ML20077E554
| ML20077E554 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 06/07/1991 |
| From: | Medford M TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9106100480 | |
| Download: ML20077E554 (6) | |
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Ma+ 0 Med'ord v,cr ne n.,1r;s mg Assg.ixe u e,,s.y u n.,
JUN 071991 U.S. Nuclear 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) - NRC INSPECTION REPORT NOS. 50-327, 328/91 RESPONSE TO NOTICE OF VIOLATION 50-327, 328/91-02-03 TVA's reply to B. A. Wilson's letter to D. A. Nauman dated May 8, 1991, which transmitted the subject notice of violation concerning examples of inadequate identification and correction of test deficiencies, is included in Enclosure 1. contains a list of commitments.
If you have any questions concerning this submittal, please telephone Russell R. Thompson at (615) 843-7410.
Very truly yours, TENNESSEE VALLEY AUTHORITY
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Medfor Enclosure cc:
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2 U.S. Nuclear Regulatory Commission JiUN 071991 Enclosure cc (Enclosure);
Ho, S.
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Black, Deputy Director Project Directorate 11-4 U.S.
Nuclear Regulatory Com'aission One b'hite Flint, North 11555 Lockville Pike Rockville, Marylani 20852 Mr. D. E. LaBargo, Project Manager U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 208S2 NRC Resident Inspector Sequoyah Nuc. lear Plant 2600 Igou Ferry Road Soddy Daisy, Tennessee 37379 Mr. B.
A. Wilson, Project Chief U.S.
Nuclear Regulatory L cunission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323
ENCLOSL*RE 1 RESPONSE TO NRC INSPECTION REPORT NOS. 50-327, 328/91-02 B. A. WILSON ' S LETTER TO D. A. NAl' MAN DATED MAY 8, 1991 Violation 50-327, 328/91-02-03
" Technical Specification 6.8.1 requires in part that written procedures shall be established, implemented and maintained covering surveillance and test activities of safet; celated equipment.
Administrative Instruction AI-47, Conduct of Testing, section 7.b, Test Deficiencies, requires that deficiencies identified during testing shall be documented, reviewed, evaluated, and corrective actions initiated.
Contrary to the above, corrective actions were not adequately initiated for deficiencies identified for SI-26.lA completed on September 20, 1988, and SI-26.2B completed on November 1, 1990, in that a procedure change was not initiated to correct the acceptance criteria at the t=30 seconds load sequence step.
In addition, the test results were inadequately reviewed for SI-26.lA completed on May 18, 1990, in that the review and approval process did not identify that the test acceptance criteria were not met for the t=30 seconds load sequence step.
This is a Sestrity Level IV violation (Supplement 1)."
Admission or Eenfal of the Alleged Violation TVA admits the violation.
Reason for the Violation As described above, there are two items associated with this violation.
The first is that the Surveillance Instruction (SI) 26 series, " Loss of Offsite Power With Safety Injection," was not corrected or revised following the performances completed on September 20, 1985, and November 1, 1990, when test deficiencies associated with incorrect acceptance criteria were noted.
The other item is that during the performance completed May 18, 1990, reviews did not identify that some acceptance criteria had not been satisfied.
The cause of not correcting the acceptance criteria in SI-26.lA was the failure of Operations personnel to track the procedure revision after being notified by Nuclear Engineering (NE) personnel of the needed change.
The contributing cause of the failure to correct the procedure following the identification of the incorrect acceptance criteria was weaknesses in administrative controls.
During the timeframe of the incident, it was permissible to close test deficiencies af ter the deficiency had been determined to be technically acceptable without tracki:.g actions to correct the cause of the deficiencies (such as incorrect acceptance criteria).
1 a
The cause of the failure to identify the minimwn voltage discrepancy on the t=30 second load step was that the responsible test director (senior reactor operator (SRO}) failed to execute his responsibilities as required by Administrative Instruction (A1) 47, " Conduct of Testing," to adequately conduct an evaluation of the test results.
