SC-A).
Paragraph 6.b.6 of report (closed).
Diesel generator air start
motors.
Paragraph 6.b.7 of report (Closed).
Shutdown board 2A-A logic relay
panel (2-BDA-202-CO-A).
The concerns documented in inspection report 86-61 relative to the
four items above dealt with TVA's documentati6n to support the
seismic qualification of these replacement parts used in
safety-related applications.
During 6nd following the 87-40
inspection TVA provided the NRC information to support qualification
of these items based on information from an earthquake experience
data base; however, SQN equipment is requirtM to be seismically
qualified to the requirements of IEEE-344/19.5 which is more
stringent.
Since the earthquake data base method is not equivalent
to the IEEE-344/1976 qualification, the use of the earthquake
experience data base is not considered acceptable for the long term.
However, as discussed in paragraph 5.1 below, the earthquake data
base method is acceptable for establishing the qualification of
replacement items for use in seismically sensitive equipment for the
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near term and for restart of SQN.
For these re'asons, these four
items are considered resolved for restart of SQN.
For the long term, these items are considered specific examples of
the overall seismic qualification problem discussed below in
paragraph 5.1.. Resolution of the overall seismic qualitication
problem for the long term will resolve these specific items.
Since
the NRC is working with TVA to resolve the long term qualification
problem, these specific items are closed.
For the long term program, TVA should be aware that the NRC has
identified concarns with the seismic qualification of electrical
relays and is working to resolve the concerns under Generic Issue
114.
Once the issue is resolved, TVA will be expected to incorporate
any required license action into their long term program as
appropriate.
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5.0 FOLLOW-UP OF INSPECTION REPORT 50-327,328/87-40 CPEN ITEMS
5.1 Unresolved Items
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50-327/87-40-01 and 50-328/87-40-02 (0 pen). Adequacy of seismic
evaluations of replace' ment p, arts for seismically qualified equipment.
The 87-40 report discussed this item relative to two concerns: (1)
the appropriateness of usirg the earthquake experience data base for
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demonstrating that TVA piece part replacement activities have re-
degraded the seismic qualification of the equipment; and (2) it tar
data base is acceptable, whether TVA is adequately justifying and/or
documenting their conclusions.
5.1.1.
Relative to the first issue, TVA submitted a letter to the
NRC, dated August 14, 1987, subject "SEQUOYAH NUCLEAR PLANT
(SON) - REPLACEMENT ITEMS PROGRAM (RIP) SEISMIC SCREENING
METHODOLOGY," stating their position regarding the use of the
experience data base.
In response to this letter, the NRC sent
a letter from J. G. Keppler to S. A. White, dated October 29,
1987, stating the NRC position on this subject.
The NRC stated, "The staff is unable to accept TVA's position
that the historic data base review conducted at Sequoyah as part
of the replacement parts programs is sufficient for the lo y
term to ensure that initial equipment qualification to
IEEE-344/75 has not been compromised by using unqualified
seismically sensitive replacement parts." The letter further
stated that based on technical considerations and the historical
reasons TVA used this approach, the staff was prepared to eccept
the technical basis of the TVA screening methodology "as an
interim justification for establishing the qualification of
replacement items for use in seismically sensitive equipment."
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Certain provisions were attached t'o'this' fnterim acceptance and
were described in the letter.
The first provision was that TVA should submit a detailed
program plan describing how SQN would ensure full compliance
with the applicable portions of IEEE-344/75 prior to the end of
the cycle 4 refueling outage.
The second provision was that the
"seismic sensitivity screening" reviews be upgraded prior to SQN
restart (Mode 2) to support the short term "interim justifica-
tion" for qualification of replacement items. -This second
provision is discussed in paragraph 5.1.2.
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With regard to the first provision, TVA comitted to submitting
a program plan to describe how SON will ensure compliance with
the applicable portions of IEEE-344/75 prior to the end of the
cycle 4 refueling outage.
