ML20086U091

Responds to NRC Re Violations Noted in IE Insp Repts 50-327/83-29 & 50-328/83-29.Corrective Actions: Work Plan 10260 Reworked Per Critical Sys,Structures & Components Requirements

ML20086U091
Person / Time
Site:	Sequoyah
Issue date:	02/08/1984
From:	Mills L TENNESSEE VALLEY AUTHORITY
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20086U083	List: ML20086U091
References
NUDOCS 8403070155
Download: ML20086U091 (6)

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TENNESSEE VALLEY, AUTHORITY

< CHATTANOOGA. TENNESSEE 37401 400 Chestnut Street Tower II February 8,1984

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- U.S. Nuclear Regulatoby' Commission ?_7

. 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-0IE REGION II INSPECTION REPORT 50-327/83-29 AND 50-328/83-29 The subject OIE inspection report dated January 10, 1984 from you to H. G. Parris cited TVA with four Severity Level IV Violations. Enclosed is

.the response to the items of violation in 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 th'e statements contained herein ar; complete and true.

Very truly yours, TENNESSEE VALLEY AUTHORITY L. M. Mills, nager Nuclear Licensing Enclosure-oo (Enclosure):

Mr. . Richard C. DeYoung, Director Office of Inspection and Enforcement zU.S ' Nuclear ;1egulatory Commission L Washington, D.C. 20555 Records Center Institute of Nuolear Powar Operations 1100 circle 75 Parkway, Suite 1500

-Atlanta, Georgia 30339' 8403070155 84022'I PDR ADOCK 050003Er/

g PM An Equal Opportunity. Employer

., ENCLOSURE RESPONSE - NRC INSPECTION REPORT NOS.

50-327/83-29 AND 50-328/83-29 JAMES P. O'REILLY'S LETTER TO H. G. PARRIS DATED JANUARY 10, 1984 Item 1'(327, 328/83-29-02) 10 CFR 50, Appendix B, Criterion X and the licensee's accepted Quality Assurance Program (Topical' Report TVA-TR75-1) Section 17 2.10 require that inspection shall be performed during modification affecting the quality of Critical Systems, Structures and Components (CSSC) items at TVA plants.

Modification and Addition Instruction (M&AI)-12 " Interconnecting Cable Termination and Insulation Inspection",' Section 5.0, further requires that QA inspectors shall be responsible for inspecting per this procedure on CSSC equipment.

Contrary to the above, inspection was not performed en CSSC equipment as required by M&AI-12 Section 5 in that during the performance of Work Plan WP10260, which mrouted signal cables from radiation monitors 1-119, 1-120,

.1-121, 2-120 and 2-121, the inspection of the cable termination per M&AI-12 was performed by the cognizant engineer instead of a QA inspector. The affected radiation monitors are CSSC 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 Work Plan' WP10260 was wrked as non-CSSC due to the fact that the cognizant angineer did not identify the equipment correctly as being a CSSC component. The cognizant algineer then signed off the work plan as he would any other non-CSSC work plan.

3 Corrective Steps Which Rave Been Taken and the Results Achieved Work Plan WP10260 has been reworked per CSSC requirements in coordination with th'e Field Quality Engineering Staff Laspectors.

4. Corrective' Steps Which Will Be Taken To Avoid Further Violations Personnel have been re-instructed to verify CSSC and non-CSSC components as future work plans are written.

5. Date When Full Compliance Will Be Achieved Full compliance was achieved on February 7,1984.

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Item 2 (327, 328/83-29-01)

Technical Specification 6.8.1.a requires that written procedures shall be implemented covering the activities referenced in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978, including discharging liquid radioactive waste as effluents. System Operating Instruction (SOI)-14.3

" Condensate Demineralizer Waste Disposal" provides requirements, conditions, precautions and instructions for releasing the High Crud Tanks

'(HCT).

Contrary to the above, procedure SOI-14.3 was not implemented in that on October 15, 198 3, during a planned release from hCT "B" to cooling tower

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blowdown, the tank was partially released to the turbine building sump because the valve alignment was not properly completed in accordance with the procedure.. When the error was discovered, the release was stopped, the

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valve alignment corrected and the release properly completed. The activity levels in the tank were less than 10 CFR 20, Appendix B, Table II limits, therefore, Technical Specification release limits were not exceeded.

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

, The proper valve lineup was not properly verified prior to the relea;e.

Personnel failed _ to completely follow die system operating instruction in aligning the system for releasc.

3. Corrective Steps Which Have Been Taken and the Results Achieved The release was terminated upon discovery. Appropriate disciplinary action was taken on the personnel involved. Retraining was conducted to reinforce the importance of following procedures and paying attention to detail. This training will also ensure that personnel understand the methods of independent (double-person) verification.

4. Corrective Steps Which Will Be Taken To Avoid Further Violations The procedure, SOI-14.3, is being revised to include double verification. This will be done by March 16, 1984.

