ML20210E305

Notice of Violation from Insp on 860728-0801

ML20210E305
Person / Time
Site:	Sequoyah
Issue date:	09/12/1986
From:	Zech G NRC - TVA OVERSIGHT GROUP, NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20210E303	List: IR 05000327/1986043 ML20210E297 ML20210E305 ML20210E310
References
50-327-86-43, 50-328-86-43, NUDOCS 8609220238
Download: ML20210E305 (2)

Text

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ENCLOSURE 1 NOTICE OF VIOLATION

' Tennessee Valley Authority Docket Nos. 50-327 and 50-328 Sequoyah 1 and 2 License Nos. DPR-77 and DPR-79 During the Nuclear Regulatory Commission (NRC) inspection conducted on July 28, 1986, to August 1,1986, violations of NRC requirements were identified. The violations involved failure to properly implement plant procedures (multiple examples) and a failure to properly change plant approved procedures. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR 2, Appendix C (1985), the violations are listed below:

A. Technical Specification (TS) 6.8.1.a requires that written procedures be established and implemented for activities recommended in Appendix "A" of Regulatory Guide 1.33, Revision 2, February 1978, which include modifica-tions and testing of safety-related equipment.

Administrative Instruction (AI)-19 Part IV, " Plant Modifications After Licensing," Revision 18, requires that any check or test necessary to return equipment back to service after modification be specified in the work plan.

Surveillance Instruction (SI)-166.6, " Post Maintenance Testing of Category A and B Valves," Revision 21, requires that functional testing pursuant to that procedure be documented on a SI-166.6 Data Package or on the Master Index. -

Contrary to the above, the following are examples of failure to properly implement the above required procedures:

1. Work Plans (WPs) 11866 and 11853 did not specify all required testing, in that the required valve timing test of TS 4.6.3.1 and Technical Instruction (TI)-69, " Summary of Pre- and Post-maintenance valve tests for ASME Section XI and 10 CFR 50, Appendix J," was not specified.

2. Work Plan 11906 did not speci fy 61 required testing, in that the required seat leak testing of TS 4.1,.6.2.2.c, TI-69, and SI-166.18, "RHR Return Valve Leak Rate Test," was not specified.

3. Neither the SI-166.6 Data Package nor the Master Index documented the testing of several valves listed in WP 11897 as being tested pursuant to the requirements of SI-166.6.

This is a Severity Level IV Violation (Supplement I).

l l 8609220238 860912 PDR ADOCK 05000327 G PDR

Tennessee Valley Authority 2 Docket Nos. 50-327 and 50-328 Watts Bar 1 and 2 License Nos. DPR-77 and DPR-79 l

l B. TS 6.8.2 identified the required review and approval of written procedures. '

Subsequent to initial approval, TS 6.8.3.1 provides limitations for initiating temporary changes to these procedures.

Administrative Instruction (AI)-4, " Plant Instructions - Document Control,"

is the plant procedure for controlling temporary changes to procedures.

Paragraph 13.1 of AI-4 defines the two conditions which TVA considers qualify as temporary changes (eg. , TVA expeditious changes). These two conditions are: 1) changes which will remain in effect _for only a limited number of instruction performances (e.g., procedures needed to be performed this one time because of plant conditions); 2) changes which are urgently needed to correct a serious deficiency.

Contrary to the above, changes to approved procedures were improperly processed, in that, changes to WP 11890 was processed using the urgent change process when neither of the two conditions existed. Additionally, changes to numerous approved procedures are being made without proper review by use of the " accomplish the applicable portion" process which TVA has and continues to use.

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

Pursuant to 10 CFR 2.201, TVA is hereby required to submit ', this office within 30 days of the date of the letter transmitting this Notice, a written statement o.r explanation in reply, includi1g for each violation: (1) admission or denial of the violation; (2) the reason for the violation if admitted; (3) the corrective steps which have been taken and the results achieved; (4) corrective steps which will be taken to avoid further violations; and (5) the date when full compliance will be achieved. Where good ause is shown, consideration will be given to extending the response time.

FOR THE NUCLEAR REGULATORY COMMISSION y -<2 w Gary G Zechi-Gl.ector TVA Projects Dated at Atlanta, Georgia this 12 day of September 1986