ML20237C833

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-327/87-18 & 50-328/87-18.Resubmittal of Response to Examples 8 & 9 Requested within 30 Days of Ltr Date

ML20237C833
Person / Time
Site:	Sequoyah
Issue date:	12/09/1987
From:	Richardson S NRC OFFICE OF SPECIAL PROJECTS
To:	White S TENNESSEE VALLEY AUTHORITY
References
NUDOCS 8712220215
Download: ML20237C833 (4)

See also: IR 05000327/1987018

Text

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DEC 0 91987

Tennessee Valley Authority

ATTN: Mr. S. A. White

Manager of Nuclear Power

6N 38A Lookout Place

1101 Market Street

Chattanooga, TN 37402-2801

Gentlemen:

SUBJECT: REPORT NOS. 50-327/87-18-01 AND 50-328/87-18-01

Thank you for your response of July 24, 1987, to our Notice of Violation issued

on June 10, 1987, concerning activities conducted at your Sequoyah facility.

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We have evaluated your response and found that it meets the requirements of

10 CFR 2.201.

After discussing the reasons for your denial of example 5 of the subject ,

violation with the associated inspector, for the reasons stated in the

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enclosure, we accept your denial. Concerning your denial of examples 8 and 9

of the subject violation, for the reasons stated in the enclosure, we believe

the violation occurred as stated. Therefore, in accordance with 10 CFR 2.201

and within 30 days of the date of this letter, please resubmit your response

for examples 8 and 9 of the subject violation.

We appreciate your corporation in this matter.

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Sincerely,

Original signed by

S. D. Richardson

Steven D. Richardson,

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Acting Director

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TVA Projects Division

Office of Special Projects

Enclosure:

Staff Review of Licensee Response

Dated July 24, 1987

cc w/ encl: I

H. L. Abercrombie, Site Director

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Sequoyah Nuclear Plant

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J. A. Kirkebo, Director,

l Nuclear Engineering

R. L. Gridley, Director

Nuclear Safety and Licensing

M. R. Harding, Site Licensing

Manager

TVA Representative, Bethesda Office

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bec w/ enc 1: (See page 2)

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Tennessee Valley Authority. 2

DEC 0 91987-

bec w/ enc 1:

S. D. Ebneter OSP

S. D. Richardson, OSP

G. G. Zech,~OSP.

B..D. Liaw, OSP

J. Rutberg, OGC-

W. S. Little OSP/RII

F. McCoy.-OSP/RII

R. Carroll, OSP/RIT i

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J. Brady, OSP/R11

NRC Resident Inspector

-DRS Technical Assistant

NRC Document Control Desk

State of Tennessee

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ENCLOSURE

STAFF REVIEW 0F LICENSEE RESPONSE

DATED JULY 24, 1987

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Violation Example 5

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"During functional and stroke time testing of a containment standpipe

isolation valve, a faulty indicator dial was used to determine valve

mid-position, and there were no procedure instructions for determining valve

full-orin position."

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Discussion l

TVA has denied this example of the 87-18 violation stating that existing .

acceptance criteria is fully adequate to determine valve travel to its

open- ptsition.

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Discussions with the NRC inspector who identified this violation indicate

concurrence with the TVA response. His subsequent evaluation of site

criteria, and test performance suggest adequate program controls in this

area.

Conclusion

The TVA denial of this example is accepted. No further action is required.

Violation Example 8

" Work activities, including disassembly and reassembly of a bolted flange and

other jcints and cleanout of instrument tubing, were performed without work

instructions, inspections, or second party verification of joint makeup."

Discussion

TVA has denied this example of the violation stating that such work

activities are within the daily skill of the craft, second party

verification was provided, and that no evidence could be obtained that i

would indicate that instrument personnel removed or rebolted the flange

mentioned in the report.

This response was discussed with the NRC inspector whu identified the

originci concern. Based upon this discussion it appears that TVA has not

adequately addressed the following concerns.

1. While TVA claims that no evidence could be found that instrument

personnel removed or rebolted the flange, the inspector observed

the flange disassembled, has reinspected the installation and

verified that the flange has been reassembled and is covered with

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insulation. Since this flange is considered a portion of critical

structures, systems, and components equipment, skill of the craft is

considered an unacceptable method for complying with the

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requirements of 10 CFR 50 Appendix B.

2. As indicated in the report the associated tubing lines had been

clogged with crystallized boric acid, and were subsequently cleaned

out by craftsmen. However, no investigation was initiated to

determine the cause, extent or possible adverse impact of this l

material upon the tubing lines.

3. The first and second-party verification mentioned in the TVA response

is limited to confinning existence of the gauge and does not address

tightness of joints or component fitup.

Conclusion

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The TVA denial of this violation example is not accepted. Additional

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evaluation which addresses the concerns detailed above and how skill of

the craft meets the requirements of 10 CFR 50 Appendix B is required.

Violation Example 9

"During functional testing of diesel generator room exhaust fans, a step

verifying that red lights on the fan breaker were energized was signed

off when, in fact, the panel lights were burned out."

Discusplon

TVA denies this example of the violation stating that the subject test

was properly performed.

Discussions with the NRC inspector who identified this concern reaffirm

that the functional test was not performed as required by test instruc-

tions, specifically, that the step which requires verification of

indi< ating lights was signed off prior to bulbs being installed for

indi ation. The criteria used at the time of sign off was whether the

fan cas running. After the sign off the inspector observed that

f.mitating bulbs were installed and the test rerun.

jonclusion

The TVA denial of this violation example is not accepted. Additional

evaluation of the performance of this test, and general test practices is

required.

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