This comitment was made in a letter
to the NRC from R. Gridley, dated December 8, 1987, subject,
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"SEQUOYAH NUCLEAR PLANT (SQN) - REPLACEMENT ITEMS PROGRAM (RIP)
SEISMIC ADEQUACY VERIFICATION." At the time of the inspection,
TVA had not submitted the plan.
Pending NRC review ano approval
of the plan and review of the TVA's implementation of the plan,
this item romaint open.
5.1.2
Relative to the adequac'y of justifications and/or documentation
of TVA's conclusions regarding seismic screening review packages
based on the earthquake experience data base, the NRC inspectors
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reviewed a sample of packages which had been upgraded since the
87-40 inspection in July 1987.
Of the 15 packa
four pertained to maintenance requisition (MR) ges reviewed,
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A-299-409, 20690, and A-5-29910 and trouble report (TR) 01563
which were discussed in 87-40. Three of these four packages
were not comoleted and approved at the time of the inspection;
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however, they were re. viewed since they had been the subject of
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discussion during the 87-40 inspection.
The inspectors' review of the fifteen packages identified only
one completed package where they had questions. The one
question concerned the addition of weights and balances to the
EGTS Backdraft Damper (MR 075110).
TVA was able to resolve the
question by demonstrating that the MR only added weights of 2.5
pounds and the dampers were qualified with weights up to 6
pounds.
While the inspectors' review of the upgraded pacirages jetermined
them to be an improvement over the packages reviewed in July
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1987, the inspectors stressed the importance of adequate
documentation of TVA's justifications relative to the seismic
qualification of installed equipment.
The inspectors stressed
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this to be especially true for those packages which r
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justified by the experience data base and require ah.itional
evaluations.
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Based on the inspectors' review an'd'the in'terim justification
criteria for seismic qualification discussed 'in paragraph 4.1.1-
above, the NRC determined that TVA's program for installed
seismically cua11fied equipment, including upgraded justifica-
tion packages and seismic evaluations as needed, would be
adequate to support restart of SQN Unit 2 when the program is
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completed.
Based on the inspection results, this part of the
unresolved item is closed.
5.2 Inspection Follow-up Items (IFIs)
5.2.1
50-328/87-40-01 Verification of seismic tasks completion.
(Closed)
In the 87-40 report two issues were addressed under this IFI.
The first issue pertained to verification that a pipe hanger
installed in the waste disposal system (WDS) under MR 48452
(87-40 mis-identified MR as 48482), dated April 17, 1979, was
part of the original installation. In respon.se to the
inspectors' questions on the hanger, TVA responded that the WDS
was part of the design reconciliation effort which would resolve
this issue prior,to restart.
During this inspection,' the NRC inspectors determined through a
review of documentation that the WDS was a part of the design
reconciliation effort and that the activities are not restart
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items.
Based on a October 2,1987 letter from R. Gridley to the
NRC, the scheduled completion date is April 1,1988.
Since the
hanger issue will be resolved by the design reconciliation
effort, this item is closed.
The other issue pertained to MR A-112165, dated October 27,
1983, upper head injection (VHI) room and the inspectors'
observation that finger clamps were missing from the conduit.
The inspectors discussed-this item with TVA and determined that
the inspection report had incorrectly identified the issue as
being on Unit 2 when it was actually a Unit 1 observation.
Since thic issue had no affect on the Unit 2 restart and the
intpectors verified that a work request had been written to
'orrect the problem, this issue is closed.
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5.2.2
50-327/87-40-02 and 50-328/87-40-03 (Closed).
package preparaticn, inspection instructions for receip1;
inspectors, and missing MRs.
5.2.2.1
Dedication Package Preparation:
In reviewing TVA's program
for the control of their preparation of dedication packages
(DPs), the inspectors reviewed the following procedures /
instructions:
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SQA45, "Procurement of Materi' lt, 'Com'ponents, Spare Parts,
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and Services," Revision 29, dated Octobe'r 19, 1987.
