ML20058P157
| ML20058P157 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 10/15/1993 |
| From: | Fenech R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9310220111 | |
| Download: ML20058P157 (6) | |
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n-A Tennenee veey unomy. em omae om pyn t, wide Dmy. Tennessee 37379.roco RoDert A Fenech u.e n sl dent sm.,uyr," thow 5w e
October 15, 1993 U.S. Nuclear Rt gulatory 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 SEQUOYAll NUCLEAR PIANT (SQN) - NRC INSPECTION REPORT NOS. 50-327, 328/93 REPLY TO NOTICE OF VIO1ATIONS (NOVs) 50-328/93-39-01 AND 50-328/93-39-02 contains TVA's response to R. V. Crlenjak's letter to Mark O. Medford dated September 16, 1993, which transmitted the subject NOVs.
The violations involve noncompliance with Technical Specification 6.8.1, which requires procedures to be established, implemented, and maintained for activities governing safety-related systems and components. contains information concerning the use of unofficial and erroneous throttle-valve configuration tags and operator implementation of.
these tags.
If you have any questions concerning this submittal, please telephone C. II. Whittemore at (615) 843-7210.
Sincerely, f$f$-
Robert A. Fenech Enclosures cc: See page 2 2200n8 9310220111 931015 P
PDR ADOCK 05000327
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it U.S. Nuclear Regulatory Commission Page 2 October 15,.1993 cc (Enclosures):
Mr. D. E. LaBarge, Project Manager U.S. Nuclear Regulatory Commission j
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 11 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323-2711
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ENCLOSURE 1 RESPONSE TO NRC INSPECTION REPORT NOS. 50-327/93-39 AND 50-328/93-39 R. V. CRLENJAK'S LETTER TO MARK 0. MEDFORD DATED SEPTEMBER. 16, 1993 i
Yiglation 50-328/93-39-01
" Technical Specification 6.8.1 requires, in part, that written procedures be established, implemented and maintained for applicable procedures
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recommended in Appendix A of Regulatory Guide 1.33, Quality Assurance Program Requirements, Revision 2, February 1978. This includes
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procedures required for the safe operation and maintenance of nuclear j
power plants including equipment and work control instructions.
" System Operating Instruction 2-S0-77-1, Attachment 2, REACTOR COOLANT _
l DRAIN TANK VALVE CHECKLIST 2-77-1.02, Revision 4, provides for equipment configuration control for the waste disposal system. The instruction t
specifies that the B Reactor Coolant Drain Tank (RCDT) pump discharge throttle valve (2-77-517B) be configured approximately five handwheel turns from the fully closed position.
" Contrary to the above, on August 25, 1993, the licensee manipulated Unit 2 throttle valve 2-77-517B and determined that it was not set in I
accordance with 2-S0-77-1, Attachment 2, REACTOR COOLANT DRAIN TANK VALVE CHECKLIST 2-77-1.02, Revision 4.
The actual configuration of the valve was approximately 1/4 handwheel turn from the closed position.
y "This is a Severity Level IV violation (Supplement 1)."
Reason for the Violation i
The reason for this violation was personnel error. During the act of removing system clearance tags and verifying valve alignments, i.e.,
lifting clearances, Operations personnel acted outside good operating l
practice and manipulated valves without the proper instructions.
Two t
contributing causes for the improper positioning of the valves were:
(1) unofficial tags with incorrect valve-positioning information were attached to the valves, and (2) the clearance instructions did not 4
f contain the necessary information to direct personnel as to the proper position for the throttle valves.
CorteclivrActinnL_Iha13avaleen_Iaba_and_the Results Achieved s
The personnel involved in the releasing of the clearances and manipulation of the valves without proper instructions have been l
counselled.
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The tags containing the erroneous information were removed. Similar tags were found on the Unit 1 RCDT pump discharge throttle valves and were removed. However, the Unit 1 valve tags contained proper throttle-valve positions.
The personnel responsible for preparing the clearances have been counselled as to the potential consequences of implementing this type activity with incomplete or inadequate instructions, i.e.,
indicating the proper position for a throttle valve.
The equipment clearance procedure has been revised to effect a more user-friendly document.
The procedure has.also been revised to better clarify the use and guidance for completing the clearance instructions.
