ML20151Q261
| ML20151Q261 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 04/20/1988 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8804260385 | |
| Download: ML20151Q261 (9) | |
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TENNESSEE VALLEY AUTHORITY CHATTANOOGA. TENNESSEE 37401 SN 1578 Lookout Place
/(Pil 201988 U.S. Nuclear Regulatory Commiss:an ATTN:
Document Control Desk Hashington, 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. 50-327/87-30 AND 50-328/87 RESPONSE TO NOTICE OF VIOLATION Enclosed is my response to S. D. Rfchardson's letter to S. A. White dated March 14, 1988, that transmitted Notice of Violation 50-327 and -328/87-30-01.
If you have any questions, please telephone M. R. Harding at (615) 870-6422.
Very truly yours, TENNES E Y AUTHORITY R. Gridley, Di ector Nuclear Licen ing and Regulatory Affairs Enclosures cc (Enclosures):
Mr. K. P. Barr, Acting Assistant Director for Inspection Programs TVA Projects Division U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Mr. G. G. Zech, Assistant Director for Projects TVA Projects Division U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 i
Sequoyah Resident Inspector Sequcyah Nuclear Plant 2600 Igou Ferry Road Soddy Daisy, Tennessee 37379
'i 8804260385 880420 DR ADOCK 0500 7
- .n Equal opportunity Employer i
Enclosure Violation 50-327, -328/87-30-01 "a) Technical Specification 6.8.1 requires that written procedures be established, implemented, and maintained covering safety-related activities addressed in Appendix 'A' of Regulatory Guide 1.33, Revision 2, February 1978.
Administrative Instruction (AI)-30, ' Nuclear Plant Method of Operation,'
Section 2.2, requires that when a condition exists that could adversely affect personnel or equipment safety while an instruction is being followed, and sufficient time is available, normal change and revision methods of AI-4,
' Preparation, Review, Approval and Use of Plant Instructions,' are to be used.
' Contrary to the above, on February 1, 1987, the unit operator did not use the formal change process of AI-4 to revise SI-166.3.
Instead, a system realignment was improvised, without written or formally. approved instructions.
b) 051.A 58, 'Haintaining Cognizance of Onerational Status,' Section E.1.,
requires that all outages or deviations associated with listed systems be logged in the configuration log.
Entries are to be made regardless of length of outage time.
Contrary to the above, 1) on February 1, 1987, five (5) valves were shut in an attempt to isolate the SG maintenance area from the RHST without entry in the configuration log as required, and 2) April 29, 1987 vent valve 1-HCV-68-594 was opened, and this deviation from the norn;al valve alignment was not entered in the configuration log.
c) SI-102 M/M, ' Diesel Generator Monthly Mechanical Inspection,' requires that the air start system manual isolation valves be closed during the performance of steps 6.2 - 6.16 for personnel safety and SI-166.36, ' Diesel Starting Air Valve Test,' states that no more than one manual isolation valve may be closed at any one time when installing pressure gauges.
Contrary to the above, on May 28, 1987, SI-102 M/M and SI-166.36 were run concurrently and all four Emergency Diesel Generator (EDG) starting air manual isolation valves were closed simultaneously for the installation of SIJ-166.36 pressure gauges.
d) AI-3, ' Clearance Procedures,' Section 3.2.1.1, states that a Hold Order clearance (red tag) is the means to ensure lines or equipment remain l
deenergized, depressurized, and isolated so work can be safely performed and l
equipment protected.
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AI-3, Section 3.1.8, requires that a caution tag identify the abnormal j
conditions and may include special instructions to the operator.
AI-3, Section 5.1.4 and 5.3.3, require that the clearance be issued to the person requesting the clearance and responsible for the work.
l Contrary to the above, the clearance activities associated with the steam generator work discussed in items a) and b) above were not performed in accordance with AI-3.
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Enclosure l
Violation 50-327. -328/87-30-01 "a) Technical Specification 6.8.1 requires that written procedures be established, implemented, and maintained covering safety-related activities addressedinAppend}x'A'ofRegulatcryGuide1.33, Revision 2, February 1978.
Administrative Instruction (AI)-30, ' Nuclear Plant Method of Operation,'
Section 2.2, requires that when a condition exists that could adverrely affect personnel or equipment safety while an instruction is being followed, and sufficient time is available, normal change and revision methods of AI-4,
' Preparation, Review, Approval and Use of Plant Instructions,' are to be used.
Contrary to the above, on February 1, 1987, the unit operator did not use the formal change process of AI-4 to revise SI-166.3.
