ML20150A673

Notice of Violation from Insp on 880104-08 & 19.Violations Noted:Failure to Adequately Establish,Implement & Maintain Procedures for Configuration Control & Identify & Correct Sys Operating Instruction Checklist Deficiencies

ML20150A673
Person / Time
Site:	Sequoyah
Issue date:	02/26/1988
From:	Barr K NRC OFFICE OF SPECIAL PROJECTS
To:
Shared Package
ML20150A667	List: ML20150A664 ML20150A673 ML20150A679
References
50-327-88-06, 50-327-88-6, 50-328-88-06, 50-328-88-6, NUDOCS 8803150378
Download: ML20150A673 (3)

Text

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ENCLOSURE 1 NOTICE OF VIOLATION Tennessee Valley Authority Docket Ncs. 50-327, 50-328 Sequoyah License Nos. DPR-77, DPR-79 During the Nuclear Regulatory Commission (NRC) inspection conducted on January 4-8 and 19,1988, violations of NRC requirements were identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1988), the violations are listed below:

5 A. Technical Specification (TS) 6.8.1 requires that procedures recommended in Appendix "A" of Regulatory Guide 1.33, Revision 2, be established, implemented, ano maintained. This includes administrative procedures.

The requirements of TS 6.8.1 are implemented by Administrative Instruction AI-37 titled "Independent Verification" and Administrative Instruction AI-58 titled "Maintaining Cognizance of Operatienal Status - Configuration Status Control". .

Contrary to the above, prior to January 4,1988, the licensee failed to adequately establish, implement, and maintain procedures for configuration control as follows:

1. The licensee failed to specify the minimum qualification level for individuals performing independent verification of SOI checklists as required by AI-37. This resulted in a failure to perform and document adequate training for all individuals performing SOI checklist verifications.

2. The licensee failed to implement the requirements in AI-58 for maintaining configuration control af ter S0I checklist completion, in that the documented positions in the configuration control system for instrument root valve 1-268A, and the breakers for post accident sampling valves on 120 V vital instrument power boards 2-III and 2-IV (breaker 17 on each board) disagreed with the actual positions.

This is a Severity Level IV violation (Supplement I).

B. 10 CFR 50, Appendix B, Criterion XVI states that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.

The Nuclear Quality Assurance Manual (NQAM), the accepted QA Program (TCA-TR75-1A), and Administrative Instruction AI-12 titled "Adverse Conditions and Corrective Actions" implements these requirements.

8803150378 880301 7 PDR ADOCK 050 0

Tennessee Valley Authority 2 Docket Nos. 50-327, 50-328 Sequoyah License Nos. DPR-77, DPR-79 Contrary to the above, prior to January 4,1988, the licensee failed to adequately identi fy and correct SOI checklist deficiencies in that numerous SOI checklists were found to have significant deficiencies after the licensee had completed corrective action for similar deficiencies and had restarted the system alignment program using those checklists. As a result, the status of numerous pieces of equipment had to be reverified to ensure that their positions were adequate for mode change.

This is a Severity Level IV violation (Suppit: ment I).

C. 10 CFR 50, Appendix B, Criterion V as implemented by the Nuclear Quality Assurance Manual (NQAM), Part I, Section 2.5, Revision 1, states that "Activities affecting' Quality shall be prescribed by documented instructions, procedures, or drawings and shall be accomplished in accordance with thesesinstructions, procedures, or drawings."

Contrary to the above, prior to January 6,1988, the licensee failed to establish or implement instructions, procedures, or drawings that would have prevented the storage of loose conductive material within safety related electrical boards. Specifically, loose spare fuses were found stored within 480 Volt safety related diesel generator auxiliary board 2Al-A which could have rendered the panel inoperable during a seismic event. Subsequent electrical board inspections by the licensee identified numerous additional significant examples of loose conductive material storage within safety-related electrical boards.

This is a severi'y level IV violation (Supplement I).

Pursuant to the provisions of 10 CFR 2.201, Tennessee Valley Authority is l hereby required to submit a written statement or explanation to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555, with a copy to the Regional Administrator, Region II, and a copy to the NRC Resident Inspector, Sequoyah, within 30 days of the date of the letter transmitting this Notice. This reply should be clearly marked as a "Reply to a Notice of Violation" and should include [for each violation]: (1) admission or denial of the violatin, (2) the reason for the violation if admitted, (3) the I

corrective steps which have been taken and the results achieved, (4) the

( corrective steps which will be taken to avoid further violations, and (5) the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending the response time. If an adequate a

.4 Tennessee Valley Authority 3 Docket Nos. 50-327, 50-328 Sequoyah License Nos. DPR-77, OPR-79  ;

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reply is not received within the time specified in this Notice, an order may be issued to show cause why the license should not be modified, suspended, or revoked or why such other action as may be proper should not be taken.

I FOR THE NUCLEAR REGULATORY COMMISSION k c'  :

Kenneth P. Barr, Acting Assistant

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Director for Inspection Programs TVA Projects Division Office of Special Projects Dated at Atlanta, Georgia 5 this/f' day of February 1988 O