ML20237H761
| ML20237H761 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 08/07/1987 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8708170346 | |
| Download: ML20237H761 (6) | |
Text
_ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ - _ _ _ _ _
l
?
TENNESSEE VALLEY AUTHORITY.
CH ATTANOOGA, TENNESSEE 37401 SN 157B Lookout Place l
AUG 071987 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk
. Washington, D.C.
20555 l
Gentlemen:-
In'the Matter of
)
Docket Nos. 50-327
. Tennessee Valley Authority
)
50-328 SEQUOYAH NUCLEAR PLANT (SQN) NRC INSPECTION REPORT NOS. 50-327/87-02 AND 50-228/87 RESPONSE TO NOTICE OF VIOLATION NOS. 50-327, -328/87-02-01 Enclosed is our revised response to Gary C. Zech's April 17,'1987 letter to S.
A.' White that transmitted the~ subject Notice of Violation. Our letter of July 22, 1907, withdrew our original response of June 12, 1987, and committed to provide a revised response by August 7, 1987. provides our response to the Notice of Violation. Enclosure 2 contains a list of commitments contained in enclosure 1.
We do not recognize any other. items described herein as commitments.
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 VALLEY AUTHORITY R. Cridley, Dir ector Nuclear Safety,and Licensing Enclosures cc: See page 2 1'
t 1
/
8708170346 870007
/ d ADOCK 0 % y7
\\
PDR 0
An Equal Opportunity Employer
S
_g.
U.S. Nuclear. Regulatory Commission M G 0'1 E -
- cc'(Enclosures):
Mr. G. G. Zech. Assistant Director for Inspection Programs Office of Special Projects U.S. Nuclear Regulatory Commission 101 Marietta Street, NW,. Suite 2900 Atlanta, Georgia 30323 Mr. J. A. Zwolinski, Assistant Director for Projects.
Division of TVA Projects j
office of, Special Projects U.S. Nuclear Regulatory Commission 4350 East West Highway EWW 322 Bethesda, Maryland 20814 l
Sequoyah Resident Inspector.
Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy Daisy, Tennessee 37379 i
i i
ENCLOSURE 1 RESPONSE - NRC-01E INSPECTION rep 0RT NOS. 50-327, -328/87-02 GARY G.:ZECH'S LETTER TO S. A. WHITE DATED APRIL 17, 1987 Violation 50-327. -328/87-02-01 10CFR50 Appendix B, Celterion III, states that design changes including field changes shall be subject to design control measures commensurate with those applied to the original design. Nuclear Engineering Procedure (NEP)-6.1 states that changes to any design documents which deviate from the approved scope of work will be evaluated against the original work scope..The evaluation against the original work scope includes applicable portions of NEP-6.1, Attachment 2.
Field change 4873 deviated from the approved scope of Engineering Change Notice (ECN) L6715, which implemented the original design change request, by addressing the removal of electrical circuits indicated in " hold clouds" from certain drawings. ECN L6715 did not address the existence or removal of these electrical circuits indicated in " hold clouds" on certain drawings.
Contrary to the above, field change 4873 was not reviewed and approved subject to design control measures commensurate with those applied to the original design in that:
a.
The design change request that initiated the original engineering change notice was not reviewed during the field change review and approval process.
b.
NEP-6.1, Attachment 2 was not used in the field change request review and approval process.
This is a Severity Level V violation (Supplement I).
1.
Admission Or Denial of The Alleged Violation TVA concurs the violation occurred.
2.
Reason For The Violation The violation resulted from personnel errors that miscategorized the involved field change request (FCR) as a category A FCR (i.e., within the scope of the engineering change notice [ECN) against Which the FCR is issued.) A contributing factor to these errors was the fact that the involved circuits under " hold" were added to the as-designed drawing by the same drawing revision that was issued for the ECN.
This gave the appearance that the involved circuits under hold were within the scope of the involved ECN.
