ML20236B303

Responds to Violations Noted in Insp Repts 50-327/87-18 & 50-328/87-18.Corrective Actions:Condition Adverse to Quality Rept SQP870373 Written to Document Failure to Follow Procedure & Work Request Replanned

ML20236B303
Person / Time
Site:	Sequoyah
Issue date:	07/24/1987
From:	Gridley R TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NUDOCS 8707290051
Download: ML20236B303 (11)

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TENNESSEE VALLEY. AUTHORITY CHATTANOOGA, TENNESSEE 374o1/

SN 157B Lookout Place l

JUL 241987 l

Ul.3. Nuclear Regulatory Commission ATTNi ' Docttment Control Desk Washington, D.C. 20555 Centlemen:

In the Matter of ): Docket hos. 50-327 Tennessee Valley Authority; ). 50-328 SEQUOYAH NUCLEAR PLANT (SQN) - UNITS 1 AND 2 - NRC INSPECTION' REPORT NOS.

50-327/87-18 AND 50-328/87 VIOLATION RESPONSE NRC Inspection Report Nos- 50-327, -328/87-18 cited TVA with one violation--50-327, -328/87-18-01, Severity Level IV. ~ The Notice of Violation contained nine examples. Our response to each of the nine examples is enclosed.

If you have any questions, please telephone M. R. Harding at 615/870-64E2.

To the best of my knowledge, I declare the statements' contained herein are.

complete and true.

Very truly yours, TENNESSEE VALLEY AUTHORITY R. Gridley,

. rector Nuclear Safe y and Licensing Enclosures cc: See page 2 1

l 87072'r0051 870724 .

7 PDR ADDCK 05000327' G PDR ,_ g l

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An Equal Opportunity Employer

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=U.S. Nuclear Regulatory Commission cc (Enclosures):

Mr. G. G. Zech,' Assistant Director for. Inspection Programs

-Office of Special Projects ,)

U.S. Nuclear Regulatory Commission

101 Marietta Street, NW, Suite'2900 Atlanta : Georgia 30323 l Mr. J. A. Zwolinski,' Assistant Director for. Proj ects Division of TVA Projects Office of Special Projects U.S. Nuclear Regulatory Commission 4350 East West Highway EW 222 Bethesda, Maryland 20814 Sequoyah Resident Inspector Sequoyah Nuclear Plant l 2600'Igou Ferry Road Soddy Daisy Tennessee 37379

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ENCLOSURE 1 Violation 50/327. -328/87-18-01 Jm During the Nuclear Regulatory Commission (NRC) inspection conducted on March 16-27 and April 13-17, 1987, a violation.of NRC ree,uirements was identified. The violation involved a failure to properly control postmodification testing. In accordance with the " General Statement of Policy .

and Procedure for NRC Enforcement Actions,".10 CFR 2, Appendix C (1985), the violation is discussed below.

Criterion XI of 10'CFR 50 Appendix B, as implemented by TVA Nuclear' Quality Assurance Manual (NQAM), Section 2.11', requires that a test program be

- established and conducted to assure that structures, systems and: components will perform satisfactorily in-service. In order-to accomplish that goal,

' Criterion XI requires that the test program be performed in accordance with written test procedures which incorporate applicable requirements 1and acceptance limits; that the test procedures include provisions for assuring all test prerequisites have been met and adequate test instrumentation is available and used; and that the test'results'are documented and evaluated to assure that test requirements have been met.

Contrary to the above, the.NRC inspectors identified cases in which the licensee failed to ensure that test procedures and instructions contained the I necessary requirements, that tests were performed in accordance with procedure requirements, and that test results were properly documented and evaluated.

These include the following examples (section numbers refer.to the body of the report):

1. During functional testing of containment isolation valves, handwritten changes were made to the approved test package without required signatures, initials, or approvals; the test instructions provided incorrect directions regcrding the energizing of a valve solenoid; and the cognizant engineer unilaterally changed the approved test instructions af ter test performance to reflect the test results (Section 4.b).

2. During component cooling system pump tests, the test procedure did not specify a proper switch alignment, breakers could not be closed because of the misalignment, and the discrepancy was not recorded by test personnel (Section 4.e.1).

