ML20206G085
| ML20206G085 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 11/17/1988 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8811220053 | |
| Download: ML20206G085 (4) | |
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TENNESSEE VALLEY AUTHORITY a
CHATTANOOGA. TEilNESSEE 374ot SN 157B Lookout Place NOV 171988 U.S. Nuclear Regulatory Comission ATTN Document Control Desk Washingto.:- D.C.
20555 Gentlement 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. 50-327/88-40 AND 50-328/88 NOTICE OF VIOLATION i
Enclosed is IVA's response to F. R. McCoy's letter to S. A. White dated October 20, 1988, that transmitted the subject notice of violation.
The enclosure provides TVA's response to the notice of violation. No new comitments are provided in t'.is response.
If you have any questions, please telephone M. A. Cooper at (615) 870-6549.
Very truly yours, TENNFSSEE V EY AUTHORITY j
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Nuclear Lie nsing and
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Regulatory Affairs l
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Enclosure cc: See page 2 ost12Toob3 881117
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PDR AnEq+ Opportunity Employer
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U.*S. Nuclear Regulatory Connaission
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l Ms. S. C. Black, Assistant Director for Projects WA Projects Division l
U.S. Nuclear Regulatory Conunission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 i.
l Mr. F. R. McCoy, Assistant Director for Inspection Programs l
WA Projects Division l
U.S. Nuclear Regulatory Conunission Region II 101 Marietta Street, hW, Suite 2900 Atlanta, Georgia 30323 Eequoyah Rerident Inspector f,equoyah t'uclear Plant 2600 Igou Ferry Road Soddy Daisy, Tetnessee 37379 i
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j ENCLOSURE RESPONSE TO NRC INSPECTION REPORT t
NOS. 50-327/88-40 AND 50-328/88-40 F. R. McC0Y'S LETTER TO S. A. WHITE DATED OCTOBER 20, 1988 3
i Violation 50-327. 328/88-40-01 "Technical Specification 6.8.1 requires that procedures recoemended in Appendix
'A' of Regulatory Guide 1.33, Revision 2 be established, implemented 1
and maintained. This includes administrative procedures.
i Administrative Instruction 47, Conduct of Testint,. requires that for testing Interruptions extending more than one shif t the 6est director shall determine the validity of all plant conditions pertaining to tne instruction before i
re-initiating performance.
Contrary to the above Surveillance Instruction 94.4 was interrupted August 26, 1988, and was re-initiated September 25, 1988, and the test I
director did not determine the validity of plant conditions pertaining to the
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instruction before re-initiating performance. This resulted in a reactor trip signal being generated and the opening of reactor trip breaker
'A'.
This is a Severity Level IV Violation (Supplement I)."
f Admission or Denial of the Alleged Violation TPA admits the violation occurred as stated, i
Reason for the Violation I
i This violation occurred because the instrument maintenance (IM) foremar 1
responsible for the performance of Serveillance Instruction (SI) 94.4, i
i "Reactor Trip / Engineered Safety Feature / Accident Monitoring Instrument Steam Generator Level Channel Calibrations (18 Months)." d correctly assumed that the steam generator water icvel bistables were in tL
^orrect (tripped) 4 position before resuming perMnance of the SI.
Additionally, a clear lack of i
conusunication between IM pe;v nel and a lack of documentation on t'io part of the IM personnel performing 3pecial Maintenance Instruction (SMI) 0-99-2, l
"Reactor Protection System Temporary Alteration to Clear Annunciators,"
j contributed to this event.
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i During the interruption in the performance of SI-94.4, it was necessary to perform SMI-0-99-2.
The implementation of this SMI required that the as-left i
test configuration of SI-94.4 be altered. However, the IM personnel performing the SMI failed to notify the SI-94.4 test director or to maintain a i
proper test log to depict the altered bistable configuration. These events, combined with the failure nf the SI-94.4 test director to follow the l
administrative instruction (AI) 47 requirements to rsverify correct bistable I
configuration before resuminC his surveillance, resulted in generation of a f
unit I reactor trip signal. At the time of this occurrence, unit I was in 0
mode 5 (cold shutdown). This event was previously reported in licensee event
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report (LER) 50-327/88037.
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Corrective Steps That Have Been Taken and Results Achieved Immediate corrective action was taken by Operations personnel to verify that the "A" train reactor trip : breaker opened ("B" was not closed) and to suspend performance of SI-94.4 until the cause of the event was identified.
To establish better communication between IM personnel during performance of the reactor protection set sis (during unit 1 cycle 3 refueling outage), SQN implemented crew /shif t turnover briefing requirements that include the status of SI initiations and completions.
Additionally, this event and the necessity to fully implement the requirements of AI-47 have been discussed with involved IM test directors.
i Corrective Steps That Will Be Taken to Avoid Further Violations As previously committed in LER 50-327/88037, the following actions will be completed to prevent recurrence of this event.
1.
IM test directors will be retrained by January 15,1989, on AI-47 i
l requirements, emphasizing the need to determine the validity cf plant conditions pertaining to the instruction before reinitiating SI pe rfo rmance.
2.
SMI-0-99-2 will be revised by January 15, 1989, to provide tighter 4
ontrols for maintaining altered test configurations. This procedure revision will provide a means to document equipment in "as-found" and "as-left" conditions as it is being implemented and will be under the control of the IM general foteman.
3.
From a lessons learned perspective, plant Operations personnel will be informed by November 15, 1988, to remain cognizant of bistable status during transmitter sense line backfillint activities.
I Date When Full Compliance Will De Achtsved i
SQN is in full compliance.
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