ML19327C027
| ML19327C027 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 11/06/1989 |
| From: | Medford M TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8911150079 | |
| Download: ML19327C027 (6) | |
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TENNECZE3 VALLEY AUTHORITY c
CHATTANOOGA, TENNESSEE 37404 6N 38A Lcokout Place 4
NOV 06 989 1
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l U.S. Nuclear Regulatory Commission ATIN:
Document control Desk Washington, D.C.
20555 Gentlemen-i In the Matter of
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Docket Nos. 50-327 Tennessee Valley Authority
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50-328 i
SEQUOYAH NUCLEAR PLANT (SQN) UNITS 1 AND 2 - NRC INSPECTION REPORT N05, 50-327, 328/89 RESPONSE TO NOTICE OF VIOLATION (NOV) 89-21-01 Enclosed is TVA's response to B. A. Wilson's letter to 0. D. Kingsley, Jr.,
dated October 6, 1989, which transmitted the subject NOV.
. provides ', A's response to' the NOV. provides TVA's response to the request for intended actions for addressing perceived f
weaknesses in content of TVA's 10 CFR S0.72 emergency notification system telephone reports.
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If you have any questions concerning this submittal, please telephone N. A. Cooper at (615) 843-6651.
Very truly yours, TENNESSEE VALLEY AUTHORITY
- 41/A 8,771&g Mark O. Medford, Vice President Nuclear Technology and Licensing Enclosures cc:
See page 2 l
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$kI*kbo$ $$bofh7 An Equal Opportunity Employer
2 U.$.NuclearRegulatoryCodmission ggg cc (Enclosures):
Ms. S. C. Black, Assistant Director for Projects TVA Projects Division U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20032 Mr. B. A. Wilson, Assistant Director for Inspection Programs TVA Projects Division U.S. Nuclear Regulatory Commission Region !!
l 101 Harletta Street, NH, Suite 2900 Atlanta, Georgia 30323 NRC Resident Inspector Sequoyah Nuclear Plant 2600 1900 Ferry Road Soddy Daisy, Tennessee 37379 i
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ENCLOSURE 1 RESPONSE TO NRC INSPECTION REPORT NOS. 50-327/89-21 AND 50-328/89-21 B. A. WILSON'S LETTER TO 0. D. KINGSLEY, JR.,
DATED OCTOBER 6, 1989 Violation 50-327 J 28/89 21-01 "10 CFR 50, Appendix B, Criterion V, states that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and thall be accomplished in accordance with these instructions.
1.
Hork Plans M/60401 and M/60501 required that circuit board soldering activities have an 'in-process' QC inspection.
Contrary to the above, an 'in-process' QC inspection was not perfortred for all soldering activities.
2.
Work Request B794653 and Maintenance Instruction 11.7.1, Hand Operated Grinnel or Saunders Type Diaphram Valve, establish the required steps to be performed during the repair of valve 62-946.
Contrary to the above, steps 6.2.1 (3) through (6) were not performed and were indicated as performed on the HI 11.7.1 check sheet.
This is a Severity Level IV violation (Supplement I)."
Admission or Dental of thr AlleSed Violation _(Exemple 1)
TVA admits the violation.
Reason for the Violation (Erample 11 Prior to May 19, 1989, the normal practice was to inspect the soldering of printed circuit board components on critical structures, systems, and components (CSSC) after the soldering was complete.
Thus, the quality control (QC) inspectois would have normally been notified to perform the inspection after the soldering activities were completed.
This approach is consistent with the attributes of the inspection (i.e., the soldered joint should be smooth; bright in appearance; free of chalky, gritty, or irregular surfaces; and free of excess solder and resin).
Interim corrective actions for Condition Adverse to Quality Report (CAQR)
SQP-890244 written to address soldering issues cited a requirement for an in-process quality assurance inspection.
Failure to perform an in-process inspection, as required by the work instructions, resulted from personnel error and confusion regarding the QC inspector's interpretation of work instructions.
In one instance, a QC inspector overlooked the words "in-process" in the work instruction; in the other instance, another QC inspector interpreted the work instructions to mean that the wotLplan was "in-process," not the inspection.
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Corrective Steps That Have Been Taken and Re5Ults Achieved (Example 1)
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r Investigations were performed to determine if these were isolated cases or if f
I other in-process inspections pertaining to soldering performed after l
May 19,1989, were missed.
Results of these investigations determined that these were isolated occurrences and that, when required, tr.-process inspections were otherwise performed.
TVA initiated CAQR SQP-890464 to document the problem.
The corrective actions of the CAQR changed the in-process inspection to a final inspection for j
e soldering activities initiated after August 30, 1989.
This 15 consistent with the attributes of the inspection criteria indicated above.
