ML20154D251
| ML20154D251 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 09/09/1988 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8809150211 | |
| Download: ML20154D251 (4) | |
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TENNESSEE VALLEv AUTHORITY CH ATTANOOGA. TENNESSEE 37401 5N 1578 Lookout Place SEP 09 B88 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) UNITS 1 AND 2 - NRC INSPECTION REPORT NOS. 50-327 -328/88 RESPONSE TO NOTICE OF VIOLATION (NOV) 50-327, -328/88-28-01 Enclosed is I'!s response to F. R. McCoy's letter to S. A. White dated August 16, 1988, that transmitted the subject NOV.
If you have any questions, please telephone H. A. Cooper at (615) 870-6549.
Very truly yours, TENNESSEE VALLEY AUTHORITY R. G id ey, nager t
l Nuclear Licensing and 4
Regulatory Affairs Enclosures cc (Enclosures):
Ms. S. C. Black, Assistant Director for Projects TVA Projects Division l
U.S. Nuclear Regulatory Comission One White Fitnt, North J
11555 Rockville Pike i
Rockville, Maryland 20852 l
Mr. F. R. McCoy, Assistant Director for Inspection Programs TVA Projects Division l
U.S. Nuclear Regulatory Commission i
Region II j
101 Marietta Street, NW, Suite 2900
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Atlanta, Georgia 30323 Sequoyah Resident Inspector Sequoyah Nuclear Plant i
2600 Igou Ferry Road Soddy Daisy, Tennessee 37379 8809150211 890909 PDR ADOCK 05000327
[O/
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PNU An Equal opportunity Employer fl
Enclosure Response to NRC Inspection Report No. 50-327, -328/88-28 F. R. McCoy's Lettar to S. A. White Dated August 16, 1988 Violation 50-327. -328/88-28-01 "Technical Spedfication (TS) 6.8.1 reqyf res that procedures recommcnded in Appendix 'A' of Regulatory Guide 1.33, Revi-Jon 2, be estatiltshed, implemented and maintained. This includes mainteaance procedures and survelilancs instructions.
The requirements of TS 6.8.1 are implemented in part by Sequop h ruclear plant standard practice SQM-2, ' Maintenance Management System' and Surveillance Iristruction SI-246, 'Recalibration Procedure for Reactor Coolant Flow Channels'.
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SQN-2, Section 6.?, requires that plant configuration discrepancies be reported to the shift technical advisor immediately.
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Contrary to the above, on May 15, 1988, an improper and undesignated butt i
sp)1ce, which was associated with steam generator No. 3 level indicat0r 2-1.I-3-97, was found to be at variance with drawing 47E 234-45 This configuration discrepancy was not immediately reported to the shift technical advisor as required, by SQM-2, Section 6.2.
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Surveillance instruction SI-245, requires that after isolating a transmitter to begin the calibration, the sense lir.es for the transnitter are to be depressurized via the test tee fittings, i
Contrary to tht above, en llay 23, 1988, instrument mechanics performing SI-246 depressurized the sense lines of flow transmitter 2-FT-68-718 via the high side drain valve on the bottom of the transmitter.
This devistion from procedure created a void in the transmitter's high side i
drain line, causing a pressure drop in the common high side sense line to
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flow transmittar 2-FT-68-710 when flow transmitter 2-IT-68-71B was q
returned to service.
This resulted in a Unit 2 reactor trip.
I This is a Severity Level IV Violation (Supplement I)."
Adn:ission or Denial of the Alleged Violation (Example 1) i TVA admits the violation.
J Reason for the Violation _(Example 1)
The reason for the delayed actions taken after the initial identification of the improper butt splic6 was a miscommunt.ation by the employees in the field J
about who would report the improper butt splice. Also, unfamiliarity with the I
requirements of Sequoyah Standard Practice (SQM) 2 "Halntenance Management j
System," on how to report this type of condition contributed to the i
miscommunication.
The reason the unqualified butt splice was present initially is attributed to the spilce being installed during the construction era of the plant when the construction specification allowed this type of splice of class lE cables i
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to be installed inside containment.
The cause of the sp1tce going undetected until the present is attributed to the splice being located inside the upper neck portion of the condulet body.
The splice was hidden from normal view when performing most work inside the condulet.
