ML20196G855
| ML20196G855 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 06/28/1988 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8807060044 | |
| Download: ML20196G855 (7) | |
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p TENNESSEE VALLEY AUTHORITY CHATTANOOGA, TENNESSEE 374of SN 157B Lookout Place
'JUN 281988 U.S. Nuclear Rcgulatory Commission ATTN:
Document Control Desk Washington, D.C.
20555 Gentlemen:
In the Matter of
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Docket Nos. 50-327 Tennessee Valley Authority
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50-328 SEQUOYAH NUCLEAR PLANT (SQN) UNITS 1 AND 2 - NRC INSPECTION REPORT NOS. 50-327/88-19 AND $0-328/88-19 RESPONSE TO NOTICE OF VIOLATION 50-327, 50-328/88-19-01 AND 03 Enclosures 1 and 2 provide TVA's response to Kenneth Barr's letter to S. A. White dated May 27, 1988, that transmitted the subject Notice of Violations.
Summary statement of commitments contained in this letter are provided in enclosure 3.
Please direct questions you may have concerning this issue to M. A. Cooper at (615) 870-6549.
Very truly yours, TENNESSEE VALLEY AUTHORITY R.
ridley, D rector Nuclear Licensing and Regulatory Affairs Enclosures cc:
See page 2 i
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8807060014 880628
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PDR ADOCK 05000327 a
PDC An Equal Opportunity Employer
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. U.S. Nuclear Regulatory Commission
. UN 281988 cc (Enclosures):
Mr. F. 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 Ms. S. C. Black Assistant Director for Projects TVA Projects Division U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Sequoyah Resident Inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road SodGy Daisy, Tennessee 37379 l
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..o-ENCLOSURE 1 RESPONSE TO NRC INSPECTION REPORT NOS. 50-327/88-19 AND 50-328/88-19 K. P. BARR'S LETTER TO S. A. WHITE DATED MAY 27, 1988 Violation 50-327. 50-328/88-19-01 "10 CYR 50, Appendlx B, Celterlon V states that activities affecting quality shall bo prescelbod by documented instructions, proceduros, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with those instructions, proceduros, or drawings.
Drawinas 47W470-4, and 47B473 sheets 2, 5, and 6 establish the proper installation of penetration seals.
Contrary to the above, prior to March 6, 1988, 16 polar crane wall penetrations were not sealed in accordance with those design drawings.
This a Severity Level IV violation (Supplomont I)."
Admission or Denial of the Alleged Violation TVA admits the violation.
Reason for the Violation Failure of TVA to follow design drawings during construction and therefore failure to properly control installation and maintenanco of penetrations and seals.
Correctivo Steps Which Havo Been Taken and Results Achieved SQN Division of Nuclear Engineering (DNE) personnel performed a completo walkdown of penetrations and seals in units 1 and 2 crano wall below elevation 693.0.
A total of 46 discrepancios were identified and work requests (WRs) were written tu correct the discrepancies requiring physical work. Those requiring documentation and drawing changes woro dispositioned and corrected on design change notices (DCNs).
This effort was documented as corrective action for Condition Adverso to Quality Report (CAQR) SQN871428.
Restart determinations were performed for the discrepancios and those determined to be restart were corrected before initial restart of unit 2.
All remaining corroctivo actions for the CAQR will be completed by July 20, 1988.
In accordance with the request in the inspection report for details concerning WR-D237496 and the associated correctivo action, the following explanation is given.
DNE perJonnel performed a complete walkdown of unit 2 penetrations below elevation 693.0.
A total of 20 discrepancies wore identified (HRC and TVA together).
One discrepancy was noted on penetration mark 284 as having a damaged Typo I link seal due to over-torquing. WR B237496 was wellten to replace the damaged coal on mark 284.
However, the WR and the CAQR mistakenly identified mark 281, not 284, as needing the link soal repaired. When
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- maintenance worked this WR, they failed to correctly identify the penetration called for in the WR.
