ML20086B879

Forwards Response to NRC Re Violations Noted in Insp Repts 50-327/95-12 & 50-328/95-12.Corrective Actions: Placed Permanent Placards on T-handles for Containment Sump Isolation Valves to Prevent Manual Operation

ML20086B879
Person / Time
Site:	Sequoyah
Issue date:	06/29/1995
From:	Adney R TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9507060147
Download: ML20086B879 (6)

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Tennessee v, , Adnusty. Pod OHu Bos MA Soccy-Omv Tennessee 37379 June 29, 1995 U.S. Nuclear Regulatory Commission ATTN Document Control Desk Washinerton, D.C. 20555 Centlement In the Hatter of ) Docket Nos. 50-327 Tennessee Valley Authority ) 50-328 SEQUOYAH NUCLEAR PLANT (SQN) - INSPECTION REPORT NOS. 50-327, 328/95 REPLY TO NOTICE OF VIOLATION (NOV) 50-327, 328/95-12-01 Enclosure 1 contains TVA's reply to Mark S. Lesser's letter to Oliver D. Kingsley, Jr., dated June 1, 1995, which transmitted the subject NOV. The violation is associated with an inadequate. procedure regarding the operation of the reach rods for the containment sump valves and the failure to have a drawing or procedure to control the configuration of the reach rods. 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.

Sincerely,

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. Adney Site Vice President Enclosures I cc: See page 2 OEU

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U.S. Nuclear Regulatory Commission

- Page 2; 1 June 29,'1995 cc (Enclosures):

'Mr. D. E. LaBarge, Project Manager-U.S.. Nuclear Regulatory Commission One White Flint, North L.

11555 Rockville Pike Rockville, Maryland 20852-2739 NRC Resident Inspector ,

Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy-Daisy, Tennessee 37379-3624 Regional Administrator i U.S. Nuclear Regulatory Commission l' Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323-2711 i-l.

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ENCLOSURE 1 RESPONSE TO NRC INSPECTION REPORT NOS. 50-327, 328/95-12 MARK S. LESSER'S LETTER TO OLIVER D. KINGSLEY, JR.

DATED JUNE 1, 1995 Violation 50-327, 328/95-12-01 "10 CFR Part 50, Appendix B, Criterion V, requires, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.

" Contrary to the above,

1. From September 3, 1993 through April 12, 1995, instructions or procedures for activities affecting quality were inadequate in that EA-88-1, Revision 0, VERIFICATION OF CONTAINMENT PENETRATION ISOLATION, incorrectly stated ' lift to disengago' regarding the operation of reach rod devices for both units containment sump rocirculation valves (1-FCV-63-72, 1-FCV-63-73, 2-FCV-63-72, and 2 FCV-63-73). This incorrect configuration control resulted in the reach rods being left in unknown configurations which could have affected operability of the subject valves.

2. On or before April 10, 1995, instructions, procedures, and/or drawings for activities affecting quality were inadequate in that reach rod devices for both units containment sump recirculation valves (1-FCV-63-72, 1-FCV-63-73, 2-FCV-63-72, and 2 FCV-63-73) did riot appear on sppropriate system flow drawings or in system operating instructions as necessary to adequately reflect the design of the facility. This lack of configuration control resulted in the reach rods being left in unknown configurations which could have affected operability of the subject valves.

"This is a Severity Level IV Violation (Supplement I)."

Reason for the Violation .

Example No. 1 The reason for Procedure EA-88-1 being incorrect was that the procedure preparer did not adequately verify the information obtained regarding manual operation of the containment sump recirculation valves. EA-88-1 was prepared based on theory of operation. The correct manual operation of the T-handles was not known by plant personnel and not recorded in plant procedures. To correctly operate the valves in manual required depressing the T-handles in the down position. The procedure preparer in

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. order to ascertain the method of operation attempted to consult several sequoyah organizations. The only responding organization, Operations, had varied responses. Some operations personnel indicated that the declutch position for the valves was with the T-handle in the up position and others indicated that the declutch position for the valves was with -

the T-handle in the down position. The procedure preparer did not question these conflicting reports. In addition, the preparer requested an AUO to inspect the T-handles. The AUO reported that the current position of the T-handles was in the down position, and testing had previously been successfully completed on the subject valves. Based on this information, the preparer incorrectly concluded that the required position for the T-handles was down.

