ML20235X154

Responds to NRC Re Violations Noted in Insp Repts 50-327/87-37 & 50-328/87-37.Corrective Actions:Evaluation of Improperly Packed Valves Made & Craftsmen Briefed Re Prejob Reviews & Procedural Adherence to Packing Requirements

ML20235X154
Person / Time
Site:	Sequoyah
Issue date:	10/09/1987
From:	Gridley R TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NUDOCS 8710190234
Download: ML20235X154 (5)

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Q l TENNESSEE VALLEY AUTHORITY -

.h CH TTANOOGI, TENNESSEE 37401

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08T 091987 s

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, !y U.S. Nuclear. Regulatory Commission d 4

? ATTN: -Document Control Desk. . $3 C

' Washington;'D.C. 20555 Gentlemen:-

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'In the Matter' of ) . Docket Nos. 50-327 W .'

' Tennessee Valley Authority- )- 50-328 o

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SEQUOYAH NUCLEAR PLANT (SQN) UNITS.1 AND 2 - NRC REGION II INSPECTION R$P0RT

'l ? 'N08.iS0-327/87-37 AND.,50-328/87 MAINTENANCE - RESPONSE TO VIOLATION i

EnclosedL is our. response to Gary G. Zech's letter. to S. A. White dated

, September 9.-1987,;that transmitted Notice of Violation 50-328/87-37-01.

. Enclosure 1 contains'our' response to,the subject. Notice'of Violation.'and

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enclosure 2 contains.the list'of commitments contained in enclosure 1.

hIf you have.any, questions..P lease telephone-N. R. Harding.at 615/870-6422.

'I To the"best of my knowledge. I declare the statements contained herein are-l  : complete and true.'

Very truly yours.

TENNESSEE V LEY AUTHORITY

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R. Gridley, irector Nuclear Lic nsing and ReSulatory Affairs Enclosures

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An Equal Opportunity Employer L2 _-

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[U.S.NuclearRegulatoryCommission 00T 091987-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. Zwo11nski, Assistant Director for Projects'.

Division of TVA Projects i Office of Special Projects.

U.S. Nuclear Regulatory Commission.

4350 East-West Highway.

EW 322 Bethesda,-Maryland 20814 Sequoyah Resident Inspector .

'Sequoyah Nuclear Plant 2600 Igou Ferry. Road Soddy Daisy, Tennessee 37379-  ;

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ENCLOSURE 1 4 ' RESPONSE - NRC REGION II INSPECTION REPORT ]

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NOS, 50-327/87-37 AND 50-328/87-37 GARY C. ZECH'S LETTER.TO S. A. WHITE

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DATED SEPTEMBER-9, 1987'

./ - (! Violation 50-328/87-37-01! I i

m' Tech'nical Specification 6.8.1 requires thatl written procedures be. implemented-  !

coveringithe" applicable' procedures recommended in' Appendix 'A' of Regulatory Guide 1.33,: Revision 2, February 1978. Appendix 'A' of Regulatory Guide 1.33 h ,

l states that' maintenance that can. affect the performance of safety-related

' equipment should be performed:in accordance with documented instructions. ,j

. Work Requests ~(WRs) B297733 and B230619 provide the instructions for repacking '

vsives 2-VLV-0704680 and 2-FCV-063-0005, respectively. The repacking steps ,

are.in both; cases specified.in MI-11.4, Maintenance:of'CSSC Valves, Rev.-19. 'J MI-11.4. requires that the.inside diameter of the stuffing box and the outside I diameter-of'the stem'or shaft be measured andLthat the dimensions obtained be .f

~ verified within +/- 1/64' inch of.the packing' ring' dimensions. This  !

! requirement-isLeontained:in steps 6.10.9.2 and 6.10.9.3 for valves with graphite' packing such as 2-VLV-070-680'-(WR B297733) and in step 6.10.6.2 and

-6.10.6.3 for. valves with split ring packing such as 2-FCV-63-0005 (WR .i it >

.B230619).- MI-11.4'also: requires, in step 6.9.2, that a Quality Control.(QC)-

inspector' verify the_ lubricant type if-a valve stem is lubricated during

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maintenance.

. Contrary (to the:above', the licensee failed to follow WRs B297733 and B230619 u in that'the: stuffing box dimensions.were not'obtained'and verified to be within'+/- 1/64 inch ofthe packing ring dimensions as required by MI-11.4.

-In addition, during the' performance of WR B230619, a lubricant was applied to

'the stem of valve'2-FCV-63-005. The type of lubricant used was not verified by;QC as required by MI-11.4.

This'is a Severity Level V violation (Supplement I).  ;

1.. ' Admission or Denial of the Violation TVA admits the violation occurred as stated.

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-Reason for the Violation I 1

The.above-cited examples of this violation relating to the failure to j take stuffing box dimensions occurred because of a misinterpretation of j the procedural requirements contained in Maintenance Instruction .)

(MI)-11.4. The craftsmen involved were estimating the i 1/64-inch l tolerance instead of obtaining an exact measurement.- This was being accomplished'by a physical comparison of the old packing to the new and/or installing the packing in the' valve to determine a proper fit.

'The craf tsmen's practice in this case was somewhat justified in that the procedure (MI-11.4) provided no place for recording this measurement as would be expected if a measurement was to be taken.

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4 With regard to the use of lubrication, this example also occurred because of a misinterpretation of the work instruction. The craftsmen considered the application of lubricant to the packing and stem for packing installation to be within their skill and did not consider this to be in i violation of the procedure. In fact, the correct lubrication was used, l

However, the craftsmen considered the fact that the Quality Control (QC) signature blanks for verification of lubricant that had been marked "N/A" by the planners meant QC verification was not required, not that lubricant itself was not required.

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3. Corrective Steps Taken and Results Achieved 1

Upon identification of the cited examples of failure to follow procedurcs, meetings were held with the craft and management personnel involved to ascertain the reason for the noncompliance. Subsequently, condition adverse to quality report SQP871274 was initiated to document

! and track corrective action. An evaluation of the valve's condition as a result of the maintenance performed on them was conducted to ensure that they had not been adversely affected. It was determined that the valves were not adversely affected, and they are acceptable as is.

4. Corrective Steps to be Taken to prevent Recurrence TG prevent future misinterpretation, SQN will conduct briefings with the craftsmen performing this type of work to emphasize procedural adherence, prejob reviews, and specifically the requirements of MI-11.4 with regard to packing. Additionally, SQN will conduct briefings with the maintenance planners with regard to the planning aspects of MI-11.4.

These briefings will be completed by November 30, 1987.

With regard to the procedural requirements for installing valve packing, .

SQN is evaluating the current packing and lubrication practices for potential generic problems and will revise MI-11.4 to clarify the procedural requirements for packing size verification. This will be completed on or before November 30, 1987.

5. Date When Full Compliance Will be Achieved SQN is now in full compliance.

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, ENCLOSURE 2

LIST OF COMMITMENTS' c

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~ $1,< 'By' November. 30','1987,;SQN will-conduct briefings with the craftsmen .{

,a performing safety-related vr.1ve repacking work to emphasize procedural' I L .' adherence..prejob reviews, and specifically the requirements of MI-11.4 for packing.

1 2.. By November 30, 1987, SQN will conduct' briefings-with the maintenance i planners with regard to the planning aspects of MI-11.4.

3. .By November 30, 1987.. SQN will complete.the review of current packing and lubrication practices and revise MI-11.4'to clarify the procedural requirements for packing size verification.

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