ML20138A459

Responds to NRC Re Violations Noted in Insp Repts 50-327/85-47 & 50-328/85-47.Corrective Actions:Steps 5.1.8 & 5.1.9 of Maint Instruction MI-II.4 Completed & Included in Workplan & Mods Personnel Will Review Instructions

ML20138A459
Person / Time
Site:	Sequoyah
Issue date:	03/05/1986
From:	Gridley R TENNESSEE VALLEY AUTHORITY
To:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
NUDOCS 8603140258
Download: ML20138A459 (4)

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. vdM6 TENNESSEE VALLEY AUTHORITY

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U.S. Nuclear Regulatory Commiselon Region II Y ' h '\

ATTN: Dr. J. Nelson Grace, Regional Administratorj ,,'

101 Mariett.a Street, NW, Sulto 2900 Atlanta, Georgia 30323 3

Dear Dr. Gra.W.* ,

SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2,- NRC-0IE REGION II INSPECTION REPORT 50-327/85-47 AND'50-328/85 RESPCNSE TO VIOLATION Enclosed 1s our r$spons.hnto D. M. Vercelli's February 3, 1986 letter to S. A. White trarismitting IE Inspec+.lon Repot*t Hos. 50-327/85-47 and 50-328/85-41 for our Sequoyah Nuclear Plant. which cited TVA with one Severity Level V Violation.

If you have any questions, please get in touch 41th R. E. Alsup at FTS 858-2725. ,

To the boct of my Knowledge, I declare the statements contained herein are complete and true, s

Very truly yours, T I- EE '/ LEY AUT110RITY R. Gridley

, Manager of Licensing r

-gi Enclosure  !

cc: Mr. James Taylor, Director ' (Enclosure)

Office of Inspection and Enforcement -

U.S. Nuclear Regulatory Cownisolon '

Washington, D.C. 20555 E 'T 1

8603140258 86030'5 PDR ADOCM 050003R7 G PD64 n;

I An Equal Opportunity Employer g

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RESPONSE - NRC-0IE INSPECTION REPORT NOS. 327/85-47 AND 328/85-47 DAVID M. VERRELLI'S LETTER TO STEVEN A. WHITE DATED FEBRUARY 3,1986 Violation 50-327/85-47-03 and 50-328/85-47-03 Technical Specification 6.8.1 requires that written procedures be estab-lished, implemented, and maintained covering safety-relatcd activities stated in Appendix A of Regulatory Guide 1.33, Revision 2.

a. Work Plan (WP) 11850 was established to implement a modification to the Essential Raw Cooling Water System (ERCW) including the instal-lation of check valves 2-VLV-67-786A, -786B, -786C, and -786D. The WP required the disassembly of the check valves in accordance with MI 11.4, Maintenance of CSSC Valves.

Contrary to the above, the WP was not adequately implemented in that the disassembly of valves 2-VLV-67-786A and -786C was not documented in accordance with MI 11.4.

b. Radio' logical Control Instruction RCI-14, Radiation Work Permit (RWP)

Program, was established to implement requirements for entry or work in an area of known or potential radiological hazard including the requirements for anti-contamination clothing. RWP 02-0-86668, which was written in accordance with this prodram, required workers entering the area near the boric acid transfer pump for removal of water on the floor to wear a top and bottom plastic suit.

Contrary to the above, two workers who entered the area on RWP 02-0-86668 did not implement the procedure in that they had unfastened the top front portion of the plastic suit, thereby increasing the potential for skin contamination. The workers' actions were being i

observed by their foreman at the time.

c. Maintenance Request (MR) A593499 was established, in part, to replace \

a NAMCO limit switch on the Unit 2 number 3 steam generator blowdown isolation valve. Maiatenance Instruction (MI) 10.37, NAMCO Limit Switches, was prescribed by MR A593499 an.1 implemented during the NAMCO limit switch replacement. MI 10.37 step 5.2 prescribed the use of Measuring and Test Equipment (M&TE), specifically a 0-30 inch pound ,

torque screwdriver.

Contrary to the above, the torque screwdriver used to accomplish step 6.1.1.2 was not a 0-30 inch pound torque screwdriver, and a "non-intent" change to MI 10.37 was not mede per Administrative Instruction AI-4 to reflect as such.

This is a Severity Level V violation (Supplement I). This violacien applies to both units.

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1. Admission or Denial of Alleged Violation TVA admits that the violation occurred as stated.

2. Reason for Violation The violation occurred due to personnel error in that:

a. During disassembly of valves 2-VLV-67-786A, -786B, -786C, and

-786D, steps 5.1.8 (record initial condition of valve) and 5.1.9 (record notes during valve work), of Maintenance Instruction (MI)-11.4, were not documented on data she sts. Since these were new valves, site personnel thought these steps did not apply to the work being performed.

b. The two wuakers involved unzipped the top portion of their plast!c suits for personal comfort.

c.

A torque screwdriver of the defined range was not available, and the responsible general foreman selected another range that was technically adequate (0-24 inch pound versus 0-30 inch peund specified in MI-10.37) .

3. Corrective Steps Taken and Results Achieved The following corrective steps have been takan:

a.

Steps 5.1.8 and 5.1.9 of M1-11.4 were completed and included in the workplan. Modifications persannel were instructed:

1. To review instructions before beginning work to familiarize themselves with the instructions.

2. To ensure the instructions are adequate for the assigned work.

3. To ensure the instructions are followed while performing the work.

b. As soon as the Radiation Work Permit '(RWP) violation was brought to the attention of the responsible foreman, the workers were instructed to properly wear the top portion of the plastic suits, c.

Although a 0-24 inch pound torque screwdriver was teed instead of the 0-30 inch pound torque range specified in MI-10.37, the intent of the instruction was met. A permanent plant instruction change to M1-10.37 has brea issued to more clearly define the acceptabic torque rar.ge.

4. Corrective Steps Taken to Avoid Further Violations

a. 1 The corrective actions identified in 3.a above have been determined to be cufficient to avoid future violations.

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b. The foreanan and crew were given retraining by the responsible section supervisor in complying with established RWP requirements. ,

c. The corrective action identified in 3.c has been deter.ained to.be sufficient to avoid future violations. '

5. Date When Full Compliance Will Be Achieved

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a. The plant was in full compliance on January 9,1986, when the data sheets were completed and included with Workplan 11850.

b. The plant was in full compliance on January 31, 1986, when retraining for the involved foreman and crew was ccepleted.

c. The plant was in full compliance on February 13, 1986, rhen the revision to MI-10.37 was ' issued.

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