SQA170, "Issuance of Materials, Components, and Spire
Parts," Revision 0, dated October 16, 1987.
TI-105, "Dedicating Commercial Grade Items for Use as Basic
Components," Revision 1, dated August 18, 1987, plus
changes includea in an instruction change form dated
October 30, 1987.
TI-110. "Procurement of Repiacement Items for Use in
Permanent Equipment, Systems and Structures," Revision 0,
dated October 19, 1987.
In addition to the above procedures / instructions review, the NRC
inspectors reviewed 19 out of a total of approximately 260 DPs
which had been prepared by the contract engineering group (CEG)
at SQN, Four of the DPs reviewed were identified as having the
same problems which resulted in the Potential Enforcement
Finding of NRC Inspection Report 86-61. The inspectors provided
comments and/or r,ecommendations for four other DPs. The
remaining eleven ops wqre considered acceptable.
Dedication package 5098 for an adapter bushing established
critical characteristics for dedication as material and
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dimensions.
Dimensions were chocked by TVA QC inspectors;
however, the material was accepted based on a Certification of
Complianca (C0C) from the supplier.
This supplier was listed on
the TVA Approved Supplier List (ASL) as qualified to provide
material under their ASME Certificate of Authorization and their
ANSI N45.2 QA Program.
However, the bushing was ordered QA
Level II (commercial grade) and the suppliers controls on
commercial grade products had not been reviewed and approved by
TVA.
Therefore, there was no basis for establishing the
validity.of the COC.
Dedication package 5137 for a temperature switch stated that the
replacement was a "like-for-like replacement" and that purchas-
ing and dedication by part number alone was acceptable.
This is
contrary to paragraph 11 of Attachment 4 to Temporary
Instruction TI-105.
Paragraph 11 states, "A check that the part
number is the same does not indicate that an item is a direct
replacement. Critical characteristics must be checked." The
part was transferred from the Watts Bar plant as QA Level II and
receipt inspection and acceptance was based solely on part
number.
Dedication package 5243 for a safety relief valve identified
adequate critical characteristics for dedication; however,
receipt inspection was based on part number verification and a
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COC from the supplier.
As in OP 5098 above, the vendor was on
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the ASL for his ASME programs; however, the part was ordered QA
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Level II (commercial grade) and the suppliers controls on
commercial grade products had not been reviewed and approved by
TVA. Therefore, there was no basis for establishing the
validity of the C0C,
Dedication package 5252 for a valve positioner identified
critical characteristics for dedication as being the model and
part number and receipt inspection was based on verification of
the model and part number.
In this particular case the vendor
had no applicable QA program, was not on the TVA ASL, and the
bases for using the vendor was that he was the original
equipment manufacturer.
Based on this, TVA had no valid basis
to dedicate the positioner solely on model and part number.
The inspectors asked questions on DPs 5008, 5025, and 5191
relative to post-installation testing adequacy for dedication.
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In DP 5008 post-installation test was initially required for
dedication then it was cancelled without any documentation of
the reason.
The inspectors were able to determine that
post-installation testing was actually performed and it was
adequate to demonstrate its function for its in-plant
application.
Questions' on DPs 5025 and 5191 relative to
post-installation testing were resolved when it was determined
that one DP was not needed and would be cancelled and the
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solenoid valves of the other DP were not needed due to a system
modification and the valves were subsequently surplused.
The
inspectors stressed to TVA the importance of ensuring that
post-installation testing requirements in DPs are clearly
defined.
The inspectors' review of DP 5175 for a linear amplifier
determined that it was classified as QA Level II (commercial
grade) procurement; however, TVA imposed ANSI N45.2 on the
vendor. The vendor was on TVA's ASL for ANSI N45.2.
The review
further determined that 10 CFR Part 21 was not imposed for the
procurement.
In discussion with TVA as to why the procurement
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was not classified as QA Level I since the procurement invoked a
nuclear specific specification, TVA explained that even though
the vendor would accept a procurement under ANSI N45.2 they
would not accept 10 CFR Part 21.
