ML20214J231
| ML20214J231 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 11/13/1986 |
| From: | Gass K, Knightly J, Stewart D TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20214H850 | List:
|
| References | |
| SWEC-SQN-37, SWEC-SQN-37-R, SWEC-SQN-37-R00, NUDOCS 8612010219 | |
| Download: ML20214J231 (11) | |
Text
,
d TVA EMPLOYEE CONCERNS REPORT NUMBER: SWEC-SQN-37 SPECIAL PROGRAM REPORT TYPE: Sequoyah Nuclear Plant Element REVISION NUMBER: 0 TITLE: Operational Safety Verification REASON FOR REVISION: N/A i
SUMMARY
STATEMENT: The items in this report were identified by the Nuclear i Regulatory Commission (NRC) and were included in the Stone & Webster Engineering Corporation (SWEC) systematic analysis. All items evaluated within this report t were verified to be adequately addressed and SWEC concerns A02 850806 014 -001, t -002, -003, -004 were closed by NRC. Concern A02 850806 014 -006 is now ready for closure and concern A02 850806 014 -005 was not an NRC numbered item.
PREPARATION PREPARED BY:
' O Y Qb ltfbfdb SIGNATUREI DATE l
. REVIEWS PEER:
Wf _W1 //- /,- 9 L DATE SIGNATURE ff / '
e $ h SIGNATURE DATE CONCURRENCES CEG-H: MJ.- Iflllffe
- I 'I SRP: / N'l7~N SIGNATURE DATE SIGNATURE
- DATE APPROVED BY:
/["/3"b N/A ECSP MANAGBR DATE MANAGER OF NUCLEAR POWER DATE q
i CONCURRENCE (FINAL REPORT ONLY)
- SRP Secretary's signature denotes SRP concurrences are in files.
2242T 8612010219 DR 861117
- p ADOCK 05000327 i - _ -
w
TENNESSEE VALLEY AUTHORITY WATTS 8AR NUCLEAR PLANT EMPLOYEE CONCERNS TASK GROUP OTHER SITES CEG Element
Title:
NRC Concerns July 1985 SWEC Concerns: A02850806014-001
-002
-003
-004
-005
-006 j
Source Document: NRC Inspection Report No. 50-327, 328/85-23 Report Number: SWEC-SQN-37 r
Evaluator: /08 J. J. Inightly Date Reviewed by: M lo/or [f 6 A. G. Debbap6 Date/
Approved by: M /0/Of[f[,
R. C. SaW6r " Dat'e
. 1814T l'
r I.
SWEC-SQN-37 NRC Inspection Report 327.328/85-23 I. INTRODUCTION 1
During a routine inspection in the areas of operational safety i
verification, June 6 through July 5, 1985, ' the Nuclear Regulatory l Commission (NRC) resident identified and reported (reference 1) several violations (Viol), inspector follow-up items (IFI), and general.
comments (327, 328/85-23-01, -03, -02, -05, -08), which were addressed as six issues in the Stone & Webster Engineering Corporation (SWEC) systematic analysis, as follow:
3 (1) A02850806014-001 (Viol 85-23-01) Storage Control of Stainless Steel j Piping (2) A02850806014-002 (Viol 85-23-03) Display of Site Security ID Badges (3) A02850806014-003 (Viol 65-23-02) Key Card to Radiation Work Permit (RWP) Record Verifications (4) A02850806014-OO4 (IFI 85-23-05) Dose Rates Estimations (5) A02850806014-005 (Unnumbered concern) Ice Condenser Door Block i
Control (6) A02850806014-006 (IFI 85-23-07, -08) Maintenance Request Specificity l Information on the background, corrective actions taken, verification methodology, verification analysis, completion status, and pertinent references for these six issues is included in this report.
II. SWEC ISSUES A. A02850806014-001, Storage Control of Stainless Steel Pipinq
- 1. Background During a follow--up review of corrective actions for a previously identified NRC violation (372, 328/83-12-01) related to storage of stainless steel piping, the NRC inspector identified adequate storage practices within the Power Stores i and Shop Stores areas of responsibility. However, a situation l similar to the previous Power Stores violation was identified
) in a stainless steel storage area within the Auxiliary
[ Building. Contrary to requirements of TI-70, " Cleaning and
( Decontamination of Plant Equipment," (reference 2) stainless L steel material was stored without the ends capped or taped in L the proper manner (NRC violation 85-23-01).