3. During motor bump tests, inadequate instructions'resulted in the inadvertent start of a decoupled motor which also threw potentially contaminated grease on two persons outside the contamination zone .

(Section 4.e.2).

4. Three boron injection tank isolation valves were energized contrary to prccedure requirements, one of the valves was operated over a hold tag on-the valve control switch, and procedure steps were not. signed off as completed (Section 4.g).

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5. During functional and stroke time testing of a containment standpipe .l isolation valve, a faulty indicator dial was used to determine valve mid-position, .and there were no procedure instructions for determining valve full-open position (Section 4.1).

6. During testing of boric acid transfer pumps, the flow diagram in the-control room had incorrect piping class boundary designations, and inadequate test conditions were specified in the applicable surveillance instruction' (Sections 5.a.2 and 5.a.3).

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7. Discrepancies were found between procedure. sketches and field markings for vibration monitoring of the motor-driven and turbine-driven AFW j pumps, component cooling pumps, one RHR pump, and a boric acid' transfer pump (Section 5.a.4). l

8. Work activities, including disassembly and reassembly of-a bolted flange and other joints and cleanout of instrument tubing, were performed without work instructions, inspections, or second party verification of joint makeup (Section 5.a.5).

9. During functional testing of diesel generator room exhaust fans, a step verifying that red lights on the fan breaker were energized was signed off when, in f act, the panel lights were burned out- (Section 5.c).

This is a Severity Level IV Violation (Supplement II).

EXAMPLE 1 Admission or Denial of Aller.ed Violation TVA admits this example of the above violation occurred as stated.

Reason For Violation If Admitted The reason for the occurrence of this example of the violation was determined to be that personnel pecforming the functional tests were inexperienced in the procedural requirements and proper conduct of functional testing.

Corrective Steps Taken And Results Achieved Condition Adverse To Quality Report (CAQR) SQP870373 was written to document this failure to follow procedure. The work request (WR) was replanned to incorporate the necessary functional test changes and was reperformed .

successfully.

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Corrective Steps Taken To Avoid Further. Violations Short Term: A memorandum was issued from the plant Manager to the principal managers of the groups / sections onsite who are responsible for testing. This memorandum provided requirements for the conduct i of testing and required all group /section supervisors to ensure _.

all test directors have been trained in the requirements set forth in the memorandum.

Long Term: A new procedure was developed that defines and implements testing and responsibilities. This procedure was issued on July 15, 1987.

Date When Full Compliance Will Be Achieved Compliance was achieved on July 15, 1987.

EXAMPLE 2 Admission or Denial of Alleged Violation TVA admits this example of the above violation occurred as stated.

Reason For Violation If Admitted As stated, the test procedure for component cooling pump C-S did not specify the proper main control room (MCR) handswitch alignment The breakers could not be closed until the MCR handswitch position was changed from "Stop pull To Lock" to "A. Auto." This discrepancy was not recorded by the test engineer because of lack of training on Administrative Instruction (AI)-19, Part IV.

Corrective Steps Taken And Results Achieved l CAQR SQP870341 was written and appropriate personnel were trained on how to handle and document test deficiencies. Functional testing was suspended until functional test procedures were reviewed and determined to be adequate or were l revised.

Corrective Steps Taken To Avoid Further Violations l

Short Term: A memorandum was issued from the plant Manager to the principal -

1 managers of the groups / sections onsite who are responsible for testing. This memorandum provided reg irements for the conduct of testing and required all group / sect.un supervisors to ensu"? .

all test directors have been trained in the requirements set forth in the memorandum.

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Long Term

A new procedure was developed that defines and implements testing and responsibilities. This procedure was issued on July 15, 1987.

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Date When Full Compliance Will Be Achieved

• Compliance was achieved on July 15, 1987.

EKAMPLE 3 1 Admission or Denial of Aller,ed Violation i TVA admits this example of the above violation occurred as stated.

Reason For Violation If Admitted I

During the motor bump test.of the component cooling pump C-S, the motor J experienced an inadvertent start. Despite warning and instruction from 'the test director to stay clear of the coupling, observers did not do so and-grease was thrown on two individuals as a result of1the pump start.

Corrective Steps Taken And Results Achieved.