A verification and validation team also reviewed the procedure. A team consists of a team leader, a qualified reviewer and other personnel with expertise in areas such as operations, Engineering, and Human Factors.

The team leader was the qualified reviewer. The team leader questioned the procedure preparer regarding the process by which the positioning of the T-handles was determined without verifying the information via other sources. The team leader was inappropriately satisfied with the information. Further, the team leader and the preparer considered that their level of effort at the time of procedure preparation was adequate and satisfied their responsibilities for verification. A subsequent  ;

discussion with the involved individuals resulted in their determination that the subject review was inadequate.

, Example No. 2 The reason for not maintaining configuration of the T-handles is ,

explained as follows. In August 1978, a field change requeat was  !

initiated to modify the design for the T-handle remote declutch device for the containment sump valves. This modification deleted a spring that l

was to hold the T-handle in the up or electrical operation position, and removed a note from the mechanical drawing which implied that the normal position should be up. The field change request incorporated the current pinning design to restrain the T-handle in the up position removing its weight from the declutch level. A review of plant history indicates that no functional testing of the T-handle was required or performed. The ]

field change reque t process at that time did not appear to have included a review by plant personnel to determine potential operational impacts. l This design is considered unique in that this is the only known application and no training or other guidance has been provided as to its operation. A similar design change made under the current design change process would include a review for potential operational impacts which would have identified the significance of this change.  ;

1 Corrective Steps That Have Been Taken and the Results Achieved A standing order was issued explaining the operation of the containment sump T-handles, notification of the revision of EA-88-1, and informing operations of the caution orders placed on the T-handles to instruct operators on their operation.

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. Permanent.pla' eds'were_placed on the T-handles for the containment sump-isolation.vals to' prevent manual operation, especially in the closed direction excr for an emergency.

Operations personnel'are being trained on'the operation of the T-handles.

-Procedure EA-88-1 has been revised to provide detailed instructionJon the operation of the T-handles. Also, the appropriate maintenance procedures

. l have been revised to address the T-handle. positions.

Engineering has reviewed design information and verified that no additional remote declutch devices exist at Sequoyah.

Corrective Stoos That'Will be Taken to Avoid Future Violations  ;

The appropriate SOI checklist will be revised to address T-handle a position for the containment sump recirculation isolation. valves. j A review of emergency procedures revised utilizing the current process, .{

which addresses activities that are not previously performed at the~ plant  !

or on the simulator to ensure that no errors exist, will be performed.  !

Other emergency procedures prepared and evaluated by the personnel involved with the subject procedure will also be evaluated.

A training course on proper verification and validation techniques will ,

be established. The course will address expectations regarding, unverified. assumptions, questioning attitude, and operating from fact  ;

versus theory.

~Date~When Full Comoliance Will be Achieved. .,

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TVA will be in full compliance by August 4, 1995, at the completion of '

the corrective actions.

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l ENCLOSURE 2 [

INSPECTION. REPORT,95-12 COMMITMENTS.-

1. LThe. appropriate SoI checklist will be revided to address.T-handle bar~

g' position for thefcontainment sump recirculation isolation valves..

This action will'be completed by. July 21, 1995. 5 P-I

2. : A review of emergency procedures revised utilizing the current process, which addresses. activities that are not previously performed

• at the plant or on the simulator to ensure that no errors exist,'will' be performed. -This action will.be completed by August 3, 1995.  :

3. Other emergency procedures prepared and evaluated by the involved: -[

personnel will be evaluated. This action will be completed.by i August 3, 1995.-

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4. A training course on proper verification and validation techniques [

will be established. The course will address expectations regarding unverified assumptions, questioning attitude, and. operating from factL i versus theory.. This action will be completed by August 4, 1995. ,

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