Instead, a system realignment was improvised, without written or formally approved instructions.
b) OSLA 58, 'Haintaining Cognizance of Operational Status,' Section E.1.,
requires that all outages or deviations associated with listed systems be logged in the configuration log.
Entries are to be made regardless of length of outage time.
Contrary to the above, 1) on February 1, 1987, five (5) valves were shut in an attempt to isolate the S0 maintenance area from the RHST without entry in the configuration log as required, and 2) April 29, 1987 vent valve 1-HCV-68-594 was opened, and this deviation from the normal valve alignment was not entered in the configuration log.
c) SI-102 M/M, ' Diesel Generator Monthly Mechanical Inspection,' requires that the air start system manual isolation valves be closed during the performance of steps 6.2 - 6.16 for personnel safety and SI-166.36, ' Diesel Starting Air Valve Test,' states that no more than one manual isolation valve may be closed at any one time when installing pressure gauges.
t Contrary to the above, on May 28, 1987, SI-102 M/M and SI-166.36 were run concurrently and all four Emergency Diesel Generator (EDG) starting air manual isolation valves were closed simultaneously for the installation of SI-166.36 I
pressure gauges.
d) AI-3, ' Clearance Procedures,' Section 5.2.1.1, states that a Hold Order clearance (red tag) is the means to ensure lines or equipment remain deenergized, depressurized, and isolated so work can be safely performed and equipment protected.
AI-3, Section 3.1.8, requires that a caution tag identify the abnormal conditions and may include special instructions to the operator.
l AI-3, Section 5.1.4 and 5.3.3, require that the clearance be issued to the I
perso1 requesting the clearance and responsible for the work.
Contrary to the above, the clearance activities associated with the steam generator work dirussed in items a) and b) above were not performed in accordance with AI-3.
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- m e), Surveillance ~ Ins'truction (SI)-45.1, ' Essential Raw Cooling Water Pumps,'
requires the licensee to maintain bearing cooling water flow between 5 gpm and 13.5 gpm.
Contrary to the above, on December 2, 1986, December 14, 1986, and May P.2, 1987, this procedure was performed without appropriate instrumentation to verify this flow rate. Consequently, recent and past performances of SI-45.1 have not included a quantithtive check of the bearing cooling water flow as required.
f) SI-46.3, ' Component Cooling Water Pump 2A-A,' requires that if the unit is on Residual Heat Removal (RHR) cooling, the heat exchanger in use for cooling is not to be used for the pump test.
Contrary to the above, on May 27, 1987, SI-46.3 was entered and aligned using the !A' RHR heat exchanger when the 'A' train of RHR was in service for decay heat removal.
This is a Severity Level IV violation (Supplement I)."
Admission or Denial of the Alleged Violation (example a)
TVA admits the violation.
Reason for the Violation SI-166.3 is used to full stroke valves during cold shutdown.
The procedure was adequate for normal cold shutdown conditions but was not adequate for the special conditions with the reactor coolant system (RCS) depressurized and drained and the steam generators open.
The operator recognized the procedure was not written to address the specific system conditions and attempted to supplement the procedure alignment through additional valve alignments noted in the operator's log.
This represented a failure to follow procedures AI-30, AI-4, and by not revising SI-166, a failure to establish adequate procedures.
The root cause is inattention to detail.
Corrective Steps That Have Been Taken SI-166 was revised to provide the correct alignment for stroking of valve FCV-63-1 with the system in the special configuration.
The operator and assistant shift supervisor involved in the event have been discip1'>ned.
Procedural adherence training that emphasized the requirements and reasons for procedural compliance has been provided to over 900 plant employees.
Operations "Lessons learned" sessions were conducted for Operations personnel following the event that included discussion of and emphasis on the requirements for establishing, following, and revising procedures.
Increased management attention has been directed toward procedural compliance, both onsite and at the corporate level, i
Corrective Steps That Hill Be Taken to Avoid Further Violations There is no further corrective action required.
Date,_When Full Compliance Hill Be Achieved TVA was in full compliance on September 2, 1987, when SI-166 was revised.
Admission or Denial of the Alleged Violation (example b)
TVA admits the violation.
Reason for the Violation The operator involved in this event noted the five valves that were manipulated outside the constraints of the procedure in the operator log, but did not enter the valves into the configuration log as required by Operations Section Letters Administrative (OSLA) 58.
This example resulted from personal interpretation of what short-term actions needed to be entered into the configuration log versus the operator log.
The root cause was an inadequate implementation procedure and confusion on requirements defined by the procedures.
