ML20235G593
| ML20235G593 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 07/02/1987 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8707140309 | |
| Download: ML20235G593 (5) | |
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TENNESSEE VALLEY AUTHORITY CHATTA NOOGA TENNESSEE 374o1 SN 157B Lookout Place JUL 0 21987 U.S. Nuclear Regulatory Commission-ATTN: Document Control Desk Washington, D.C.
20555 Gentlemen:
In the Matter of
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Docket Nos. 50-327-Tennessee Valley Authority
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50-328
.SEQUOYAH NUCLEAR P1. ANT (SQN) UNITS 1 AND 2 - NRC REGION II INSPECTION REPORT NOS. 50-327/87-15 AND 50-328/87 RESPONSE TO VIOLATION Enclosed is our respoase to G. G. Zech's May 29, 1987 letter to S. A. White that transmitted Notice of Violation 50-328/87-15-02 for SQN. is our response to the violation', and enclosure 2 is the list of commitments contained in enclosure 1.
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If you have any questions, please telephone M. R. Harding'at (615) 870-6422.
l To the best of my knowledge, I declare the statements contained herein are complete snd true.
Very truly yours, TENNESSEE VALLEY AUTHORITY R. Gridley, Dir ctor Nuclear Safety nd Licensing Enclosures cc:
See page 2 B707140309$$0 27 g/
PDR ADOCK ppg An Egel Opportunity Employer m.
e U.S. Nuclear Regulatory Commission JUL 0 2 087 cc (Enclosures):
Mr. G. G. Zech, Assistant Director for Inspection Programs Office of Special Projects U.S. Nuclear Regulatory Commission l
101 Marietta Street, NW, Suite 2900
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Atlanta, Georgia 30323 Mr. J. A. Zwolinski, Assistant Director for Projects Division of TVA Projects i
I office of Special Projects U.S. Nuclear Regulatory Commission 4350 East West Hithway i
EWW 322 Bethesda, Maryland 20814 Sequoyah Resident Inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy Daisy, Tennessee 37379
4 ENCLOSURE 1 RESPONSE TO NRC INSPECTION REPORT NOS. 50-327/87-15 AND 50-328/87-15 GARY G. ZECH'S LETTER TO S. A. WHITE DATED MAY 29, 1987 Violation 50-328/87-15-01 Technical Specification 6.8.1 states that written procedures shall be established, implemented and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33 Revision 2, February 1978. Regulatory Guide 1.33, Appendix A, states that maintenance which can affect the performance of safety-related equipment should be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances. The licensee prepared Work Request B217268 to replace splices for cables 2V1418A and 2V1419A at penetration 30 of the Unit 2 containment.
Work Request B217268 referenced procedure M&AI-7, Cable Terminations, Splicing and Repairing of Damaged Cables, to specify the requirements for repair of the cables.
Contrary to the above, on March 4, 1987, the inspector observed workers removing a required fire retardant coating from the pigtails on the annulus side of penetration 30 with a heat gun and a screwdriver instead of using a solvent approved by the cable manufacturer as required by M&AI-7.
Furthermore, Work Request B217268 did not specify the removal or require that the coating be replaced following the work in accordance with a commitment documented in an October 18, 1984, letter to the NRC.
This is a Severity Level IV violation (Supplement I).
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Admission or Denial of Alleged Violation TVA admits the violation occurred as stated.
2.
Reason For The Violation Flamemastic coatings were removed by Modifications Group A employees from pigtails in penetrations 15, 16, 28, 30, 37, 44, and 47 in preparation for terminating field cables to pigtails. This violation resulted from a breakdown in communication between management and craft employees.
The procedure used was insufficient with respect to precautions and
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limitations and did not address requirements for Flamemastic l
replacements. The craft employees were unaware that the work i
instructions given were insufficient for removing and replacing I
Flamemastic coatings and, therefore, proceeded with the work before the l
pcocedural requirements were in place.
3.
Corrective Steps Taken and Results Achieved i
Condition Adverse to Quality Report (CAQR) SQP870250 was initiated and completed to document and correct this deficiency.
The procedural i
requirements for removing and replacing Flamemastic coatings were added
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to Workplan (WP) 12403 by Instruction Change 87-265.
This change was l
reviewed by the Plant Operations Review Committee (PORC) on March 10, 1987, and the work was completed in accordance with the l
approved instructions.
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Corrective Steps Taken To l'revent Recurrence A training session was held f0r Modifications Group A management, engineering, and craft employe+.s to reiterate the importance of procedural requirements. Modification and Addition Instruction (M&AI)-13 is being revised to reflect removel instructions, precautions, and limitations on removing Flamemastic coating from cable. M&AI-7 has been revised to include instructions to follow the requirements in M&AI-13 when the cable preparation for Raychem application requires the removal of Flamemastic coating. The revision of M&AI-13 will be completed by July 20, 1987.
5.
Date When Full Compliance Will Be Achieved 1
SQN is in. full compliance.
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% CLOSURE 2 l
COMMITMENTS IN ENCLOSURE 1 1.
SQN will revise M&AI-13 by July 20, 1987, to reflect removal instructions, precautions, and limitations on removing Flamemastic coating from cable.
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