I Page 1 of 9 8 - . , - _-.-.-._.-;._...__--..--_-----__._... -.. - ,, - , . . - -. - . ,
- 2. Corrective Actions Taken 1
Sequoyah Nuclear Plant's (SQN) response to the NRC (reference 3) stated that TI-70 was unnecessarily inflexible, in that no flexibility for the capping requirement was i
available while the stainless steel material was in the
=
fabrication or installation stage. SQN revised the technical
, instruction and scheduled training sessions for craft personnel 7 to emphasize the handling requirements.
1
( 3. Verification Methodology 3
$ The SWEC concern identified for Employee Concerns Task Group j (ECTG) verification was stated as follows:
l j RIMS Number Issue RIMS Item i
j A02850806014 Stainless steel piping RIMS-001 and flanges stored in an Auxiliary Building designated storage area were not sealed with plugs or tape contrary to Quality
)i Assurance (QA) Program requirements.
h ECTG reviewed the SQN Compliance Licensing files for internal and external correspondence related to this issue, applicable procedures, and NRC tracking and closure files. This review of the pertinent documentation formed the basis for this verification activity.
4 '. Verification Analysis 0
The ECTG review of the pertinent documents indicated that the
} NRC item was adequately resolved as follows:
j (a) Procedure TI-70 was revised August 13, 1985, to clarify g requirements for end caps by providing for flexibility a during fabrication and installation.
q (b) Documentr:d training concerning handling and storage of J stainless steel piping was performed and completed 1 January 17, 1986.
- l 0 (c) The NRC closed the violation in report 327, 328/86-06 j (Reference 4).
12 l 5. Completion Status l, Based on SQN's corrective actions and NRC's closure of the violation, this SWEC issue is considered closed.
l' Page 2 of 9 i
l' L
B. A02850806014-002 - Display of Site Security ID Badges
- 1. Background During routine walkdowns within the protected area, the NRC inspector observed one employee witnin a group of 12 who did not have his identification badge in his possession and another not displaying the badge correctly. (NRC violation 85-23-03)
- 2. Corrective Actions Taken SQN stated that both employees had been wearing shirts as outer garments. One had taken off his shirt, leaving it with his badge affixed in the truck. The other had put his shirt back on after previously taking it off, forgetting to place his visitor's badge on the outside of the shirt from his inner garment. Both individuals corrected the problem on the spot when told. SQN stated that correct procedures were in place and that training / instructions were adequate.
- 3. Verification Methodology 4
2 The SWEC concern identified for ECTG verification was stated as
- follows
i RIMS Number Issue RIMS Item i
A02850806014 Failure to display RIMS-OO2 identification badges according to security
- procedure. Two construction workers.
- cited.
ECTG reviewed the SQN Compliance Licensing files for internal and external correspondence related to this issue, applicable procedures, and the NRC tracking and closure files. This j review formed the basis for this verification activity.
- 4. Verification Analysis
$ The ECTG review of this issue indicated that the NRC violation l was adequately resolved as follows:
i l (a) During follow-up review in April 1986, the NRC stated that
, " observations of individuals over the past six months have i indicated that personnel are properly displaying picture badges." (Reference 5, page 2)
(b) The violation was closed by the NRC (reference 5),
f j Page 3 of 9 l
f -- - - . --- ..- - -- - - - -
m . _ - .. - . ___ _ . . . _ __m. _ _ _ _ - . . __
(c) During several plant inspections at SQN, ECTG saw no cases where picture badges were improperly displayed within the protected areas.
, 5. Completion Status i
Based on SQN's compliance with requirements and NRC's closure of this violation, this SWEC issue is considered closed.
{ C. A028506014-003 - Key Card To RWP Record Verifications l 1. Background This issue concerning periodic comparison of radiation work permit (RWP) data and key card entry data was identified by the NRC as a violation (Ai-23-02). An NRC audit of SQN's
! corrective action response from a previous violation (83-31-01) indicated that SQN had failed to take corrective actions regarding the conduct of periodic RWP/ key card comparisons.
