ML20196G999
| ML20196G999 | |
| 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 8807060069 | |
| Download: ML20196G999 (4) | |
Text
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TENNESSEE VALLEY AUTHORITY CHATTANOOGA. TENNESSEE 374ol l~
5N 157B Lookout Place JUN 281988 U.S. Nuclear Regulatory Comission ATTN:
Document Control Desk Washington, D.C.
20555 Gentlemen:
In the Matter of
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Docket Nos. 50-327 Tennessee Valley Authority
)
50-328 SEQUOYAH NUCLEAR PLANT (SQN) - RESPONSE TO NOTICE OF VIOLATION NOS. 50-327/88-07 AND 50-328/88-07 provides TVA's response to the Notice of Violation that was transmitted by letter from S. D. Richardson to S. A. White dated May 27, 1988. Sumary statements of comitments contained in this submittal are provided in enclosure 2.
If you have any questions, please telephone M. A. Cooper at (615) 870-6549.
Very truly yours, TENNESSEE V LLEY AUTHORITY
/
R. Gridley, 1 rector Nuclear Licensing and Regulatory Affairs Enclosures cc (EncloJures):
Mr. F. McCoy, Assistant Director j
i for Inspection Programs TVA Projects Division U.S. duelear 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 Comission One White Flint, North 11555 Rockville Pike 7
Rockville, Maryland 20852
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/p \\l Sequoyah Resident Inspector i
Sequoyah Nuclear Plant
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2600 Igou Ferry Road Soddy Daisy, Tennessee 37379 8807060069 880628 PDR ADOCK 05000327 An Equal Opportunity Employer Q
1 ENCLOSURE 1 RESPONSE TO NRC INSPECTION REPORT NOS, 50-327/88-07 and 50-328/88-07 S. D. RICHARDSON'S LETTER TO S. A. WHITE DATED MAY 27, 1988 Violation 50-327, 328/88-07-01 "10 CFR Part 50, Appendix B, Criterion XVI, states, in part, ' Measures shall be established to assure that conditiois adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and noncorformances are promptly identified and corrected.
In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.'
Paragraph 11 of Attachment 4 to Temporary (sic) Instruction TI-105,
' Dedicating Commercial Grade Items for Use as Basic Components,' Revision 1, dated August 18, 1987, which was developed in response to NRC Inspection Report 50-327, 328/86-61, states, in part, 'A check that the part number is the same does not indicate that an item is a direct replacement.
Critical characteristics must be checked.
Contrary to the above, as of the date of the inspection TVA failed to take adequate corrective action to correct deficiencies in the' areas of procurement of safety-related equipment which were identified in TVA's Nuclear Safety Review Staff Report R-84-17-NPS and NRC Inspection Reports 50-327,328/86-61 and 50-327,328/87-40.
Examples of TVA's failure to take adequate corrective actions are:
(1) dedication package 5137 dedicated a commercial grade temperature switch used in a safety-related plant application based solely on part number; (2) dedication package 5252 dedicated a commercial grade valve positioner used in a safety-related application based on model number and part number from a vendor who had no applicable QA program and was not on the TVA approved supplier list (ASL); and (3) dedication package 5243 dedicated a commercial grade safety relief valve with adequate critical characteristics for dedication; however, receipt inspection was based on part number verification and an unsupported Certifieste of Compliance (the supplier's commercial grade QA program had not been reviewed and approved by TVA).
Therefore, the dedication was, in essence, based solely on part number verification.
This is a Severity Level IV violation (Supplement I)."
Admission or Denial of the AlleRed Violation TVA admits the violation.
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i Reason for the Violation l
The violation, dedication of commercial-grade replacement items based solely on part number verification, occurred as a result of a failure to follow procedures. Contributing factors to the failure are:
a procedure, "Dedicating Commerical Grade Items for Use as Basic Components" Technical Instruction (TI-105), that does not provide specific logical criteria in some vital areas for assessing adequacy of commercial-grade items for dedication in safety-related applications; SQN Contract Engineering Group (CEG) engineers that lacked sufficient understanding of the requirements to verify critical characteristics of commercial-grade items; and CEG supervision that was inadequate to ensure dedication packages are adequately prepared.
Corrective Steps That Have Been Taken As noted in the subject inspectior report, "TVA took immediate 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."
Verification of all material issued against identified dedication packages was completed as an initial unit 2, mode 4 prerequisite. Additional packages were reviewed for which material had not been issued for use in safety-related areas and were properly dispositioned before restart of unit 2.
Formal training regarding part number and certificate of compliance has also been given to personnel responsible for dedication package preparation in addition to extensive dedication training for all associated personnel utilizing the services of one of the industry's recognized experts on the subject.
A change in CEG supervision has also been made.
Corrective Steps That Will Be Taken To Avoid Further Violations The Division of Nucicar Engineering / Engineering Assurance (DNE/EA) has been monitoring new dedication packages and will monitor the dedication process in the future to ensure continued effective implementation.
TI-110. "Procurement of Replacetnent Items for Use in Permanent plant i
Eq'dpment, Systems and Structures," will be revised by July 15, 1988, to incerporate TI-105 requirements.
This revision will provide an enhanced logic and documentation path for determination of dedication requirements. TI-105 will subsequently be deleted.
Management and independent technical review is being reinforced until this revision is accomplished to ensure sound judgment is utilized in the dedication process.
Date When Full Compliance Will Be Achieved SQN is in full compliance.
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ENCLOSURE 2 i
List of Commitments 1.
TI-110 will be revised by July 15, 1988, to incorporate TI-105 requirements.
This revision will' provide an enhanced logic and documentation path for determination of dedication requirements.
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