ML20058L657
| ML20058L657 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 12/09/1993 |
| From: | Fenech R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9312170131 | |
| Download: ML20058L657 (9) | |
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A Tennessee Valley Authonty, Post Office Box 2000. Soddy Oaisy. Tennee,ee 37379-2000 Robert A. Fenech Vice President. Sequoyah Nuclear Plant December 9, 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) - NRC INSPECTION REPORT NOS. 50-327, 328/93 REPLY TO NOTICE OF VIOLATIONS (NOVs) 50-327, 328/93-42-01 AND 93-42-03 contains TVA's reply to R. V. Crienjak's letter to Mark O. Medford dated November 9,1993, which transmitted the subject.
NOVs. The violations involve the failure to follow procedures. The first violation is associated with maintenance activities while working on electrical equipment. The second violation is associated with closing
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out a work document before the postmaintenance test was completed.
' contains the list of commitments.
To address NRC's concern regarding inspections of the inner containment liner, TVA has performed inspections of the liner. As a result of the
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inspections, some surface corrosion indications were identified on both i
units. These indicators have been determined not to affect the I
operability of the liner, and an evaluation of the indications is being performed to determine additional corrective actions.
If you have any questions concerning this submittal, please telephone J. W. Proffitt at (615) 843-6651.
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Sincerely, b."%
Robert A. Fenech i
Enclosures h
cc: See page 2 9312170131 931209 f
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4 U.S. Nuclear Regulatory Commission Page 2-December 9, 1993 cc.(Enclosures):
Mr. D. E. LaBarge, Project Manager U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike 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
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i ENCLOSURE 1 REPLY TO NRC INSPECTION RETORT NOS. 50-327, 328/93-42 R. V. CRLENJAK'S LETTER TO MARK 0. MEDFORD l
DATED NOVEMBER 9, 1993 Violation 50-327. 328/93-42-01 I
" Technical Specification Section 6.8.1 requires, in part, that procedures shall be established, implemented, and maintained covering the activities i
recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Appendix A of Regulatory Guide 1.33 includes-administrative procedures for equipment control and for performing maintenance.
" SSP-12.3, Equipment Clearance Procedure, Revision 2, established the process to provide protection for personnel and plant equipment during operation, maintenance, and modification activities through the use of clearances.
Section 3.1.5.N of SSP-12.3 requires 1that the person placing safety grounds shall be issued the clearance before placing the ground.-
Sections 3.1.4.D and 3.1.4.E require that during testing activities auch as high-potential testing (meggering),:only the-person doing the testing shall be on the clearance. Section 3.2.9 requires that clearance sheets shall be carefully and completely filled out to ensure that all information is recorded and available for future reference. This.
includes the entry of work document and work description on the clearance sheet.
" Contrary to the above, these requirements.were not met'for the following four examples.
1.
On May 14, 1993, electricians performed work in breaker compartments on Unit Board 1B without being under a clearance hold order as required by SSP-12.3. In performing this work, they-inadvertently i
grounded the Unit Board bus. Had the bus been energized with~this ground in place, serious equipment damage and personnel injury could have resulted.
2.
On May 14, 1993, an electrical foreman holding clearance 1-93-1220 obtained an electrical ground under that clearance and gave it to another foreman who was not authorized to obtain a ground because he was not working under a clearance.
3.
On May 14, 1993, the licensee failed to remove multiple individuals from clearance hold order 1-H0-93-1220 while meggering was in progress.
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Between March 24 and September 3, 1993, clearance helder sheets for Hold Orders 1-93-1220, 1-93-1302, 1-93-1239, 1-93-1015, and 1-93-1076 were incompletely filled out with respect to work documents and work activities.
"This is a severity level IV violation (Supplement 1)."
Reason for Violation l
Example No. 1:
The reason for the violation is the failure to follow procedures in that l
a foreman had personnel perform work activities on equipment that required a hold order without getting on a hold order indicating the activity to be performed.
There were two contributing factors to the violation, inadequate procedures and inadequate communications.
The procedures for delineating special precautions to be taken while performing activities near energized equipment were deficient; a clear-cut definition of what is considered "in the vicinity" of electrical equipment was not provided. A lack of communication allowed the inappropriate action of transferring grounds from one position to another.
Informal turnover meetings did not provide clear and concise information for placement of the ground.
Example No. 2:
The reason for the violation was that the procedure requirements allowed the practice of using floating grounds. This allowed grounds to be moved from one place to another without clear accountability for'the location of the grounds.
Example No. 3:
The reason for the violation is that the foreman holding the clearance did not verify that each individual had been removed from the hold order before testing began. This was based on the foreman's considerations that the testing being perforn;ed would not be harmful to other personnel on the hold order.
