ML20153D487
| ML20153D487 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 05/04/1988 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8805090166 | |
| Download: ML20153D487 (6) | |
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k TENNEGSEE VALLEY AUTHORITY CHATTANOOGA, TENNESSEE 37401 SN 1578 Lookout Place MAY 0 41988 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, 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 AND
-328/87 RESPONSE TO NOTICE OF VIOLATIONS 50-327, 50-328/87-76-01 AND -02 Enclosed is my response to K. P. Barr's letter to S. A. White dated April 8, 1988, that transmitted Notice of Violations 50-327, -328/87-76-01 and -02.
Enclosure i provides my response to the notice of violations.
contains a list of commitments contained in this ichmittal.
If you have any questions, please telephone M. R. Harding at (615) 870-6422.
Very truly yours, TENNESSEE V Y AUTHORITY
/
/
R. Gridley, D ector 4
Nuclear Licensing and Regulatory Affairs 1
Enclosures cc: See page 2 t
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1 p et i i 8805090166 800504 DR ADOCK O 37 An Equal opportunity Employer
. U.S. Nuclear Regulatory Commission htAY 0 41988 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 Sequoyah Resident Inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy Daisy, Tennessee 37379
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ENCLOSURE 1 RESPONSE TO NRC INSPECTION REPORT NUMBERS 50-327/87-76 AND 50-328/87-76 K. P. BARR'S LETTER TO S. A. WHITE DATED APRIL 8, 1988 Violation 50-327, -328/87-76-02 "A.
Technical Specification (TS) 6.8.1 requires that procedures recommended in Appendix
'A' of Regulatory Guide 1.33. Revision 2, be established, implemented, and maintained. This includes administrative procedures and surveillance instructions.
i Surveillance Instruction (SI) - 153.4 Revision 2, Test Requirements for the Electric Hydrogen Recombiner System, requires a visual verification that the orifice at the bottom of the hydrogen recombiner housing is clear of obstruction.
Administrative Instruction (AI)-3, Clearance Procedure, section 4.2.5, requires that the shift engineer verify that pressure is zero and equipment drained prior to issuing a mechanical clearance.
Contrary to the above:
1.
On December 14, 1987, the licenses failed to adequately implement SI-153.4 on Hydrogen Recombiner 2A-A, in that the requirement to visually verify the Recombiner's orifice clear of obstruction was not adequately conducted.
2.
On November 25, 1987, the licensee failed to implement AI-3 in that a section of piping in the Unit 2 Auxiliary Feedwater System was not drained and depressurized prior to issuing the associated clearance.
This is a Severity Level IV violation (Supplement I)."
Admiss,lon or Denial of the Alleged Violation (example 1)
TVA admits the violation.
Reason for the Violation The root cause of this violation is twofold:
(1) Surveillance Instruction (SI) 153.4 did not provide adequate direction to perform the inspection of the orifice plate required by step 5.3.4, and (2) the maintenance electrician (ME), who had requested clarification of step 5.3.4 before beginning the
'3 inspection, decided that the step meant to inspect the exterior louver openings on the side of the recombiner and performed the step without waiting for the cognizant engineer to provide the requested information.
Corrective Steps That Have Been Taken The ME performing the SI reperformed the inspection of the orifice plate of recombiners 2A-A and 2B-B.
The*importance of waiting on a clarification was discussed with the ME.
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. Corrective Steps That Will Be Taken to Avoid Further Violacions SI-153.4 will be revised to provide adequate description of the orifice plate to be inspected in step 5.3.4.
This revision will be completed by September 1, 1988.
Craft personnel will be instructed to wait on clarification of procedure steps when procedures do not provide adequate information. Once clarification has been determined, procedural revisions will be implemented if required. This instruction will be accomplished during the monthly safety meetings and will be completed by June 15, 1988.
Date When Full Compliance Will Be Achieved TVA is in full compliance.
Admission or Denial of the Alleged Violation (example 2)
TVA admits the violation.
Reason for the Violaticn The assistant shift supervisor inadvertently overlooked the flow control valve that was inside the tagging boundary during depressurization and drain down of the line.
During removal of the blind flange, the flow control valve was stroked resulting in a minor spill of approximately two gallons of water.
Corrective Steps That Have Been Taken The responsible individual was immediately aware of his mistake after the occurrence and was also aware of how to prevent recurrence. However, the situation was still discussed with the individual and "attention to detail" was stressed.
Corrective Steps That Will Be Taken to Avoid Further Violation There is no further corrective action required.
Date When Full Compliance Will Be Achieved TVA is in full compliance.
3
. Violation 50-327. -328/87-76-01 "B.
Technical Specification (TS) 6.8.1 requires that procedures recomreended in Appendix
'A' of Regulatory Guide 1.33. Revision 2 be establistied, implemented, and maintained. This includes surveillance and test activities of safety related equipment.
l Contrary to the above, post maintenance testing on the 2A-A emergency diesel generator in support of the voltage regulator card replacement of November 8, 1986, was inadequate in that the post maintenance test conducted did not test operation of the voltage regulator under rapid i
loading / rejection conditions. As a result, the replacement voltage regulator card was not found to be defective until October 1987.
l This is a Severity Level IV violatiore (supplement I)"
Admission or Denial of the Alleged Violathn I
TVA admits the violation.
Reason for the Violation i
The root cause of not detecting the reversed diode installed in the voltage regulator card during previous testing was deteroined to be the lack of
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adequate guidelines for writing test procedures to ensure that adequate postmaintenance testing (PMI) would be accomplished for testing of the voltage regulator.
Previously performed test procedures did not consider the diesel l
generator (D/G) output voltage at the time the voltage permissive relay energised because the series contacts must close--one for speed a,nd one for i
voltage--to energize the closing coil of the D/G output breaker (the terminal voltage at time (t) = 0 is a function of governor response time).
The procedures did test voltage at breaker closure time.
j Corrective Steps That Have Been Taken Standard Practice SQM66, "Post Maintenance Testing," was revised on d
December 16, 1987, to ensure testing requirements on any voltage regulator work would be evaluated on an individual case basis until appropriate postmaintenance tests are in place.
Corrective Steps That Will Be Taken to Void Further Violations To correct inadequate PMT following voltage regulator and governor maintenance l
performed on the D/G guidelines will be prepared by Division of Nuclear Engineering and issued as committed to in Licensee Event Report (LER)
SQRO-50-327/87070, revision 3.
PMT procedures will be subsequently written in accordance with these guidelines within 30 days, as stated in the referenced j
LER.
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Date When Full Compliance Will Be Achieved TVA is in full compliance.
a ENCLOSURE 2 List of Commitments 1
1.
Division of Nuclear Engineering will develop and issue guidelines to i
correct inadequate PMT following regulator and governor maintenance as j
committed to in LER SQRO-50-327/87070, revision 3.
2.
PMT procedures will be subsequently written in accordance with these guidelines within 30 days as stated in the LER SQRO-50-327/87080, revision 3.
3.
SI-153.4 will be revised to provide adequate description of the orifice plate to be inspected by September 1, 1988.
i 4.
Craft personnel will be instructed to wait for clarification of procedur'e i
7-steps when procedures do not provide adequate information. This will be completed by June 15, 1988.
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