Corrective Steps That Have Been Taken and Results Achieveo (Examole 1) 4 1
Immediate corrective actions were to declare tne channel inoperable and l
eliminate the unquallfled butt splice.
Rather than upgrade the butt splice with a qualifi9d splice, the comp 10te transmitter pigtall sssembly was replaced back to the first junction box. An immediate investigation was initiated to determine what caused the unqualified splice, and it m determined to be an isolated case.
Three othar steam generator level i
transmitters of a similar design were also inspected to give additional l
assuratice that this was an isolated case.
No other unqualified splices were i
discovered, i
C_Qtrettive Steps That Will Be Taken to Avoid Further Violations (Example 1)
Because the presente of the unqualified butt splice was determined to be an isolated case, no further recurrence centrol 15 planned.
The plant procedure, Mcdtftcation S Addition Instruction 7, "Cable Terminations Splicing, and l
l Repairing of Damaged Cables," which presently implements th+ design requirements for performing splices, requires strict control of splice tratallations to ensure 10 CFR 50.49 qualifications are maintained.
Previous v
efforts of Inspecting and replacing all known 10 CFR 50.49-related splices requireo for untt 2 restart have been completed and documented under a TVA design output document, "10 CFR 50.49 Cal;1e and Splice List." This document was issued on March 7, 1988.
To easure that situations that could affect plant safety or conditions that
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are not accoroing to design documents are identified to the appropriate levels (i.e., shift technical advisor or shift operations supervisor) in a timely manner, plant superintendents (Maintenance, Radiological Control, Operations, t
and Technical Support) have discussed this event and provided training to j
their respective plant eniployees.
This training included emphasis on the i
necessity to report adverse conditions immediately and addressed the correct i
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method of reporting these adverse condttions as delineated in SQM2.
In additlen to this tral'11ag, Instrument Maintenance employees recO ved training
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1 on how to identify prtper and improper butt spil;es.
The site quality control manager has provided training to the electrical and instrument and control otsciplines to ensure that these employees are aware of 1
I the operability n"ification requirements of SQM2.
Administrative Instruction i
I (AI) 20, "QA Inspection Program," has been revised to clarify the i
documentation requirements for inspection personnel whenever a rejected 1 tem l
is discovered.
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Admission or Denial of the Alleged Violation (Example 2)
TVA admits the violation.
Reason for the Violation _(Ejample 2) f Instrument mechanics (IHs) were performing surveillance instruction 246, which was written to calibrate the transmitter (2-FT-68-718) while "on-line" with0ut losing any of the reactor coolant system (RCS) fill fluid in the sense line.
The procedure instructs the performer to "rack the transmitter high side test a
tee fitting to bleed pressere then remove the test tee fitting" after the transmitter is removed from service.
This step is performed to relieve RCS pressure before connecting calibration equipment.
The IMs relieved system pressure fron the sense lines by the high-side drain valve, which is located at the lowest point in the sense line.
The drain line routes to a closed drain system that made it impossible to determine how much fill fluid was lost when the drain valve was opened. Venting to the drain line was done to eliminate the chance of pressurized RCS r'111 fluid being sprayed into the i
By utilizing the drain line, the IMs cr ated a void in the high-side area.
drain line.
At the time, the IMs did not consider this a departure from the l
procedure, only a cleaner method of venting.
4 Corrective Steps That llave_Been Taken and Results Achieved (Example 2)
Following an investigation into the event, the appropriate ind!viduals were disciplined.
The event, its cause, and the results were discussed in a section meeting on May 31, 1988. Add 151onally, IMs were ;:autioned about the
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possible effects of failing to follow procedures.
IMs wers also reminded that inability to follow procederes for any reason should be reported to their immediate supervisor before alternate methods were attempted. Use of j
alternate methods requires a change in pracedures as addressed by AI-47, "Conduct of Testing."
4 Corrective Steps That Will Be Taken to_, Avoid Further Violations (Evample 2)
IMs are required to complete training course ICT-202.002, which primarily addresses conflquration control but also addresses compliance with procedures and is a yearly (annual) retraining commitment. Additionally, the subject of
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followtag procedures precisely is being addressed and discussed in Instrument i
Maintenknce section meetings, along with the proper steps to be taken when j
problems are encountered.
I Date When Full Compliance Will Be Achieved (Ex(tmples 1 and 2) j SQN is in full compliance, i
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