Corrective Stena_That Will be Taken to Avoid Future _Violationa
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This event, along with what constitutes safe and reliable operation of l
equipment, will be discussed during the next Operations section
" stand-down" meeting.
Datr_When_h ll_Complianne Will be Athieled TVA is in full compliance with the violation as stated. However, additional actions are being taken to prevent recurrence.
Commilmenta This event, along with what constitutes safe and reliable operation of equipment, will be discussed during the next Operations section
" stand-down" meeting. This will be accomplished by December 6, 1993.
Violation 50-328/93-39-02
" Technical Specification 6.8.1 requires, in part, that written 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. This includes procedures required for the safe operation and maintennace of nuclear power plants including equipment and work control instructions.
" Site Standard Practice (SSP) 6.23, MAINTENANCE MANAGEMENT SYSTEM TROUBLESHOOTING WITH WORK ORDERS, Revision 1, provides instructions for controlling work activities associated with or which require equipment troubleshooting.
"Section 3.1.4.G of SSP 6.23 requires, in part, that 'If at any time the scope of the troubleshooting changes such that the troubleshooting instructions are no longer valid or are inadequate, then ensure that the work order is replanned.'
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"dontrarytotheabove,onAugust 12, 1993, after testing of the Unit 2 2B RCDT pump revealed that the pump performance continued to be degraded, the licensee perfonned on-the-spot troubleshooting activities without replanning the work order to provide adequate troubleshooting instructions. As a result,.the licensee performed work outside of the j
scope of the troubleshooting instruction, including the manipulation of related system components.
"This is a Severity Level IV violation (Supplement 1)."
Renann_fpr the Vlalation
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The reason for this violation was personnel error in failing to follow procedures.
The system engineer failed to refer to and. adhere to the instructions contained in the troubleshooting work package. As a result, the scope of the troubleshooting work package was exceeded. A contributing factor for this is that the work package was not maintained at the work location as required. Further, Operations personnel (who were assisting the system engineer) manipulated valves without the proper authorization. The manipulation of valves and safety-related components without proper authorization is not according to management's expectations for configuration control.
Cartective Actiona_Ihat_liaYe_leen_Taken_and the Resulta_ Achieved The personnel involved have been counselled. The system engineers have reviewed the event, and a lessons-learned hand-out sheet was issued to the engineers and their supervisors.
A standing order, for Operations' supervisory involvement in the field, clearly defining management's expectations-that work is to be accomplished only with proper authorization was promulgated on September 27, 1993. Recent ansessment of adherence to the guidance provided in the standing orde', i.e., supervisors inspecting the actions and performance of operators, indicates that it is having an appropriate impact.
Co rre ctire_ Step 1LThat_M11Lhe_IakeILin_Aynid_Entute_ Viol a t ions No further actions are necessary.
Date_When_EulLEampliance_WilLhe_ Achieved TVA is in full compliance.
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1 ENCLOSURE 2
]lgquested Information The tags attached to the throttle valves were not legitimate operator aids nor were they authorized for any operational purpose. Operator aids are controlled by procedures and the tags are appropriately designated as i
approved aids. The information contained on the tags was incorrect according to the present required throttle position.
The information did correspond to the original preoperational test-positioning values; therefore, it is believed that the tags originated during preoperational testing activities.
The operators who used these tags were not familiar with the valves and their throttle positions. The information contained in the clearance instruction was deficient in not specifying the valves as being throttled and not indicating the throttle positions. Therefore, when the operators arrived in the vicinity of the valves and found tags with information indicating throttle positions, they inadvertently
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mistook the information as accurate and manipulated the valves accordingly.
Similar tags were found on the Unit 1 RCDT pump discharge throttle valves and were removed as were the tags on the Unit 2 RCDT pump discharge throttle valves. The throttle valve positioning information contained on the Unit 1 tags was correct.
The existence of these tags is believed to be an isolated case.
This is based on the fact that Operations personnel and the system engineers are aware of the fact that unofficial tags and operating aids are not allowed in the field where they could possibly be mistakenly used to manipulate valves or other components. The reason that these tags have existed in the field for so long is believed to be because the operators who manipulate the valves are trained to use and rely on the valve-checklist procedure for information and may have never noticed that the tags contained incorrect information. The system engineers rely on Operations personnel to manipulate the valves and may never have noticed that the valves contained incorrect information.
The corrective actions specified for the first violation are applicable to this tagging issue.
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