ML20148B556
| ML20148B556 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 01/21/1988 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8801250030 | |
| Download: ML20148B556 (8) | |
Text
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i TENNESSEE VALLEY AUTHORITY CHATTANOOGA, TENNESSEE 374ol SN 157B Lookout Place JAN 211988 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washingtoa, D.C.
20555 Gentlemen:
In the Matter of
)
Docket Nos. 50-327 Tennessee Valley Authority
)
50-328 SEQUOYAH NUCLEAR PLANT (SQN) - NRC INSPECTION REPORT NOS. 50-327/87-66 AND 50-328/87 11YSTEM ALIGNMENT INSPECTION - RESPONSE TO VIOLATIONS Enclosed is our response to itenneth P. Barr's December 21, 1987 letter to S. A. White that transmitted a notice of two violations.
If you have any questions, please telephone M. R. Harding at 615/870-6422.
l Very truly yours.
TENNESSEE V LEY AUTHORITY R. Gridley, 1 rector Nuclear Licensing and Regulatory Affairs l
cc (Enclosure):
Hr. K. P. Barr, Acting Assistant DiRetor for Inspection Programs TVA Projects Division Office of Special Projects U.S. Nuclear Regulatory Commission Region II I
101 Marietta Street, NW, Suite 2900 Atlanta, Geo.gia 30323 Mr. G. G. Zech, Assistant Director for Projects l
TVA Projects Division Office of Special Projects U.S. Nuclear Regulatory Commission Mail Stop 7E23 7920 Norfolk Avenuo Bethesda, Maryland 20814 Sequoyah Resident Insp;ctor
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Sequoyah Nuclear Plant 2000 Igou Ferry Road Soddy Daisy, Tennessee 37379 gn V
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PDR ADOCK O PDR An Equal Opportunity Employer G
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, ]p))((lhhh U.S. Nuclear Regulatory Commission MRH:CBK:RHS:GC cc: (Enclosure):
RIMS, MR 4R 72A-C (Ref: A02 8*/1228 011)
H. L. Abercrombie, 0&PS-4, Sequoyah C. E. Ayers, LP 6N 25D-C J. R. Bynum, LP 6N 3SA-C E. S. Christenbury E11 B33 C-K W. H. Hannum, BR IN 77B-C M.'R. Harding. O&PS-4, Sequoyah N. C. Kazanas. LP 4N 45A-C J. A. Kirkebo, W12 A12 C-K G. R. Mullee, BR SS 168A-C D. R. Nichols, BR SS 100A-C P. J. Polk, Bethesda Licensing Office M. J. Ray, LP 5N 105B-C G. L. Rogers, LP 6N 38A-C S. J. Smith, POB-2, Sequoyah D. L. Williams, W10 B85 C-K l
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1 ENCLOSURE i
RESPONSE TO NRC INSPECTION REPORT NUMBERS 50-327/87-66 AND 50-328/87-66 KENNETH P. BARR'S LETTER TO S. A. WHITE DATED DECEMBER 21, 1987 l
Violation 50-327
-328/87-66-01 "A.
Technical Specification (TS) 6.8.1 requires that precedures recommended i
in Appendix
'A' of Regulatory Guide 1.33. Revision 2 be established, implemented, and maintained.
This includes administrative procedures.
The requirements of TS 6.8.1 are implemented by Administrative Instruction AI-2 titled ' Authorities ar.d Responsibilities for Safe Operation and Shutdown' Administrative Instruction AI-4 titled
' Preparation, Review, Approval and Use of Plant Instructions', and Administrative Instruction AI-30, titled ' Nuclear Plant Method of Operation.'
Operation Section Administrative Letter OSLA-58, titled
' Maintaining Cognizance of Operational Status - Configuration Control',
implements the requirements of AI-2 and AI-30 for maintaining configuration control.
Contrary to the above, prior to October 30, 1987, the licensee failed to adequately establish, implement, and maintain procedures for configuration control as follows:
1.
The licensee failed to adequately specify when configuration control should start in that OSLA-58 requires the unit's lead operator to maintain configuration control records only after the System Operating Instruction (SOI) checklists are completed, but not while the checklists are in progress.
2.
The licensee f ailed to specify in AI-2 or OSLA-58 an appropriate method for deviating from SOI checklists in that deviations to SOI checklists were not considered as procedure changes.
Because of this, the licensee did not use the appropriate criteria or approval level for processing deviations.
3.
The licensee failed to adequately implement the requirements in AI-4 and OSLA-58 for the use of working copies of SOI checklists in that the completed working copy for SOI valve checklist 68.lA indicated the checklist was not properly performed while the final copy did not.
AI-4 requires that information be transferred from the working copy to the final copy after the completion of work.
4.
The licensee f ailed to implement the requirements in OSLA-58 for recording of deviations from SOI checklists in that the designated unit operator was not placing the date next to his initials when deviating an item on the status file copies of checklists as required by OSLA-58.
