ML20082A028
| ML20082A028 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 11/01/1983 |
| From: | Mills L TENNESSEE VALLEY AUTHORITY |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20082A024 | List: |
| References | |
| NUDOCS 8311180008 | |
| Download: ML20082A028 (3) | |
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TENNESSEE VALLEY AUTHORITY CHATTANOOGA TENNESSEE 37401 400ChestnutStreetTowg 4g 29 Nove%er 1,198 U.S. Nuclear Regulatory Commission Region II Attn:
Mr. James P. O'Reilly, Regional Administrator 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30303
Dear Mr. O'Reilly:
SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 - NRC-OIE REGION II INSPECTION REPORT 50-327/83-18 AND 50-328/83 RESPONSE TO VIOLATION q
l The subject OIE inspection report dated October 3,1983 from R. C. Lewis to H. G. Parris cited TVA with one Severity Level IV Violation.
Enclosed is our response to the subject inspection report.
If you have any questions, please get in touch with R. H. Shell at FTS 858-2688.
To the best of my knowledge, I declare the statements contained herein are complete and true.
Very truly yours, TENNESSEE VALLEY AUTHORITY L. M. Mills, Ma ager Nuclea:' Licensing Enclosure ec:
Mr. Richcrd C. DeYoung, Director (Enclosure)
Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Records Center (Enclosure)
Institute of Nuclear Power Operations 1100 Circle 75 Parkway, Suite 1500 Atlanta, Georgia 30339 8311180003 031107 PDR ADOCK 05000327 G
PDR 1983-TVA SOTH ANNIVERS ARY An Equal Opportunity Employer
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EHCLOSURE RESPONSE - NEC INSPECTION REPORT NOS.
50-327/83-18 AND 50-328/83-18 R. C. LEWIS' LETTER TO H. G. PARRIS DATED OCTOBER 3, 1983 Item _327,328/83-18-01 Unit 2 License Condition 2.C.(16)c. requires that procedures shall be available to verify the adequacy of operating activities in accordance with paragraph I.C.6 of NUREG 0737. Paragraph I.C.6 references section 5.2.6 of ANSI Standard N18.7 which requires that temporary modifications such as lifting of leads be controlled by approved procedures which shall include a
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requirement-for independent verification.
Contrary to the above, adequate procedures were not available to verify the adequacy of operating activities'in that on August 3, 1983, the inspector observed a portion of the Unit 2' Auxiliary Feedwater, F-3-142 loop, calibration being performed with an inadequate procedure. The procedure, IMI-3 " Main and Auxiliary Feedwater", did not include the requirements or the data sheets necessary to verify the correct lifting and terminating of electrical leads. The lifting of leads is required during loop calibration to install test equipment.
This is a Severity Level IV Violation (Supplement I).
This violation applies to both units.
1.
Admission or Denial of the Alleged Violation TVA admits the violation occurred as stated.
2.
Reasons for the Violation if Admitted In a letter to A. Schwencer ~of NRC. dated May 11, 1981, TVA stated in its response to NUREG 0737, item I.C.6, that operability is
' demonstrated before a system is returned to service. Surveillance Instruction (SI)-207 and IMI-3 include a double signoff that the loop (FT-3-142) was calibrated and that all technical specification criteria were met. Also, plant procedures require various surveillances to be performed on a periodic basis to verify operability of this loop, such as channel checks and running of the turbine-driven auxiliary feedwater pump.
Item 5 under " clarification" of the NUREG states that second party verification is required unless a functional test is performed.
Based on the above, the plant interpreted that double verification of wire lifts for this instrument following calibration was not considered a requirement since post-calibration testing would have detected any wire lift errors.
4.
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3 Corrective Steps Which Have Been Taken and the Results Achieved Upon event discovery, the loon had already been returned to service and verified operabis.
Instr'ume.: maintenance personnel were instructed to include configurt. tion control sheets on future work involving CSSC instruments. Also, a review of Procedures similar to IMI-3 was initiated to ensure that double verification was included.
4.
_ Corrective Steps 'dhich Wil? Be Taken To Avoid Further Violations Procedures, including IMI ~3, identified in the review as needing double verification signoffs, vt11 be revised by December 30, 1983.
- 5. 'Date Whhn Full Compliancp_Will Be Achieved The plant was in full compliance on August 4, 1983.
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