From this example and several other recent incidents, it has been concluded that in some cass,. *est directors have become less rigorous in the performance of their responsibilities to ensure that the test packages are complete and accurate, possibly because of training weaknesses.
The test director accelted a verbal statement from the NF test representative that the test results had met the required acceptance criteria and did not independently review the test results en the data package.
To determine the actual test values, several Visicorder charts have to be reviewed, which require calculation and independent verification.
This data is logged on information spread sheets for calculation purposes.
Once computed, the voltage values are transferred to the SI-26 data sheets.
The information spread sheets contained the correct acceptance criteria.
Based on this process and data evaluation, it was recognized by the NE test representative that the test voltage data was acceptable.
The error occurred during and following the transfer of data to the SI-26.lA data sheets when a review of actual test values versus SI-26.lA acceptance criteria was not performed.
The NE representative who reviewed and signed the SI data sheet failed to compare the actual voltage with the acceptance criteria in the SI package. lie did verify the voltage to be greater than the acceptance criteria contained within the spread sheet, which was known to be correct.
Ele was not aware that the SI-26 acceptance criteria were different from that specified on the spread sheet. The NE representative indicated that he believed his signature reflected the correct transfer of data from the spread sheet to the SI, not a review of the SI acceptance criteria. This was not understood by the test director who was ultimately responsible for ensuring that acceptance criteria were satisfied.
The acceptance criteria promulgated by this surveillance are numerous and are scattered throughout the procedure in various data sheets. While it is not an acceptable basis for inadequate performance of responsibilities, this situation is considered to have possibly contributed to the SRO accepting the verbal assurance and not separately reviewing the data sheets.
Corrective Steps That Have Been Taken and Results Achieved AI-47 has been superseded by Site Standard Practice SSP-3.1, " Conduct of Testing." As described in Section 4.3.2 of Inspection Report 91-02, SSP-S.1 includes additional controls to prevent the disposition of test deficiencies without properly identifying and tracking needed corrective actions.
Site Standard Practice (SSP) 7.50, " Work Approval and Closure, was irplemented on April 1, 1991.
This procedure provides a standardized process for work approval and closure and delineates signature meaning and requirements for validating acceptance.
This is intended to ensure the acceptability of the work or test, whether it is a surveillance instruction, work order, workplan, or preventative maintenance instruction.
In addition, site personnel have been reminded of the necessity for quality level reviews in the areas of data acquisition and data review in determining component / system operability.
This activity was accomplished by a site dispatch from the Plant Manager that was distributed throughout the SQN site.
Correct Steps That !.'ill Be Taken to Avoid Further Violations SI-26 will be revised to incorporate the correct ac c e p tam:e criteria in accordance with the ongoing procedure enhancement program that will provide highlighted or accented data results along with the associated acceptance criteria.
Also, the acceptance criteria will be placed at one central location in the body of the surveillar.ce instruction so that the data obtained can be analyzed in order to determine operability.
The revised procedure will also incorporate clear, uniform lines of responsibility for reviews and signatures.
Requirements for thorough, detailed reviews for testing and work documentation will be discussed with licensed operators during Week 3 requalification training scheduled to be completed by June 21, 1991.
Additionally, *.est directors are to be retrained and the selection and qualificaticu of test directors will be controlled by a senior plant management position in accordance with SSP S.I.
This will ensure that an adequate level of experience for each individual evolution is maintained during the performance and review of test results te obtain a thorough and accurate finished product for plant surveillance instructions.
The retraining and controlling of the new test director position will be implemented by July 5, 1991.
Date When Full Comcliance Will Be Achieved SI-26 series procedures will be revised by October 1, 1991, to support the next scheduled performance.
SQN will be in full compliance at this time.
i
ENCI.0SURE 2 LIST OF COFNITMENTS 1.
SI-26 series will be revised by October 1, 1991, to support the next scheduled performance.
2.
Requirements for thorough, detailed reviews for testing and work documentation wil> be discussed with licensed operators during L'eek 3 requalification training scheduled to be completed by June 21. 1991.
3.
The retraining and controlling of the new test director position will be implemented by July 5, 1991.
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