ML20106A082
| ML20106A082 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 09/11/1992 |
| From: | Joshua Wilson TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9209250125 | |
| Download: ML20106A082 (8) | |
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IUA vnn.* voe, an, ene om,e un (,uv om 1.w.sw arm J L Whon vu montw n,e#howret September 11, 1992 U.S. Nuclear Regulatory Conunission ATIN:
Document Control Desk Washington, D.C. 20555 Centlemen:
In the Matter of
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Docket Nos. 50-327 Tennessee Valley Authority
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50-328 SEQUOYAH NUCLEAR PIANT (SQN) - NRC INSPECTION REPORT NOS. 50-327, 328/92 RESPONSE TO NOTICES OF VI0lATION (NOVs) 50-327, 328/92-22-01, -02 Enclosed is IVA's response to Bruce A. Wilson's letter to M. O. Medford dated August-12, 1992, which transmitted the subject NOVs. The first violation addressed management oversite of housekeeping and craft inattention to detail during the conduct of work activities around safety-related equipment. The 'second violation _ r.ddressed a continuing problem with implementing confs p ration control, spacifically implementation of the verification-process.
In an,11 tion to the respor u to the second violation..a request was made for TVA to address the untimely notification of the event. The notification and surrounding circumstances for the perceived untimely reporting are addressed as coditional Information following the second violation. -provides IVA's response to the NOVs. Commitments contained in this submittal are provided in Enclosure 2.
If you have any questions concerning this submittal, please telephone J. D.-Smith at (615) 843-6672.
Sincerely, JnL i
L. Wilson 1
Enclosures e?30013 h[
cc:. See page 2 f
9209250125 920911 p'
PDR-ADDCK 05000327
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U.S. Nuclear Regulatory Commission Page 2 September 11, 1992 Enclosures cc (Enclosures):
Mr. D. E. LaBarge, Project Manager U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 NRC Resident inspector Sequoyah Nuclear Plant
.2600 Igou: Ferry Road Soddy-Daisy, Tennessee 37379 Mr. B. A. Wilson, Project Chief U.S. Nuclear Regulatory Commission Region 11 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 a
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Enclooure 1 RESPONSE TO NRC INSPECTION REPORT NOS. 50-327/92-22 AND 50-328/92-22 BRUCE A. WILSON'S LETTER TO H. O. MEDFORD DATED AUGUST 12, 1992
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i Violation.10-32L_32802-22:01 "Technien! Specification 6.8.1 requires that written procedures be establiched, implemented and maintained for applicable procedures secommended in Appendix A of Regulatory Culde 1.33, Quality Assurance 1
Program Requirements, Revision 2. February.1978. Appendix A to Regulatory Guide 1.33 requires that administrative procedures be established to ensure that maintenance that can affeet the performance of safety-related equipment be properly pre-planned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances.
"(1) Site Standard Practice 12.7, HOUSEKEEPING / TEMPORARY EQUIPMENT CONTROL, Revision 7 Section 3.1.1.B. states, in part, that the foreman or work supervisot in charge of an activity shall ensure that proper cleanliness is maintained during and after completion of a work activity.
"(2) Maintenance Instruction (MI) 10.14, APPLICATION REPAIR OF PROTECTIVE COATINGS IN THE REACTORS AND AUXILIARY BUILDINGS, Revision 24, Fection 3.6, states, in part, that equipment that may be damaged by coating work activities shall be protected by covering, enclosing, or removal from the work area to ensure that no equipment degradation occurs. Section 3.8, states, in part, that precautions shall be taken to ensure that coating of components with moving parts are not compromised for their intended design function due to binding, resulting from coating material le., (sic] mechanical linkage on the Diesel Generators.
" Contrary to the above, the previous procedures were not properly established or impicmented as indicated in the following examples:
On or before July 24, 1992, modifications personnel failed to maintain adequate cleanliness control during floor stripping activities in the Turbine Driven Auxiliary Feedwater Pump room.
This condition resulted in a failure of the pump to_ pass its required post-maintenance test and also resulted in a significant delay in returning the safety-related pump to operable-status.- On July 29, 1992, operability of the Unit 2 Turbine Driven Auxiliary Feedwater Pump was again compromised during room refurbishment (repainting) activities due to modifications personnel allowing epoxy coating to be applied to the mechanical linkages and other equipment necessar} for normal operation of the pump governor valve.
"This is a Severity Level IV violation (Supplement 1)."
l Reason _for_the_ViolaiJon i
On May 13, 1992, a werk document was initiated f or general refurbishment (repainting) of the auxiliary building, Elevation 669.