All functional. testing was stopped until procedural control of the prefunctional-test briefing was added to the work document. AI-19, Part IV, was revised to include the procedural control of prefunctional-test briefing.

Corrective Steps Taken To Avoid Further Violations Short Tenn: A memorandum was issued from the Plant Manager to the principal managers of the groups / sections onsite who are responsible for testing. This memorandum provided requirements for the conduct of testing and required all group /section supervisors _to ensure all test directors have been trained in the requirements set forth in the memorandum.

Long Term: A new procedure was developed that defines and implements testing and responsibilities. This procedure was issued on July 15, 1987.

Date When Full Compliance Will Be Achieved 1

Compliance was achieved on July 15, 1987.

. I EXAMPLE 4' &

3dmission Or Denial Of Alleged Violation I TVA admits this example of the above violation occurred as stated.

Reason For Violation If Admitted '3 TVA agrees that the hold order for valves 2-FCV-63-26A, ~39A, and -40B was released before the valves were.placed in the midposition as required by the functional test instruction. Also, the functional tests steps were not initialed or signed off at.the completion of each step. The reason for the occurrence of.these two items was determined to be that the personnel performing the functional test were inexperienced in the procedural requirements and proper conduct of functional testing.

An assistant shif t engineer (ASE) did operate a valve with a hold ' notice still attached to the. valve control switch in the MCR. However, the controlling form that prevents equipment operatian during a clearance is the clearance sheet. The ASE had released all personnel.from the clearance sheet; and, therefore, the. clearance boundary was no longer in effect at the time the.

valve was operated. The operator's action did not jeopardize any employee's safety.

Corrective Steps Taken And Results Achieved Corrective action taken in this instance was to implement retesting of devices in accordance with a sampling plan as specified by military specification (MIL-STD) 105D. To date, 17 of 20 retests have been successfully completed with no indications of any generic defielencies. The remaining three retests are scheduled to be complete by August 1, 1987. i A' night order was issued June 26, 1987, which emphasized the importance of removing hold notices from affected equipment following release of a clearance before operating the equipment.

Corrective Steps Taken To Avoid Further Violations Short Term: A memorandum was issued _from the Plant Manager to the principal managers of the groups / sections onsite who are responsible for testing. This memorandum provided requirements for the conduct ,

of testing and required all group /section supervisors to ensure all test directors have been trained in the requirements set- .

forth in the memorandum.

Long Term: A new procedure was developed that defines and implements testing and responsibilities. This procedure was-issued on July 15, 1987.

Date When Full Compliance Will Be Achieved Compliance was achieved on July 15, 1987.

EXAMPLE 5 r-Admission or Denial of Alleged Violation TVA denies this example of the above violation occurred as stated.

Peason For Denial The term "midposition" is a standard term used in functional test to convey approximate valve position to allow for verification of direction of valve travel without valve damage. Handcranking a valve to midposition is l considered to be within the skill of the craft, and it is not required that I the functional test procedure specify indication to use when performing this i task, 1

The functional test that was observed by the inspector was performed to ensure that valve 2-FCV-26-240 operated correctly following replacement of the motor l center taps. Following completion of the work request, (WR)-B219647, the valve was handcranked to midposition using skill of the craft to determine that position. Having midpositioned the valve, the test personnel conducting the test then stroke-tested the valve to the open position using the following acceptance criteria as documented in step 6 of the functional test procedure.

Valve goes full open Red light remains illuminated j Green light goes out Motor deenergizes at full open position It is our belief that this acceptance criteria is fully adequate to determine valve travel to its open position.

EXAMPLE 6 i

Admission or Denial of Alleged Violation l

TVA admits this example of the above violation occurred as stated.

I Reason For Violation If Admitted The incorrect piping class boundary designations discussed in the above violation were the result of an error on the as-constructed drawing. Review of the latest revision of the design drawing showed the correct piping class boundaries. .

As stated in the report, the initial valve lineup for the test was inadequate. The inadequate valve lineup occurred because surveillance instruction (SI)-304 did not reflect a November 4, 1986 revision that was made to system operating instruction (SOI)-62.5, which allowed an alternate valve lineup. Instead of recirculating to "B" boric acid tank (BAT), which is the

normal lineup for the 2A-A pump, it was actually in recirculation to "C" BAT.

