ML20044F827
| ML20044F827 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 05/21/1993 |
| From: | Fenech R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9306010093 | |
| Download: ML20044F827 (7) | |
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Tennessee vamy Aarnomy. Post othce Boa 20m soody-Daisy Tennessee 37379 ?'JJO Robert A. Fenech Vce Prescent Seaucyah Nucear Pent May 21, 1993 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Gentlemen:
In the Matter of
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Docket Nos. 50-327 Tennessee Valley Authority
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50-328 SEQUOYAH NUCLEAR PLANT (SQN) - NLC INSPECTION REPORT NOS. 50-327, 328/93 REPLY TO NOTICE OF VIOIATION (NOV) 50-327, 328/93-09-01 AND -03 i
Enclosed is TVA's response to Paul E. Fredrickson's letter to Mark O. Medford dated April 22, 1993, which transmitted the subject NOV.
This letter contained two violations. The first violation is associated with several components that were not configured properly. The second violation is associated with numerous safety-related instruments that i
were not calibrated as the result of an inadequate surveillance t
instruction deferral process.
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Part of the condition associated with the first violation was previously reported in accordance with 10 CFR 50.73 by Licensee Event
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Report 50-328/93002 dated April 19, 1993. There are no new commitments associated with that violation. Enclosure 2 of this submittal contains conunitments associated with the second violation.
If you have any questions concerning this submittal, please telephone K. E. Meade at (615) 843-7766.
Sincerely, i
M cA Robert A. Fenech i.
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cc: See page 2
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9306010093 930521 PDR 'ADOCK 05000327
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4 U.S. Nuclear Regulatory Commission Page 2 May '1, 1993 i
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Mr. D. E. LaBarge, Project Manager U.S. Nuclear Regulatory Commission l
One White Flint, North 11555 Rockville Pike i
Rockville, Maryland 20852-2739 NRC Resident Inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy-Daisy, Tennessee 37379-3624 Regional Administrator U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323-2711 l
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g ENCLOSURE 1 RESPONSE TO NRC INSPECTION REPORT NOS. 50-327/93-09 AND 50-328/93-09 PAUL E. FREDRICKSON'S LETTER TO MARK 0. MEDFORD DATED APRIL 22, 1993 Violation 50-327. 328/93-09-01 "A.
Technical Specification 6.8.1 requires, in part, that written I
procedures be established, implemented, and maintained for applicable procedures recommendr.? in Appendix A of Regulatory Guide 1.33, Quality Assurance Program Requirements, Revision 2, February 1978. Appendix A to Regulatory Guide 1.33 requires administrative procedures, which include safe operation of nuclear power plants.
Site Standard Practice SSP-12.2, SYSTEM AND EQUIPMENT CONTROL, Rev. 1, requires that all safety-related systems and equipment required to be operable shall be included in the configuration control scope with the associated checklists listed in Attachments 1 - 6 as applicable.
i Contrary to the above, during the period of March 19 through March 26, 1993, operators determined that seven safety-related l
f valves and two safety-related power fuses were not configured as required by checklists identified in SSP-12.2.
This is a Severity Level IV violation (Supplement 1)."
Reason for the Vinlation The cause of this violation could not be explicitly determined. The i
investigation of this event identified several possible causes (listed below) for the devices being misconfigured. While it could not be determined which of the following causes resulted in the given conditions, corrective actions are being taken to address each of the causes.
Relative to the valves not being secured:
1.
Procedure / drawing inadequacico and inconsistencies existed. The valve alignment checklists required the valves to be closed and capped, while the " Verification of Containment Integrity" surveillance instruction (SI) required the valves to be locked, q
closed, and capped.
The valve alignment checklists were being performed during the same timeframe as the containment integrity
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verification SI.
The valve alignment checklist may have been performed subsequent to the containment integrity verification SI for the subject valves. Since the valve alignment checklist did not i
require the valves to be locked, the locks may have been removed i
af ter the containment integrity verification SI was completed. This seems to be the most plausible explanation; however, failure to j
further investigate this type of disagreement between the procedure and the as-found component configuration represents a lack of i
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- appropriate sensitivity to configuration management issues.
It was also determined that the associated plant drawings do not indicate the locked closed requirement for these and similar valves that are required to be locked closed.
2.
The containment integrity verification S1 may have been incorrectly performed, leaving the valves unlocked.
Relative to the valves found open:
1.
The valves may have been inadvertently manipulated or bumped open.
It should be noted that these are T-handle valves.