Planning steps.
instructed craftsmen to obtain the required permits and make the required notifications before work start and/or restart. The craftsmen were to
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~2-pr epare and paint all areas of walls, ceilings, steel surf aces, or WA denwings and in accordance with the requirements of Maintenance
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equi eent below the reierence line, using appropriate paint as listed on l
lustruction (MI) 10.14. " Application Itepnir of Protective Coatings in the Itenetors and Auxiliary fluildings." Psework briefings were held with all craftsmeu on June 29, 1992, in which the precautions and limitations-described in Mi-10.14 and methods of preparation and conting application were discussed.
Conting pacpatation work on auxiliary building, Elevation 669, began on June 30, 1992, with repainting operations outside of the Unit 2 i
turbine-driven auxiliary f eedwater ptunp (TDAINP) room being accoinplished i
befose July 20, 1992.
Duritig this period, no specific wor k instructions (written or verbal) were given to the involved craf tsmen concerning the possible migration of dust into the Unit 1 TDAINP room. On i
July 20, 1992, the Modificationr. painters began surface preparations in the Unit 2 TDAINP toom by use of needle guns to remove the existing conting. The painters were given no specific werk instructions (written or verbal) f or preenullons reintive to dust control around equipment in the TDAINP room. Crnitsmen were verbally lustructed to recoat all surfaces that had previously been coated.
On July 29,1992, a Modiflentions painter was repninting the Unit 2 TUAINP equipment when he inndvertently applied paint (brush marks) to the shnf L surface of the TDAINP governor servo valve. We craftsman did not recognize the mistake.
The application of paint to moving par'.s is attributed to personnel cnrelessness, conflicting work lustructions, and inadequate work document i
pinnning. Additionally, dust intrusion lato TDAINP components is i
attributed to weak oversight and direct. ion, inadequate work document planning, nud inadequate coordinntlon and communication.
Correctlyc Steps,ThatJiavc 3cen_Taken_end_the Results Achicved Management suspended the ongoing conting and preparation for coating l
operations on July 30, 1992, when it was identifled that moving parts had been painted.
l Walkdowns were performed by Modifications and Operations personnel:to determine if paint was present on other safety-reinted equi uent l
actuating surfaces. Also, the walkdowns focused on housekeeping associnted with dust produced by the conting preparation activities. The walkdowns did not identify degradation of safety-related equipment.
Minor discrepancies such as protective coating on nonmoving parts of snubbers, threaded valve stems, and stainless steel (piping and tanks) were identifled and corrected as appropriate. A dedicated walkdown of electrical equipment was performed to evaluate dust intrusion.
The walkdown did reveal dust intrusion; however, no operability concerns were identified. Work documents were initinted to clean affected electrical cabinets.
I Degradation of constantly running equipment was evalunted by a review of bearing and windin-temperatures of the component cooling pumps.- These ptunps were selected ior_ review because of their operating mede and beenuse conting preparation and painting had been performed in the area of the ptunps.
No equipment degradation was identifled.
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3-4 To dete mine if other safety-telated equipment had been affected, work I
documents written on any equipment located on Elevation 669 that were initiated during the timeframe of the painting activities were evaluated..The condition and corrective action of the work documents were reviewed, and it was found that neither dust nor paint had caused additional equipment malfunctions.
Ventilation paths were reviewed to determine if dust carry-over through the ventilation system could provide a common modo condition for l
redundant safety-related equipment located on Elevation 669. The investigation determined that the safety-related pump rooms on Elevation 669 had individual supply from and returns to the auxiliary building general supply fans, and dust in the hall areas would not affect compartmentalized equipment. The exception was the TDAWP room with normal air circulation taken f rom the general hall area of the auxiliary building.
This made the TDAWP rooms more susceptible to increased dust icvels in the general area.
The investigation concluded that dust generated by coating preparation did not present a coninon mode condition to redundant safety-reinted items.
Each painter craftsman was reindoctrinated to the procedural requirements concerning housekeeping and painting. Also, the applicable work document I
was replanned to add a checklist for performing a preliminary walkdown-Lo conting preparation and applicat4on and daily housekeeping inspection requirements.
Co r r e c t iv e_S te p a _Th aL W11 L b e.,.Ta k e n_Ln_ AY.01LIu r t herJini ation s M1-10.14 will be revised to include additional precautions in be taken during coating preparations.
i Da t e_Whe nJn11Jomp lia nc e_W11 L b.e_Ac hiev e d 1VA is in full compliance.
Viointion_50-32L_328/S2:22:02
" Technical Specification 6.8.1 requires that: written procedures be e.tablished, implemented and maintained _for applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Quality Assurance Program Requirements Revision 2, February 1978. Appendix A to Regulatory Guide 1.33 requires that administrative proctdures be established to ensure that maintenance that can' affect the performance of safety-related egalpment be property' pre-planned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances.
