ML20138C144
| ML20138C144 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 03/20/1986 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8604020372 | |
| Download: ML20138C144 (5) | |
Text
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TENNESSEE VALLEY AUTHORITY ca
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SN 157B Lookout Place
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cn March 20, 1986 U.S. Nuclear Regulatory Commission 2
Region II m
ATTN:
Dr. J. Nelson Grace, Regional Administrator u
101 Marietta Street, NW, Suite 2900 Atlanta, Georgia.30323
Dear Dr. Grace:
SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 - NRC-OIE REGION II INSPECTION REPORT 50-327/85-45 AND 50-328/85 RESPONSE TO VIOLATIONS is our response to J. A. Olshinski's February 18, 1986 letter to S. A. White transmitting IE Inspection Report Nos. 50-327/85-45 and 50-328/85-45 for our Sequoyah Nuclear Plant which cited TVA with two Severity Level IV Violations.
.If you have any questions, please get in touch with R. E. Alsup at FTS.
858-2725.
To the best of my knowledge, I declare the statements contained herein are complete and true.
Very truly yours, TENNESSEE VALLEY AUTHORITY R.
idley Manager of icensing Enclosure ec:
Mr. James Taylor, Director (Enclosure)
Office of Inspection and Enforcement U.S. Nuclear Regulatory Comission Washington, D.C.
20555 8604020372 860320 PDR ADOCK 05000327 G
PM 7
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An Equal Opportunity Employer
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j ENCLOSURE
' RESPONSE - NRC-0IE INSPECTION REPORT NOS. 50-327/85-45 AND 50-328/85-45 JOHN A. OLSHINSKI'S LETTER TO S. A. WHITE DATED FEBRUARY 18, 1986 I
Violation 50-327/85-45-06 and 50-328/85-45-06
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10 CFR 50, Appendix B, Criterion IVI requires that measures shall be established to assure that conditions adverse to quality, such as failures.
l malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.
Contrary to the above, two examples were noted where the licensee failed to promptly correct conditions adverse to quality. Specifically:
l A licensee Corrective Action Report (CAR) 4b-82-45 and supplemental a.
1, responses reported deficiencies in completing engineering and quality l
assurance reviews of field completed maintenance requests due to their being lost or discarded. Additionally, the supplemental responses committed to disposition of lost or discarded maintenance requests by April 12, 1985. As of December 5, 1985, 670 maintenance requests with field completion dates prior to February 18, 1983, had not completed the engineering and quality assurance review process as a result of failure to complete all required actions of the CAR Ab-82-45.
Additionally, as of December 5, 1985, 710 maintenance requests were noted to have been in review following completion of work in excess of 60 days which can contribute to a situation where maintenance requests may inadvertently become lost or discarded.
b.
In June 1983, short-term corrective actions were implemented to resolve, in part, problems with Upper Head Injection (UHI) level switches j
repeatedly being found out of calibration. These actions, which were taken as an interim measure until suitable replacement level switches could be found, appeared to be effective in demonstrating system operability until June 1984 on Unit 2 and August 1984 on Unit 1 at which time monthly calibration data indicated that the level switches were 4
.again repeatedly out of calibration.
In spite of this condition, additional interim measures were not established to ensure continuous i
system operability until level switch replacer.;ent could be completed, Engineering authorization was issued for replacement of level switches s
with a more reliable design in August 1985 and level switches were actually replaced on Unit 1.
However, level switch replacement for Unit i
2 was not scheduled until the next refueling outage cycle which is approximately six months subsequent to the currently scheduled restart.
I Scheduled implementation of this long-term corrective action for Unit 2 l
is not considered appropriate or timely in light of the recurrence of level switch calibration problems and the failure to implement additional l
interim corrective actions as a result of this recurrence.
This is a Severity Level IV violation (Supplement I).
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. 1.
Admission or Denial of Alleged Violation TVA admits that the violation occurred as stated.
2.
Reason for Violation This portion of the violation occurred because the guidelines in a.
Sequoyah Standard Practice SQM2 for handling and tracking status of completed maintenance requests (MRs) were not well defined.
Low priority was being given to completing the review of MRs and some were misplaced or lost in the review process.
b.
This portion of the violation occurred due to a lack of controls for the scheduling of the unit 2 level switch replacement.
3.
Corrective Steps Taken and Results Achieved Increased priority has been placed on completing the evaluation of a.
the 670 MRs identified by CAR 4b-82-45 as lost.
The evaluation is an ongoing activity, and currently, there are 432 MRs still requiring evaluation.
SQM2 was revised to clearly define MR routing and to maintain better status of tracking. MRs in the review process are being identified, and proper tracking status is noted.
