ML20005E083

LER 89-032-00:on 891201,discovered That Tech Spec Surveillance Requirement to Verify That Valves 1-67-748 & 2-67-748 in Open Position Not Met.Caused by Personnel Error.Correct Valve Position verified.W/891222 Ltr

ML20005E083
Person / Time
Site:	Sequoyah
Issue date:	12/22/1989
From:	Bynum J, Spencer S TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-89-032-01, LER-89-32-1, NUDOCS 9001030228
Download: ML20005E083 (4)

Text

m. 0; Io TENNESSEE VALLEY AUTHORITY 6N 38A Lookout Place December 22, 1989 i U.S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, D.C. 20555 .

Gentlement TENNESSEE VALLEY AUTHORITY - SEQUOYAH NUCLEAR PLANT UNIT 1 - DOCKET NO. '

50-327 - FACILITY OPERATING LICENSE DPR LICENSEE EVENT REPORT (LER) 50-337/89032 The enclosed LER provides details concerning a failure to perform a technical

. specification surveillance requirement within the specified time interval as.

the result of inadvertent deletion of procedural steps from a surveillance instruction. This event is being reported in accordance with 10 CFR 50.73, paragraph a.2.1.b.

Very truly yours, TENNESSEE VALLEY AUTHORITY

, s-U. R. Bynum,g ice President Nuclear Power Production Enclosure cc (Enclosure):

Regional Administration U.S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region II 101 Marietta Street, Suite 2900 Atlanta, Georgia 30323 INPO Records Center Institute of Nuclear Power Operations 1100 Circle 75~ Parkway, Suite 1500 Atlanta, Georgia 30339 NRC Resident Inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road-Soddy Daisy, Tennessee 37379 fGP 6

900103CG?28 891222 PDR ADOCK 05000327 S PDC An Equal Opportunity Employer

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"' Failure to perform a surveillance requirement within the specified time interval i bicmuse of inadvertant deletion of procedural ste> during procedure revisions EVENT DATE 15) LER NUMSER lol REPOfli DATE 171 OTHER F ACILITIES INVOLVED tel

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NAME TELEPHONE NUM8ER AMsACODE Sydney W. Spencer, Compliance 1.icensing Encineer 61115 81 41 31-17 151410 COMPLETE ONE LINE FOR E ACH COMPONENT 7 ALLURE DESCRIBED IN THt$ REPORT (131 0

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l I I I I i 1 l 1 l l l 'l l l Y l l I l l l l SUPPLEMENT AL REPORf lixPECTED (141 MONTH DAY YEAR l SU8 Mission YE$ II! res comotore RX*ECTED SUOM15SION DATf' NO l l l ASST 3.ACT tlaw4 801400 weces. 6 e , eooronunerety Meeen song'e nonce troewnteen hnes) USE On December 1, 1989, with Units 1 and 2 at 100 percent power, it was discovered that a tschnical specification surveillance requirement had not been met because of an inidequate surveillance instruction. The surveillance instruction had recently been rsvised and two valves were inadvertently deleted. The root cause of this event has l-b;sn. determined to be a clerical personnel error with a contributing cause being that ths engineer failed to verify that the final procedure agreed with the draft version.

As immediate corrective action, an instruction change form was initiated to include the missing valves, and the procedure was completed on December 3, 1989. As additional j corrective action, responsible clerical and engineering personnel have been appropriately disciplined. .

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0[0 0l 2 0F 0l3 Description of Event

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'On December 1, 1989, with Units 1 and 2 in Mode 1. (100 percent power, 2,235 pounds per square inch gauge, and 578 degrees Fahrenheit), it was discovered that two valves (1-67-748 and 2-67-748) had been inadvertently deleted from Surveillance Instruction (SI) 167 during Revision 23. The two valves are technical specification (TS) required v:1ves to meet Surveillance Requirement 3.7.11.lb. As a result of the valves not being varifled in the open position, the TS required surveillance interval of 31 days was cxceeded. SI-167 was completed successfully on October 3, 1989, and should have been completed by November 10, 1989, based on maximum allowable extension of the surveillance interval. These valves are part of the high pressure fire protection system (EIIS Code KP).

During preparation of the proposed Revision 23, to SI-167, " Fire Header Valve Lineup Inspection, the fire protection staff completely reviewed the existing revision and psrformed a general revision. The purpose of this revision was to provide the

.parforming craft with an inspection sequence that was more appropriate for the present plant configuration and staffing levels. The revision also added a description of the vs,1ve locations. The proposed revision was marked up and forwarded to typing. The rough typed copy was received and checked for accuracy by the fire protection engineer.

The two valves in question were included in the proposed procedure revision. The rough draft was sent for independent qualified reviewer (IQR) review. The comments from the IQR review were received by the fire protection engineer, resolved with the commenter, and incorporated.into the rough draft for inclusion into the final approved procedure.

The revised rough draft was then forwarded to typing for incorporation of final comments. There was no comment to delete the two valves, and the valves were still included at this time. Typing completed the changes as marked on the rough draft and raturned the fire protection engineer.

The fire protection engineer reviewed the changes but the particular section that contained the missing valves was not checked because no changes were supposed to be made to that section. The approved copy of the procedure, Revision 23, was distributed for use on October 31, 1989.

During the December 3, 1989 performance of SI-167, the fire operations staff identified that the essential raw cooling water Valves 1-67-748 and 2-67-748 had been deleted from the SI data sheets. The fire protection staff immediately compared Revision 22 to Rsvision 23 and confirmed that no other valves had been inadvertently deleted. A

- varification of the two valve positions was immediately performed, and the shif t operations supervisor (SOS) was notified. Instruction Change Form (ICF) 89-0841 was initiated, SI-167 was completed on December 3, 1989, and Condition Adverse to Quality Rsport (CAQR) SQP890654 was written.

02use of Event The root cause of this event has been attributed to personnel error on the part of parsonnel involved in preparation of the procedure revision. A lack of attention to datail during the final review of the procedure contributed to the problem.

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0l0 0 l3 0F 0l3 Analysis of Event This event is being reported in accordance with 10 CFR 50.73, paragraph a.2.1.B. as an ,

operation prohibited by TSs in that a surveillance requirement performance frequency was

.not met.

SI-167 verifies the valve positions for the high pressure fire system. For worse case, operator action may have been required had a fire been detected with no suppression system initiation. At the time of discovery, the valve position was immediately varified to be in the correct position. Therefore, there was no adverse effect on the

'hsalth and safety of the public or the plant.

Corrective Action Immediate corrective actions consisted of notification of the SOS, verification of ,

correct valve position, initiation of a CAQR, initiation of ICF 89-0841 and subsequent parformance of the corrected SI-167.

As intermediate and long-term corrective actions, the personnel involved with the procedure preparation and review have been reinstructed on correct procedure revision  !

methods and attention to detail in regard to job parformance. . All responsible personnel have been appropriately disciplined.

Additional Information.

There have been 21 LERs previously written as a result of sis not ensuring complicnce with TSs--SQN 50-327/86007, 86008, 86013, 86017, 86018, 86028, 86030, 86035, 86039, 86040, 86042, 86044, 86050, 87002, 87007, 87008, 87009, 87025, 89025, SQN 50-328/86006, and 86007. After a review of the previously written LERs, only one LER (50-328/86006) was identified where an item (i.e., smoke detector) was deleted during the procedure revision process.

Commitments None.

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l NMC Perm 306A ($49)

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