ML20070K301
| ML20070K301 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 07/14/1994 |
| From: | Powers K TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9407260174 | |
| Download: ML20070K301 (6) | |
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1 Trnwee vaney Acu*y. Post O'hce Box 2cm S<AJy Dev. Tumes* 37379 2000 f
Ken Powers j
Vio Fiesomt. Saynyah Ntv$w F%vit j
I July 14, 1994 1
U.S.
Nucleatr 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) - INSPECTION REPORT NOS. 50-327, 328/94 REPLY TO NOTICE OF VIOLATION (NOV) 50-327, 328/94-15-01 l
' contains TVA's reply to Mark S.
Lesser's letter to Oliver D.
Kingsley, Jr. dated June 20, 1994, which transmitted the subject NOV.
The violation is associated with the failure to follow procedures and an inadequate procedure concerning the verification of valve position. A list of commitments is included in Enclosure 2.
If you have any questions concerning this submittal, please telephone J.
W. Proffitt at (615) 843-6651.
Sincerelyj/A Q/ bn Ken Powers Enclosures cc See page 2 c.
.,m fpD@e) I 9407260174 940714 PDR ADOCK 05000327
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U.S.
Nuclear Regulatory Commission Page 2 July 14, 1994 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 l
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C.____________________________________________.__________________._________________________
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ENCLOSURE 1 RESPONSE TO NRC INSPECTION REPORT NOS. 50-327, 328/94-15 MARK S. LESSER'S LETTER TO OLIVER D. KINGSLEY, JR.
DATED JUNE 20, 1994 Violation 50-327, 328/94-15-01
" 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 197e. Appendix A of Regulatory Guide 1.33 includes operations procedures to maintain required configuration control for safety-related components and systems.
" Surveillance Procedure 2-SI-SXP-072-001.A, CONTAINMENT SPRAY PUMP 2A-A QUARTERLY OPERABILITY TEST, Revision 0, Section 6, step 31 requires second party verification during positioning of Valves 2-72-503 and 2-72-502 in the CLOSED and LOCKED position.
" Site Standard Procedure SSP-12.6, EQUIPMENT STATUS VERIFICATION AND CHECKING PROGRAM, Revision 6, establishes the responsibilities, requirements and techniques for the Equipment Status and Verification Program.
Paragraph 3.3.4.B.1 of SSP-12.6 states that the position of locked valves which are in the full open or close position requires independent verification.
" Contrary to the above, 1.
On May 26, 1994, Surveillance Procedure 2-SI-SXP-072-001.A, Section 6,
step 31 was not followed in that second party verifications for Valves 2-72-503 and 2-72-502 in the CLOSED and LOCKED positions were not performed as required.
2.
On May 26, 1994, surveillance Procedure 2-SI-SXP-072-001.A was determined to be inadequate in that step 31 of Section 6 did not require Valves 2-72-503 and 2-72-502 to be independently verified as CLOSED and LOCKED as required by SSP-12.6.
"This in a Severity Level IV violation (Sutolement I)."
Reason for the Violation Example No. 1 The reason for the failure to follow the surveillance instruction involving the verification of valve position was personnei error. The individual had received the required training and stated that he knew the requirements but failed to perform the veriftcation in accordance with the requirements.
The valves to be maniput.ated were located within a contamination boundary. The first iridividual was to position the valves then lock the valves in that position. The second individual was to verify the valves' required position and actual condition.
The first individual performed the required manipulations.
The second individual witressed the manipulations from outside the contamination boundary and signed as performing the verification. The second individual shauld have entered the contamination boundary and verified the actual condition of the valve.
Example No. 2 The reason for the inadequate procedure was inadequate nanagement oversight in the implementation of a reviolon to the verification program. The verification program was revir.ed in October 1992 to require independent verification for valves that are locked in the full open or closed position.
Implementation of this requirement was performed during a general revision to the verification procedure.
The revision was not clearly identified, resulting in the failure to identify and revise procedures affected by the revision.
Independent verification should have been performed for the activity identified in the violation.
Corrective Steps That Have Been Taken and the Results Achieved After the event was conveyed to management, independent verification of the valves' position was performed, and it was determined that the valves were closed and locked as required.
A barrier analysis was performed that determined the breakdown in the verification process.
A standing order was issued to Operatione personnel, providing the results of the analysis. The barrier analysis identified the followings (1) there was a problem with the interim measure to perform concurrent verification, (2) the surseillance should have specified independent verification to be performed, (3) when performing concurrent verific ation, both parties are required to be present at the location of the component to be manipulated, and (4) the concurrent verification that was performed was not performed in accordance with procedures or training.
The surveillance instruction was revised to require independent verification to be performed for the manipulation of the valves.
The appropriate personnel action has been taken for the individuals involved in the event.
j gprrective Steos That Will be Taken to Avoid Future Violations The verification program will be revised to clarify the requirements relative to locked valves and to provide explicit guidance when performing verification.
- 1 A review of the appropriate procedures impacted by Revision 2 of the verification program will be performed to determine if similar problems exist, and the procedures will be revised as appropriate.
The appropriate training material will be revised to amplify the verification process requirements.
The procedure governing the administration of site' procedures will be revised to establish guidelines for the identification and tracking of procedures impacted as a result of program revisions.
Date When Full Compliance Will be Achieved TVA will be in full compliance by December 16, 1994, at the completion of the corrective actions.
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ENCLOSURE 2 COMMITMENTS INSPECTION REPORT 94-15 1.
The verification program procedure will be revised to clarify the requirements relative to locked valves and to provide explicit guidance when performing verification. This action will be completed by December 16, 1994.
2.
A review of the appropriate procedures impacted by Revision 2 of the verification program will be performed to determine if similar problema exist, and the procedures will be revised as appropriate.
These actions will be completed by December 16, 1994.
3.
The appropriate training material will be revised to amplify the verification process requirements.
This action will be completed by December 16, 1994.
4.
The procedure governing the administration of site procedures will be revised to establish guidelines for the identification and tracking of procedures affected by program revisions.
This action will be completed 'y October 7, 1994.
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