Maintenance replaced the damaged link seal in mark 284 with a Typo III seal although a Type 11 seal was required by drawing 47B472-1 for mark 281. Type III is technically adequate for penetration mark No. 284; however, this change created a drawing deviation.
Type III will remain in penetration mark 284 and drawing 47B473-1 will be revised in accordance with DCN X00282 to reflect Type III seal for pontration mark 284.
Corrective Steps Which Will Be Taken To Avoid Further Violation The penetration and seals have been inspected and compared to design drawings. Discrepancies have boon noted and recorded. Corrective actions have been formulated in the revision of drawings, documentation, or installation of proper seals. No further actions are necessary to prevent another violation of penetrations and seals not conforming to design drawings.
Date When Full Compliance Will Be Achieved SQN will be in full compliance July 20, 1988.
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ENCLOSURE 2 RESPONSE TO NRC INSPECTION REPORT NUMBERS NOS. 50-327/88-19 AND 50-328/88-19 K. P. BARR'S LETTER TO S. A. WHITE DATED MAY 27, 1988 Violation 50-327. 50-328/88-19-03 "Technical specification 6.8.1 requires that written procedures be established, implemented, and maintained for surveillance and testing activities of safety-related equipment, Fire Protection Program implementation, and procedures recommended in' Appendix A of Regulatory Guide 1.33. Revision 2. February 1978.
Surveillance instruction (SI) 233.1, ' Visual Inspections of Penetration Fire Barriers - Mechanical System 302 (Penetrations)' implements required periodic visual surveillance of fire barriers.
Contrary to the above, prior to March 6, 1988, the licensee failed to have an adequate procedure for periodic inspections of the shield building penettution fire barrier foam saals. Fabric boot sleeves were installed during original plant construction on 53 of these penetrations, for hydraulic considerations, making the foam fire barriers inaccessible.
SI 233.1, ' Visual Inspections of Penetration Fire Barriers-Mechanical System 302 (penetrations)' and its predecessors did not require removal of these sleeves to permit fire barrier inspection or require inspection of the barrier from the opposite side of the wall. As a result, the licensee had not met the requirements of TS 4.7.12 for visual inspection of fire barrier seals since plant licensing.
This is a Severity Level IV violation (Supplement I)."
Admission or Denial of the Alleged Violation The violation is valid and TVA admits the violation.
Reason for the Violation The root cause of the inadequate SI 233.1 was determined to be that the acceptance criteria of the procedure was not properly defined.
Specifically, for fire barriers with boot seals, the SI did not require an inspection of the silicone foam seals from the opposite side of the shield-building wall.
l Corrective Steps Which Have Been Taken and the Results Achieved Potential Reportable Occurrence (PRO) 1-88-037 and Licensco Event Report (LER) 1-87-040-01 were initiated by the Plant Operations Review Staff.
Additionally, CAQR SQP-880115 was written to investigate, document, and correct the problem.
Instruction change forms (ICFs) 88-0219, 88-0338, and 88-0371 were written to allow proper inspection of both units 1 and 2 shield-wall penetrations. Only three boot seals were found deficient with minor tears and required repairs. PRO 1-88-065 and PRO 2-88-039 were written to document the deficiencies in the boot seals.
This was reported in LER 87040-01. Unit 2 inspection was completed February 7,1988, and unit 1 inspection was completed on February 14, 1988.
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Corrective Steps Which Will Be Taken To Avoid Further Violation The acceptance criteria of the SI 233.1 was revised on February 2, 1988, in accordance with ICF 88-0219 to require visual inspection of the silicone foam seals from inside or outside of the annulus for penetrations with boot seals, No additional actions are necessary to ensure compliance with technical t
specification 4.7.12 for visual inspection of fire-barrier seals.
Date When Full Compliance Will Be Achieved SQN is in full compliance.
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ENCLOSURE 3 LIST OF COMMITMENTS
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The work requests written to disposition and correct minor field discrepancies and the design change notices written to disposition and correct documentation and drawing discrepancies will be completed by July 20, 1988, as described in CAQR SQN871428.
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