ML20154H739

Forwards Response to NRC 880519 Request for Clarification Re Reason for Violation Noted in Insp Repts 50-327/88-06 & 50-328/88-06.Violation Caused by Misinterpretation of Administrative Instruction 37

ML20154H739
Person / Time
Site:	Sequoyah
Issue date:	05/19/1988
From:	Gridley R TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NUDOCS 8805260053
Download: ML20154H739 (5)

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TENNESSEE VALLEY AUTHORITY CHATTANOOG A. TENNESSEE 37401 SN 1578 Lookout Place ,

.MAY 191988 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) REVISED RESPONSE TO NRC INSPECTION REPORT NOS. 50-327/88-06 AND 50-328/88-06 Enclosed is TVA's response to Kenneth P. Barr's April 19, 1988 letter to S. A. White that requested a supplemental response clarifying the reason for violation 88-06-01 and whether the six additional loose items (found in IE electrical panels) described in violation 88-06-03 have now been removed.

Enclosed is the revised response to violation 88-06-01 that clarifles the reason for the violation.

The remaining six loose items that were identified in an Operations plant inspection of IE electrical panels on January 16, 1988, were subsequently removed by January 28, 1988.

If you have any questions, please telephone H. R. Harding at (615) 870-6422.

Very truly yours, TENNESSEE VAL AUTHORITY

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R. Gridley, Di ector Nuclear Licensing and Regulatory Affairs Enclosure cc: See page 2

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i 8805260053 DR 890519 An Equal Opportunity Employer ADOCK 05000327 DCD _

e U.S. Nuclear Regulatory Commission cc (Enclosure):

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 Diviston U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockyi11e, Maryland 20852 Sequoyah Resident Inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy Daisy, Tennessee 37379

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ENCLOSURE I t

REVISED RESPONSE TO WRC INSPECTION REPORT NOS. ,

50-327/88-06 AND 50-328/88-06 KENNETH P. BARR'S LETTER TO S. A. WHITE  :

DATED MARCH 1, 1988  !

Violation 50-327. -328/S8-06-01  ;

"A. Technical Spetification (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, i The requiremente of TS 6.8.1 are implemented by Administrative Instruction AI-37 titisd ' Independent Verification' and Administrative 4- Instruction AI-58 titled ' Maintaining Cognizance of Operational Status -

Configuration Status Control'.

Contrary to the abovo, prior to January 4, 1988, the licensee failed to i adequately establish, implement, and maintain procedures for  :

configuration control as follows:

1. The licensec failed to specify the minimum qualification level for-individuals performing independent verification of Sol checklists as [

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required by AI-37. This resulted in a failure to perform and e i

document adequate training for all individuals performing SOI .

checklist verifteations. )

i j 2. The licensee failed to implement the requirements in Al-58 for 1

maintaining configuration control after SOI checklist completion, in  :

i that the documented positions in the configuration control system for instrument root valve 1-268A, and the breakers for post accident satapling valves on 120 V vital instrument power boards 2-III and 2-IV r I

(breaker 17 on each board) disagreed with the actual positions.

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This is a Severity Lovel IV violation (Supplemcat I)."

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Reasor, f or the Violation (i

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1. The failure to specify the minimum qualification level for individuals Performing system operating instruction (SOI) checklist verifications was  ;

in part the result of a misinterpretation of Administrative Instruction r (AI) 37. This instruction previously contained the minimum qualification ,

requirements for Oc a,.thus' personnel who can perform independent  !

verifications. H-37 was later revised to delete the qualification j requirements for Operations' independent verifications. The >

l qualifications were replaced with a moro general statement "Each plant section chall evtablish a minimum qualification icyc1 for individuals '

l performing independent verifie:ation. personaal should bo trained, i certified, or qualified for the job requirements." Operations' personnel 4 i responsible for preparation of Al-SC, revision O. (which was prepared i

subsequent to the AI-37 revision discussed above) believed that l

certification as a TVA assictant unit operator (AUO) catisfied the  !

requirements of AI-37 and that additional documentation in AI-58 was not [

l necessary. [

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Discussions hold between Operations' management and NRC during a previous inspection on what additional training should be required for AUOs, who were on loan from other TVA sites, resulted in an agreement to provido SQN site-specific training so that these individuals would be fully cognizant of the SON system alignment process. The agreement also included provision'for documentation and validation of this training.

Subsequent to this agreement, a change occurred in personnel responsible for overseeing the unit 2 system alignments. The replacement personnel had not been informed of the pruvious agreement betwoon NRC and Operations management. Consequently, AI-58, revision 0, which was prepared following the change in personnel, did not include specific training requirements for AUOs on loan from other sites.

2. The reason for the mispositioning of the valve circuit breakers on the Postaccident Sampling Facility (PASF) was determined to be personnel error because the assistant shift supervisor / shift operator, who had closed the two breakere to allow performance of Surveillance Instruction (SI) 722.3, misinterpreted AI-58, section 2.2.2.1, and assumed that a configuration los entry was not required. AI-58 stated that, if a picco of equipment is controlled from the main control room control pancis and had positivo position indicators at the panol, its positioning does not have to be entered in the configuration log. The assistant shift engineer thought that the valvo position indicating lights, which came on when the becakers were closed, were positivo indication of their Position. However, the breakers are not controlled (com the control room panel.

No reason could be determined for the mispositioning of instrument root valve 1-268A.

Corrective Steps That Have Been Taken All employees who had participated in the independent verification of checklists were TVA-certified AUOs. Specific minimum qualification requirements were determined, and formal training in the appropriate areas was conducted and documented for all involved employces.

AI-58 was revised to include the minimum qualification requirements for independent verification personnel. Additionally, a form was added that will be used to document completion of the required training for AUOs on loan from other sites.

The mispositioning of instrument root valvo 1-268A was entered in the

{ configuration log. When no reason could be found for the valve to be closed, i

it was returned to its normal position; and the configuration log entry was cleared.

l The PASF valvo circuit breakers were returned to the*r normal positions.

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Ths requirements for placing an entry in the configuration log were clarified

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for the senior reactor operator involved. To ensure that no others had the save misunderstanding, a letter was given to all shift supervisors directing them to ensure that all onshift Operations' nmployees had a cicar understanding of the requiremchts of AI-58 concerning exceptions to i tonfiguration los entrics. AI-58 was revised to clarify the exception statement. A ictter was also sent to each shift supervisor, assistant shift supervisor, and unit operator rotativo to this revision. SI-722.3 was revised to require two-party independent verification when placing power on the PASF valvo circuits and when opening th6 breakers at the conclusion of the test.

l' Additionally, signs wore placed at the units 1 and 2 PASF valve breakcrs that state, "Bcfore closing breaker to PASF valves, consider requirements of Y.S.

LCO 3.6.1.1 and configuration log entry."

Corrective Steps That Will Be Taken to Avoid Further Violaticus The AI-58 revision should be sufficient to prevent further viciations rotative to the qualificati9n of independent verification personnel.

The corrective actions taken with respect to the PASF valve breakers are considered adequate to prevent recurrence of similar violations.

The mispositioning of instrument root valvo 1-268A is considered an isolated event, and no further corrective actions are anticipateo.

Date When Full Compliance Will Be Achieved All correctivo actions were completed by February 12, 1988.