ML20151T409
| ML20151T409 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 04/22/1988 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8804290007 | |
| Download: ML20151T409 (7) | |
Text
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TENNESSEE VALLEY AUTHORITY
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CHATTANOOGA. TENNESSEE 374ot SN 157B Lookout Placo APR 221988 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C.
20555 Gentlemen:
In the Matter of.
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Docket Nos. 50-327 Tennessee Valley Authority
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50-328 SEQUOYAH NUCLEAR PLANT (SQN) - NRC INSPECTION REPORT NOS. 50-327/88-17 AND 50-328/88 RESPONSE TO NOTICE OF VIOLATION 50-327, -328/88-17-01 Enclosed is my response to F. R. McCoy's letter to S. A. White dated March 24, 1988, that transmitted Notice of Violation 50-327, -328/88-17-01 with three examples and request for response to one item identified by cover letter. provides my response to the Notice of Violation and item identified by cover letter. Enclosure 2 contains a list of commitments contained in this submittal.
The due date for the requested response to unresolved item 50-327,
-328/88-17-02 was extended to May 6, 1988, in a conversation between C. Kirk and Frank McCoy on April 21, 1988.
If you have any questions, please telephone.M. R. Harding at (615) 870-6422.
Very truly yours, TENNESSEE VALLEY AUTHORITY
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,jV R'. Grid' ley, Direct r Nuclear Licensing and Regulatory Affairs Enclosures cc: See page 2 i
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'8804290007 880422
'PDR ADOCK 05000327 An Equal Opportunity Employer DCD j
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. U.S. Nuclear Regulatory Commission od)R 221988 l
cc (Enclosures):
P.r. 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 Piko Rockville, Maryland 20852 J
Sequoyah Resident Inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy Daisy, Tennessee 37379 4
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- s ENCLOSURE 1 Violation 50-327 -328/88-17-01 "Technical Specification (TS) 6.8.1 requires that procedures be established, implemented and maintained covering maintenance, surveillance and test activities of safety related equipment.
1.
The procedure used to perform reactor coolant system (RCS) resistant temperature detector (RTD) cross-calibration was Surveillance Instruction SI-488', RCS RTD Sensor Verification of Calibration, in conjunction with Technical Instruction (TI)-60 Incore Thermocouple and RTD Cross Calibration.
Contrary to the above, on February 7,1988 the sequence of returning the RTDs to service as stipulated in TI-60 was not followod, resulting in the inadvertent opening of the Power Operated Relief Valves.
2.
Standard Practice SQM2, Maintenance Management System, implements TS 6.8.1 requirements for the control of maintenance activities through work request (WR) implementation and documentation of maintenance work activities.
Contrary to the above, on February 8,1988 maintenance activities conduc.ted on valve 2-LCV-62-118 were not adequately described or implemented 'on WR B285685 and resulted in an inadvertent diversion of approximately 465 gallons of RCS water to the Holdup Tank rather than the Volume Control Tank, and an entry into TS Limiting Condition for operation 3.4.6.2.d.
3.
Administrative Instruction ( AI)-3, Clearance Procedure, implements the requirement for an equipment cir.arance procedure through the use of hold orders.
AI-3 states that no work shall be performed except under the applicable clearance procedure unless authorized on a case-by-case basis and in order to perform troubleshooting on equipment which cannot be accomplished under a normal clearance or perform work of a limited scope where full control can be provided and maintained in the immediate proximity.
In addition, the shift supervisor shall verify that pressure is zero and equipment drained prior to issuing a mechanical clearance.
Contrary to the above, in support of the February 8,1988 maintenance on valve 2-LCV-62-118, maintenance personnel and the shift supervisor failed to establish a clearance for the air supply to the valve or a mechanical clearance for the valve itself.
They further failed to remove system pressure from a component that was disassembled and was subject to a pressure greater than zero.
This is a Severity Level IV (Supplement 1) Violation."
Admission or Denial of the Alleged Violation (example 1)
TVA admits the violation.
Reason for the Violation (example 1)
Surveillance Instruction (SI) 488/ Technical Instruction (TI) 60 was not written in sufficient detail to properly document removal of a temperature channel from service and subsequent restoration of the temperature channel to service. The section of the procedure that placed the channel back in service was a generic, seven-step appendix that did not require performer signature or independent verification.
The procedure was not in the possession of the performers because it did not require their signof fs.
Two of the steps used for restoring the channel to service were performed out of sequence causing the temperature channel to go downscale. With the temperature channel downscale and the primary RCS pressure at 460 pounds per square inch gauge, a cold-overpressurization (COP) signal was initiated.
