ML20205R416
| ML20205R416 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 04/01/1987 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20205R421 | List: |
| References | |
| NUDOCS 8704060340 | |
| Download: ML20205R416 (4) | |
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TENNESSEE VALLEY AUTHORITY CHATTANOOGA, TENNESSEE 37401 SN 157B Lookout Place U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C.
20555 i
Gentlemen:
In the Matter of
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Docket Nos. 50-327 j
Tennessee Valley Authority )
50-328 SEQUOYAH NUCLEAR PLANT (SQN) - PROGRAM PLAN FOR REPLACEMENT ITEMS PROJECT TVA's Nuclear Safety Review Staff (NSRS) Reports Nos. R-84-17-NPS, I-83-13-NPS, and R-85-07-NPS identified deficiencies in TVA's practices for the procurement of safety-related replacement items.
NRC Inspection Report i
Nos. 50-327, -328/86-81 cited similar deficiencies. Specifically, TVA's procurement program could have allowed previously quallfled equipment to be degraded by purchasing replacement components and parts as commercial grade, without documentation of 1ts qualification, and without adequate dedication of the items by TVA. While TVA took corrective action to improve the procurement program, TVA had no programmatic requirements for the dedication of commercial-grade items and failed to address the effect that past procurement practices may have had on the qualification of installed equipment.
In recognition of.the cited procurement deficiencies and the need to address them programmatically, TVA initiated the Replacement Items Program (RIP) in November 1986.
It is a corporate effort to verify that the qualification status of safety-related equipment has not and will not be degraded through the use of unquallfled replacement items.
The SQN Replacement Items Project is implementing the RIP at that facility and will serve as a model for the other TVA nuclear plants.
The Replacement Items Project Program Plan (Enclosure 1), which is hereby provided for your information, establishes the basis for the Replacement Items Project at SQN.
In addition, it explains the methodology for performing engineering evaluations and dedications in support of the following (refer to the Program Plan, Appendix B, " Acceptability of Replacement Items Used in CSSC Applications"):
The procurement and dedication of commercial-grade material for use j
in safety-related applications.
The evaluation of commercial-grade items installed in safety-related equipment.
The assessment of previous item replacements during maintenance activities for seismic sensitivity.
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An Equal opportunity Employer
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. U.S. Nuclear Regulatory Commission APR 011987 l
The evaluation of commercial-grada items located in the plant warehouse (Power Stores).
The purpose is to determine whether such items may be used in defined safety-related applications (that is, whether they can be dedicated).
The evaluation of balance-of-plant (BOP) items, inventorted within Power Stores, for which a specific safety-related application has been defined.
The development of preengineered specifications (mini-specifications) for safety-related equipment to provide assurance that replacement items are not introduced into critical components / systems that could degrade their ability to perform their required safety-related function (s).
i It should be noted that the RIP will be implemented in accordance with i
site-specific procedures. A list of the RIF site-specific procedures germane i
to SQN can be found in the Program Plan, Section 2, " References."
i The Replacement Items Project began examining past replacement activities which originated around the time of the issuance of the operating license (OL). During construction, before the granting of the OL, procurements were 4
handled by the TVA Division of Engineering Design (EN DES).
The procurements generally involved whole devices for initial construction that were qualified in their entirety. At approximately the time the OL was granted (phased in slightly before the OL), EN DES turned the plant over to the Division of Power Production (DPP), which then handled procurements for maintenance activities.
Maintenance procedures used by DPP were governed by site procurement procedures (e.g., SQN-45) and the Operating Quality Assurance Manual (0QAM),
Part III, Section 2.1.
As noted in the cited NRC inspection report, QA Level II was defined as "CSSC materials, components, and spare parts that can l
be purchased by positive identification, provided they are not QA Level I";
this definition and other sections of the procedure allowed replacement items to be procured as commercial grade, regardless of the seismic and environmental qualification of the component in which the item was to be installed.
To compound the problem, there was no mechanism for 'he dedication of commercial-grade items.
These proolems have been corrected.
The Nuclear Quality Assurance Manual (NQAM) (which replaced the OQAM) Part III, Section 2.1, has been revised and a procedure for the dedication of commercial-grade items has been added (Part I, Section 2.7.2).
These procedural revisions along with the evaluation of commercial-grade items that were in Power Stores before the implementation of these revised NQAM procedures, and other aspects of the RIP described in the Program Plan, will provide assurance that i
replacement items will not degrade the qualification of safety-related equipment.
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. U.S. Nuclear Regulatory Commission APR 011987 The pre-and post-restart scope of the Replacement Items Project has been clearly defined in the enclosed Program Plan.
To summarize, seismically sensitive equipment within the boundaries of the Phase I Design Baseline and Verification Program and 10 CFR 50.49 equipment wlil be evaluated before restart. Consistent with SQN restart criteria, this scope provides assurance that components and devices whose failure or inoperability have a significant probability of leading to the inoperability of a system required for startup or operation by the appropriate technical specifications have not been degraded by past replacement practices. is a list of commitments related to this submittal. Other specific statements in the Program Plan reflect TVA's intent and are provided for your information.
Should you have any questions about the commitments or the RIP, please telephone J. D. Ziegler at (615) 751-8077.
4 Very truly yours, TENNESSEE VALLEY AUTHORITY I
R. L. Gridley Director Nuclear Safet. and Licensing Enclosures cc (Enclosures):
Mr. G. G. Zech, Assistant Director Regional Inspections Division of TVA Projects Office of Special Projects U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Sequoyah Resident Inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy Daisy, Tennessee 37379 l
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4 ENCLOSURE 2 SEQUOYAH NUCLEAR PLANT (SQN)
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REPLACEMENT ITEMS PROJECT COMMITMENTS 1.
TVA will provide a schedule for the post-restart scope of the SQN j
Replacement Items Project by May 15, 1987.
The schedule completion for the post-restart scope will be consistent with the schedule completion of 1
Phase II of the Design Baseline and Verification Program.
2.
The seismically sensitive equipment within the boundaries of the Phase I l
Design Baseline and Verification Program and 10 CFR 50.49 equipment will j
be evaluated before SQN restart.
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