ML20116C436

Responds to NRC Re Violations Noted in Insp Repts 50-327/96-04 & 50-328/96-04.CA:SIs 1- & 2-SI-OPS-082-026.A, Have Been Placed on Administrative Hold to Prevent Use Until Instructions Are Revised

ML20116C436
Person / Time
Site:	Sequoyah
Issue date:	07/26/1996
From:	Adney R TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9607310179
Download: ML20116C436 (6)

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• - . i Ten.1essee Valley Authority, Post Office Box 2000, Soddy-Daisy, Tennessee 37379-2000 R.J. Adney Site Vice President l j

Sequoyah Nuclear Plant ,

July 26, 1996 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Gentlemen:

In the Matter of ) Docket Nos. 50-327 Tennessee Valley Authority ) 50-328 SEQUOYAH NUCLEAR PLANT (SON) - NRC INSPECTION REPORT NOS. 50-327, 328/96 REVISED REPLY TO NOTICE OF VIOLATION (NOV) 50-327, 328/96-04-02 Enclosed is TVA's revised reply to Mark S. Lesser's letter to Oliver D. Kingsley, 'Jr.,

j dated June 5,1996, which transmitted the subject NOV. The revision is necessary to i correct minor discrepancies in the " Reason for Violation" section of the response to NOV 50-327,328/96-04-02 and is distinguished by a revision bar in the right-hand margin. This revision will not affect any of the corrective actions that TVA had accomplished or previously committed to perform.

Commitments associated with the submittal are included in Enclosure 2. l If you have any questions concerning this submittal, please telephone me at (423)843-7001. j Sincerely, l

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d R. 7. Adney Enclosures - y 'o- [

cc: See page 2 ,.

9607310179 960726

'PDR ADOCK 05000327 G PDR m m.

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U.S. Nuclear Regulatory Commission Page 2

-July 26, 1996 l l

cc (Enclosures)- l Mr. R. W. Hernan, Project Manager i Nuclear Regulatory Commission  !

One White Flint, North l 11555 Rockville Pike 1 Rockville, Maryland 20852-2739 NRC Resident inspector Sequoyah Nuclear Plant  ;

2600 lgou Ferry Road I Soddy-Daisy, Tennessee 37379-3624 Regional Administrator U.S. Nuclear Regulatory Commission Region il ,

101 Marietta Street, NW, Suite 2900 l Atlanta, Georgia 30323-2711 I

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ENCLOSURE 1 RESPONSE TO NRC INSPECTION REPORT NOS. 50-327,328/96-04 MARK S. LESSER'S LETTER TO OLIVER D. KINGSLEY, JR.

DATED JUNE 5,1996  ;

VIOLATION 50-327.328/96-04-02

" Technical Specification 6.8.1.a requires, in part, that procedures shall be established, implemented, and maintained covering the activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978," Quality Assurance Program  !

Requirements (Operations)." Appendix A of Regulatory Guide 1.33, Section 1 includes administrative procedures for shift and relief turnover and log entries and Section 8 provides procedures for surveillance tests.

1. 2-SI-OPS-082-26.A, LOSS OF OFFSITE POWER WITH SAFETY INJECTION-DG 2A-A CONTAINMENT ISOLATION TEST, Revision 11, Section 6.10, Return to Normal, requires that systems be returned to their normal alignment following  ;

performance of the test.

2. 2-SI-IRT-099-699.A, RESPONSE TIME TEST OF ESFAS SAFETY INJECTION ]

SIGNAL WITH STATION BLACKOUT TRAIN A, Revision 1, Section 7.2, j Restoration, requires that equipment be aligned as desired for plant conditions J upon completion of the response time testing.

3. 2-PI-OPS-000-038.1, AUXILIARY BUILDING AUO DUTY STATION SHIFT RELIEF AND ROUNDS SHEETS-MODES 5 & 6, Revision 3, Appendix B, i Rounds Sheets, requires that the Spent Fuel Pit temperature be logged each ,

day during the day shift.

" Contrary to the above, the following examples of procedures were either inadequate or not followed and contributed to the loss of cooling to the Spent Fuel Pool for apporximately 28 hour3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br />s:

1. On April 22,1996,2-SI-OPS-082-026.Awas inadequate in that it did not contain instructions fe; restoration of the Spent Fuel Pit Cooling.