1 5.
The licensee failed to implement the requirements in 03LA-58 for maintaining configuration control after SOI checklists are completo in that the documented positions in the configuration control system for the four Reactor Cot ; ant Pump Seal Return Flow Control Valves, the Excess Letdown Heat Exchanger Supply Containment Isolation Valve, and the three Boron Injection Tank recirculation valves disagreed with the actual positions.
. 6.
The licensee failed to implement the requirements in OSLA-58 for processing a revision to SOI checklist 63.1d in that the configuration los entries for RHR supply valves 2-FCV-74-1 and 2-FCV-74-2 were cleared when the checklist revision was received without reperforming the portion of the checklist that had been revised. This resulted in the documented positions in the configuration control system being in disagreement with the actual positions.
This is a Severity Level IV violation (Supplement I)."
Admission or Denial of The Violation TVA admits the violation and all examples stated.
Reason For The Violation An inadequate instruction letter (OSLA-58), coupled with a lack of management attention to the system alignment and configuration control program, was the cause of this violation.
Corrective Steps That Have Been Taken i
Corrective actions taken with respect to this violation include the conversion i
of OSLA-58 to AI-58.
This conversion included addressing the prncedural i
problem areas identified in this violation. Additionally, AI-55 is reviewed
{
and approved by PORC.
Management personnel were assigned to directly supervise the system alignmant program, and training was given to all personnel involved in this program regarding the importance of following procedures. OSLA-107 was performed on all AI-58 Appendix A checklists before their performance.
Corrective Steps That Will Be Taken To Avoid Further Violations The corrective actions taken with respect to this violation should be sufficient to prevent further violations of this nature.
Date When Full Compliance Will Be Achieved All corrective actions referenced in this response have been completed.
Specific corrective actions for the examples of the violation are given below.
Example 1 "The licensee failed to adequately specify when configuration control should start in that OSLA-58 requires the unit's lead operator to maintain ccnfiguration control records only af ter the System operating Instruction (SOI) checklists are completed, but not while the checklists are in progress."
. Corrective Steps That Have Been Taken OSLA-58 was converted to AI-58; AI-58, revision 1, section 3.2.f. specifically requires configuration control to be maintained throughout the performance of an SOI checklist. Additionally, involved permanent and temporary SQN Operations Group employees have received training on AI-58.
This training was conducted before employees used the revised procedure.
Example 2 "The licensee failed to specify in AI-2 or OSLA-58 an appropriate method for deviating from SOI checklists in that deviations to SOI checklists were not considered as procedure changes.
Because of this, the licensee did not use the appropriate criteria or approval level for processing deviations."
Corrective Steps That Have Been Taken AI-58 addresses checklist deviations in section 3.5.
The method of deviation meets technical specifications 6.8.3 and 6.5.1A.la approval and implementation criteria. Deviations now receive the same level of review as a temporary procedure change.
Involved Operationc Group employees have been trained on the deviation process.
Example 3 "The licensee failed to adequately implement the requirements in AI-4 and OSLA-58 for the use of working copies of SOI checklists in that the completed working copy for SOI valve checklist 68.1A indicated the checklist was not properly performed while the final copy did not.
AI-4 requires that information be transferred from the working copy to the final copy after the completion of work."
Corrective Steps That Have Been Taken An assistant shift supervisor was assigned to directly supervise this activity, and involved employees were retrained on procedural compliance.
Example 4 "The licensee failed to implement the requirements in OSLA-58 for recording of deviations from SOI checklists in that the designated unit operator was not placing the date next to his initials when deviating an item on the status file copies of checklists as required by OSLA-58."
Corrective Steps That Have Been Taken Employees involved were counselled on the importance of adhering to procedures. Additionally, new designated unit operators and a shift management member were selected to supervise system and valve alignment verification reperformance.
. Example S "The licensee failed to implement the requirements in OSLA-58 for maintaining configuration control nf ter SOI checklists are complete in that the documented positions in the configuration control system for the four Reactor Coolant pump Seal Return Flow Control Valves, the Excess Lotdown Heat Exchanger Supply Containment Irolation Valvo, and the three Boron Injection Tank recirculation valves disagreed with the actual positions."
Corrective Steps That Have Been Taken Management personnel were assigned to directly supervise the system alignment activities, and involved employees were retrained regarding the importance of following procedures. Additionally, the issuance of AI-58, which addresses the identified program deficiencies, should aid in proventing further violations of this nature.
Example 6 "The licensee failed to implement the requirements in OSLA-58 for processing a revision to SOI checklist 63.ld in that the configuration log entries for Ri!R supply valves 2-FCV-74-1 and 2-FCV-74-2 were cleared when the checklist revision was received without reperforming the portion of the checklist that had been revised.
