ML20154B447
| ML20154B447 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 09/06/1988 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8809140013 | |
| Download: ML20154B447 (5) | |
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TENNESSEE VALLEY AUTHORITY CH ATTANOOGA. TENNESSEE 37401 SN 1578 lookout Place SEP 061988 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Hashington 0.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) UNITS 1 AND 2 - NRC INSPECTION REPORT (IR)
N05. 50-327, -328/88 SUPPLEMENTAL RESPONSE TO NOTICE OF VIOLATION (NOV)
This supplemental response addresses the five examples of configuration control problems cited in IR 88-28 as requested by the letter transmitting that report. Also Joe Brady of your staff has requested that a review of two previous inspections (87-66 and 88-06) w!th a discussion as to the' relationship of corrective action and root causes relative to the most recent inspections (88-26 and 88-28) be included.
Enclosed is TVA's supplemental response to F. R. McCoy's letter to S. A. White dated June 17, 1988, that transmitted the subjact NOV. contains SQN's response and corrective action to the five additional configuration contiol problems as described in NRC's IR 88-28. contains SQN's review and comparison of the configuration control problems described in previous MC irs.
If jou have any questions concerning this submittal, please telephone M. A. Cooper at (615) 870-6549.
Very truly yours, TENNESSFE VALLEY AUTHORITf h.
R. Gridley, Manager Nuclear Licensing and Regulatory Affairs Enclosures cc:
See page 2 4go I 0009140013 880904 PDR ADOCK 05000327 Q
PDC An Equal opportunity Employer
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U.S. Nuclear Regulatory Commission 8D 06 m cc (Enclosures):
Ms. S. C. Black, Assistant Director for Projects TVA Projects Olvision U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 0 852 Mr. F. R. McCoy, Assistant Director for Inspection Prograrts TVA Projects Division U.S. Nuclear Regulatory Commission Region II 101 Harletta Street, NW, Suite 2900 Atlanta, Georgia 30323 Sequoyah Resident Inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy-Daisy, Tennessee 37379
ENCLOSURE 1 NRC cited SQN with four configuration control problems in the IR 88-26.
The corrective action to correct the problems and prevent recurrence included a revision of Administrative Instruction (AI) 3, "Clearance Procedures," AI-30, "Nuclear Plant Conduct of Operations," and AI-58, "Maintaining Cognizance of Operation Status - Configuration Status Control," along with training of appropriate personnel.
The additional five examples, as referenced in the IR 88-28, occurred in a very close timeframe and are of the same nature as those ident! fled in IR 88-26.
Specific corrective actions for the first events were being implemented, the broader root cause was being determined, and further corrective actions were identified during the time the five additional ever.ts occurred.
The revision of AI-3, AI-30, and AI-58 to correct and control the 88-26 issues plus the training of personnel will also correct, control and prevent the recurrence of the additional five examples cited in IR 88-28.
The examples, TVA's corrective actions and NRC's review and approval of results, are described in detall in IR 88-28.
The following is a summary of the five additional examples and their specific corrective actions as outlined in a condition adverse to quality report (CAQR) (CAQR SQN880414),
which was written to address the issue, correct the problems, and document the corrective action.
E ample No. I X
Valve 2-HVC-70-661 on the component cooling water system (CCS) return from beric acid evaporator 8 was found misaligned while performing Surveillance Instruction (SI) 32.
Root Cause Personnel allowed to manipulate valves did not fully understand the importance and effect of throttle valve position.
Corrective Action Specialized training of personnel was inttlated to address the importance of throttle valve positions and their function.
Ex_ ample _No. 2 Valves 2-67-680 and 0-67-5518 were found out-of-position during performance of SI-682.
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Personnel allowed to manipulate valves did not fully understand the importance and effect of throttle valve position.
Corrective Action Specialized training of personnel was initiated to address the importance of throttle valve positions and their function.
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Example No._3 Valve 2-62-951 was misaligned and caused a spill (May 17, 1988) in the holdup tank (HUT) valve gallery.
Root Caug The extension stem operator did not function properly; also, the valve did not have an operable valve position indicator.
Corrective Action A preventative maintenance (PM) program was established for extension stem operators to improve reliability.
Example No. 4 Valve 2-62-945 was misa11gned and caused a spill (May 18, 1988) in the.:UT valve gallery.
Root Cause The status board incorrectly indicated the valve 2-62-945 as being open.
AI-58 allowed changes to the status board without accountability or traceability.
Corrective Action Al-58 was revised to delete the status board for denoting configuration and require the use of a configuration log.
Exa_mple No. 5 Los; of unit 1 residual heat removal (RHR) suction May 23, 1988, resulted from personnel opening the wrong valve.
Root Cause Miscommunication between the unit operator (U0) and assistant unit operator (AVO) during prejob briefing.
Corrective Action AI-30 was revised to incorporate use of "READ-BACK CARDS" to be used by AU0s to record instructions. AI-58 was revised to fill out Appendix B1, "Configuration File Sheet," before valve manipulation, t
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ENCLOSURE 2 Multiple examples of configuration control problems, cited in IR 88-26 and IR 88-28, caused NRC to question the effectiveness of SQN's configuration centrol program and procedures. One question that was raised is the relationship of previous identifled configuration control problems and the effectiveness of the associated corrective action to the recent examples identifled in irs 88-26 and 88-28.
The root causes and corrective actions required for the IR 88-26 and 88-28 examples are addressed in TVA's July 14, 1988 initial response to violation 88-26-01, NRC IR 88-28, and enclosure I to this submittal.
Previous configuration control problems were identified in NRC inspections 87-66 and 88-06.
During the October 1987 inspection (87-66), six examples I
indicated that Operations Section Letter Administrative (OSLA) 58 was l
inadequate and should be revised.
05LA-58 was revised and converted to AI-58 with the necessary provisions to correct the identified configuration control problems. Converting OSLA-58 to Al-58 also increased management's involvement.
AI-58 was issued December 8, 1987.
In January 1988 an NRC inspection (88-06) pointed out the need for specifying a minimum qualificatior.
level for individuals performing System Operating Instruction (50:) checklist verifications; also, an "exception statement" in AI-58 needed clarlfication.
AI-58 was revised accordingly on January 17, 1988.
In summary, SQN experienced configuration control problems in October 1987 and appropriate corrective action was taken in the issuance of a procedure (AI-58) to maintain cognizance of operating status and configuration control.
In January 1988, an NRC inspection Identified problems concerning second-party verification qualifications. As a result, AI-58 was revised to correct the problem.
TVA's responses to these two NRC inspections (87-66 and 88-06) contain the detailed discussions of the items and their appropriate corrective actions.
In retrospect, the conflouration problems identified in NRC's earlier inspections (87-66 and 83-06) were entirely different from those identified :n 88-26 end 88-28.
The configuration control problems identified in the earlier reports were correctad and recurrence control has been effective for those types of problems.
The corrective actions for the earlier problems could not have prevented the events outilned in the 88-26 and 88-28 reports.
Disregarding human error. SQN experienced four problems in October 1987, two in January 1988, one in April 1988, and one in May 1988.
SQN is maintaining cognizance of operating status and configuration control, and the corrective actions implemented in response to problems have proven effective.
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