ML20211C749

Forwards Revised Supplemental Response to Violations 50-327/86-43-02 & 50-328/86-43-02 Noted in Insp Repts 50-327/86-43 & 50-328/86-43 on 860912,submitted Per 870121 Telcon.Listed Procedures Will Be Revised

ML20211C749
Person / Time
Site:	Sequoyah
Issue date:	02/11/1987
From:	Gridley R TENNESSEE VALLEY AUTHORITY
To:	Grace J NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
NUDOCS 8702200204
Download: ML20211C749 (5)

Text

o TENNESSEE VALLEY AUTHORITY CHATTANOOGA. TENNESSEE 374ot SN 157B Lookout Place FEB 111987 U.S. Nuclear Regulatory Comission Attn: Document Control Desk Office of Nuclear Reactor Regulation Washington, D.C. 20555 Attention: Dr. J. Nelson Grace In the Matter of ) Docket Nos. 50-327 Tennessee Valley Authority ) 50-328 SEQUOYAH NUCLEAR PLANT (SQN) UNITS 1 AND 2 - NRC-OIE REGION II INSPECTION REPORT 50-327/86-43 AND 50-328/86 REVISED SUPPLEMENTAL RESPONSE TO VIOLATION NOS. 50-327/86-43-02 AND 50-328/86-43-02 Enclosed is our revised supplemental response to Gary G. Zech's September 12, 1986 letter to S. A. White which transmitted Notice of Violation Nos. 50-327/86-43-02 and 50-328/86-43-02. This response, submitted in accordance with'a telephone conversation between G. B. Kirk, TVA, and Frank McCoy, NRC, on January _21, 1987, revises the supplemental response previously transmitted in a letter from me dated December 19, 1986.

Enclosure 1 is our revised supplemental response to the subject Notice of Violation. Enclosure 2 contains the list of commitments contained in enclosure 1. Please note that the previous commitments (contained in the December 19, 1986 submittal) pertaining to the revision of Administrative Instruction (AI)-4 and Sequoyah Standard Practice (SQM)-2 have been revised and the third commitment regarding the improvement plan for the Plant Operations Review Committee (PORC) responsibilities has been deleted.

If you have any questions, please get in touch with M. R. Harding at 615/870-6422.

To the best of my knowledge, I declare the statements contained herein are complete and true.

Very truly yours, TENNESSEE VALLEY AUTHORITY 8702200204 870211 7 DR ADOCK 050 /,

R. Gridley, irector Nuclear Saf ty and Licensing Enclosures cc: See page 2 An Equal Opportunity Employer

e U.S. Nuclear Regulatory Commission FEB 111987 cc (Enclosures):

Mr. J. J. Holonich Sequoyah Project Manager U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue Bethesda, Maryland 20814 Mr. James Taylor, Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. B. J. Youngblood U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue.

Bethesda, Maryland 20814 Mr. G. G. Zech, Director TVA 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 37319 l

ENCLOSURE 1 REVISED SUPPLEMENTAL RESPONSE-NRC-0IE INSPECTION REPORT NOS. 50-327/86-43-02 AND 50-328/86-43-02 GARY G. ZECH'S LETTER TO S. A. WHITE DATED SEPTEMBER 12, 1986 In accordance with our original response to Notice of Violation 327, 328/86-43-02 (transmitted by letter from R. L. Gridley to Dr. Grace dated October 31, 1986), a review of changes to irstructions using the Administrative Instruction (AI)-4, Appendix G, Instruction Change Form (ICF) was initiated. That review along with the review of AI-4 indicated that a clarification of the AI-4 requirements was needed. AI-4 will be revised by

. April 1, 1987, to allow changes to instructions when it is discovered that a change is needed to complete work in progress. Such changes will be processed utilizing the Appendix G ICF. AI-4 will continue to meet the requirements of Sequoyah technical specifications 6.8.2 and 6.8.3 in that nonintent changes will continue to require approval by two SR0s or a SRO and a cognizant supervisor before the change may be implemented. The nonintent change must also be reviewed by PORC and approved by the Plant Manager or his designee within 14 days of the date the change was implemented. Intent changes to instructions will continue to require (1) approval of a SRO or cognizant supervisor, (2) review and concurrence of QA Staff, and (3) review by PORC and approval of Plant Manager or his designee before being implemented.

To ensure correctness and explicitness of work instructions for postmaintenance tests (PMTs) specified on work requests (WRs), the phrase

" perform the applicable portion," has been and will continue to be significantly reduced. More specific instructions for PMTs are being provided by having the planners define in the work package the specific approved instruction or " stand alone" portion of an approved instruction to be used for a PMT. A " stand alone" portion of an instruction is a section of clearly defined steps which can be performed independent of the remainder of the procedure (considering the applicable prerequisites and precautions) to perform the test. The phrase " perform the applicable portion" will only be used in cases where the total work scope cannot be explicitly defined. In these instances, before the testing is implemented, a cognizant responsible person (e.g., Engineering Supervisor, Maintenance Planner, Shift Engineer, SRO, C-4 level Engineer) must review the work document and specify the " stand alone" portion of the instruction that is to be performed to prove the equipment / system operable. If a " stand alone" portion of an instruction is l

not applicable for the testing required, the cognizant responsible person will l identify that a new instruction is required. The maintenance program procedure (SQM-2) will be revised by April 1, 1987, to include these

! requirements.

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As a long-range objective to improve methods for identifying what activities (tests, inspections, etc.) are needed after specific maintenance activities are performed, a plant procedure on pMTs is being developed. This program procedure will provide specific guidance to the maintenance planners by outlining in matrix form, for generic or specific equipment, the types of testing that should be considered versus the type of maintenance performed.

The plant program procedure will address pMT requirements, PMT instruction preparation, planners requirements for identifying needed instructions, etc.

The end product of this program procedure will be specific definition and requirements of the program, guidance to the planners for the type testing to be considered, and will identify if an existing instruction is available. The initial draft of this procedure should be completed by March 20, 1987. Once approved for use, additional improvements can be made, such as identifying within the matrix those specific plant-approved instructions to be used for pMT. This in turn will readily identify to the planner that an approved procedure is.in place or that a procedure may need to be written. Those previously approved plant instructions contained within the matrix will be revised to specifically indicate that they can be, or a portion of them can be, used as a pMT for certain equipment. When testing is of sufficient detail to require a specific instruction, or will likely be repeated and there is not an approved instruction in place, a request will be made by the maintenance planner to the appropriate maintenance manager that an instruction be written. These instructions can be written and approved as specific for testing a certain component or generic for a group of components. These instructions will be maintained and referenced in the program procedure matrixes.

TVA will submit an updated response by June 30, 1987, to provide the status of the PMT program procedure and its scheduled implementation.

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ENCLOSURE 2 LIST OF COMMITMENTS

1. Revise AI-4 by April 1,1987, to allow changes to instructions when it is

- discovered that a change is needed to complete work in progress.

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2. Revise SQM-2 by April 1,1987, to include the requirements for using the statement " perform the applicable portion."

3. Complete the initial draft of PMT program procedure by March 20, 1987.

4. Submit an updated response by June 30, 1987, to provide the status of the PMT program procedure and its scheduled implementation.

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