2. On April 23,1996,2-SI-lRT-099-699.Awas inadequate in tFat it did not contain instructions regarding the tripping of the C-S spent fuel pit pump and did not contain instructions for restoration of the Spent Fuel Pit cooling system following the test. Furthermore,2-SI-IRT099-699.Awas inadequate in that it incorrectly indicated that the A spent fuel pit pump was required for the response time test.

'3. On April 23,1996,2-PI-OPS-000-038.1 was not followed in that the Auxiliary Building Assistant Unit Operator failed to record the Spent Fuel Pit temperature as required.

"This is a Severity Level IV Violation (Supplement 1)."

Reason for the Violation The root cause of the violation was inadequate procedural guidance resulting in the failure to restore spent fuel pool cooling (SFPC) after the completion of testing. The surveillance instructions (Sis) that were being performed removed SFPC from service.

The sis do not address restoration of SFPC in the " Return to Normal" section of the procedures. Therefore, after completion of the subject Sis, there was no procedural guidance to remind Operations personnel to restore SFPC. Additionally, one of the sis contained incorrect information. Test alignment required the A A spent fuel pit pump to be started for performance of the Sl instead of the C-S spent fuel pit pump. This is in error because the A-A pump is not affected by the Si performance. The SI performance resulted in the C-S pump being removed from operation. Removing the C-S pump from service resulted in the termination of cooling to the spent fuel pool.

A contributor to fuel pool heat-up was inadequate awareness of and sensitivity toward the SFPC system. This inadequate watch standing is exemplified by the following: 1) field operators did not monitor the system closely enough to detect the misalignment before the high temperature alarm annunciated in the main control room,2) the pool temperature was not recorded during one of the operator rounds, and 3) the data sheet omission was not identified during the review.

Inadequate procedural guidance also contributed to the increase in pool temperature.

The associated periodic instruction (2-PI-OPS-000-038.1)specified a nominal temperature range of 70 to 150 degrees Fahrenheit (F) which was not consistent with alarm annunciation. The high temperature alarm setpoint is 127 degrees F.

Corrective Actions That Have Been Taken and the Results Achieved Sls 1- and 2-SI-OPS-082-026.A have been placed on administrative hold to prevent use until the instructions are revised. The performance of these procedures and 1- and 2-SI-IRT-099-699.A occur on a refueling outage frequency.

The appropriate disciplinary action has been taken relative to the failure to record the spent fuel pool temperature and the omission during the review of the periodic instruction data sheet. The importance of comparing recorded data to expected parameters while walking down a system has been stressed with Operations personnel. The past performance of the individuals involved has been reviewed and found to be good. Management monitoring and coaching in the plant and during training has been extensive, and personnel performance is improving. Observations from these activities are reviewed weekly and no generic operator watch standing deficiency has been identified.

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' The periodic instructions used for monitoring fuel pool temperature have been revised to reduce the temperature band, consistent with alarm annunciation. Additionally, the instruction revision enhanced the fuel pool monitoring frequency from once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to once each 8-hour shift.

l' The Corrective Steos Taken to Avoid Future Violations The appropriate procedures will be reviewed and revised to correct testing inadequacies relative to equipment alignment and restoration which resulted in the violation. The procedures that will be reviewed and revised are performed on a i refueling outage frequency. The necessary procedure revisions will be completed by l l January 24,1997, which is before the next use during the Unit 1 Cycle 8 refueling outage. An independent assessment of operator watch standing will be performed by August 9,1996,to evaluate the quality of operator performance.

Date When Full Comoliance Will be Achieved With respect to the examples cited, TVA will be in full compliance by January 24, 1997 after procedure revisions are completed.

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1 ENCLOSURE 2 COMMITMENTS FOR RESPONSE TO NRC INSPECTION REPORT NOS. 50-327,328/96-04 MARK S. LESSER'S LETTER TO OLIVER D. KINGSLEY, JR.

DATED JUNE 5,1996 NOV 50-327,328/96-04-02

1. The appropriate procedures will be reviewed and revised by January 24,1997, to correct testing inadequacies relative to equipment alignment and restoration that resulted in the violation.

2. An independent assessment of operator watch standing will be performed by August 9,1996, to evaluate the quality of operator performance.

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