The inspectors discussed with TVA the NRC position that when a
nuclear specific specification (in this example ANSI N45.2) is
imposed in procurement documents, that the procured item cannot
be classified as commercial grade. The NRC position is that the
item would not meet the definition of commercial grade item
defined in 10 CFR Part 22.
In this example the amplifier should
nct have been classified commercial grade and 10 CFR Part 21
should have been imposed.
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The inspectors acknowledged the problenis f' acing a licensee when
a vendor will not accept 10 CFR Part 21. The' inspectors
suggested that TVA include 10 CFR Part 21 in all procurement
documents as appropriate and negotiate with the vendor
concerning its inclusion if he will not accept 10 CFR Part 21.
When the inspectors determined that the reviews identified some
of the same problems which the NRC had identified in earlier NRC
procurement inspections, the' inspectors met with TVA corporate
and Sequoyah site management to apprise them of the review
results. Based on discussion with TVA management, TVA took
insnediate action to establish the scope of the problem, to
prevent potentially improperly dedicated items from being issued
from power stores and installed in the plant until proper
dedication could be verified, and to implement corrective action
to prevent the problem from occurring in the future.
In
conjunction with these activities TVA wrote condition adverse to
quality report (CAOR) number SQN880088, dated Janucry 27, 1988
to address the NRC concerns.
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In defining the scope of the problem, TVA reviewed all of the
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approximately 260,DPs generated by CEG to identify which DPs had
the same problems identified during this inspection.
From this
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review TVA identified 19 DPs (in addition to the DPs identified
inspectors.
Including the DPs identified by the inspectors TVA
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by the NRC) which had similar problems as identified by tw NRC
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identified 10 packages which covered equipment issued to the
plant.
Prior to the end of the inspection TVA was able to
satisfactorily demonstrate that all equipment covered by these
10 DPs were acceptable for perfonning their respective
safety-related functions.
This demonstration for equipment
installed in the plant alleviated NRC concerns relative to
restart of Unit 2.
Suninary: With consideration of the fact that the NRC inspectors
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identified some of the same problems identified in previous
inspections and the fact that the TVA Replacement Items Program
was created to prevent these problems from occurring, these
inspection findings are considered an apparent violation of NRC
requirements for failure to take adequate corrective action and
failure to follow procedures.
This apparent violation is
identified as inspection item 50-327,328/88-07-01.
In vie,w of
this apparent violation, the DP portion of IFIs 50-327/87-40-02
and 50-328/87-40-03 are closed.
5.2.2.2
Inspection Instructions for Receipt Inspectors: As part of
the inspection of receipt inspection, the inspector reviewed the
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following procedures / instructions which apply to receipt
inspection activities:
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AI-11, "Receipt Inspection, Noncoriforining Items, QA
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Level / Description Changes and Substitutions," Revision 44,
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dated October 27, 1987.
QMI 710.2, "Inspection Plans," Revision 0, dated July 16,
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1987;
QMI 710.3, "Inspection Reports," Revision 0, dated July 16,
1987.
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Inspection Plan (I.P.) No. U01-0001, "Receipt Inspection,"
Revision 1 dated November 12, 1987.
I.P. U01-0002, "Receipt Inspection," Revision 2, dated
November 12, 1987.
In addition to reviewing the above instructions / procedures, the
inspectors reviewed eight receiving inspection reports (IR)
associated with seven DPs.
Two of the eight were determined to
be acceptable and problems / comments were discussed with TVA on
the remaining six.
The inspectors identified problems with the dimensional
inspections documented by irs R-87-0019 and -0020, which
received items under DP 5138.
No tools were listed on the irs
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that could have been used to verify thread type or threads per
inch. The inspectors were told by the supervisor for the
inspection area that uncontrolled thread gages were used to make
these measurements. Additionally, there was insufficient
objective evidence that the dimensional inspection had been
performed. The objective evidence consisted of an item number
marked next to the general inspection attributes "Dimensions"
and "Special Inspection," but there were no records of the
actual measurements taken or even a listing of the dimensions
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that were to be verified and an inspector sign-off that each
dimension required to be verified for dedication had been
measured.
