ML20151E778
| ML20151E778 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 07/14/1988 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8807260205 | |
| Download: ML20151E778 (5) | |
Text
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TENNESSEE VALLEY AUTHORITY CHATTANOOGA, TENNESSEE 374o1 SN 157B Lookout Place JUL 141988 U.S. Nuclear Regulatory Commission ATTN Document Control Desk Washington, D.C.
20555 centlemen:
In the Matter of
)
Dockot Nos. 50-327 Tennessee Valloy Authority
)
50-328 SEQUOYAll NUCLEAR PLANT (SQN) UNITS 1 AND 2 - NRC INSPECTION REPORT NOS. 50-327/88-26 AND 50-328/88 RESPONSE TO NOTICE OF VIOLATION Enclosed is TVA's responso to F. R. McCoy's lottor to S. A. Whito dated June 17, 1988, that. transmitted the subject notico of violation.
P,nclosure 1 provides TVA's response to the nollco of vlolation. Enclosuro 2 provides TVA's response to the untosolved item (URI) that was also requested in the subject report.
I Please direct questions concerning this issue to M. A. Cooper at l
(615) 870-6549.
Very truly yours, TE E E'
LEY AUTit0RITY e
I ridley, D ector Nuclear Licensing and Regulatory Affairs Enc?:%ures cc g uiclosures):
Ms. S. C. Black, Assistant Dicoctor for Projects TVA Projects Division U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Plko g
Rockville, Maryland 20852 g
Mr. F. R. McCoy, Assistant Director oc for Inspection Programs Cg (i g
TVA Projects Division U.S. Nuclear Regulatory Commission
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Region II
@g 101 Mariotta Street, NW, Suito 2900 l
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q Atlanta, coorgl.a 30323 k
@g Sequoyah Resident Inspector (D a. o Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy Daisy, Tennesseo 37379 An Equal Opportunity Employer i
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e FNCLOSURE 1 RESPONSE TO NRC INSPECTION REPORT NOS. 50-327/88-26 AND 50-328/88-26 F. R. McCOY'S LEriER TO S. A. WHITE DATED JUNE 17, 1988 Violation 50-327. -328/88-2(-01 "Technical Specification (TS) 6.8.1 requires that procedures recommended in Appendix ' A' of Regulatory Guide 1.33, Revision 2, February 1978, be established, implemented, and maintained, including administrative procedures.
The requirements of TS 6.8.1 are implemented in part by Administrative Instruction AI-37, Independent Verification, Administrative Instruction AI-58, Maintaining Cognizance of Operational Status -
Configuration Status Control, and General Operating Instruction GOI-6, Apparatus Operation.
Contrary to the above, the licensco failed to implement procedural requirements in the following instances:
1)
The licensee failed to implement the requirements in AI-58 for maintaining configuration control after SOI checklist completion, in that on April 30, 1988, valve 2-62-392A was determined to be out of its normal system alignment position and was not configured in the configuration log as required.
2)
The licensee failed to implement the requirements in AI-58 for maintaining configuration control after SOI checklist completion, in that on May 1, 1988, valves 2-87-543 and 2-87-542 were determined to be out of their normal system alignment and were not configured in the configueation log as required.
3)
The lleensee failed to implement the requirements of GOI-6, AI-37, and AI-58 for proper performanca of SOI checklists, in that on the May 1, 1988 performance of SOI checklist 72.1, two individuals signed that valve 2-72-504 was in the locked closed position, when in fact the valve was not locked.
4)
A licenuce QA audit conducted on May 4, 1988, found chat the CST B supply to the AFW, Valve 0-2-505, was shut rather than locked open as required by the SGI checklist and indicated in the system statuc log.
5)
The licensee failed to implement the requirement of AI-58 to hold open, rather than deviato SOI checklists for items which affect operability, i
procedure intent, or mode ch&nge, in that the April 25 performance of SOI checklist 68.1A had been signed off as complete when, in fact, items had been deviated which affected the operability of mode 4 equipment.
This is a Severity Level IV Violation (Supplement I)"
Admission or Denial of the A11oned Violation TVA admits the violation.
s ?
Reason for the violation The reason for the first four examples of this violation can be attributed to Operations falling to maintain cognizance of operational status and configuration status control and falling to follow procedures.
These are examples of configuration control problems.
l The reason for the fifth example of the violation concerning an intentional deviation from procedure is the fact that System Operating Instruction (SOI) checklist 68.1 is a preccquisito for General Operating Instruction (GUI) 1.
The SOI checklist could not legitimately be signed off because a few deviations, which affected modo change, were still outstanding. However, operations personnel, realizing these deviacions were on equipment having specific steps further into the GOI (before mode chango), signed the 301 checklist as completo assuming the deviations would be resolved and cleared later in the GOI.