These comparisons were not a regulatory requirement and had not been implemented by SQN but were included in SQN procedures and commitments.
- 2. Corrective Actions Taken SQN provided a response (reference 3) to the 1985 violation and, concurrently a revised response (reference 7) to the
, earlier 1983 violation. These responses deleted the commitment for checks of key card records. The responses were found acceptable to the NRC, and the items were closed by NRC in April 1986 (reference 5). SQN reviewed all open and closed NRC commitments as discussed in the SQN Nuclear Performance Plan, section 3.2, in order to identify and schedule any other missed actions. The SQN commitment to prompt corrective actions was l reiterated.
l
- 3. Verification Methodology 1 The SWEC concern identified for ECTG verification was stated as
- follows
RIMS Number Issue RIMS Item
( A02850806014 TVA response to NRC RIMS-003 committed to periodic checks of key cards data against RWP records.
Corrective action not implemented.
4
- Page 4 of 9
/
ECTG reviewed the SQN Compliance Licensing files for internal and external correspondence related to this . issue, the Nuclear Performance Improvement Flan, and the NRC tracking and closure files. This documentation review formed the basis for this verification activity.
- 4. Verification Analysis The ECTG review of this issue indicated that the SQN corrective actions had been completed. SQN's commitment to providing appropriate due dates and to meeting these commitments is described in the SQN Nuclear Performance Plan, Section II-2.5,
" Corrective Action," which outlines the steps taken to improve overall, corrective action performance.
- 5. Completion Status Based on SQN's corrective actions, NRC closure of the items, and commitments in the SQN Nuclear Performance Plan, activities pertaining to the SWEC concern have been completed. The concern is closed.
D. A02850806014-OO4 - Incorrect Dose Rate Estimates
1. Background
] The NRC inspector determined that on two separate occasions, j individuals who requested dose records upon terminating i assignments were given incorrect written estimates for the time periods requested. In both cases, the estimates indicated a dose higher that that received and were therefore, conservative. The item was identified as an Inspector Followup
- Item (IFI 85-23-05) pending NRC Region II review of additional l licensee dose records.
! 2. Corrective Act: ions Taken i
j SQN provided additional licensee dose records for NRC review and explained SQN's basis for recording dose rates. This
- explanation was not documented but occurred March 1986 g according to SQN compliance personnel. Following review and j evaluation, the item was closed by the NRC in Reference 5.
I L 3. Verification Methodology j The SWEC concern identified for ECTG verification was stated as follows:
i h
l Page 5 of 9 l-
RIMS Number Issue RIMS Item A02850806014 Incorrect written estimates RIMS-004
(
of dose rates for radiation workers were received from Operations. Doses were conservative.
ECTG reviewed the SQN compliarce licensing files for internal and external correspondence related to this issue and the NRC
- tracking and closure files. This review, in addition to discussion with SQN compliance engineering personnel, formed
{ the basis for this verification activity.
a
] 4. Verification Analysis g
The ECTG review of this issue indicated that the NRC follow-up
( item was satisfactorily resolved and that the item was closed j by the NRC April 4, 1986.
- 5. Completion Status 4
j Based on SQN's compliance with requirements and NRC closure of j
this item, the SWEC concern is closed.
E. A02850806014-005 - Inadequate Door Block Controls on the Ice Condenser
- 1. Backaround h
h In conjunction with an operational verification of the ice
! condenser on unit 1, it was determined by the NRC that j procedures to control observations of the ice condenser doors
/ to assure their operability do not control removal of door l blocking devices individually. This was a concern because the
? blocking devices, if not removed before plant operation, could make the ice condenser inoperable. Blocking devices were not identified individually, and no signoff was required for each device. During the NRC investigation, SQN committed (refer-ence 1, page 9) to revise administrative controls or to justify the current practices. No NRC violation or followup, or SQN commitment cate was specified.
I
- 2. Corrective Actions Taken The NRC inspection report (reference 1) states that "this deficiency was discussed with the licensee and a commitment obtained frem the licensee to justify the practice or revise administrative controls." Subsequently, controls were revised through development of a new maintenance instruction, MI-5.4
" Blocking of Ice Condenser Lower Inlet Doors During Cold Shut-down" (revision 0, September 6,1985).