The pressurizer vent valve was not maintained in the normal closed position at the time of the event, and the off-normal position was not indicated in the configuration control log. Why the valve was placed in this position could not be ascertained.
Extensive work in containment was going on during the time before this event. Configuration of the pressurizer vent valve was not maintained.
Corrective Steps That Have Been Taken The importance of configuration control and failure to comply with procedures regarding this event were discussed during the Operations Lessons Learned sessions.
Feedback was received during these sessions concerning the configuration control process and implementing procedures. This feedback resulted in the revision of OSLA-58 to provide specific guidance regaroing the configuration control log. OSLA-58 was subsequently deleted and replaced by AI-58, "Maintenance Cognizance of Operation Status - Configuration Status Control," to provide more positive control of plant configuration.
In addition to the above, a unit operator and two auxiliary unit opera' ors (AU0s) were assigned to each unit to reverify configuration status and review and correct status files and the configuration log.
Corrective Steps That Will Be Taken to Avoid Further Violations There is no further corrective action required.
Date When Full Compliance Will Be Achieved l
TVA is in full compliance.
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Admission or Dental of the Alleged Violation (example c)
TVA admits the violation occurred as stated subject to the following clarification.
Reason for the Violation The test personnel responsible for performing'the air start valve test believed that because the EDG was inoperable, isolating all valves at the same time was acceptable, even though the procedure required otherwise.
This was the result of lack of attentic.) to detail in adhering to procedures.
The -
concurrent performance of the t.fo sis was not correctly coordinated.
- The, Mechanical Maintenance personnel signed off in SI-102 for isolation of the air start valves (whe'n_ isolated by the AUO for SI-166.36) instead of the AUO; therefore, when the AVO ms required to unisolate the valves upon reaching the applicable step in SI-166.36, he did not immediately realize that this would violate alignment required for conduct of SI-102, which was still in progress e
(i.e., SI-102 still required the air start system to be isolated).
The lack of coordination for conduct of interfacing / overlapping tests was the root cause for this event.
Corrective Steps That Have Been Taken The test personnel involved in performance of SI-166.36 were counseled in the requirements for adhering to the procefure.
SI-102 was revised to require AU0 signoff for isolation of the air start system.
A aew administrative instruction, AI-47, "Conduct of Testing," was established to resolve various probiems identified during this event and other problems related to testing and to consolidate all requirement: from existing plant procedures into a single instruction.
This instruction requires an overall test director to be assigned for each test and an overall test director to be assigned when several interfacing tests are being conducted concurrently.
This overall test director would be responsible for ensuring the tests are compatible for concurrent performance and that any special consideration for coordination during performance is achieved. AI-47 further defines the specific responsibilities'of the test director and performers, defines requirements regarding compliance with precautions, and provides guidance in handling of problems identified during testing. All personnel conducting testing have been trained in the requirements of this new instruction.
Corrective Step 1 That Will Be Taken to Avoid Further Violations There is no further corrective action required.
Date When Full Compliance Will Be Achieved TVA is in full compliance.
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.l' Admission or Dental of the Alleged Violation (example d)
TVA admits the violation.
Reason for the Violation The root cause of this example was the previous plant philosophy regarding use of a caution order on the RHR flow contrni valve from the refueling water storage tank (RHST) (FCV-63-1).
This was based on a specific licensee concern to ensure the capability for rapid RCS makeup. A clearance properly implemented using a caution order w&s considered to provide adequate personnel protection, and for the steam generator (S/G) maintenance activity, and at the same time afforded better capability for rapid RCS makeup than the use of a hold order.
The'AI-3 excerpt, "... A hold order clearance (red tag) 1s the means to ensure..." referenced in the violation was not considered to identify the only method to ensure personnel protection, rather the praferred tethod given all consider:tions. The decision to use & caution order for valve FCV-63-1 was a conscious decision in accordance with the management philo:ophy thai prevailed during the timeframe of the S/G event.
This decision was further documented by the requirements that were in Maintenance Instruction (MI) 3.1 to use a caution order.
Implementation of the caution order at the time of the event did not occur in accordance with procedural requirement: of AI-3 in that only the assistant shift supervisor's approval was required to lift the caution and open the valve. and nc specific precautions were given associated with respect to personnel working in the S/G.
Corrective. Steps That Ha'fe B_een Taken The incident was discussed fully with the personnel involved.
Management has determined the use of a caution order is not appropriate for the protection and safety of personnel. AI-3 has been revised to state, "A caution order will not be used as a clearance boundary or in-plant for p otection and safety of personnel."
