ML20198S068

Responds to NRC Re Violations Noted in Insp Repts 50-327/86-12 & 50-328/86-12.Corrective Actions:Test Data Packages Relocated to Document Control Ctr Vault for Storage

ML20198S068
Person / Time
Site:	Sequoyah
Issue date:	05/27/1986
From:	Gridley R TENNESSEE VALLEY AUTHORITY
To:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
NUDOCS 8606100314
Download: ML20198S068 (4)

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. 4 TENNESSEE VALLEY AUTHORITYs CH ATTANOOGA IkNNESSEE 37401 Sl '

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Nay 27, 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-OIE REGION II INSPECTION REPORT 50-327/86-12 AND 50-328/86 RESPONSE TO VIOLATION Enclosed is our response to J. A. Olshinski's April 25, 1986 letter to S. A. White which transmitted IE Inspection Report Nos. 50-327/86-12 and 50-328/86-12 for our Sequoyah Nuclear Plant which cited TVA with one Severity Level V Violation. Enclosure 1 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 5et 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, TENNESSEE VALLEY AUTHORIIY

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R. ridley, irector Nuclear Saf ty and Licensing Enclosures cc: Mr. James Taylor, Director (Enclosures) i Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C. 20555 8606100314 860527 PDR ADOCK 05000327 g PDR l

An Equal Opportunity Employer p I

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, N ENCLOSURE 1 EESPONSE - NRC-0IE INSPECTION REPORT NOS. 50-327/86-12 AND 50-328/86-12 JOHN A. OLSHINSKI'S LETTER TO S. A. WHITE DATED APRIL 25, 1986 Violation 50-327/86-12-01 and 50-328/86-12-01 10 CFR 50 Appendix B, Criterion XVII, and the accepted Quality Assurance Program (TVA-TR75-1A) require that sufficient records be maintained to furnish evidence of activities affecting quality. The licensee is committed to Regulatory Cuide 1.88 which endorses ANSI N45.2.9-1974, Requirements for Collection, Storage, and Maintenance of Quality Assurance Records for Nuclear Power Plants. Section 5 of this Standard delineates requirements for storage, preservation, and safekeeping.

Contrary to the above, 19 preoperational tests record packages being kept by the Preoperational Test Unit did not meet ANSI N45.2.9, Section 5 requirements for proper record storage.

This is a Severity Level V violation (Supplement I).

1. Admission or Denial of Alleged Violation TVA admits the violation occurred as stated.

2. Reason for Violation The violation occurred due to a misinterpretation of the definition of a Quality Assurance (QA) record as outlined in the site procedures wt.ch were based on the statement in ANSI N45.2.9-1974, "For the purpose of this standard, a document is considered a Quality Assurance record when the document has been completed."

While the actual testing activities involving these preoperational tests were complete for operation, these particular test data package documents were considered by personnel to be incomplete. The packages require vendor review comments and/or subsequent plant manager's approval. These documents were being held in a special file location pending completion.

All other preoperational tests were complete, considered QA records, and stored accordingly. Even though the duplicate storage location was not documented, duplicate copies were issued to TVA's Division of Nuclear Engineering (DNE) and to Westinghouse Electric Corporation (W-11.10, unit 2, was hand delivered to DNE on November 25, 1985) and considered to be retrievable from the DNE in the event the original was lost.

At the time of the NRC inspection (February 10-14, 1986), TVA was currently in negotiations with Westinghouse Elect ric Corporation to complete these final reviews. The plant manager's approval will follow the Westinghouse review. The reevaluation of all open preoperational test items was a licensee-identified area which is scheduled to be egmg)ggegefgrerestart,andwasalsoidentifiedbyNRCasIFI50-327,

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3. Corrective Steps Taken and Results Achieved On February 14, 1986, these test data packages were relocated to the Document Control Center (DCC) vault for storage and will be handled as QA records until the reviews and approvals are complete. At that time, they will be formally transmitted to the DCC as a permanent plant QA record.

4. Corrective Steps Taken to Avoid Further Violations This was the last group of preoperational tests at SQN that were not already stored as QA records, and no further action is required.

5. Date When Full Compliance Will Be Achieved The plant was in full compliance on February 14, 1986, when the test data packages were transferred to DCC for storage.

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m ENCLOSURE 2 COMMITMENTS

1. By startup we will have completed our reevaluation of all open preoperational test items. Note: This commitment was originally documented in our letter dated March 6, 1986 from R. Gridley to J. Nelson Grace.

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