ML20196L603
| ML20196L603 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 07/01/1988 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8807080049 | |
| Download: ML20196L603 (7) | |
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TENNESSEE VALLEY AUTHORITY CH ATTANOOGA. TENNESEEE 37401 SN '1578 Lookout Place JUL 011988
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U.S. Nuclear Regulatory-Commisston ATTN:
Document Control Desk ~
Hashington, D.C.
20555 Gentlemen:
knthe~Matterof
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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. 50-327/88-09 AND 50-328/88 RESPONSE TO NOTICE OF VIOLATIONS
'NOS. 50-327, 50-328/88-09-01 AND -02 Enclosed.is TVA's response to Kenneth Barr's letter to S. A. White dated May-.17, 1988, that transmitted the. subject Notice of Violations.
Enclosures 1 and 2 provides our response.. Summary statements of commitments contained in this submittal 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, I
TENNESS E V Y AUTHORITY R. Gridley,.Di ector Nuclear Licensing and Regulatory Affairs l.
Enclosures cc:
See page 2 l
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PDC An Equal Opportunity En.ployer
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U.S. Nuclear Regulatory Commission.
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cc (Enclosures):
Mr. F. R. McCoy, Assistant Director for Inspection Programs
~TVA Projects Division U.S.:duclear Regulatory Commission Region II-101 Marietta Street, NH, Suite 2900 Atlanta, Georgia 30323 Ms. S. C. Black, Assistent 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 Soddy Daisy, Tennessee 37379 1
w ENCLOSURE 1 RESPONSE TO NRC INSPECTION REPORT NOS. 50-327/88-09 AND 50-328/88-09 K. P. BARR'S LETTER TO S.- A. WHITE DATED MAY 17, 1988 VIOL /dI_Of 50-327, 50-328/88-09-01 "10 C A 50 Appenjlx 8, Criterion V, and the licensee's accepted Quality Assurance (QA) program (TVA Topical Report TVA-TR75-1A, Section 17.2.5) require that ' Activities affecting Quality be prescribed by documented procedures or-drawings and be accomplished in accordance with these procedures or drawings.'
Procedures and drawings were not followed for installation and inspection of high strength bolts in seismic restraints added to the movable incore transfer device per recommendations of IE Information Notice 85-45.
1.
Engineering change notice (ECN) L6447, implemented by work plan (WP) 11672, required installation of A325 high strength bolts in the braces (seismic restraints) added by the ECN to restrain the movable incore transfer device during a seismic event.
Contrary to this requirement, A307 medium strength bolts were installed in the seismic restraints.
2.
TVA Sequoyah Modification and Addition Instruction M&AI-9, Tightening, Inspection, and Documentation of Bolted Connections requires licensee inspectors to visually inspect new bolted connections and verify that the correct type of bolts and nuts were installed in connections.
Contrary to these requirements, licentee inspectors failed to identify that the improper type (A307) bolts were installed in the connections on the new seismic restraints.
Inspecti x records in the work plan package were incorrectly signed off to indicate that the proper type (A-325) bolts were used in the connections.
This is a Severity Level IV violation (Supplement I)."
Admission or Dental of the Alleged Violation TVA admits the first issue of the violation in that A-307 bolting material was found installed despite require:aents for A-325 bolting material in the cited ECH and workplan (WP).
However, concerning the second issue involving quality control (QCi inspections, our ir.vestigation results indicate tne correct material was installed in the WP and the introduction of incorrect A-307 bolting material apparently occurred subsequent to the 1985 HP implementation and installation inspection. Our response is therefore based on the following:
1.
The inspection records contained in WP 11672 are believed correct and accurate based upon review of available documentation and personnel interviews.
2.
A malr.tenance activity on the same support framing was performed after the original installation of the A-325 bolts.
This activity used a set of maintenance instructions (mis.) (1.9.1, MI-1.9.2, and MI-1.10) that were unclear and not updated to refle.t the use of A-325 bolts installed under HP 11672.
The mis used specified use of A-307 bolts.
This apparently resulted in incorrect bolt-type replacement at the completion of the maintenance activity.
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For these reasons we bel'4 eve stron9 n :nat correct inspections were performed for the WP installation of.A-325 bolts.
-Reason for the Violation The violation can be attributed to inadequate configuration control created by delays in the WP closure process.
Specifically, HF 11672, which modified the transfer device frame and added the A-325 bolts, was implemented in June 1985, but affected as-constructed drawings and milntenance procedures have not yet been updated.
Corrective Stops Which Have Been Taken and Re'sults Achieved The A-307 bolts in the unit 2 incore-transfer device seismic restraints have been replaced with high-strength bolts on work request (WR) 8273600.