MI-3.1 has been revised to require a hold order be placed on valve FCV-63-1 when S/G is open.
MI-3.1 also requires comreuaications between Operations and personnel performing S/G work to be established before each entry or half entry into the S/G.
The consequences of the improper implementation of the caution order were pr3sented to Operations personnel during "Lessons Learned" sacsions.
Operations personnel were instructed to issue hold orders fc' 'n-plant protectinn and safety of personr-1.
Site personnel have attended procedural adherence training, and management reiterated its commitment to procedural compliance.
Correctiva Steps That Will Be Taken to Avoid Further Violation There is no further corrective action required.
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, d Date When Full Compliance Will Be Achieved TVA is in full compliance.
Admission or Denial of the Alleged Violation (example e)
TVA admits the violation.
Reason for the Violation The precaution to verify cooling flow of 5 to 13.5 gallons per minute to the essential raw cooling water (ERCW) pump bearing coolers could not be specifically verified because of a lack of a flow measuring device. A stream of flow could be physically observed to a drain but could not be quantifit.d through instrumented measurement.
Inability to comply with the precaution was not previously identified because of an apparent unclear responsibility.for performance of various sections of SI-45.1.
This test is a pump test required by Section XI.
The Mechanical Test Section has responsibility for the test program and procedures, Operations had responsibility for performing the particular test, and Mechanical Test was responsible for obtaining data of the pump vibrations for the test.
It was unclear which section had the overall responsibility for conduct of the test, and therefore each section assumed the other was responsible for verifying the precaution. Additionally, the lack of clear guidance in regard to compliance with precautions contributed to this problem.
Corrective Steps That Have Been Taken SI-45.1 was revised to verify flow, not a specific value. Measurement of a specific value is not necessary because the flow is from a fixed resistance sy: tem, and any inadequacy in cooling flow would be detected through bearing temperature measurement.
Clear responsibility for overall conduct of this and other Section XI pump tests was assigned to the Mechanical Test Section, with Operations providing support.
A new administrative instruction, AI-47, "Conduct of Testing," was established to resolve various problems identified during this event and other problems related to testing and to consolida'.e all equirements from existing plant procedures into a single instructic-This instruction requires an overall test director to be assigned for each test, defines the requirements regarding compliance with precautions, and provides guidance in handling of problems identified during testing. All personnel conducting testing have been trained in the requiremants of the new instruction.
Corrective Steps That Will Be Taken to Avoid Further Violations There is no further currective action required.
Date WJjen Full Compliance Will Be Achieved TVA is in full compliance.
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- Admission or Denial of the Alleged Violation (example f)
TVA admits the violation.
Reason for the Violation The operator involved in this event evaluated the precaution for the condition of the plant and determined that compliance was not necessary because of a low decay heat load resulting from the extended plant shutdown.
Lack of clarity in requirements for complying with precautions led the operator to believe that he could make that determination without revising the procedure (i.e.,
evaluate whether applicable). Also contributing to the event was the uncertainty over who was responsible for ensuring precautions were met for this test.
This' test is a pump test required by Section XI.
As previously discussed in example e Mechanical Test has resoonsibility for the test program and procedures, Operations had r sponsibility for performing the particular test, and Mechanical Test was rosponsible for obtaining pump vibrations data for the test.
It was unclear which section had overall responsibility for conduct of the test; therefore, each section assumed the other was responsible for verifying precautions.
The system had been correctly aligned the previous night before the test, but had been realigned during the night. Mechanical Test assumed the system was still aligned correctly; and the operator who realized it was not aligned correctly believed it was acceptable.
Corrective Steps That Have Been Takej),
When the lack of compliance was identified during performance of the test, the test was stopped and the system aligned correctly before performing the remainder of the test. Clear responsibliity for overall conduct of this'and other Section XI pump tests was assigned to Mechanical Test, with Operations providing support.
A new adcinistrative instruction. AI-47, "Conduct of Testing," was established to resolve various problems identified during this event and other problems related to testing and to consolidate all requirements from existing plant procedures into a single instruction.
This instruction requires an overall test dirc-tor to be assigned for each test, defines the responsibilities of the test director and performers, defines requirements regarding compliance with precautions, and provides guidance in handling of problems identified during testing. All personnel conducting testing have been trained in the rdquirements of this new instruction.
Corrective Steps That Will Be Taken to Avoid Further Violations There is no further corrective action required.
Date When Full Compliance Will Be Achleco TVA is in full compliance.
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