ML20215K755
| ML20215K755 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 10/15/1986 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8610280291 | |
| Download: ML20215K755 (5) | |
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29u3 TENNESSEE VALLEY AUTHORITY CH ATTANOOGA. TENNESSEE 37401 SN 157B Lookout Place d,6 00717 A S : 38 OCT 15 886 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-0IE REGION II INSPECTION REPORT NOS. 50-327/86-43 AND 50-328/86 RESPONSE TO VIOLATIONS Enclosed is our response to Gary G. Zech's September 12, 1986 letter to S. A. White which transmitted Notice of Violation No. 50-327, 328/86-43-01 for our Sequoyah Nuclear Plant (SQN). is our response to the subject violation and our cominitments are listed in enclosure 2.
We do not recognize any other actions described herein or the subject inspection report as commitments.
As agreed in a telephone conversation on October 8, 1986 between M. R. Harding and P. R. Wallace of SQN and Brian Debs and Ken Barr of NRC, the resoonse to Notice of Violation 50-327, 328/86-43-02 of this same report will be submitted by October 31, 1986 (date established by telephone conversation between Ken Barr of your staff arid G. B. Kirk of my staff on October 9,1986).
In addition, our actions to improve the effectiveness of the post-modifications test program and our plans to review workplans issued subsequent to those reviawed by the Post-Modification Task Force for verification of adequate post-modification testing will be addressed in the October 31, 1986 response.
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 k&
R.Grdiey,Otrhetor Nuclear Safety Jnd Licensing Enclosures cc:
See page 2 8610280291 861015 DR ADOCK 05000327 PDR
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' U.S. Nuclear Regulatory Commission CNIT 15 Ek35 cc (Enclosures):
-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 I
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ENCLOSURE 1 RESPONSE - NRC-0IE INSPECTION REPORT NOS. 50-327/86-43 AND 50-328/86-43 GARY G ZECH'S LETTER TO S. A. WHITE DATED SEPTEMBER 12, 1986 Violation 50-327, 328/86-43-01 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 modifications 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 proper 1/
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 specify all required testing, in that the required seat leak testing of TS 4.4.6.2.2.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 1
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).
i 1.
Admission or Dental Of The Violation TVA admits the violation occurred as stated.
2.
Reason For The Violation a.
Workplans 11866 and 11853 - The wire replacement and circuit modifications were considered not to affect the timing of the operators and were therefore waived.
This was an incorrect interpretation.
b.
Workplan 11906 - The motor replacement was not considered to affect the closing capability of the operator since no torque or limit switch settings were altered.
This was an incorrect assumption and a misinterpretation of TI-69.
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. c.
Workplan 11897 - This portion of the violation occurred because of a personnel error in that the test data package was not adequately filled out.
3.
Corrective Steps Taken and Results Achieved a.
Workplans 11866 and 11853 - These WPs have already been completed and are in the closure cycle. Therefore, a revision to these WPs requiring that SI-166.6 testing be performed vould not be appropriate.
SQN already has an extensive testing program underway on safety-related valves involving the use of motor-operated valve analysis and test systems (MOVATS) and all of the valves in WPs 11866 and 11853 either have been or will be tested in accordance with SI-166.6 as a result.
However, a review will be performed by November 1, 1986 to ensure that the applicable valves have been tested in accordance with SI-166.6. Any valve identified as not having been tested will be included in the existing test program, b.
Workplan 11906 - This WP will be revised to incorporate the SI-166.18 test requirements.
c.
Workplan 11897 - TVA is satisfied that SI-166.6 was performed after the work was completed.
4.
Corrective Steps Taken To Avoid Further Violatiors a.
Workplans 11866 and 11853 - Systems Engineering is now a direct part of the workplan review cycle to specifically review the functional test requirements.
This is in accordance with SQN Standard Practice (SQA)-168.
b.
Workplan 11906 - Systems Engineering is now a direct part of the workplan review cycle to specifically review the functional test requirements.
This is in accordance with SQA-168.
c.
Workplan 11897 - The personnel submitting requests for SI-166.6 testing have been directed to ensure that the data package is properly filled out or, in the case of utilizing the master notation list, that all pertinent information is submitted.
5.
Date When Full Compliance Will Be Achieved a.
The valves in.4Ps 11866 and 11853 will be verified to have been tested in accordance with SI-166.6 or will be identifled by November 1, 1986 to be tested.
b.
WP 11906 will be revised to incorporate the SI-166.18 test requirements by November 1, 1986.
c.
Full compliance has been achieved, this item is complete.
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ENCLOSURE 2 LIST OF COMMITMENTS j
. 1.
The valves in WPs 11866 and 11853 will be verified to have been tested in accordance with SI-166.6 or will be identified by November 1, 1986 to be tested.
2.
WP 11906 will be revised to incorporate the SI-166.18 test requirements by November 1, 1986.
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