ML20154Q909

Responds to NRC Re Violations Noted in Insp Repts 50-327/85-49 & 50-328/85-49.Corrective Actions:Supports Brought Up to Current Insp Stds & All Mods & Maint Carpenters Instructed

ML20154Q909
Person / Time
Site:	Sequoyah
Issue date:	03/07/1986
From:	Gridley R TENNESSEE VALLEY AUTHORITY
To:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
NUDOCS 8603240170
Download: ML20154Q909 (6)

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7 (DM6 TENNESSEE VALLEY AUTHORITY CH ATTANOOGA. TENNESSEE 37401 LP SN 15715 Lookout Place u 3 !@,17 P 2 tia3qi 7, 1986 U.S. Nuclear Regulatory Commission Region II ATTN: Dr. J. Nelson Grace, Regional Administrator 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323

Dear Dr. Grace:

SEQUOYAH HUCLEAR PLANT UNITS 1 AND 2 - URC -OIE REGICH II INSPECTION REPORT 50-327/85-49 AND 50-328/85 RESPONSE TO VIOLATION Enclosure 1 is our response to J. A. Olshinski's February 6, 1986 letter to S. A. White transmitting IE Inspection Report Nos. 50-327/85-49 and 50-328/85-49 for our Sequoyah Nuclear Plant which cited TVA with one Severity Level IV Violation. Com.mitments are provided in enclosure 2. We do not recognize any other actions described herein au commitments.

If you have any questions, please get in touch with R. E. Alsup at FTS 858-2725.

To the best of Iny knowledge, I declare the statements contained herein are complete and true.

Very truly yours, TENNESSE' LLEY AUTHORITY R. Gridley.

Manager of icensing Enclosures cc: Mr. James Taylor, Director (Enclosures)

Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C. 20555 i

8603240170 860307-PDR G ADOCK 05000327 PDR An Equal Opportunity Employer I I'

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r ENCLOSURE 1 Resp 0USE - URC-ole INSPECTION REPORT UOS. 50-321/85-49 AND 50-328/85-49 J. A. OLSH1HSKI'S LETTER TU S. A. h'lllTE DATED FEBRUARY 6, 1986 Violation 50-327/8$-49-01 and 50-328/85-49-01 10 CPR 50 Appendix B, Criterion V, requires that activities affecting quality shall be prescribed by documented instructions, procedures, and drawings, and shall be accomplished in accordance with those instructions, procedures, and drawings.

Sequoyah inspection instruction No. 66, inspection of supports, requires that installation conforms to applicable drawings and that all bolts are properly engaged and tightened.

Contrary to the above, between December 16-20, 1985, activities affecting quality had not been accomplished in accordance with documented instructions and drawings in that a field inspection of eight supports revealed four seismically designed supports with the following deviations from the documented requirements.

1. Support No. 1 - AFD!(-24 4, Rev. 7, pipe clamp bolts on the snubber side was loose.

2. Support No. 1-AFDH-254, kev. 6 jam nut on the structural attachment side ot the sway strut was loose

3. Support No. 1- AFDil- 411, Hov. 1, item 2 of the vertical rod was bent.

4. Support No. 2-Slil-444A, Hev. 1, one of the two vertical trapeze rods was disconnected.

This is_a Severity Level IV violation (Supplement 1).

1. Admission or Denia_1 of _A_11eged Violation TVA admits that the violation occurred as stated.

2. Reason for Violation The violation occurred due Lo personnel error in that :

a. The bolts on Support No. 1-AFDH-244 appear to have been loosened while removing the Calcium Silicate insulation. (Violation Item No.

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b. The bent vertical rod on SupporL Ho. 1-AFDH-411 appears to have been-damaged due Lo modification and repair work ongoing in the area . j (scaffolding being beaced against rods). (violation Item Ho. 3)

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c. The vertical trapeze rod on Support No. 2-31H 444A appears to have been disconnected to provide clearance Lo perf orm work on valve FCV-63-4. (Violation ltem No. 4)

Ho evidence could be found to determino the reason the pipe clamp bolts were loose on Support !!o. 1-AFDH-254. (Violation ILea No. 2)

3. Corceetive Steps Taken and Results Achieved

a. The supports referenced in the Notice of Violation have been brought up to current inspection clandards. A walkdown inspection was perf ormed in Lhe Auxiliary Building to determine the severity of the problem. The walkdown team consisted of a mechanical engineer f rom the Modifications Group, two craftsmen, and a Quality Control (QC)

' inspector. The scope of the walkdown was to inspect as many accessible supports as possible, to tight i laose bolts and correct bend rods in the presence of a QC inspectr7, and noLe any other obvious problems. Supports inside C-zone areas and supports requiring scaffoldinn were not included in this inspection.

Approxi.nately 3,000 supports were inspected of which 66 (22 on pipe lar6er than two-inch diameter) were found to have loose bolted connections and 10 (seven on pipe larger than Lwo-inch diameLer) with bent or broken rudc. Approximately 90 other supports were found to exhibit probierm such au chipped grout under base plates, welds needing paint, and apparently missing Unistrut cla.tpu for instrument lines.