An additional HR is currently being processed to replace the discrepant bolts in the unit 1 transfer device restraints. SQN will complete that replacement before restart of unit 1.
Corrective Steps Which Hill Be Taken To Avoid Further Violations 1.
SQN will complete closure of WP 11672 by July 30, 1988.
2.
SQN will review all HPs, which have been field-complete for more than 90 days and are not yet closed to determine if procedure changes are outstanding.
Based on results of this review, a plan of action will be formulated to revise the affected procedures and transmitted to NRC by July 30, 1988.
3.
Existing procedure, Sequoyah Engineering Project (SQEP) 30, Revision 5, "Jontrol of As-constructed Drawings," issued March 3, 1988, requires all drawings to be updated and issued within 90 days of WP field inglemer.tation.
(Note that control room drawings must-be updated before declaring system operable.) The backlog of ECNs, as defined in NRC commitment NC0870041001, are being addressed in accordance with that commitment.
Date When Full Compliance Will Be Achieved it.e incorrect bolts on the unit 2 incore-transfer device seismic support have been replaced.
The incorrect bolts on unit I will be replaced before unit i restart.
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ENCLOSURE 2 RESPONSE TO NRC INSPECTION REPORT NOS 50-327, 50-328/88-09 Kenneth Barr's letter to S. A. White dated May 17, 1988 VIOLATION 50-327, 50-328/88-09-02 "10 CFR 50 Appendix B,-Criterion XVI, and the licensee's accepted QA program (Section 17.2.16) require that conditions adverse to quality, such as deficiencies, deviations, and nonconformances, be promptly identified, and..
corrected. 10 CFR 50, Appendix B, Criterion XVII, and the licensee's accepted QA program (Section 17.2.17) require that the licer.see establish requirements concerning retention of quality assurance records to be stored in facilities which will protect the records from possible destruction by cause such as fire, flooding, tornadoes, insects, rodents, and extreme variations in temperature and humidity.
Contrary-to the above, a deficiency pertaining to inadequate storage of quality records was identified on Corrective Action Report (CAR)86-024 on May 12, 1986. The licensee has failed to take prompt corrective action to correct this deficiency which is evidenced by fact that the CAR still remains open, and that the deficiency (improper storage of quality records) still exists. In excess of 200 work plan packages were stored on open shelves in a facility (a trailer) which did not protect the records from possible destruction by cause such as fire, flooding, tornadoes, insects, rodents, and extreme variations in temperature and humidity. The work plan packages document pt.jsically completed modifications ta various safety related structures, systems and components and contained quality assurance records which furnish evidence of identification and control of matert.-Is, parts and components, documentation of completed inspections, control of special processes, and inspection, test and operating status. These quality assurance records had been stored in this trailer in excess of six months. Duplicate copies of these records were not available.
This is a severity level IV violation (Supplement 1)."
Admission or Denial of The A11 edged Violation TVA denies the violation based on the fact that the documents in question are Quality Assurance (QA) documents, not QA records. A QA document does not become a QA record until it is completed and the last signature is affixed attesting to the completion of the document.
The following references confirm this position:
1.
American National Standards Institute - ANSI N45.2.9 (1974) 2.
Regulatory Guide 1.88, revision 2 (October 1976)
TVA - Nuclear Quality Assurance Manual (NQAM), part II, section 4.1, revision 2 4.
TVA - SQN - Administration Instruction (AI) 7 1
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ENCLOSURE 2 TVA agrees with NRC that the documents in question and a few other different type documents do indeed require serious consideration for special handling and storage during processing.
The original issue involving CAR-86-024 was failure to identify transient fire loads where QA documents were involved.
The corrective actions identified in the initial CAR-86-024 are complete.
However, in December 1986 CAR-86-024 corrective action was expanded to reflect desired program enhancements to control and protect in-process QA documents.
Although many enhancement activities are completed, several remain on-going at this time. -The accepted. completion date for all enhancement activities--is September 30, 1988.
Those activities already completed that are considered enhancements include revision of the NQAM to include a section on storage for "In-Process QA Records;" and SQN has revised AI-7 to include a section for in-process QA records.
These procedures will now effectively control the handling and storage of hrs, surveilla..ce instructions, and HPs.
These actions will correct and prevent recurrence of the problem causing this
-alleged violation.
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ENCLOSURE 3 list-of Comm1tments
- 1. -The correct bolts will be installed in the unit I transfer device'before unit I restart.
2.
SQN will review all HPs, which have been field-complete for more than 90 days and are not yet closed, to determine if procedure changes are outstanding. -Based-on results of this -review,-a plan of action will-be formulated to revise the affected procedures and transmitted to NRC by July 30, 1988.,
3.
SQN will complete closure of WP 11672 by July 30, 1988.
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