Increased emphasis has been placed on completing MR reviews within 60 days.
b.
Workplan (WP) 11907 was issued to install the unit 2 UHI level switches.
WP 11907 has been field completed with the exception of calibrating the level switches which will be complete before startup.
4.
Corrective Steps Taken to Avoid Further Violations Computer changes are being made to implement the improved MR status a.
tracking program. Also, training will be conducted for foremen, maintenance planners, and NPRDS aides on their responsibilities for review and tracking of MRs. The computer changes will be completed by May 1, 1986. The training for foremen, maintenance planners, and NPRDS aides will be completed by May 1, 1986.
b.
Replacement of the UHI level switches in units 1 and 2 will prevent any further violations.
5.
Date When Full Complicnce Will Be Achieved The plant was in full compliance on February 27, 1986, when the a.
revision to SQM2 was issued.
b.
The plant will be in full compliance by startup.
. Violation 50-327/85-45-09 and 50-328/85-45-09 Technical Specification 6.8.1 states that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Appendix A of Regulatory Guide 1.33, Revision 2, February 1978 recommended that maintenance that can affect the performance of safety related equipment should be performed in accordance with written procedures, documented instructions or drawings appropriate to the circumstances, and additionally recommended that the control of maintenance, repair, replacement, and modification work be covered by written. procedures.
Contrary to the above, three examples were noted where the licensee failed to properly implement required procedures. Specifically:
During performance of valve rewiring activities on valve 2-FCV-70-134, a.
in accordance with work plan 11853, NUREG-0588, 10 CFR 50.49, Valve Rewiring, and electrical jumper was not removed from the valve as required by the work plan.
b.
14 Pall Trinity Micro Corporation preventative maintenance recommendations associated with auxiliary air compressor dryers were not taken into consideration during development of the preventative maintenance program as required by Standard Practice Procedure SQM-57 Preventative Maintenance.
This resulted in no preventative maintenance being established and implemented for these dryers.
Numerous and sustained housekeeping deficiencies were noted in auxiliary c.
building contaminated areas.
This condition reflected that requitaments of Standard Practice Procedure SQM-66, Plant Housekeeping, with regard to ensuring clean up of work areas upon completion of maintenance or modification work and with regard to. adequate performance of housekeeping checks were not complied with.
This is a Severity Level IV violation (Supplement I).
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1.
Admission or Denial of Alleged Violation l
TVA admits that the violation occurred as stated.
l 2.
Reason for Violation This portion of the violation occurred due to personnel error in a.
that the jumper was not removed as required by the workplan.
i b.
l This portion of the violation occurred because Sequoyah Standard Practice SQM57 was not interpreted to mean all vendor recommendations had to be followed and incorporated into the initial preventative maintenance (PM) program.
However, it should be noted i
f that the statement in the violation that no PM was established or implemented on these dryers is inaccurate.
Surveillance Instruction (SI)-689 is performed quarterly on the auxiliary control air system and checks system operating parameters which include pressures and dew point.
1
.- This portion of the violation occurred because final cleanup of c.
these areas had not been initiated since the present outage schedule is indeterminate, and additional work activities in these areas could be identified. Modification and maintenance activities had been performed or were ongoing in the cited areas during the inspection period.
3.
Corrective Steps Taken and Results Achieved A maintenance request was issued to visually inspect all unit 2 a.
valves that were functionally tested in accordance with the modifications package to ensure that there were no other occurrences of jumpers not being removed. No similar occurrences were identified.
b.
SQM57 has been revised to clearly address how vendor recommendations are utilized in the development of the PM program. Additionally, the applicable vendor recommendations for the air dryers have been reviewed, and appropriate PM activities have been added to the PM program.
The excess materials were removed, and the areas were cleaned. The c.
NRC inspection team (maintenance reinspection) on site during the period February 24-28 reinspected the areas and indicated in the exit meeting that they were satisfied with the results.
4.
Corrective Steps Taken to Avoid Further Violations An instruction change has been issued to include an inspection to a.
verify correct wiring on the valves before the functional test is performed. This change was incorporated before the unit 1 testing.
In addition, all crews involved with the modifications package have been instructed on the requirements to follow established procedures.
b.
SQM57 has been revised to clearly address vendor recommendations.
General cleanup activities are continuing. Because of the large c.
quantity of modifications that have taken place since shutdown, a comprehensive cleanup and housekeeping inspections will be performed before restart of the respective units.
5.
Date When Full Compliance Will Be Achieved The plant was in full compliance on February 25, 1986.
a.
b.
The plant was in full compliance on February 25, 1986.
The plant was in full compliance on February 25, 1986. However, as c.
stated in 4.c above, a comprehensive cleanup and inspections will be performed before restart of the respective units.