Of the 66 supports found to have loose bo1 Led connections, 30 were due to loose rods. Hudifications and Additions instruction-(M&AL)-11 concerning inctallation and incpection of seismic supporte states: "It is acceptable for a vertical support to have a tolul gap of 5/32 inch under the pipe, provided that the first vertical.

support upstceam and downstream of the subject support is in contact with the pipe." This statement implies that a vertical support may exhibit looco rods- provided adjacent vertical supports do not exhibit loose roda. Such was the case on all 30 loose rods found on

, the walkdown inspection. In order to enhance the margin available in the supports, the loouc rods were tightened during the course of the walkdown, and other noted cuspected discrepancies have been dispositioned.

Ten bent rods were identified. Two of these had scaffolding' built i around them. TVA concluded that modification and repair work caused the rod bending.

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b. In addition, Lhe siechanical Maintenance Section reviewed UNC's concern about the "handt.ight" acceptance criteria of H&A1 4 A determination has been cade that the bolted connection acceptance criteria in H&Al-9, step 6.2.3.1, is fully adequate to ensure connections are properly tight uL Lhc time the work is performed and inspoeted,

c. Also, NRC expressed concern that thu Sequoyah pipe Support Design Manual (pSDM), Volume 4, indicates tha all pipe clamp hex nuts should be replaced with two Jaa nuts, a d none of the supports observed had douhle jam nut installations. The Sequoyah Office ut Engineering (UE) concurs that the pSDM is a guideline used by pipe support designers, and its intended function is $ to define support installation criteria to the field. Sequoyah installs pipe supports in accordance with criteria spe: itled in G-43, "The Construction Specification for Support and installation of piping Systems in Category I Structures." paragraph 2.7, of G-43, addresses locking devices, but footnote 3 to paragraph 2./ indicates that locking devices are only required for plants under the jueisdiction of AS6E Boiler and pressure Vessel Code, section ill, subsection UF. BellefonLu Huclear Plant is the first TVA plant under the jurisdicLiun of subsection UF. Therefore, paragraph 2.7 of G-43 is not applicable to Sequoyuh.

4. Corcretive Steps Taken to Avoid Further Violation

a. All codifications and maintenance carpenters are to be instructed ici Lhe requirer.ents of Itazard Cositrol InsLeuction (liCI)-M2 as iL applies to scaffolds supported from CSSC equipcent with special emphasis on hangers. This llem will be compleLed by April JO, 1986,

b. TVA's Employee Concern program emphasizes that employees are obligated to report items found to be out of compliance with specifications or procedures. This has been explained to all site employees.

. c. The periodic performance of Surveillance Instruction (SI)-114 "preservice Baseline Inspection for Tennescoe Valley Authority Sequoyah Huclear PlanL," SI-114.1, "ASME Section XI In-Se'evice Inspection program Unit 1," and SI-ll4.2, "In-Spevice Inspection program for Tennessee Valley Authority Sequoyah Nuclear PlanL Unit 2 Only, " will encuro that any loose fasteners on code Class I, II, and III, pipe supports will be Identified'. The implementing Inspection Instruction NVT- 1, of Technical InstrucLion (TI)-51,

" Assignment of Detailed Test Methods and Responsibility f or Non-Destructive Tc; Ling," goes beyond the' normal scope of ASME, section XI, in that bane plates and anchorage are' included.

S1-162.1, " Snubber Visual. Inspection (flydraulic.and Mechanical),"

will ensure that loose fasteners on safety-related snubbces will be G

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l identified. 'The sis require checking for loose fastenern-and iniliuling work rcquests to correct the problem. Field Change i Request (FCR-4093) has been initiated to cdd a note to the 47A050 series, hanger installation notes, to allow the plant staff to take l remedial actions for loose fasLeners. Afler the. revision to drawing' -

4/A050 is issued, Mechanical Maintenance will take action (after approval by the office ot Engineecing) to cecure any support identified to havn loose facteners with an appropriate locking device. This action will bc Laken whether the loose fastenern are found during curveillance or maintenance-activities. The J

information contained in the plant instruction to ensure compliance and in 47A050's note will be included in UVT-1 to ensure that-

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In-Service Inspection Section is informed concerning requirements for locking devices. NVT-1 will be revised by September 5, 1936.

S. Dato When Full Co.npliance Will Be Achieved The plant was in full co.tpliance on February.24, 1986. 11owever, as stated in cection 4 above, the modificatiuns and mainLenance eurpenters will be lustructed in the requirements of IfCL-n2 by April .30, 1986,-and-UVT- 1 will be reviced by Seple.nber 5, 1986.

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O Ei! CLOSURE 2 COMMITi4EIIT3 MADE III HEupot!SE -TO 50-327, -320/85-49

1. By Septer.ber 5, 1986 revise inspection procedure NVT-1 Lo enuure titat the inservice inspecLlon Section. is inf or.ned, concerning requiretaents for locking devicec. The revision will reflect changes to add a note to 4 7A050 ceries hanger installation note pursuant to Field Change Request FCR 4093.

2. By April 30, 1936, Modificativus carpenters are to be inutructed in the require:nents of Hazard control Instruction (IICI-h2) an it applies to scaffolds fro.n CSSC equipment, with specific emphasis on hangers.

3. Liy April 30, 1986, Maintenance carpenters are to be instructed in the requireraents of Hazard Control Instruction (ItC1-H2) as it applies to scaffolds from CSSC equipment, with upecific emphacis on hangers.

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