The involved circuits under hold were draf ted into the drawings but were placed under hold when the final approved scope of the ECN was reduced from the scope that had been anticipated.
r
_3 Sequoyah Engineering Procedure (SQEP) AI-11A requires that category A FCRs be within the scope of the involved ECN and unreviewed safety question determination (USQD).
In this case, portions of the FCR were not within the scope of the approved ECN, although the involved circuits under hold were within the scope of the engineering report (ER) upon which the ECN was based.
The involved circuits were not addressed by another ECN.
TVA has identified that a contributing cause to this violation was the lack of specific definitive procedural controls involving the use of hold circles on as-designed drawings.
This lack of definitive controls resulted in errors in the addition of the hold circles for ECN L6715 and the subsequent removal by FCR 4873.
Since the information on hold on as-designed drawing 2 procedurally cannot be field implemented and since the information on hold was not associated with another ECN, removal of the involved circuits under hold did not affect the physical configuration, operation, or maintenance of the plant.
TVA does not agree that failure to review the original design change request (DCR) or to utilize Nuclear Engineering Procedure (NEP)-6.1, attachment 2, during the review and approval of this FCR was a contributor to this violation.
DCR-2259 is a generic DCR that authorizes implementation of corrective action identified in nonconformance reports (NCRs), significant condition reports (SCRs),
and ERs.
Review of this generic DCR would not have provided any specific information relative to the ECN.
The information contained in NEP 6.1, attachment 2, is addressed by the modification criteria e
that is a part of the ECN package. Although the individuals involved did not perform a word by word or page by page review of this ECN as part of the review and approval of the FCR, these individuals were knowledgeable of the ECN contents as a result of.their involvement with its preparation and approval.
3.
Corrective Actions Taken Condition Adverse to Quality Report (CAQR) SQP870011 was written to address the problem and identify corrective action.
The corrective action identified was subsequently determined to be invalid, and CAQR SQP870812 was generated.
The corrective action for this CAQR will be to remove the remaining information on hold related to ECN L6715 by March 1, 1988.
TVA has implemented a transitional design control system that improves the design control process and provides for an effective transition to the permanent system.
Specified details on this system are provided in the Sequoyah Nuclear Performance Plan (SNPP),Section II.3.3.1.
SQEP-13 " Procedure for Transitional Design Change Control," defines the design change control process in the transition between the past design change control process and the permanent Plant Modification Package (PMP) system.
t 4 l l
1 The transitional design control process provides the necessary design j
change controls to ensure that the SQN design baseline and as-constructed configuration are maintained in design documentation.
It ensures that quality design change work is performed while introducing SQN personnel to the integrated design change package and single controlled drawing concepts that will be used in the future PMP system.
Utilization of the single controlled drawing concept and PMP in accordance with SQEP-13 obviates the use of hold c.ircles.
SQEP-13 requires new ECNs to be controlled under the SQEP-13 process. Thus the need to provide definitive controls on the additions of hold circles to drawings is not needed.
4.
Corrective Action To Be Taken To Preclude Recurrence NEPs will be revised by October 15, 1987, to provide definitive controls for the removal of existing hold circles from as-designed drawings.
These revision (s) will ensure that the removal of existing hold circles from as-designed drawings for those existing ECNs still under the control of SQEP-AI-11 is subject to appropriate administrative controls.
The remaining information on hold related to ECN L6715 will be removed by March 1, 1988.
5.
Date When Full compliance Will Be Achieved c
Full compliance relative to this violation has been achieved.
I
{
i l
.1
ENCLOSURE 2 LIST OF COMMITMENTS 1.
NEPs will be revised-by October 15, 1987, to provide definitive controls for the removal of hold circles from as-designed drawings.
2.
The remaining information on hold related to ECN L6715 will be removed by March 1, 1988.
.T
_ _ _. - - - _ - _ _ - _ _ _ _ _ _ _ _ - _ - _ - _ - _.