Inspection report R-87-0383 was generated to document the
results of an inspection of ASTM A-307 bolts being dedicated
under DP 5116. The DP required that 3 of 10 bolts be
dimensionally inspected and tested for hardness.
The DP
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required the bolts to be inspected using "G0/N0-G0" thread gages
or an equivalent mernnd.
The only piece of inspection equipment
listed on the IR was a dial caliper (E09528). When asked how
threads per inch, thread type, and hardness had been verified,
the inspectors were informed that uncontrolled equipment had
been used to verify threads per inch and thread type and that a
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Certified Material Test Report (CMTR) supplied by the vendor had
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been the basis for acceptance for hardness.
The QC inspection
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group had not received documented pehnissfon from CEG to waive
the hardness testing upon receipt.
Inspection report R-87-0237 was generated to document the
results of an inspection of terminal lugs under DP 5065. The DP
required part number, size, and Underwriters Laboratory (UL)
label or marking be verified as required by the purchase
requisition (PR). The PR included minimum hole size as a
requirement.
In reviewing the inspection report, the inspectors
noted that no measuring or test equipment was listed as being
used and the block next to the general attribute "Dimensions"
,
was marked "NA" (not applicable).
Inspection report R-88-01342 was generated to document inspec-
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tien of wire mesh being dedicated under DP 5313. The critical
chtracteristics listed in the DP were wire diameter, mesh hole
size, and material. The inspection report indicated that the
dimensional inspection had been accomplished using a dial
caliper and the material was accepted based on a CMTR received
from the vendor. The vendor's commercial quality program had
been reviewed and approved by TVA. However, the CMTR was from a
third party (the , manufacturer of the wire) who had not been
reviewed and approved by TVA. As such, a separate tese of t:,e
material should have been performed upon receipt of the
material.
Inspection report R-87-0336 documented the performance of a
reinspection of carbon steel, ASTM A-307, Grade A bolts to the
requirements of TI-105 Attachment 5 for DP 5016.
This report
listed a dial caliper as the only piece of measuring and test
equipment (M&TE) used for the inspection. Thread type and
threads per inch were verified by uncontrolled thread gages.
The NRC comments provided earlier for irs R-87-0019 and -0020
are equally applicable for this IR.
During the review of IR 87-0336 and its associated DP, the
inspectors identified that the DP called for the procurement to
be classified QA Level II (comercial grade) and invoked ANSI
N45.2Property "ANSI code" (as page type) with input value "ANSI</br></br>N45.2" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. for a QA Program; however, 10 CFR Part 21 was not invoked.
This situation is identical to the situation discussed for DP
517E in paragraph 5.2.2.1; therefore, the coments provided
there are also applicable for this case.
After reviewing the irs, the inspectors discussed with TVA the
NRC position that when critical characteristics are identified
for inspection in DPs, the characteristics should be inspected
with controlled and calibrated M&TE and inspection documentation
should demonstrate that identified inspection requirements have
been met.
This documentation should include, but not be limited
to, number of items inspected, inspection criteria (i.e.
dimensions with tolerances), actual measurcrents obtSt.u d,.".'.TE
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used, inspectors name, and whether oi n'ot'the. items are
acceptable.
This NRC position is based on the fact that the
process of dedication provides licensees the means to use a
comercial grade item in a safety-related application in a
nuclear plant; therefore, the licensee should have objective
evidence available which demonstrates that critical
characteristics, necessary to ensure the item's suitability to
perfom its safety-related function in the plant, have been met.
Summary: While the NRC review of the receipt inspection process
determined that improvements have been made since the 87-40
inspection, additional improvements are in process. Among
improvements observed by the NRC inspectors was the segregation
of material which had been received but not receipt inspected,
establishment of a receipt inspection area with some inspection
equipinent, segregated areas for nonconforming materials, and
improved receipt inspection documentation.
