ML20215D001
| ML20215D001 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 09/29/1986 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8610100570 | |
| Download: ML20215D001 (3) | |
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TENNESSEE VALLEY AUTHORITY CHATTANOOGA. TENNESSEE 37401 SN 157B Lookout Place SEP 29 986 E
c3 U.S. Nuclear Regulatory Conunission C
Region II ATTN:
Dr. J. Nelson Grace, Regional Administrator 101 Marietta Street, NW, Suite 2900 g
Atlanta, Georgia 30323
Dear Dr. Grace:
!.4 4D SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 - NRO-OIE REGION II INSPECTION REPORT 50-327/86-41 AND 50-328/86 RESPONSE TO VIOLATIONS Enclosed is our response to Gary G. Zech's August 29, 1986 letter to S. A. White which transmitted IE Inspection Report Nos. 50-327/86-41 and 50-328/86-41 for our Sequoyah Nuclear Plant which cited TVA with one Severity Level V violation. Enclosed is our response to the subject violation. As identified in the transmittal letter, the Deputy Director, Nuclear Quality
-Assurance, stated that TVA would submit a formal response to the inspector follow-up item identified in the subject report. This response will be sent as a separate submittal.
If you have any questions, please get in touch with G. B. Kirk at 615/870-6549.
To the best of my knowledge, I declare the statements contained herein are complete and true.
Very truly yours, TENNESSEE VALLEY AUTHORITY R. Gridley, D ector Nuclear Safety and Licensing Enclosure cc (Enclosure):
Mr. James Taylor Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. G. G. Zech Director. TVA Projects U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 860929 1
G 05000327
\\gl PDR An Equal Opportunity Employer
e ENCLOSURE RESPONSE - NRC-0IE INSPECTION REPORT NOS. 50-327/86-41 AND 50-328/86-41 GARY G. ZECH'S LETT3R TO S. A. WHITE DATED AUGUST 29, 1986 VIOLATION 50-327/86-41-01 AND 50-328/86-41-01 10 CFR 50, Appendix B, Criterion V and the TVA accepted Quality Assurance (QA) program, TVA-TR75-1A, QA Program Description for the Design, Construction, and Operation of TVA Nuclear Power Plants, Revision 8, Section 17.2.5, collectively require that activities affecting quality be prescribed by documented instructions and accomplished in accordance with those instructions. TVA Procedure DQAI-204, Handling of Control (sic] office Corrective Action Reports and Discrepancy Reports, Revision 0, procedurally delineates processing Corrective Action Request (CARS) in TVA Central Offices.
1.
DQAI-204, Attachment 1, Step 7 requires that:
The responsible supervisor provide recommended corrective action, both remedial and recurrence control and estimated completion dates for both.
Contrary to the above, remedial control corrective action estimated completion dates were not provided for all NCO-CAR-86-003 items.
2.
DQAI-204, Attachment 1, Step 7 requires that:
The responsible supervisor return the CAR to the Programs Development Group (PDG) within 14 working days for significant CARS.
Contrary to the above, NCO-CAR-86-003 dated February 5,1986, and judged to be significant by licensee personnel was not returned within 14 working days as required. The response was required by March 3, 1986, within 30 working days which is required for non-significant CARS.
This is a Severity Level V violation (Supplement I).
1.
Admission or Denial of the Alleged Violation TVA admits the portion of the violation concerning the failure to provide completion dates for remedial corrective action for all NCO-CAR-86-003 items (detail 1 above). However, af ter further research, information not provided to the NRC inspector has indicated that the 14 working day requirement was not violated and the second detail is denied.
2.
Reason for the Violation (Remedial Corrective Action Completion Dates)
The violation occurred due to an isolated personnel oversight in that the remedial control corrective action completion dates were not clearly defined for all NCO-CAR-86-003 items.
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Corrective Steps Taken and Results Achieved The remedial control corrective actions have been completed, actions have been verified as complete, and these facts have been appropriately documented by responsible personnel.
4.
Corrective Steps Taken to Avoid Further Violations In order to avoid further violations of this type, responsible personnel and supervision have been reminded that corrective action completion dates must be clearly defined before corrective action plans can be approved.
5.
Date When Full Compliance Will Be Achieved Full cciapliance was achieved on September 3,1986 when remedial control corrective action was completed, and responsible personnel and supervision were reminded that corrective action completion dates must be clearly defined before corrective action plans can be approved.
6.
Reason for Denial (NCO-CAR-86-003 not being returned within 14 working days) 4 NCO-CAR-86-003 dated February 5,1986 by the originator was issued per procedure on February 10, 1986.
The procedure requires the Quality Systems Branch perform a review of all CARS received and to issue significant CARS requesting corrective action within 14 working days.
This CAR was issued on February 10, 1986 and a response was requested by March 3,1986, which is 14 working days considering February 17, 1986 was a TVA holiday. The corrective action was provided on March 3, 1986, within 14 working days as required by the procedure.
This matter was perceived to constitute a violation of procedures because the quality organization failed to direct the inspectors' attention to the issue date of February 10, 1986, which was five days later than the origination date.
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