Corrective Steps That Have Been Taken (example 1)
The restoration of the temperature channels was completed shortly after the event initiation, and Operations terminated the event by closing the power-operated relief valve after consulting the COP system setpoint curve and determining the alarm was false.
Instruction change form (ICF) 88-0443 has been written to detail the steps required to take a temperature instrument i
channel out of service and to restore it back to service. This ICF requires step-by-step signoffs and independent verification signoffs.
Corrective Steps That Will Be Taken to Avoid Further Violations (example 1)
SI-488/TI-60 will be revised to incorporate the detailed step-by-step performance signoffs and independent verification signoffs. This will ensure that the proper sequence of events occurs during removal of temperature channels from service and subsequent restoration of temperature channels to service.
Date When Full Compliance Will Be Achieved (example 1)
TVA was in full compliance when ICF 88-0443 was approved for use.
SI-488/TI-60 will be revised before the mode 4, 250-degree-Fahrenheit plateau on unit 1.
Admission or Denial of the Alleged Violation (example 2)
TVA admits the violation.
Reason for the Violation (example 2)
The root cause of this violation was a failure of personnel performing the work to have the WR replanned when the work went beyond the scope of the initial WR, with the removal of the valve operator from the valve.
In addition, there were inadequate communications between Maintenance and operations on the actual work to be performed.
A contributing factor is that during this time the assistant shift supervisor was assigned the responsibility of performing a nuclear safety review of work packages in addition to the fundamental responsibilities as the unit senior reactor operator.
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. Corrective Steps That Have Been Taken (example 2)
The additional responsibility of the assistant shif t supervisor performing a nuclear safety review of work packages has been eliminated by establishing a work control group.
The work control gecup is responsible for ensuring that:
Scope of work is defined; effects on the system and system interfaces are identified; determination of work impacts on TS requirements is identified; adequate clearances are established; and plant configuration is controlled.
Maintenance has stopped issuance of a troubleshoot and repair work request (WR).
A WR will be issued to troubleshoot and determine the problem.
Upon completion of the troubleshooting effort, the WR will be returned to the planners to be replanned or a new WR will be written, unless the subsequent corrective action is only to perform calibration.
Corrective Steps That Will Be Taken to Avoid Further Violations lexample 2)
There is no further corrective action required.
Date When Full Compliance Will Be Achieved (example 2)
TVA is in full compliance.
Admission or Denial of the Alleged Violation (example 3)
TVA admits the violation.
yeason for the Violation (example 31 The root cause of this violation was inadequate communications between Maintenance and Operatlons, personnel failed to have the WR replanned when 11:e work went beyond the scope of the initial WR, and therefore adequate discussion did not transpire between the assistant shift supervisor and the Maintenance foreman before removal of the operator from the valve body.
Corroctive Steps That Have Been Taken (example 3)
A work control group has been established to ensure that:
Scope of work is defined
- cffects on the system and system interfaces are identified; determ..iation of work impacts on TS requirements is identified; adequate clearances are established; and plant configuration is controlled.
Maintenance has stopped issuance of a troubleshoot and repair WR.
A WR will be issued to troubleshoot and determine the problem.
Upon completion of the troubleshooting effort, the WR will be returned to the planners to be replanned or a new WR will be written, unless the subsequent corrective action is only to perform calibration.
Corrective Steps That Will Be Taken to Avoid Further Violations (example 3)
There is no further corrective action required.
Date When Full Compliance Will Be Achieved (example 3)
TVA is in full compliance.
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l ADDITIONAL INFORMATION REQUESTED FOR EXAMPLE 50-327, -328/87-78-01 AdmissionorDenialoftheAller,edVlokation TVA admits the violation.
Reason for the Violation The root cause of this violation was a lack of management attention to the requirements of AI-30, "Plant Staff Overtime Limitr,."
Corrective Steps That Have Been Taken The individual responsible has been counseled on the requirements contained in AI-30.
The Plant Manager has strcssed to all plant management thd'importance of reducing the need for personnel to work in excess of overtime limits defined in AI-30.
These identified actions, along with the actions identified.
by the response to 50-327, -328/87-78-01, should preclude recurrence.
Corrective Steps That Will Be Taken to Avoid Further Violations There is no further corrective action required.
Date When Full Compliance Will Bo Achieved TVA is in full compliance.
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ENCLOSURE 2 LIST OF COMMITMENTS 1.
SI-488/TI-60 will be revised before the mode 4, 250-degree-Fahrenheit plateau on unit 1.
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