5. Date When Full Compliance Will Be Achieved Full compliance was achieved October 15, 1983 a

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Item 3-(328/83-29-03)

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' Technical Specification 3 5.1.2 requires that the Upper Head Injection Accumulator System'shall be operable with the unit in Mode 3 above

-1900,psig. . Technical Specification 3.0.4 requires that entry into an Operational Mode or. other specified condition shall not be made unless the conditions. for' the Limiting Condition for Operation are met without

, reliance on provisions contained in the Action requirements.

- Contrary to the above, Unit. 2 was in Mode 3 and went above 1900 psig en

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LNovember 7, .1983, without -the Upper Head Injection Accumulator System

. operable :in' that mactor coolant system pressum was allowed to increase priorfto placing-the~ system in service. The condition for LCO 3 5.1.2 was

!not met without reliance ~ on provisions contained -in the action require-

- ments. Reactor coolant system pressum was quickly reduced to less than

• 1900 psig when the. error was discovered. Pressure was above 1900 psig for approximately one hour.

This ~ is a' Severity Level IV Violation (Supplement I). This violation applies to Unit 2 only. .

1. Admission or Denial of the Alleged Violation '

1 TVA admits the violation occurred as. stated..

2. -- Reasons for the Violation if Admitted -

The event fot November 7,1983, was caused by. a personnel error in that the operator inadvertently failed - to follow procedures. During the

, startup phase, the ' operator had become involved in several other jobs at the same time:and failed to notice the reactor coolant system (RCS) presaum increase and ~ to open the upper. head injeotion (UHI) -isolation

= valves.- Immediately upon event discovery, the operator decreased RCS presaure to-less than 1900.psig by opening the pressurizer sprays and turning off the pressurizer heaters.

3 Corrective Steps Which Have Been Taken and the Results Achieved The operator uns counseled and disciplinary action initiated to

, reinforce the importance of- followin; procedures

e. and observance of

-plant parameters.

L4h Corrective' Steps Which Will Be Taken to Avoid Further Violations L All plant personnel have-been given training to ensure that they tunderst'and the importance of paying attention to detail and following procedures. -

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5. Date When' Full' Compliance Will Be Achieved j

1 Full compliance was achieved on November 7,1983, when the operator '

- reduced presaure less ' than 1900. psig.

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E Item 4 (328/83-29-04)

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 reforences section 5.2.6 of ANSI Standard N18.7 Which reqaires that temporary modifications such as lifting of leads be controlled by approved procedures which shall include a requirement for independent verification.

Contrary to the above, adequate procedures were not available to verify the adequacy of operating activities in that on November 1, 1983, leads were lifted from Unit 2 Upper Head Injection level switches (L/S) 87-23 and 87-24 to support calibration per SI-196.2. The lead lifting was not controlled by SI-196.2 and there was no requirement for independent verification of .the retermination. The wires were reterminated incorrectly and caused equipment inoperability. The error on L/S 87-23 was identified and corrected on November 8. The error on L/S 87-24 was identified and corrected on November 15.

This is a Severity Level IV Violation (Supplement I). This violation applies to Unit 2 only. ,

1. Admission or Denial of the Alleged Violation

- TVA admits the violation occurred as stated.

2. Reasons for the Violation if Admitted lit November 1, 1983, while the unit was in mode 1 at 100 percent power, the instrumentation mechanics calibrated UHI level switches 2-LS-87-23 and -24. These level switches contain a microswitch which has two sets of contacts, one for closing the associated valve using the control room handswitch 'and the other for actuating the dump solenoid to fast close the isolation valve on an accumulator -low level. The internal wiring .bo the level switches was lifted to better fhcilitate the test equipment setup; however, the calibration procedure (SI-196.2) did not contain steps to lift wiring. Following calibration, the wiring was incorrectly reterminated and the unit condition did not allow for post-maintenance . testing of the valves.' Therefore, the error was not noted at this time.

On November 2,1983, with unit 2 shut down for a scheduled outage and while trying to close the UHI isolation valves in mode 3 before going below 1200 psig, valve 2-FCV-87-23 would not close by tne control room hand switch. Initial troubleshooting did not reycal the problem and the valve was fast closed by jumpering the dump solenoid at the level switch. The problem was thought to be in the control room handswitch, and troubleshooting between November 3,1983, and November 7,1983, did not reveal the problem.

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3 Corrective Steps Which Have Been Taken and the Results Achieved Plant management initiated an investigation into all problems associated - with the ' UHI system. At this time, the wiring errors were noted. . Valve 2-FCV-87-23 was found such that it would have closed on a low-level signal if required, but not from the control room hand-switch. Valve 2-FCV-8J-24 would not have closed on a low-level signal and, therefore, did not cottply with LCO 3 5.1.2 require-ments. . However, the valve would operate from the control room handswitch.

4. Corrective Steps Which Will Be Taken To Avoid Further Violations Maintenance personnel will be given training on the use of configuration control' forms. This will be reinforced periodically on an annual' basis. The UHI level switch procedure (SI-196.2) was

. revised to add the necessary steps to use configuration control forms if leads are lifted.

The configuration log and system status file shall be maintained such that any outages or deviations shall be documented in either file.

Also,- these files may be relied on for system operability and ,

alignment.

5. Date When Full Compliance Will Be Achieved Full compliance was achieved on November 25, 1983, when SI-196.2 was

. revised.

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