ML20198R894
| ML20198R894 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 05/29/1986 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8606100250 | |
| Download: ML20198R894 (4) | |
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TENNESSEE VALLEY AUTHORITY CHATTANOOGA TENNESSEE 374o1 g
1,518\\LookoutPlace
. b,.,1 1 May 29, 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 NUCLEAR PLANT UNITS 1 AND 2 - NRC-0IE IIECION II INSPECTION REPORT 50-327/86-24 AND 50-328/86 RESPONSE TO VIOLATION Enclosed is our response to J. A. Olshinski's April 30, 1986 letter to S. A. White which transmitted IE Inspection Report Nos. 50-327/86-24 and 50-328/86-24 for our Sequoyah Nuclear Plant which cited TVA with one Severity Level IV Violation. is our response to the subject violation and our commitments are listed in enclosure 2.
We do not recognize any other actions. described herein or the subject inspection report as commitments.
If you have any questions, please get in touch with R.
E. Alsup at FTS 858-2725.
To the best of my knowledge, I declare the statements contained herein are complete and true.
Very truly yours, T NES,SEE LEY AUTHORITY R.
idley, D ector Nuclear Safet and Licensing Enclosures cc (Enclosures):
Mr. James Taylor, Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Mr. S. P. Weise, Chief Reactor Projects Branch 1 Division of Reactor Projects U.S. Nuclear Regulatory Commission Region II - Suite 2900 101 Marietta Stree, NW Atlanta, Georgia 30323 4
8606100250 860529 PDR ADOCK 05000327 G
PDR An Equal Opportunity Employer
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ENCLOSURE 1 s
RESPONSE y NRC-OIE INSPECTION REPORT NOS. 50-327/86-24 AND 50-328/86-24 JOHN A. OLSHINSKI'S LETTER TO S. A. WHITE DATED APRIL 30, 1986 Violation 50-327/86-24-01 and 50-328/86-24-01 Technical Specification 6.8.1 requires written procedures for activities referenced in Appendix A of Regulatory Cuide 1.33, Revision 2, February 1978.
Paragraph 8.b of Appendix A requires that specific procedures for each surveillance test listed in the Technical Specifications be written and implemented.
Technical Specification 6.10.1.d. requires that records of Technical Specification surveillance activities be retained for at least five years.
Contrary to the above, procedures were not establish for the functional testing required by Technical Specifications 4.7.9.e.1 to verify snubber activation takes place in both directions of travel for safety-related mechanical snubberr. Records of mechanical snubber activation testing performed prior to September 1985 were not retained.
This is a Severity Level IV violation (Supplement I).
1.
Admission or Denial of Alleged Violation TVA admits that the violation occurred as stated.
2.
Reason for Violation The violation occurred due to an inadequate procedure that failed to require documentation for all inspection considerations related to snubber activation testing.
The responsible engineer felt that activation was sufficiently proven by the work activities performed in preparation for and performance of the drag-force testing. Previous experience has shown that a snubber is either completely inoperable and f
will not cycle or that if a snubber passes the drag-force test, it will consequently pass the activation test required to be performed at Sequoyah Nuclear Plant'(SQN).
SQN engineering personnel performing the drag-force test recognized the operability / activation of the snubbers during dra'giforce testing but did not specifically document activation until September 1985.
3.
corrective Steps Taken and Results Achieved As a result of questions raised by SQN Mechanical Maintenance personnel on the adequacy of Surveillance Instruction'(SI)-l't.2, " Snubber Functional Testing (Hydraulic and Mechanical)," inspection personnel were i
Instructed to document snubber activation on the drag-force testing data uheet during the unit 1, cycle 3 refueling outage. This was completed in l
September 1985.
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2 4.
Corrective Steps Taken to Avoid Further Violations SI-162.2 will be revised to describe the test method, criteria, and documentation requirements for activation testing of mechanical snubbers before the next' scheduled performance date of March 10, 1987.
5.
Date When Full Compliance Will Be Achieved The plant was in full compliance in September 1985 when the inspection personnel were required to document snubber activation. However, as stated in section 4, SI-162.2 will be revised before the next performance date of March 10, 1987.
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1 ENCLOSURE 2 COMMITMENTS 1.
By the next scheduled performance date of March 10, 1987, we will revise SI-162.2 to describe the test method, criteria, and documentation requirements for activation testing of mechanical snubbers.
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