2.
sis or valve checklist instructions may have been Lmproperly performed.
Relative to the fuses found in the wrong position:
The power availability checklist instruction was improperly performed.
Corrective Steps That Have Bien _Iaken_and the Results_ Achieved The subject valves have been placed in the correct position with locking devices installed, as appropriate. The subject fuses were also placed in the correct position.
Corrgetive Stens That Will be Taken to Avoid F.urther Violations The following corrective actions are being taken to address potential CauSes.
1.
Procedures that manipulate valves, breaker positions, or fuse removal, etc., will be reviewed to ensure that configurations for common components are consistent. Procedures that require revisions as the result of the review mentioned above will be revised before
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their use, supporting restart of the respective units from the current outages.
2.
Drawings will be revised to ensure that requirements for locked valves are properly reflected.
3.
A systenetic verification of the configuration of required components will be performed on each unit. Primary and secondary process system components will be verified to be correctly configured before restart of their respective units.
4.
A more positive method of locking T-handle valves will be developed.
5.
To minimize the potential for inadvertent valve manipulation, e.g.,
bumping, the sequence for containment closecut and containment.
integrity verification closecut will be revised. Containment integrity verification will be performed sufficiently late in the schedule (as near as practicable to the administrative closure of containment).
6.
Management's expectations regarding'the initiation of the appropriate corrective action document on finding components in other than expected configurations will be communicated to Operations personnel.
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Extensive actions are ongoing to strengthen the Sequoyah configuration control process and implementation including: clear definition of expectations and ownership for Operations personnel; verification process and training upgrades; procedure _and drawing reviews / revisions to ensure correct component configuration; additional training on consistent methods for verifying various types
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of components; and plant / design review to ensure that plant components requiring configuration control are captured in procedures.
Data _Hhen Full Compliance Will be Achieved TVA is in full compliance with the specific violation. Additional corrective actions are being taken to strengthen performance in the area of overall configuration control.
I Yiniation 327. 323/93-09-03 "B. Technical Specification 6.8.1 requires, in part, that written i
procedures be established, implemented, and maintained for applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Quality Assurance Program Requirements, Revision 2, February 1978.
Appendix A to Regulatory Guide 1.33 requires administrative l
procedures, which include the calibration of safety-related instruments.
Site Standard Practice SSP-8.2, SURVEILLANCE TEST PROGRAM, Rev. O, requires that surveillance instructions be performed at scheduled Intervals specified in the surveillance instruction. The SSP also provided a method for def erral of surveillance instructions.
Contrary to the above, on March 30, 1993, more than 50 safety-related instrument calibrations were identified as having not been performed as required by their respective surveillance instructions due to'use
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of an inappropriate process for deferral of performance of the surveillance instructions for the instrument calibrations.
This is a Severity Level IV violation (Supplement 1)."
Reason for the violation j
t The cause of this event was an inadequate deferral process for sis that
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did not satisfy technical specification (TS) surveillance requirements, f
i.e., non-TS sis.
The procedure that was utilized to defer non-TS sis i
failed to require a technical evaluation in order to delay performance of these procedures. This resulted in numerous safety-related. instruments not being calibrated within the timeframes specified by the non-TS sis and no technical justification for the deferral.
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Corrective Steps That Have Been Taken and the Results Achinyrd A list of components with delinquent calibrations has been developed.
Instrument Maintenance is presently calibrating these components based on the priority established by Technical Support.
Corrective Stept._Ihat Will be Taken_Lo Avoid Further Violations Components with delinquent calibrations that are safety-related, compliance, or postaccident monitoring instruments will either be calibrated or have a technical evaluation to justify deferral before restart of the respective units from the current outages.
The procedure utilized to defer non-TS sis will be revised to require a technical evaluation before a non-TS SI may be deferred.
All late non-TS sis will either be performed or have a technical evaluation to justify deferral of the procedure before restart of the respective units from the current outages.
Date_Rhen Full Compliance Will be Achleyed TVA will be in full compliance with the violation before restart of the respective units from the current outages.
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ENCLOSURE 2 a
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u y-fangnitment s 1.
Components with delinquent calibrations that are safety-related, compliance, or postaccident monitoring instruments will either be calibrated or have a technical evaluation to justify deferral before restart of the respective units from the current outages.
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The procedure utilized to defer non-TS sis will be revised by July 1,1993, to require a technical evaluation before a non-TS SI may be deferred.
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All late non-TS sis will either be performed or have a technical evaluation to justify deferral of the procedure before restart of the respective units from the current outages.
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