Example No. 4:
The reason for the violation is a lack of sensitivity to procedural requirements and a lack of attention to detail while denoting the work document for the associated work activities.
The specific reasons for each cited-example of the violation are stated' above. However, overall review of the first three examples indicates that the electrical safety standards within Electrical Maintenance were too low.
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Acceptance of_the existence of electrical safety hazards:iniday-to-day work practices, with insufficient effort to improve conditions where:
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possible. has been a regular occurrence. The. practice of working on or in-the vicinity of energized equipment over the years has become routine,;
with insufficient considerations given to reducing' potential hazards to' the extent possible and/or providing compensating precautionary measures.
Corrective Actions That'Have Been Taken and the Results Achieved t
With respect to electrical safety:..The Maintenance department ctandards for working on or in the vicinity of energized equipment have. been changed via the issuance of a revised; Site Maintenance Management i
Directive. This directive has tightenedL the' standards as follows:. The--
i voltage level above which special precautions are required (dangerous voltages) has been changed from greater-than nominal 125 volts-(V) to greater than 30-V alternating current (ac) or'30-V direct current (de) 1 nominal. The term "in the vicinity" of-energized equipment has-been-defined to mean breaking the plane of the cabinet, compartment','or cubicle door or cover in which dangerous voltages ~are present.
I The philosophy of not normally working ~ on energized equipment is being instituted. Management permission'is required when1 working on. energized =
equipment above specifications listed above. ' Permission.will'not be?
given if discussion indicates that the' job could be' reasonably worked.
with the equipment deenergized. One recent example of1the resul.ts achieved from this new philosophy.is the. Arrow-Hart contactor inspection / repair project: On Unit 2-(before.the' philosophy change),;
l about 800-900 contactors were inspected / repaired in the. vicinity of'.'
energized 480-V ac and 125-or 250-V de' sources. ForlUnitlll(afterlthe.
philosophy change), the entire boards.were deenergized and; tagged'out to accomplish the 800-900 Unit 1 contactor inspections / repairs..
Training and repeated discussions with Electrical Maintenance personnel have resulted in the heightened awareness th't:it is notfacceptable to l
circumvent procedures (safety or otherwise) in.the interest oft expediency. The revised rules for working on or near energized equipment I
have caused considerable discussion and increased. awareness of a better=
standard of electrically safe work practices.-
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Other grounds installed at SQN were verified to be installed.in the right locations and the floating ground process was-terminated.
The Corrective Steps That Will be TakRn to Avoid Future Violationg
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With respect to Electrical Safety: Ongoing training / coaching'and H
l increased management attention in adhering to the new' standards and.
.j improving consnunication will reduce the potential, for future violations.
J Additional planned improvements, such as obtaining an-increased supply of:
electrical grade rubber gloves and. rubber matting and certifying Electrical Maintenance in cardiopulmonary' resuscitation,(CPR),'will, further enhance the'overall electrical safetyLwork practices for site.
personnel.
An audit of the outstanding hold orders will be performed to determinefif.
there are any additional incompletely filled out hold orders. Any identified deficiencies'will be corrected.
A' training letter from-the'
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l Operations superintendent will be issued to the appropriate Operations personnel. The training letter will use the cited examples to illustrate the incompleteness of the forms and the inattention to detail.
Datt.Jhen Full Compliance Will be Achieved Full compliance will be achieved on December 17, 1993.
Viointion 50-327. 328/93-42-03
" Technical Specification Section 6.8.1 requires, in part, that procedures shall be established, implemented, and maintained covering the activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Appendix A of Regulatory Guide 1.33 incluces administrative procedures for equipment control and for' performing maintenance.
" Contrary to the above, these requirements were not met for the following three examples:
I 1.
Site Standard Practice'- 6.26, ' Maintenance Management System Completion of Work Orders ' Section 3.1.b'1, states that to close out a work document as complete, the General Foreman / Designee must ensure all documentation used to' perform and/or document work is attached to the work order package and ensure all signatures and date entries have been addressed. This instruction was not followed when Work.
Order 93-08201-00 for Work Request C222713 was signed by the Maintenance Work Supervisor as having all Post Maintenance Testing complete when a Post Maintenance Test for this Work Order had not i
been completed.
2.
Site Standard Practice - 6.31, ' Maintenance Management System Pre-or Post-Maintenance Testing,' Section 3.4, Responsibilities, states that prior to close out of a work document the SR0/ SOS /ASOS shall review and verify the completion of Post Maintenance Tests' listed in the Work Order package. This instruction was not followed when Work order 93-08201-00 for Work Request C222713 was signed by an Operations Senior Reactor Operator as having all. Post Maintenance Testing complete when a Post Maintenance Test for this Work Order had not been completed.
