ML20213G011
| ML20213G011 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 10/31/1986 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8611170281 | |
| Download: ML20213G011 (5) | |
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DmB TENNESSEE VALLEY AUTHORITY CH ATTANOOGA. TENNESSEE 374o1 SN 157B Lookout Plince OCT 31886 5l0'! I2 P j - Q U.S. Nuclear Regulatory Comission i
Region II ATTN:
Dr. J. Nelson Grace, Regional Administrator 101 Marietta Street, NW, Suite 2900 i
Atlanta, Georgia 30323
Dear Dr. Grace:
3 SEQUOYAHNUCLEARPLANT(SQN) UNITS 1AND2-NRC-OIEREGIONII'fNSPECTION REPORT 50-327/86-43 AND 50-328/86 RESPONSE TO VIOLATIONS NOS.
50-327/86-43-02 AND 50-328/86-43-02 Enclosed is our response to Gary G. Zech's September 12, 1986 letter to S. A. White which transmitted Notice of Violation Nos. 50-327/86-43-02 and 50-328/86-43-02.
Also enclosed is, our response to your request for additional infonnation regarding our actions to improve the effectiveness of the'
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postmodifications test program and our plans to review workplans issued 1
subsequent to those reviewed by the Postmodification Task Force for l
verification of adequate postmodification testing. Enclosure 1 is our response to the subject violation and enclosure 2 is our response to /our 7
request for additional information. contains the list of commitments contained in enclosures 1 and 2.
We do not recognize any other actions described herein or the subject inspection report as commitments.
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If you have any questions, please call M. R. Harding at 635/870-6422.
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To the best of my knowledge,'I declare the statements contained herein are complete and true.
Very truly yours, TENNESSEE VAL Y AUTHORITY v,
R. Gridley, Di ector Nuclear Safety and Licensing g
Enclosures cc (Enclosures):
Mr. James Taylor, Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. G. G. Zech Director, TVA Projects U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 8611170281 861031 PDR ADOCK 05000327 An Equal Opportunity Employer
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ENCLOSURE 1 RE3PONSE - NRC-OIE INSPECTION REPORT NOS. 50-327/86-43 AND 50-328/86-43 CARY G. ZECH'S LETTER TO S. A. WHITE l
' DATED SEPTEMBER 12, 1986 Violatind 50-327/86-43-02 and 50-328/86-43-02 TS 6.8.2 identified the required review and approval of written procedures.
Subsequent to initial approval, TS 6.8.3.1 provides limitations for initiating temporary changes to these procedures.
Administrative Instruction (AI)-4, " Plant Instructions - Document Control," is the ; plant procedure for controlling temporary changes to procedures.
Paragraph 13.1 of AI-4 defines the two conditions which TVA considers qualify
'T as temporary changes (eg., TVA expeditious changes). These two conditions are: 1) changes which will remain in effect for only a limited number of instruction performances (e.g., procedures needed to be performed this one tiro because of plant conditions; 2) changes which are urgently needed to corr,ect a serious deficiency.
Contrary to the above, changes to approved procedures were improperly processed, in that, changes to WP 11890 was processed using the urgent change process when neither of the two conditions existed. Additionally, changes to numerous approved procedures are being made without proper review by use of the " accomplish the applicable portion" process which TVA has and continues to use.
This is a Severity Level V Violation (Supplement I).
1.
Admission or Denial Of The Violation TVA admits the violation occurred as stated.
2.
Reason For The Violation The portion of this violation dealing with Workplan (WP) 11890 is attributed to personnel error brought on by a common practice associated with needed changes to WPs.
WPs are written instructions to perform a plant modification / test and are only performed once. Therefore, expeditious changes to WPs per AI-4 were considered acceptable since the changes would only be in effect for a single performance of the document.
The lack of explicit work instructions (i.e., the use of " perform the applicable portions") which also resulted in this violation is attributed to bad engineering practice.
3.
Corrective Steps Taken and Results Achieved
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i Since the WP was already completed, no immediate corrective action was taken.
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Corrective Steps To Be Taken To Avoid Further Violations To ensure proper management attention is placed on the use of temporary and urgent changes, either the plant superintendents or plant manager, beginning November 1, 1986, will review these changes until March 1, 1987.
In addition, the plant manager will evaluate the procedure change process as described in AI-4 and identify any necessary corrective actions (i.e., revisions) by November 30, 1986.
In addition, to ensure correctness and explicitness of work instructions and reduce the use of " perform the applicable portions",
Administrative Instructions, especially those governing postmodifications/ maintenance testing, will be reviewed by March 1, 1987 to determine if revisions are necessary. As an interim measure, the plant manager will by November 30, 1986, issue directions to plant personnel to reduce the use of instructions phrased " perform the applicable portion" by including explicit work instructions in the work documents. When this phrase is continued to be used, and just before its implementation, a cognizant responsible person (i.e., engineering supervisor, maintenance planner, foreman, general foreman, shift engineer, SRO, C-4 level engineer) will review the work document and define the specific steps of any " applicable portions" of necessary instructions.
5.
Date When Full Compliance Will Be Achieved Full compliance will be achieved by March 1, 1987.
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ENCLOSURE 2 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION IN G. G. ZECH'S LETTER TO S. A. WHITE DATED SEPTEMBER 12, 1986 The following information is provided in response to the request for additional information made in paragraph 4 of the referenced notice of violation.
As described in section 4 (corrective steps taken to avoid further violations) of SQN's response to Notice of Violation 50-327, 328/86-43-01, (transmitted in letter to Dr. J. N. Grace from R. L. Gridley dated October 15, 1986) the Systems Engineering Section is now required to review WPs for adequacy of testing, and as of August 25, 1986, WPs entering the approval cycle must have the Systems Engineering Section entered in Item II of Attachment 2 (Workplan Control Form) AI-19, Part IV and routed and signed off accordingly. This requirement for review will remain in place until the Division of Nuclear Engineering (DNE) assumes this responsibility of reviewing WPs for adequacy of testing.
With regard to SQN's plans for reviewing WPs issued subsequent to those reviewed by the Postmodification Task Force, DNE is reviewing modification WPs on the 37 systems or portions of systems (systems identified as necessary to mitigate the consequences of and achieve and maintain hot standby following postulation of the Chapter 15 events) included in the Design Baseline and Verification Program (DB&VP) to verify the adequacy of this testing.
This effort will be completed upon conclusion of the DB&VP which is scheduled to be completed before unit 2 restart (Note: The DB&VP will review the remaining safety-related systems after unit 2 restart).
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ENCLOSURE 3 LIST OF COMMITMENTS CONTAINED IN ENCLOSURES 1 AND 2 1.
Plant Superintendents or Plant Manager are to review the use of temporary or urgent changes beginning November 1, 1986, until March 1, 1987.
2.
Evaluate the procedure change process as described in AI-4 and identify any necessary corrective actions (i.e., revisions) by November 30, 1986.
3.
Review administrative instructions by March 1,1987 to determine if revisions are necessary to ensure explicit work instructions are provided.
4.
By November 30, 1986, issue directions to plant personnel to reduce use of " perform the applicable portions" by including explicit work instructions in the work documents.
5.
DNE will complete the review of modification WPs as included in the DB&VP by unit 2 restart for the 37 systems or portions of systems identified.
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