Page 6 of 9 e
r
- 3. Verification Methodology The SWEC concern identified for ECTG verification was stated as follows:
RIMS Number Issue RIMS Item A02850806014 Procedures for Administrative RIMS-005 Control of door blocking devices for the ice condenser do not control individual removal of each blocking device & verify, ECTG discussions with SQN Licensing and Maintenance personnel, in addition to review of the SQN compliance licensing files and the applicable maintenance instruction, formed the basis for this verification activity.
- 4. Verification Analysis The ECTG review of this issue verified that the maintenance instruction MI-5.4 contained appropriate provisions for control i
of door blocking devices. These provisions include (1) numbering of devices for each bay (numbers 1 through 24);
(2) sign-off for installation of each block; and (3) two-party sign-off for removal of each block.
- 5. Completion Status ECTG verified that SQN now has in place an appropriate procedure for control of door blocking devices for the ice i condenser. Because there was no NRC violation or follow-up specified, there will be no NRC closure for this item. Based on SQN's corrective action, this SWEC issue is closed.
F. A02850806014-C06 - MR Information Lacking
- 1. Background During observations of corrective maintenance activities
! concerning an electropneumatic transducer regulating current to a pneumatic converter for a unit 1 auxiliary feedwater system j level control valve, the NRC inspector identified the following problems: (1) maintenance work sheets did not clearly describe work to be performed, and (2) maintenance work sheets did not i
include sufficient information on special equipment needed.
These problems were identified as Unresolved Item 85-23-07 and Inspector Follow-up Item 85-23-08, respectively.
Page 7 of 9
, - - - -. - - . = .- . _ .
l
- 2. Corrective Actions Taken SQN issued a September 5, 1985 revision to Instrument Maintenance Instruction, IMI-134, " Configuration Control of Instrument Maintenance Activities." The purpose of this revision was to provide specific guidance for effective preparation of the maintenance work sheet.
- 3. Verification Methodology.
The SWEC concern identified for ECTG verification was stated as follows:
RIMS Number Issue RIMS Item P02850806014 Maintenance Request did not RIMS-006 include all information required by procedures. (No explicit work instructions, no special tool listed, excessive referencing)
ECTG discussions with SQN Licensing personnel, in addition to review of the applicable procedure (reference 6), and NRC tracking and closure files, formed the basis for this verification activity.
- 4. Verification Analysis The ECTG review of this issue indicated that the SWEC issue has been satisfactorily addressed by the SQN corrective action.
The present revision (September 5, 1985) of the IMI-134 instruction provides clear step-by-step guidance to the preparers of maintenance work sheets. It is expected by SQN that NRC followup on the maintenance request issues will find the work descriptions and backup information satisfactorily
! defined.
- 5. Completion Status The NRC issues remain open at the present time. Based on SQN corrective actions, these issues are ready for closure.
t Following the NRC closure, the SWEC issues will be considered closed.
I i
Page 8 of 9
III. REFERENCES
- 1. NRC Inspection Report numbers 50/327/85-23 and 50-328/85-23, dated August 2, 1985, from D. M. Verrelli to H. C. Parris
- 2. Technical Instruction TI-70, " Cleaning and Decontamination of Plant l Equipment," revision, August 13, 1985
- 3. TVA Letter, "Sequoyah Nuclear Plant Units 1 and 2 - NRC-OIE Region
! II Inspection Report 50-327/85-23 and 50/328/85 Response to Violations," dated August 29, 1985, from J. A. Domer to J. Nelson Grace
- 4. NRC Inspection Report Nos., 50-327/86-06 and 50-328/86-06, dated March 5, 1986
\
- 5. NRC Inspection Report Nos. 50-32/86-15 and 50-328/86-15, dated April 4, 1986 B
- 6. Instrument Maintenance Instruction (IMI-134), Configuration Control of Instrument Maintenance Activities
- 7. TVA Letter, "Sequoyah Nuclear Plant Units 1 and 2 - NRC-OIE Region II Inspection Report 50-327/83-31 and 50-328/83 Revised Response to Violations," dated September 9,1985, from J. A. Domer to J. Nelson Grace i
L i
I Page 9 of 9 h >