ML20059C910
| ML20059C910 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 12/27/1993 |
| From: | Fenech R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9401060203 | |
| Download: ML20059C910 (4) | |
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Tennessee Vaky Authority. Post Office Box 2000 Saddy-Dassv. Tennessee 37379-2000 Robert A. Fenech Vice President. Sequoyah Nuclear Plant December 27, 1993 l
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U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 i
Gentlemen:
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In the Matter of
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Docket Nos. 50-327 Tennessee Valley Authority
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50-328 SEQUOYAH NUCLEAR PIANT (SQN) - NRC INSPECTION REPORT NOS. 50-327,-
l 328/93-50.- REPLY TO NOTICE OF VIOLATION (NOV) 50-327, 328/93-50-03 ll Enclosed is TVA's response to R. V. Crienjak's letter to Mark 0. Medford 1!
dated December 3,1993, which transmitted. the subject NOV. The violation addressed the failure to follow procedures during implementation of the clearance process.
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The enclosure provides TVA's response to the NOV. No commitments are contained in this submittal.
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If you have any questions concerning this submittal, please telephone l
R. H. Shell at (615) 843-7170.
Sincerely, Robert A. Fenech
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Enclosures j
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i-Page 2 December 27, 1993
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Mr. D. E. LaBarge, Project Manager U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland-20852-2739.
l NRC Resident Inspector i
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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'd ENCLOSURE RESPONSE TO NRC INSPECTION REPORT l
1 NOS. 50-327, 328/93-50 R. V. CRLENJAK'S LETTER TO MARK 0.-MEDFORD
' DATED DECEMBER 3, 1993 Violation 50-327 12B/93-50-03
" 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, j
February 1978. Appendix A of Regulatory Guide 1.33 includes administrative procedures for equipment control and for performing i
maintenance.
" SSP-12.3, Equipment Clearance Procedure, Revision 4, established the process to provide protection for personnel and plant equipment during operation, maintenance, and modification activities through the use of clearances. 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 the time /date when the clearance is issued and released.
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" Contrary to the above, procedures were not implemented in that on October 28, 1993, the ASOS failed to complete the time /date release portion of clearance 2-93-1334 prior to the system being returned to service. On November 1, 1993, the ASOS failed to complete the time /date 4
issue portion of the same clearance when it was reissued. From October 28 until November 1, 1993, clearance 2-93-1334 was actually-released even though the clearance sheet indicated that it'was still issued to the ASOS.
"This is a severity-level IV violation (Supplement 1)."
Reason._fsr Violation The cause for the improper implementation of the clearance procedure was li personnel error, inattention to detail. Clearance 2-93-1334 was issued to isolate reactor coolant system (RCS) Hot Sample. Valve 2-43-24 for the performance of maintenance activities. Upon completion of the work, Maintenance' personnel released the clearance. ' The assistant shif t-operations supervisor (ASOS) released the clearance'and the clearance tag; was removed from the valve; however, the ASOS failed to sign and date'the.
clearance cover sheet documenting the clearance release. Subsequently, a small leak, one drop in three minutes, was identified coming from a rivet holding the valve nameplate' in place.
Because of the valve body leakage and the associated industrial safety concerns, management requested the
-placement of a clearance on the valve. Clearance 2-93-1357 was issued, isolating the valve from the RCS. Clearance 2-93-1334 was then reissued l
establishing work boundaries.
The ASOS reissuing-the clearance failed to
-sign and date the clearance cover sheet to reflect reissuance'of the clearance.
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CDIIective ActioDA lhat_Have Been Taken and the_Results Achieved The. appropriate Operations. personnel have been counseled, and the appropriate disciplinary action has been taken relative to the need for attention to detail.during implementation of the clearance process.
Also, the proper completion of clearance procedure documentation was stressed.
Other clearance documents were reviewed and no other entry omissions of this type were identified.
Additionally, the' inspection report (50-327, 328/93-50) noted a-potential venkness in Site Standard Practice 12.3, " Equipment Clearance l
Procedure." Specifically, the NRC inspector determined that the procedure did not provide adequate guidance for clearance control.
During TVA's review of the clearance procedure, it was determined that-l
. procedural guidanc) did not contribute to this event. However, the procedure was unclear as to when the shift operations supervisor (SOS) or the SOS representative should sign and date the " release time and date" block of the clearance cover sheet after the clearance holder has released the-clearance. An action item to enhance the procedure to provide a sequencing of events when the ASOS releases a clearance and picks up the clearance tag has been established within the site corrective action program.
The_ Corrective Steps That Will be Talten to Avoid Future Violatirna No additional actions are necessary.
Datt.Rhen_. full _ Compliance Will be Achieved TVA is in full compliance.
Commilments None.
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