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"(1) Site Standard Practice (SSP) 12.6, INDEPENDENT VERIFICATION, Revision 1 specifies provisions for independent and second-party-
- verification. Section 3.3.4. states, in part, that a second party verification and a functional test may be specified instead of an independent verification in work orders and approved plant procedures.
This is provided that the testing-does, in fact, verify each component under consideration.
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" SSP-12.6, Section 3.1.5 further states, in part..that the preparers of site procedures / instructions shall ensure that applicable site procedures / instructions provide for independent verification /second party verification as appropriate.
"(2) Preventive Maintenance procedure PM 030272002 detailed actions for establishing correct configuration after work activities were performed on flow switch 2-FS-74-24.
" Contrary to the above, the preceding procedures were not properly established or implemented as indicated in the folloving example On or before July 1, 1992, the licensee failed to implement the requirements of SSP-12.6 and PM 030272002 resulting in improper termination of a lead to flow switch 2-FS-74-24
.These actions resulted in a mislaid wire termination and potentially affected operability of the 2D-B residual heat removal pump.
"This is a Severity Level IV Violation (Supplement 1)."
Reasottior_thcliolatlon inadequate self-checking and inattention to detall'were the causes for the craf tsmen to incorrectly terminate the field wire.
There was only one wire removed and roterminated during the July 1, 1992, calibration preventive maintenance (PM) of the flow switch.
Second-party verification was not effectively implemented.
The verifier did not identify that the field wire was terminated on the correct terminal.
The terminal block was correctly labeled and the label corresponded to the procedure and drawing. The wire was misterminated on a terminal that was not Inbeled.
Another cause for this event was that the postmaintenance test (PMT) was ineffective..The work request (WR) did not clearly specify requirements necessary to verify that the miniflow valve functioned properly after the flow switch was replaced in conjunction with the PM..The PMT as stated in the WR was to properly calibrate and functionally check-the flow switch. The ambiguity in the PMT led the craftsmen to believe that a system functional test or independent verification was not required.
Additional details concerning this event were reported in Licensee Event Report (LER) 50-328/92010 dated August 17, 1992.
Correct 1xn_ Steps _IhaLilayc_BectLTaken and._.the.leaulta_Achicyed
-The misplaced wire was correctly terminated and a functional test verified that the miniflow valve performed as designed. Wiring on the other miniflow switches for Units 1 and 2 was checked and verified as being correctly terminated.
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CurrecLivc_EtcraJhaLM11Lbe Jaken tolYoidJutther_Violat< ions Maintenance crafts; men, planners, and procedure writers have been briefed or, this event with an emphasis on the need for an adequate 1MT or specifying an independent verificat1<n In lieu of a PMT.
The lustrument PM data packages associated with the residual heat removal (RHR) miniflow valve switches have been revised to require independent verification for wire connections and also for jumpers.
Maintenance planners have been trained on the proper way to specify acceptance criteria for verifying that components can perform their intended functions.
Ilroader corrective actions associated with postmaintenance testing and verificatlon are being pursued as the result of the safety lujection pump brenker lasue as described in IIR 50-327/92014 and Inspection Report 50-327, 328/92-29.
Date_When_Eu1LCompliance W11Lbe_ Achieved TVA is in full compilance.
Additionallnformation on July 17, 1992, the shifL operations supervisor (SOS) made the reportability call for this event based on the luformation available to him at the time. lie determined that it was a 30-day report according to 10 CFR 50. 73, a. 2.1.11, and 10 CFR 50.73, m.2.11, and verified this through concurrence with the Duty Plant Mt.;ager and the Site 1,1 censing Manager. A review of Operations' logs was not done at this time to determine 10 CFR 50.72 reportability.
As new information was made available, the investigation team should have reevaluated reportability of the event under 10 CFR 50.72 criteria, liowever, the lucident investigation process did not drive the investigation in this directions and without the proper expertise, the team members did not readily recognize the liabilities associated wits a train of RilR being out of serv'.co.
This weakness in the incident investigat. ion program has been corrected. The lucident investigation program has been revised to provide a limited number cf responsible event manngers. These managers will be knowledgenble of reprtability requirements. Also, the procedures g.rverning regulatory reportini.,
requirements and incident investigation, i.e., SSP-4.5 und SSP-12.9 are being enhanced to Jnclude additional reportability guidelines.
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Encloento 2 Ce nittnentu V.iolatiott$0-327/32:2R:01 The procedure governind application at.d repair of protective coatings will be revised by November 30, 1992, to include precautions to be taken during coating preparatlotts.
Violation 30-327192-22:02 There are none in addition to t. hose already identifitd in LER 50-328/92010.
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