ML070320281

Special Inspection Charter to Evaluate Operations and Maintenance on Time Critical Manual Valves

ML070320281
Person / Time
Site:	Sequoyah
Issue date:	02/01/2007
From:	Travers W NRC/RGN-II
To:	Speck M Reactor Projects Region 2 Branch 6
References
Download: ML070320281 (4)

Text

February 1, 2007 MEMORANDUM TO: Mark E. Speck, Resident Inspector Sequoyah Nuclear Plant Reactor Projects Branch 6 Division of Reactor Projects FROM: William D. Travers, Regional Administrator /RA/

SUBJECT:

SPECIAL INSPECTION CHARTER TO EVALUATE OPERATIONS AND MAINTENANCE ON TIME CRITICAL MANUAL VALVES AT SEQUOYAH You have been selected to lead a Special Inspection to assess the circumstances surrounding the inability to operate manual valve 2-62-527 within the required time of Abnormal Operating Procedure (AOP)-N.08 Appendix R Fire Safe Shutdown, at Sequoyah Unit 2 on November 27, 2006. Your inspection should begin on February 5, 2007. Ronald F. Aiello will be assisting you in this effort.

A. Basis On November 27, 2006, the licensee shut valve 2-62-527 as part of a clearance activity to support Unit 2 outage maintenance and found the valve difficult to operate (i.e.,

required two operators approximately 30 minutes to close). Closing this valve is one of several manual operator actions required by AOP-N.08 to be completed in less than 13 minutes in order to restore Reactor Coolant Pump (RCP) seal flow and prevent RCP seal failure. Review of corrective action documents indicate that operators raised questions as to the ability to perform these actions as early as October 24, 2005.

In accordance with Management Directive 8.3, NRC Incident Investigation Program, deterministic and conditional risk criteria were used to evaluate the level of NRC response for this operational event. Based on the deterministic criteria that involved possible adverse generic implications combined with the event characteristics that are beyond the scope and capability of the risk assessment for this degraded condition, Region II determined that the appropriate level of NRC response was the conduct of a Special Inspection in accordance with Manual Chapter 0309, Reactive Inspection Decision Basis for Reactors.

This Special Inspection is chartered to identify the circumstances surrounding this event and review the licensees actions following discovery of the conditions. In addition, the inspectors will review this event for generic aspects regarding time critical operator actions being impacted by maintenance activities.

CONTACT: Malcolm T. Widmann, DRP/RPB6 404-562-4550

M. Speck 2 B. Scope The inspection is expected to perform data gathering and fact-finding in order to address the following:

1. Develop a sequence of events including applicable management decision points from the time the concern for the inability to operate Appendix R manual valves was raised through troubleshooting and repair activities.

2. Review the extent of condition for this event for generic safety implications involving time constrained manual operator actions in emergency, abnormal and Appendix R fire/safe shutdown procedures, i.e., determine if processes or procedures assure manual action operability during post-maintenance testing.

3. Assess operating and maintenance procedures and operations and maintenance personnel training concerning Appendix R or emergency operating procedures manual actions manual valves and determine if operations and maintenance personnel are made aware of time constraints placed on operating these valves.

4. Assess the process for maintaining, recognizing and protecting time critical manual actions and if such processes are defeated (i.e., through tag-outs, impairment, etc.) if compensatory measures are implemented for the manual actions.

5. Determine if there are regulatory or licensee requirements to assure either fire or emergency operating manual actions are verified through post-maintenance testing procedures.

6. Collect data necessary to support completing the significance determination process for the associated Sequoyah Unresolved item (URI) and close the URI, if possible.

C. Guidance Inspection Procedure 93812, "Special Inspection," provides additional guidance to be used during the conduct of the Special Inspection. Your duties will be as described in Inspection Procedure 93812. The inspection should emphasize fact-finding in its review of the circumstances surrounding the event. Safety or security concerns identified that are not directly related to the event should be reported to the Region II office for appropriate action.

You will report to the site, conduct an entrance, and begin inspection no later than February 5, 2007. It is anticipated that the on-site portion of the inspection will be completed during the week of February 5, 2007. A status briefing of Region II management will be provided the first day on-site at 4:00 p.m. A report documenting the results of the inspection should be issued within 30 days of the completion of the inspection.

M. Speck 3 This Charter may be modified should you develop significant new information that warrants review. Should you have any questions concerning this Charter, contact Malcolm Widmann at (404) 562-4550.

Docket Nos.: 50-327 and 50-328 License Nos.: DPR-77 and DPR-79 cc: W. Kane, OEDO S. Campbell, OEDO J. Dyer, NRR C. Haney, NRR B. Moroney, NRR R. Zimmerman, NSIR V. McCree, RII C. Casto, RII H. Christensen, RII J. Shea, RII K. Kennedy, RII M. Widmann, RII R. Haag, RII

OFFICE RII:DRP RII:DRP RII:DRS ORA SIGNATURE /RA/ /RA/ ./RA By K. Kennedy for/ /RA/

NAME MWidmann CCasto JShea VMcCree DATE 1/31/07 1/31/07 1/31/07 2/1/07 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO