ML20235H945
| ML20235H945 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 09/22/1987 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8710010224 | |
| Download: ML20235H945 (6) | |
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-I TENNESSEE VAll_EY AUTHORITY CH ATTANOOGA, TENNESSEE 374o1 i
SN 157B Lookout Place' l
HP 221987 E
t$ 5 7-M'
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U.S. Nuclear Regulatory Commission l
.0.' O ATTN: Document Control Desk
' Washington, D.C.
20555-M i
4' Oentlemen:
y In the Matter of
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Docket Nos. 50-327-Tennessee Valley Authority
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50-328 j
SEQUOYAH NUCLEAR PLANT (SQN) UNITS 1 AND.2 - NRC OFFICE OF SPECIAL PROJECTS (OSP) INSPECTION REPORT NOS. 50-327/87-23 AND.50-328/87-23, SPECIAL TEAM INSPECTION OF EMPLOYEE CONCERN ELEMENT REPORTS - RESPONSE TO VIOLATION Enclosed is our response to Stewart D. Ebneter's August 18. 1987 letter to S. A. White that transmitted Notice of Violation 50-327, 328/87-23. contains our response to the subject notice of violation, and enclosure 2 contains the list of commitments contained in enclosure 1.
If you have any questions, please telephone 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 VA EY AUTHORITY R. Cridley, Di ector Nuclear Safet and Licensing Enclosures ec:
see page 2 hjg %
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An Equal Opportunity Employer l
. U.S. Nuclear Regulatory Commission 8fP 221987 i
cc (Enclosures):
Mr. G. G. Zech, Assistant Director i
I for Inspection Programs office of Special Projects U.S. Nuclear Regulatory Commission 101 Marietta Street, NW,. Suite 2900 Atlanta, Georgia 30323 I
Mr. J. A. Zwolinski, Assistant Director for Projects Division of TVA Projects Office of Special Projects U.S. Nuclear Regulatory Commission 4350 East-West Highway l
EWW 322
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Bethesda, Maryland 20814 Sequoyah Resident Inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy Daisy, Tennessee 37379 l
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4 ENCLOSURE 1 RESPONSE - NRC OFFICE OF SPECIAL PROJECTS (OSP)
INSPECTION REPORT NOS. 50-327/87-23 AND 50-328/87-23 STEWART L. EBNETER'S LETTER TO S. A. WHITE DATED AUGUST 18, 1987 Violation 50-327. -328/87-23-02
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Criterion V of 10 CFR 50 Appendix B, as implemented by TVA NQAM Part 1, Section 2.5, Revision 0, states, in part, that " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, and shall be accomplished in accordance with these instructions, procedures, or drawings."
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l Contrary to the above, the inspection team identified numerous significant instances in which safety-related activities for verification of the as-built configuration of safety-related instrument mountings were not performed in l
accordance with the established engineering calculation instructions.
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a.
Required instruction sign-off steps for performance of walkdown inspection and drawing confirmations were not completed, especially for
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cases where the installation differed from existing typical drawings, f
b.
Required documentation of engineering evaluations of installations that I
differ from typical drawings was not evident, j
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Installations indicated by engineering to be in accordance with existing detail drawings were in error when compared to as-built field sketches and photographs.
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I d.
References to applicable detail drawings on an associated listing of
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instruments were in error, f
e.
Summary and conclusion statements for calculations were in error or misleading in regard to the following:
J The conclusion stated that each item on the summary list had been inspected when only 210 of the initial selection of 547 items were determined to be within the scope of the program, and only 98 had inspection data sheets completed and filed with the calculation.
The summary stated that for instruments that did not have an existing l
mounting detail, a sketch had been " submitted to Civil Engineering Branch I
(CEB) for seismic analysis to determine the acceptability." Only one CEB calculation could be provided.
It was an as-built analysis of two identical instruments for which no detail drawing existed. No one in DNE (electrical of civil) could show that CEB had performed any evaluation of the many remaining installations with field sketches.
The conclusion stated that each item in the summary listing had
" documented, design approved mounting details." Existing documentation does not support this statement.
This is a Severity Level IV violation (4.j and 7.b.(3), 87-23-02).
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Admission or Denial of the Aller,ed Violation TVA admits the violation occurred as stated.
2.
Reason for the Violation This violation, with multiple examples, occurred because Division of Nuclear Engineering (DNE) calculation SQN-El-005 did not comply with the requirements of Nuclear Engineering Procedure (NEP) 3.1 for calculations.
NEP 3.1 specifies the details for compliance with 10 CFR 50 Appendix B for calculations.
These areas of noncompliance stem from lack of detail in scoping the basis of calculation, lack of consistency in preparing the calculation, and finally, lack of proper review as specified in NEP 3.1.
3.
Corrective Steps Taken DNE calculation SQN-El-005 was initially prepared to answer employee-concern 805.01.
The process involves field inspection and data ~ collection by DNE field inspectors without the involvement of quality control (QC) l personnel.
In a parallel effort, TVA was also conducting an evaluation of a Gilbert j
commonwealth concern regarding the mounting of instrument plate to local panels. This evaluation, which did involve QC personnel, resulted in the generation of approximately 150 work requests outside the intended scope j
of the walkdowm. These deficiencies resulted in initiation of Corrective Action Report (CAR) 87-14.
Upon identification of the numerous concerns with regard to DNE calculation SQN-El-005, it was determined that the corrective actions for CAR 87-14 would best resolve employee concern 805.01.
Therefore, DNE calculation SQN-El-005 is being revised to indicate that the corrective action for CAR 87-14, instead of the calculation, will be utilized to resolve employee concern 805.01.
The revision will be complete by October 15, 1987.
The corrective action for CAR 87-14 includes the preparation of Special Maintenance Instruction (SMI)-0-317-61 to perform a field verification of safety-related instruments. This verification is to be accomplished in two phases.
Phase I on unit 2 (currently in progress) inspects instrumentation required for safety system operation.
During preparation of the inspection packages for SMI-0-317-61, the previously identified examples of lack of mounting details were noted. As a result, identifiable mounting details are being prepared for those instruments that previously did not have mounting details. The final report for phase I will be complete by October 15, 1987. Phase II on unit 2, which will perform a similar verification of documentation on other 1E instrumentation, is scheduled to be complete by September 1, 1989.
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'4.
Corrective Steps To Be Taken-To Prevent Recurrence-i TVA h'as beenJinvolved in an extensive calculation review process.
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i results of thisfreview have not shown'a' generic condition.of noncompliance of., calculations to NEP 3.1.
Therefore..this violation is considered to be an. isolated occurrence and no further corrective action, other'than-j mana5ement attention to procedural adherence, is' required.
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Date When' Full-Compliance Will Be Achieved l
l SQN will be in full compliance on October 15, 1987, when DNE. cal'culation SQN-El-005 is revised.
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ENCLOSURE 2 LIST OF COMMITMENTS.
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By October 15,.1987, SQN will revise.SQN-El-005 to show it'is superseded by CAR 87-14.
2.~ By October 15.'1987, SQN will complete the final report on Phase.I for
_ field verification of safety-related instruments on unit-2.
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3.. By September 1, 1989.SQN will complete the final report on Phase II for field verification of'other 1E instrumentation on' unit 2.
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