Corrective Steps That Havo Been Taken and the Results Achieved Examplo 1 The Maintenance / Engineering sections have been instructed as to who may and who may not manipulate valves. Additionally, Administrative Instruction (AI) 3, "Clearance Procedure," has been revised to more clearly define the conditions when the clearanco procedure requirements can be relaxed to more expeditiously proceed with work.
Examplo 2 T1.o valves Imvo been realigned in the proper sequence, and because the reason for misalignment was never discovered, no further action is ar.ticipatoi in this apparently isolated incidence.
3 Exampin 3 Example 3 is a licensee-identified deviation fem. pecceduros. The Plant I
Oparations Review Staff (PORS) performed a root cause analysis in accordance with Sequoyah Standard Practice SQA-186, "Root Cause Assessment For Adverso l
Actions / Conditions." Their findings indicate that the roet cause was l
personnel error by failing to follow procedures. The recommended correctivo action was to (1) rework all the survolllance instructions (sis) and SOIs that the individuals performed or assisted in performing during thole shif t; (2) review the performance of the particular SI (SI-186) for any deficiencies l
(none found); (3) perform another SI-186 before mode 4; and (4) distribute lessons learned information to operating crews.
All the correctivo actiono have been accomplished.
Examplo 4 Example 4 is a licensec-identified deviation f rom precedures. Deviations from checklists are to be recorded in the configuration log in accordance with AI-58, "Haintaining Cognizance of Operation Status - Configuration Status Control." In this instanca. the deviation was tocorded in the unit operator's los but not in the conf ? e cation log.
AI-58 has been revised requiring Appendix B, which tracks the deviated item, to be laitiated before any configuration changes to systems listed in AI-58 or any system inside the radiologically conttolled area (RCA).
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Example 5 Example 5 is an example of a deviated checklist being accepted and signed off, therefore violating procedure AI-58.
Operations personnel recognized that the deviations were on equipment that had specific steps in the GOI-1; therefore, the 301-68 checklist was signed off, thus permitting entry into GOI-1.
No specific corrective action was required before mode 4 entry because the inspector determined that the operators had maintained cognizance and control of equipment status. The supervisor involved was counseled on the importance of configuration control and following procedures.
Corrective Steps That Will Be Taken to Avold Further Violations The revision of AI-58 should be sufficient to prevent further violations relative to deviated checklists and configuration control problems.
Example 1 No further action is required.
Example 2 No further action is required.
Example 3 The results of the investigation into this issue indicate that this incident was an isolated case of personnel not following procedures. Therm is no further action to be taken.
Example 4 AI-58 has been reviced to require the Shift Operations Supervisor (S03) er the Assistant Shlft Operations Supervisor (ASOS) to approve removal from normal alignment any item in systems maintained in modes 1, 2, 3, or 4.
Before tranipulation of any valves, Appendix B, "Configuration File Shoot," shall be filled out; and the ASOS shall determine if a coafiguration log entry is required if an approved plant instruction is not ocing used.
Exagpie 5 Employees have been reminded that procedures shall not bu intentionally violated even though it is known the violation will not affect the safe operaticu of the plant. This was cunsidered an isolated incident, and no further corrective action is anticipated.
Date Whea Full Compliance Will Be Achieved Examples 1. 2 3, 4. and 5 SQN is in full compliance.
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o ENCLOSURE 2 RESPONSE TO NRC INSPECTION REPORT NOS. 50-327/89-26 AND 50-328/88-26 F. R. McC0Y'S LETTER TO S. A. WHITE DATED JUNE 17, 1988 URI 50-32 7. -328/88-26-02 "3.
Control Room Observation (71715)
A.
Control Room Activities Including conduct of Operations "The inspector observed at least one instance where, with the Unit in Mode 5, a Unit 2 operator momentarily left the horseshoe area of the control room to go to one of the back panels, leaving no licensed operator in the horseshoe.
Al-30, "Nuclear Plant Conduct of Operation," is the implementing procedu.e for technical specification (TS) 6.2.2 that prescribes conditions during which the unit controls will be manned by a licensed operator.
This procedure (AI-30) defines specifically the arcan to which the unit operators are restricted during all modes of normal plant operations. AI-30 was revised May 5, 1988, to include areas of entry in an emergency situation affecting safety of operations. Before the revision, the operators were allowed freedom in modes 5 and 6 to leave the horseshoe area to observe the back panels. This did not violate the TS; however, the revision to AI-30 now limits the exiting of the horseshoe to emargencies and then only to the areas described in the procedure. SQN believes that the question of permissible entry into areas by the unit operator in all normal operating modes and in cases of emergency is now clearly defined and that SQN is in full compliance with its TSs.