Corrective Steps That Will Be Taken to Avoid further Violations (Example 1)
I' Because the investigt. tion revealed that these were isolated cases, both QC L
-inspectors involved were advised as to the intent of the in-process requirement..
t Date When Full Compliance Wtil-Be Achieved (Example 1)
SQN 1s in full compliance.
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. Admission or Denial of the Alleged Violation (Example 2)
TVA admits the violation.
I Reason for the Violation (Example 2)
The reason for the violation was a failure of the responsible craftsmen and l
foreman to ensure work was properly documented in the work package. The cause i
for falling to properly document the work performed was personnel error.
l Prior to starting the work, the craftsmen involved mutually agreed to the scope of the work to be performed and that only one craftsman was needed to perform the work.
The work was performed by one craftsman inside the
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contamination zone (C-zone) while the other craftsman remained outside the I
C-tone to record the entries of the work performed in the work package.
This method of performtry the work was utilized because the radiological conditions required a face mast and because of the close pionimity of the work conditions and the relatively small C-zone.
During performance of the work, the l
craftsman outside the C-zone marked off steps in the work package prior to the work being performed.
This resulted in the appearance that work had been i
performed in the field that was not ccmpleted at that time.
While the valve was being disassembled, an unexpected release of radioactive gas from the valve occurred causing the auxiliary building airborne radiation monitors to alarm. At this time, the work was stopped; the craftsman outside the C-zone exited the auxiliary building, and the craftsman inside the C-Zone i
. reestablished the valve pressure bNdary, then exited the C-zone and auxiliary building.
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]nvestigation into the source of the alarm consumed the remainder of tne shift. Consequently, when the craftsnan that entered the C-zone v
.e involved in the investigation, the work package was not reviewe,, the craftsmen nor the foreman.
Tna work package was reviewed and torrected on the following shift.
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Corrective Steps That Have Been Taken and Results Achieved (Exemple 2)
}f Upon discovery, the work package was thoroughly reviewed and corrected.
TVA initiated Problem Reporting Document SQN 890467P to document and correct the problem.
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.An informal sampling of Mechanical Maintenance personnel indicated that this L
is not a generic problem.
Normal practice is to take two validated / controlled t
copies of the work package to the work area; one copy is taken into the f
C-rone, and the other copy is left outside the C.rone, in case the extra copy l
1s needed.
In this particular case, it was more convenient for only one craftsman to enter the C. tone and perform the steps in the work package previously discussed and agreed on, i
. Corrective Steps That Will Be Taken to Avoid Further Violation (Example 2)
The individuals involved were appropriately otsciplined with emphasis on following procedures and maintaining accurate work packages. A training letter was issued on October 31, 1989 -to Maintenance employees at SQN describing this event, reinforcing the need and requirement to maintain accurate work packages and to follow procedures.
Nechanical Maintenance conducted a briefing with foremen and general foremen f
to explain their responsibilities concerning proper and timely documentation r
of work activities.
The foremen then briefed their crews on the l
responsibilities of the individual craftsmen in documenting work activities.
t This corrective action was completed November 3, 1989, i
U M6nagement involvement in fleid activities has been increased.
This includes monitoring the quality of work packages in the field, ensuring corrective entries are made in instructions, ensuring the work packages accurately reflect the status of fieldwork, and providing immediate feedback to workers l
to ensure that standards of performance are communicated vertically throughout the department.
These actions serve to reinforce the training letter and are intended to further ensure compliance with plant proccdures.
Date When Full Compliance Will Be Achieved (Erample_2) h SQN is in full compliance.
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,,y ENCLOSURE 2 s
Cmergency Notification System (ENS) Telephone Reports I
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TVA believes that the information provided in the two ENS telephone reports
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1 was correct and adeyv&tely enveloped pertinent safety' aspects of each l
L situation, fvent investigettons often develop additional information regarding events.
In these two cases, the onsite NRC resident inspectors were
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fully aware of the events, and these events were subsequently reported in i
c Licensee Event Reports 50-328/89008 and 50-327/89025.
4 TVA has reviewed points made by NRC and initiated actions intended to i
standardire 50.72 reports and promote consistent transfer of information from f
SQN to the NRC Operations Center.
A night order was issued to emphasize the
.i importa. ice of this information trahsfer and the use of SQN's Administrative l
Instruction 18.18, Appendix C, during reporting.
Appendix C is a replication of an NRC event notification worksheet form, which is used as a checklist for i
reporting all the pertinent information necessary to describe the event
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classification, category, cause of failure, corrective actions, safety t
systems / components operating, etc.
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TVA is sensitive to NRC's reporting needs and has provided management emphasis i
to address those concerns.
TVA has and will continue to notify and report events / conditions to NRC as required and will strive to fully communicate pertinent information surrounding events to NRC.
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