While improvements in receipt inspection as related to DPs were
observed, the above identified problems with the reviewed
inspection reports indicates that work is still needed to ensure
that critical characteristics identified in OP inspection
requirements are verified for compliance during receipt
inspection or by other appropriate means and that documentation
supports the conclusions.
,
Since discussions with TVA indicated some disagreement with the
NRC position regarding the documentation details necessary for
ensuring DP critical characteristics were being met, TVA is
requested to respond in writing to the above NRC stated position
by describing how they plan to ensure, through inspections and
inspection documentation, that comercial grade items are
adequately dedicated for use in safety-related systems.
Since TVA is still making improvements in their receipt inspec-
tion area and based on NRC findings during this inspection TVA
is requested to respond to the NRC position concerning
documentation requirements for demonstrating DP inspection
requir.ements have been met. A new inspection follow-up item
(50-327,328/88-07-02) is identified relative to these items.
In
view of the new IFl. the related portion of IFIs 50-327/87-40-02
and 50-326/8740-03 are closed.
While'an IFI was identified above, the inspectors considered
TVA's receipt inspection process to be satisfactory to support
restart of SQN Unit 2.
5.2.2.3
Missing MRs: The NRC inspectors reviewed TVA's actions rela-
tive to approximately 3000 maintenance requests (MRs) which were
identified to the NRC as being missing during the 87-40
inspection.
Since the 87-40 inspection, TVA reduced the number
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to approximately 2250 MRs.
Since TVA has been unable to find
any of the remaining missing MRs, they performed an analysis of
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the relative impact that these MRs would have o~n the
qualification of installed 10 CFR 50.49 equipment.
The inspectors reviewed the TVA analysis that concluded that
since only five items of equipment were replaced in 10 CFR 50.49
qualified equipment as a result of the RIP evaluation of over
192,000 MRs, the probability of one of the missing MRs
introducing unqualified material into the plant was extremely
small.
TVA also felt that if unqualified material had been
introduced into the plant by the missing MRs, it would have been
discovered by equipment functional testing.
Based on the
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inspectors' review of the analysis and discussions with TVA, the
inspectors found the TVA conclusion to be acceptable.
Therefore, the missing MR portion of IFIs 50-327/87-40-02 and
50-328/87-40-03 are closed.
5.2.3
50-327/87-40-03 and 50-328/87-40-04 (Closed). Walkdown
inspection observations in fifth vital battery room.
The NRC inspector,s verified that TVA issued "Clearance Order,"
number 1606, dated Sept; ember 1,1987, concerning the fifth vital
battery room. This order identified that no credit could be
taken for the fifth vital battery room during plant operations
until deficiencies with the room, identified during NRC
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inspections, are corrected.
Since NRC-inspection report
50-327,328/87-76 has identified unresolved items
(50-327,328/87-76-03) to follow TVA's resolution of NRC
identified deficiencies (including these IFIs) with tiie fifth
vital battery room, these IFIs are closed.
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Mr. S. A. White
.
Tennessee Valley Authority
Sequoyah Nuclear Plant
SUBJECT:
FOLLOW-UP INSPECTION FOR PIECE PARTS PROCUREMENT (50-327/88-07
AND 50-328/88-07
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DISTRIBUTION (w/ enc 1):
(DC5-(Docktt: Fo. 50-327/328)
~
LPDR
OSP R/F
TVA R/F
JPartlow, NRR
BGrimes, NRR
FMiraglia, NRR
SEbneter
JAxelrad
SRichardson
GZech
BDLiaw
i
KBarr
RHermann
RPierson
,
EMarinos
GHubbard
EBaker, NRR
j
JDonohew, OSP
FMcCoy, RII.
BHayes, 01
SConnelly, OIA
EJordan, AEOD
JRutberg, OGC
i
TVA-Rockville
Resident Inspector
ACRS (10)
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