This resulted in the documented positions in the configuration conteci system teing in disagreement with the actual positions."
Corrective Steps That Have Feen Taken Management personnel were assigned to directly "upervisa the system alignment activities, and involved employees were retrained regarding the importance of i
following procedures.
Additionally, the issuance of AI-58, which addresses the identified program deficiencies, should aid in preventing further violations of this nature.
Violation 50-327
-328/87-66-02 "B.
Technical Specification 6.8.1 requires that procedures recommended in Appendix
'A' of Regulatory Guide 1.33. Revision 2, be established, implemented, and maintained.
Appendix A of Regulatory Guide 1.33 requires procedures for startup, operation, and shutdown of safety related PWR sy.?tems.
Contrary to the above, prior to October 30, 1987, the licensco failed to provide an adequate System Operating Instructirn (SOI-63) for the Emergency Core Cooling System as follows:"
a
. Violation 50-327. -328/87-66-02 (cont'd)
"1. The licensee failed to provide for the initial positioning of all system 63 valves and blank flanges in that SOI-63 valve checklists do not specify or verify the positions of the root valves to RWST level transmitters 2-63-46, 2-63-49, 2-63-50, 2-63-51, 2-63-52, and 2-63-53; the root valve to pressure instrument 2-63-74; and the flanges downstream of valves 2-63-599 and 2-74-549.
2.
The licensee failed to provide for the initial positioning of all system 63 electrical equipment in that SOI power availability checklist 63.1d does not specify the positions for the power supply breakers to control valves 2-HIC-74-16, 2-HIC-74-32, and 2-HIC-74-28.
3.
The lleensee failed to provide adequate instructions to ensure specified fuses were installed for system 63 electrical equipment in that the locations for the penetration and penetration control fuses for 2-FCV-63-17 on SOI power availability checklist 63.1A-8 were not adequately specified on the checklist or reference print.
This is a Severity Level IV violation (Supplement I)."
Admission or Denial of The violation TVA admits the violation and the three examples stated.
Reason F:r The Violation Example 1 of this violation occurred because an OSLA-107, Appendix B validation of the SOI-63 chacklist had not been completed before this inspection.
liad this verification been done, the referenced discrepancies should have been identified.
With respect to the refueling water storage tank (RWST) level transmitters, it should be mentioned that Surveillance Instruction (SI) 98.5, and Instrument Maintenance Instruction 63, double verifles their root valve position when placing them in sovvice.
Additionally, SI-2 reluires RWST lovele to be checked on every shif t in all mod s.
Extensive tr.odifications were performed on the plant before valve alignment.
This effort caused the plant to lead or lag the prints and procedures in some c r.s e s. The OSLA-107 process was designed L.
identify and correct these discrepancies.
Exarapie 2 occurred because the OSLA-107 validation had not been completed for the S01-63 checklist.
Historically, employees have assumed tha> a breaker being listed on a power availability checklist indicated that it was to be closed unless otherwise specified.
Example 3 occurred because there was ma.ior modifications work done to install the fuses referenced in the example.
Although Operations reviewed the workplans, they did not review the many field change requests (FCRs) written against the workplans.
This resulted in these fuses not being adequately specified on the checklist or referenced print.
~6-i Corrective Steps Tha_t Have Been Taken i
OSLA-107 has been performed on all AI-58, Appendix A, checklists before their performance. This process provided an initial verification of the checklists and was also continued during the system lineups.
In order to prevent plant modifications from adversely affecting the SOI checklists, the procedures revision project reviews all workplans and associated FCRs for their effect on the SOIs.
Modifications Branch ensures that all workplans have a signoff block for the operationa procedure revision project and for drawing update.
Corrective Steps That Will Be Taken To Avold Further Violations The OSLA-107 process is ongoing and will ccatinue to aid in documenting the identification and resolution of SOI d8.screpancies.
Addit}onally, a phase 2 procedures enhancement program is to be implemented to ensure human factors, consistency, and clarity in all SOIs.
Date When Full Compliance Will Be Achieved i
The procedure enhancement program will be implemented in a timely manner as specified in the Nuclear Performance Plan.
All other corrective actions referenced in this response have been completed.
NRC expressed concern that TVA would inillate and carry out programs as important as the system alignment program without having previously addressed the problem areas identifitd by this inspection report.
Because of management inat tention to the system aligr. ment program. OSLA-107 walkdowns were r.ot completed. The purpose of OSLA-107 is to provide a method for technical
<: valuation and verification of SOIs.
This instruction provides for a tabletop technical verification (Appendix A) of the instruction and a physical walkdown verification (Appendix B) of checklists, which includes a comparison of verification to latest "as constructed" drawings, and a review by an accredited unit operator to ensuro checklist accuracy. IIad the OSLA-107 walkdowns been completed, the deficiencier identified by this inspection should have been detected.
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