The alternate alignment allowed flow through a two-inch line to B BAT instead of through a three-quarter-inch line and orifice to the C BAT. Reduced line resistance resulted in the low discharge pressure and low delta "p" causing the pump to fail to meet the acceptance criteria.

If this alternate lineup had existed on any previous tests, the pump would have failed to meet the acceptance criteria. The difference in the pipe resistance between the proper three-quarter-inch line with the orifice and the two-inch unrestricted line is such that the pump would never pass established acceptance criteria. A record check did not show any previous failures attributable to improper valve lineup. The pumps tested during the first quarter of 1987, after the SOI change, were acceptable.

Corrective Steps Taken And Results Achieved A revision will be made to the as-constructed drawing to correct the error.

This revision will be made before August 7, 1987. This is considered an isolated incident, and no further corrective action is planned.

A temporary change, (TC)87-379, was written to incorporate the SOI change into SI-304.  ;

1 Corrective Steps Taken To Avoid Further Violations l

Corrections made to SI-304 by TC 87-379 will be made permanent before restart of unit 2.

Date When Full Compliance Will Be Achieved Compliance will be achieved before unit 2 restart, j l .

I EXAMPLE 7 l Admission or Denial Of Alleged Violation TVA admits this example of the above violation occurred as stated.

Reason For Violation If Admitted Because of manpower allocations, the person taking the vibration readings was not the usual person taking the data, and he was not familiar with the exact location to place the pickup. The location markings had been painted over during recent maintenance. He therefore placed the pickup in the general area of the inboard pump bearing, vertical and horizontal, in accordance with American Society of Mechanical Engineers (ASME)Section XI.

Corrective Steps Taken And Results Achieved All locations for Section XI vibration testing were reverified and remarked as necessary by Mechanical Test personnel.

Corrective Steps Taken To Avoid Further Violations Short Term: A memorandum was issued from'the Plant Manager to the principal managers of the groups / sections onsite who are responsible for testing. This memorandum provided requirements for the conduct of testing and required all group /section supervisors to ensure all test directors have been trained in the requirements set forth in the memorandum.

Long Term: A new procedure was developed that defines and implements testing and responsibilities. This procedure was issued on July 15, 1987.

Date When Full Compliance Will Be Achieved 1

Compliance was achieved on July 15, 1987.

EXAMPLE 8 Admission or Denial of Alleged Violation TVA denies this exataple of the above violation occurred as stated.

Reason For Denial l The instrument mechanics did install temporary test gauges in support of I SI-304. These gauges are not part of the critical structures, systems, and components list. They did remove the gauge and cleaned out, "rodde#d,"

approximately three inches of crystallized boric acid from the tubing at the gauge. This did not clear the line so the line was heated with a heat gun and the boric acid clog broke free, allowing the gauge to indicate pressure. No inspections or second-party verifications are required for making up tubing joints or gauge joints. The installation and removal of the test gauges are, however, provided for in SI-304 with first- and second-party verification required. Both the installation of test gauges and the cleaning out of sense i lines are within the daily skill of the craft. We can find no evidence that instrument personnel removed or rebolted the flange mentioned in the report.

EXAMPLE _9 Admission or Denial Of Alleged Violation TVA denies this example of the above violation occurred ar stated.

Reason For Denial l The description of the events that led to this example of.the above violation l l is incorrect. The first test on diesel generator 2B-B was started; and during the test. performance, it was discovered that the red indicating lights were burned out. A search was undertaken to obtain replacement bulbs. Replacement i bulbs were obtained from other compartments, and testing was resumed. At this point, the red lights were verified energized and the test step was signed off as complete. At the completion of the testing of the other fans, enough replacement bulbs were obtained to relamp all panels. This was completed I before the end of the shift.

. . . . e ENCLOSURE 2 COMMITMENTS

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1. In accordance with a sampling plan as specified by military specification (MIL-STD) 105D, 20 devices will be retested by August 1, 1987.

2. A revision will be made to the 47W809-5 as-constructed drawing to correct _

piping class designation errors. This revision is to be complete before August 7, 1987.

3. Corrections made to SI-304 by TC 87-379 will be made permanent before restart of unit 2.

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