ML20066C059
| ML20066C059 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 01/03/1991 |
| From: | Medford M TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9101090169 | |
| Download: ML20066C059 (5) | |
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f,tn o Medwo v.- t ht,-am tu w to en e ic e og c n I wt JAN 031991 U.S. Nuclear Regulatory Commission ATTN Document Control Desk Washington, D.C.
20555 Gentlersen t In the Matter of
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Docket Nos. 50-327 Tennessee Valley Authority
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50-328 SEQUOYAll NUCLEAR PLANT (SQN) - NRC INSPECTION REPORT NOS. 50-327, 328/90 RESPONSE TO NOTICE OF VIOLATION (NOV) 50-327, 328/96-25-01 Enclosed is TVA's response to B. A. Wilson's letter to
- 0. D. Kingsley, Jr., dated November 20, 1990, and to C. A. Julian's letter to 0. D. Kingsicy, Jr., dated December 5, 1990, which transmitted the sub.iect NOV.
Encicsure 1 provides TVA's response to the NOV. Summary statements of commitments contained in the submittal are provided in Enclosure 2.
If you have any questions concerning this submittal, please telephone M. A. Cooper at (615) 843-8422.
Very truly yours, TENNESSEE VALLEY AUT110RITY ff 2h Y
Mark O. Medford Enclosures cc: See page 2 9101090169 910103 PDR ADOCK 05000327 I'46 0 /
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U.S. Nuclear Regulatory Commission ec (Enclosures):
Ms. S. C. Black, Deputy Director Project Directorate II-6 U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852
.ir. J. N. Dor.ohew, Project Manager U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 NRC Resident Inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy Daisy, Tennessee 37379 Mr. B. A. Wilson, Project Chief U.S. Nucicar Regulatory Connission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 s
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ENCLOSilRE 1 i
j RESPONSE TO NRC INSPECTION REPORT NOS. 50-327/90-25 AND 50-328/90-25-01 B. A. WILSON'S LETTER TO 0. D. KINGSLEY, JR.,
DATED NOVEMBER 20, 1990 Violation 50-327 328/90-25-01 3
10 CFR 50, Appendix B, Criterion V as implemented by the Nuclear Quality Assurance Manual (NQAM) states that, " activities affecting quality shall be prescribed by documented instructions, procedures, or drawings and shall be accomplished in accordance with these instructions, procedures, or drawings." Standard Practice SQA66 Plant Housekeeping (Rev. 18), provided administrative control of housekeeping requirements for work activities, conditions, and environments, that included requirements for work instructions, and j
worker and supervisor responsibilities during and following the conduct of maintenance or modifleation work.
Contrary to the above, prior to July 23, 1990, the licensee failed to implement instructions, procedures, and performance that would prevent the storage and/or accumulation of loose conductive material within safety related electrical boards.
Specifically, numerous nuts, botta, washers, lugs, copper and steel shavings, conduit plugs, and fuses were found stored or accumulated as a result of maintenance and/or modifications in numerous 120 volt AC and 125 volt DC vital distribution panois and instrumentation and control cabinets which could have rendered the panels inoperable during a seismic event.
This is a Severity Level IV violation (Supplement 1).
Admission or Denial of_the Alleged Violation TVA admits the violation.
Reason for the Violation The cause of this violation was inattention to detail with respect to cleanliness requirements and good housekeeping practices by personnel involved in work activities in the low-voltage electrical panels.
Based on the type of debris found in the panels, the violation appears to have occurred during previous modifleation work activities.
TVA acknowledges the similarity between this violation and the violation issued in 1988, which involved the storage or accumulation of fuses and other conductive material in 6900-volt (V) and 480-V equipment. A review of the corrective actions for Violation 50-327, 328/88-06-03 concluded that previous corrective actions focused on the high-voltage electrical panels and cabinets and were inadequate to prevent recurrence in the low-voltage electrical panels.
Corrective Steps That_Have Been Taken and Results Achieved Maintenance has inspected and cleaned the low-voltage electrical panels specifically identified during the NRC maintenance team inspection.
The remaining low-voltage electrical panels have been inspected and cleaned, with the exception of eight panels which still require cleaning. A schedule to clean these eight panels has been developed, and the removal of the enclosures from service has been facilitated.
Baseline cleaning in the eight enclosures will be completed by January 14, 1991.
To emphasize compliance with SQN Standard Practice SQA66. " Plant Housekeeping " training, which outlined each person's responsibilities with regard to good housekeeping practices, was provided to Modifications' personnel. Compliance with the requirements.of SQA66 was also emphasized in a memorandum from the SQN Modifications Manager.
The Modifications' foremen were directed to conduct personal inspections of electrical panels for cleanliness during the completion stages of applicable modification workplans. This inspection has been added as a requirement to Modification and Additions Instruction 7. " Cable Terminations. Splicing, and Repairing of Damaged Cables."
Corrective Steps That Will Be Taken To Avoid Further Violations As an additional measure to prevent recurrence, periodic inspections by line management will be included in the routine housekeeping walkdowns performed in accordance with SQN Site Standard Practice 1.50, " Management and Radiologicel Emergency Plan Duty Roster." Appropriate procedure revisions will be made by January 14. 1991.
Date_When Full Compliance Will Be Achieved SQN will be in full compliance by January 14, 1991.
Remaining corrective actions to prevent recurrence will also be completed by January 14, 1991.
ENCLOSURE 2 List of Connitments 1.
Baseline cleaning of the low-voltage electrical panels will be completed by January 14, 1991.
2.
Periodic inspection of electrical cabinets and panels will be included in the routine housekeeping walkdowns performed in accordance with SQN Site Standard Practice 1.50, " Management and Radiological Emergency Plan Duty Roster." Appropriate procedure revisions will be made by January 14, 1991.
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