ML20059L085

Notice of Violation from Insp on 930904-1010.Violation Noted:Nrc Requirements Were Not Met for Listed Examples

ML20059L085
Person / Time
Site:	Sequoyah
Issue date:	11/09/1993
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20059L077	List: IR 05000327/1993042 ML20059L073 ML20059L085
References
50-327-93-42, 50-328-93-42, NUDOCS 9311160296
Download: ML20059L085 (3)

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ENCLOSURE 1 I i

NOTICE OF VIOLATION [

Tennessee Valley Authority Docket Nos. 50-327 and 50-328 '{

Sequoyah Units 1 and 2 License Nos. DPR-78 and DPR-79  :

During the Nuclear Regulatory Commission (NRC) inspection conducted from '?

September 4 through October 10, 1993, violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions,10 CFR Part 2, Appendix C, the violations are- ,

listed below:

A. 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' l 2, February 1978. Appendix A of Regulatory Guide 1.33 includes-administrative procedures for equipment control and for performing 1 maintenance.

SSP-12.3, Equipment Clearance Procedure,. Revision 2, established the process to provide protection for personnel and plant equipment during i operation, maintenance, and modification activities through the use of- ,

clearances. Section 3.1.5.N of SSP-12.3 requires that the person i 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 such as high-potential testing (meggering), only the person j 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 j reference. This includes the entry of work document and work  !

description on the clearance sheet. j Contrary to the above, these requirements were not met for the l following four examples. -:

1. On May 14, 1993, electricians performed work in breaker I compartments on Unit Board IB without being under a clearance hold  ;

order as required by SSP-12.3. In performing this work, they .;

inadvertently grounded the Unit Board bus. Had the bus been -i energized with this ground in place, serious equipment damage and  !

personnel injury ~could have resulted.  !

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2. On May 14, 1993, an electrical foreman-holding' clearance 1-93-1220 obtained an electrical ground under that clearance 'and gave it to l another foreman who was not authorized to obtain a ground because j he was not working under a clearance.  :

l 9311160296 931109 PDR ADOCK 05000327 i G PDR l

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Tennessee Valley Authority 2 Docket Nos. 50-327 and 50-328 Sequoyah Units 1 and 2 License Nos. DPR-78 and DPR-79

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.

4. Between March 24 and September 3, 1993, clearance holder 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).

B. 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 includes administrative procedures for equipment control and for performing maintenance.

Contrary to the above, these requirements were not met for the following three examples:

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 whan a Post Maintenance Test for this Work Order had not 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 /AS05 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 Dequest 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.

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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 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 Technical Specifications of the

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Tennessee Valley Authority 3 Docket Nos. 50-327 and 50-328 -

Sequoyah Units 1 and 2 License Nos. DPR-78 and DPR-79 l 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 TSCCR is completed.  ;

c. It is replaced by another TSCCR. q This work instruction was not followed when TSCCR'2-93-0100 was '

closed out before all Post Maintenance Testing was completed-and the system returned to Technical Specification Operability.

This is a Severity Level IV violation (Supplement'1).

Pursuant to the provisions of 10 CFR 2.201, Tennessee Valley Authority is  !

hereby required to submit a written statement or explanation to the U.S.  ;

Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C.

20555 with a copy to the. Regional Administrator, Region II, and a copv to the l NRC Resident _ Inspector, within 30 days of the date of the letter transmitting a this Notice of Violation (Notice). This reply should be clearly marked " Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or, if contested, the basis for' disputing the violation, (2) the corrective steps that have been taken and the results  :

achieved, (3) the corrective steps that will be taken to avoid further 1 violations, and (4) the date when full compliance will be achieved. If an adequate _ reply is not received within the time specified in this Notice, an order or demand for information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.

1; Dated at Atlanta, Georgia i this 9th day of November 1993 l q

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