3.
Site Standard Practice - 12.57, ' Technical Specification Component Condition Record,' Section 3.8, states that a Technical Specification-Component Condition Record (TSCCR) shall not be closed out until the Technical Specification related equipment covered by this record is l
restored to Technical Specification operability.: It also states that-if the maintenance is complete, but the Post Maintenance Test is not' completed, the TSCCR form should be modified to reflect the.Technieni Specifications of the incomplete Post Maintenance Test.
It further states that a TSCCR shall be closed out when:
a.
The condition reported on a TSCCR form is corrected.
b.
The work tracked by the TSCC". is completed.
c.
It is replaced by another TSCCR.
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s This work instruction was not followed when TSCCR 2-93-0100 was closed before all Post Maintenance Testing was completed'and the system returned to Technical Specification Operability.
"This is a Severity Level IV violation (Supplement'1)."'
Reason for the Violation The reason for the violation is that the foreman signed the' work. document as being complete based on the work being field complete. A contributing factor was that the work approval and closure procedure does not flow logically in that the sign-offs are out of sequence,:potentially leading to a misinterpretation of the procedural requirements. The: foreman signed off the work as complete knowing that the postmaintenance tests (PMTs) were not complete. The work document was not closed out but was placed in open status awaiting completion of the PMTs.-
Operations' review of the completed work activities was-limited to ensuring that the appropriate sign-offs had been completed. Contributing to the operators' inadequate review of the work document was that there was no required sign-off for the leak test PMT in the work document.
Also, Operations closed the TSCCR and did'not revise the master valve list TSCCR to reflect the additional valve based on the work activity being complete without regard that the valve stroke PMT was not' complete. This is considered inattention to detail on the part of Operations personnel.
Corrective Actions That Have Been Taken and the Results Achieved A verification of the valves listed on the Unit 1-and Unit 2 master list i
for valves to be stroked was performed to determine if the PMTs were completed. As a result of the verification effort, there were.five valves (three on Unit 1 and two on Unit 2) where there was no documentation to support that the required FMTs.had been performed. For the three valves on Unit 1, the work orders (W0s) were corrected to -
reflect the current status and on Unit 2 the PMTs were completed and the W0s were closed. Additional deficiencies (e.g., incorrect valve numbers, incorrect work order numbers, and W0s signed by Operations personnel certifying that the PMTs were complete without annotating that it was transferred as required by procedures) were identified and corrected.
Training sessions with the appropriate Modifications personnel were conducted. The training included, as appropriate, a review of the identified deficiencies, a review of the specific procedural requirements regarding PMTs, work package closure, and a discussion relating PMTs and technical specification criteria.
The work approval and closure procedure has been revised to clarify.the sequence and logic flow for the sign-offs..
A standing order was issued to Operations personnel reinforcing the process for transferring PMTs to the master valve list to ensure that this activity is being performed correctly.
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-'I TfieCorrectiveStepsThatWillbeTakritoAvoidFutureViolations.
Training sessions with the appropriate Operations and Maintenance...
personnel will be conducted. The training will include, as appropriate,.
a-review of the identifled deficiencies; a review;of_the. specific--
i procedural requirements regarding PMTs, work package closure, TSCCR' tracking, and use of the master list; and a discussion ~ relating PMTs and technical' specification criteria..
i Date When Full Compliance Will be AEhieved t
TVA is in full compliance.
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ENCLOSUREL2-l
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.COMMIIMENTS.
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INSPECTION REPORT-93-423 h
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An audit of the outstanding hold orders will'be' performed toD determine'if there are any additional _ incompletely. filled outihold f
orders. Any identified deficiencies will bejcorrected by1 December' 17,11993.
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A' training' letter from the Operations: superintendent,will be issuedt
'to the appropriate Operations personnel.c The training letter'will use the cited' examples to illustrate the' incompleteness offthefforms; and the. inattention to detail. This' action vill be complet'ed byr December 17,71993.
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j A training session with. the' appropriate: Operations ;and. Maintenance-3.
personnel will be conducted. The ' training. wiliz include b as : -
appropriate,-a review of the identified'deficienciest:a review'of1then specific' procedural requirements?regarding.PMTs,. work. package.
closure, TSCCR tracking,'and use of.the master listgiandla, discussion 1 relating PMTs and technical specificationEcriteria'.1-.Thisfaction'will:
be completed by April 15, 1994.
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