ML20237E698

Notice of Violation from Insp on 871019-30.Violations Noted:Licensee Failed to Adequately Establish,Implement & Maintain Procedures for Configuration Control & Provide Adequate Sys Operating Instruction SOI-63 for ECCS

ML20237E698
Person / Time
Site:	Sequoyah
Issue date:	12/21/1987
From:	Barr K NRC OFFICE OF SPECIAL PROJECTS
To:
Shared Package
ML20237E678	List: IR 05000327/1987066 ML20237E676 ML20237E698
References
50-327-87-66, 50-328-87-66, NUDOCS 8712290134
Download: ML20237E698 (3)

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ENCLOSURE 1 NOTICE OF VIOLATION Tennessee Valley Authority Docket Nos. 50-327 and 50-328 Sequoyah License Nos. DPR-77 and DPR-79 During the Nuclear Regulatory Commission (NRC) inspection conducted on October 19-30, 1987, violations of NRC requirements were identified. The violations involved failures to adequately establish, implement, and maintain written procedures. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1986), the violations are listed below:

A. Technical Specification (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.

The requirements of TS 6.8.1 are implemented by Administrative Instruction AI-2 titled " Authorities and Responsibilities for Safe Operation and Shutdown", Administrative Instruction AI-4 titled " Preparation, Review, Approval and Use of Plant Instructions", and Administrative Instruction AI-30, titled " Nuclear Plant Method of Operation." Operation Section Administrative Letter OSLA-58, titled " Maintaining Cognizance of Opera-tional Status - Configuration Control", implements the requirements of AI-2 and AI-30 for maintaining configuration control.

Contrary to the above, prior to October 30, 1987, the licensee failed to adequately establish, implement, and maintain procedures for configuration control as follows:

1. The licensee failed to adequately specify when configuration control should start in that OSLA-58 requires the unit's lead operator to maintain configuration control records only after the System Operating Instruction (501) checklists are completed, but not while the checklists are in progress.

2. The licensee failed to specify in AI-2 or OSLA-58 an appropriate method for deviating from SOI checklists in that deviations to SOI checklists were not considered as procedure changes. Because of j this, the licensee did not use the appropriate criteria or approval ,

level for processing deviations. I

3. The licensee failed to adequately implement the requirements in AI-4 and OSLA-58 for the use of working copies of SOI checklists in that )

the completed working copy for SOI valve checklist 68.1A indicated 8712290134 871221  !

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1 Tennessee Valley Authority '2 Docket Nos. 327, 328 Sequoyah License Nos. DPR-77 and DPR-79 the checklist was not properly performed while the final copy did not. AI-4 requires that information be transferred from the working copy to the final copy after the completion of work.

4. The licensee failed to implement the requirements in OSLA-58 for recording of deviations from SOI checklists in that the designated unit operator was not placing the date next to his initials when deviating an item on the status file copies of checklists as required by OSLA-58.

5. The licensee -failed to implement the requirements in OSLA-58 for maintaining configuration control after 50I checklists are complete in that the documented positions in the configuration control system for the four Reactor Coolant Pump Seal Return Flow Control Valves, the Excess Letdown Heat Exchanger Supply Containment Isolation Valve, and the three Boron Injection Tank recirculation valves disagreed with the actual positions.

6. The licensee failed to implement the requirements in OSLA-58 for processing a revision to SOI checklist 63.1d in that the configura-tion log entries for RHR supply valves 2-FCV-74-1 and 2-FCV-74-2 were cleared when the checklist revision was received without reperforming the portion of the checklist that had been revised. This resulted in the documented positions in the configuration control system being in disagreement with the actual positions.

This is a Severity Level IV violation (Supplement I).

B. Technical Specification 6.8.1 requires that procedures recommended in Appendix "A" of Regulatory Guide 1.33, Revision 2, be established, implemented, and maintained. Appendix A of Regulatory Guide 1.33 requires procedures for startup, operation, and shutdown of safety related PWR systems.

Contrary to the above, prior to October 30, 1987, the licensee failed to provide an adequate System Operating Instruction (50I-63) for the Emergency Core Cooling System as follows: 1

1. The licensee failed to provide for the initial positioning of all '

system 63 valves and blank flanges in that 501-63 valve checklists do i not specify or verify the positions of the root valves to RWST level )

transmitters 2-63-46, 2-63-49, 2-63-50, 2-63-51, 2-63-52, and 1 2-63-53; the root valve to pressure instrument 2-63-74; and the

. flanges downstream of valves 2-63-599 and 2-74-549.

2. The licensee failed to provide for the initial positioning of all system 63 electrical equipment in that 501 power . availability checklist 63.1d does not specify the positions for the power supply breakers to control valves 2-HIC-74-16, 2-HIC-74-32, and 2-HIC-74-28.

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Tennessee Valley Authority 3 Docket Nos. 327, 328 Sequoyah License Nos. DPR-77 and DPR-79 l 3. The licensee failed to provide adequate instructions to ensure specified fuses were installed for system 63 electrical equipment in that the locations for the penetration and penetration control fuses for 2-FCV-63-67 on 50I power availability checklist 63.1A-8 were not adequately specified on the checklist or reference print.

This is a Severity Level IV violation (Supplement I).

Pursuant to the provisions of 10 CFR 2.201, Tennessee Valley Authority is hereby required to submit to this Office within 30 days of the date of the letter transmitting this Notice a written statement or explanation in reply including (for each violation): (1) admission or denial of the violation, (2) the reason for the violation if admitted, (3) the corrective steps which have been taken and the results achieved, (4) the corrective steps which will be taken to avoid further violations, and (5) the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending the response time.

FOR Tile NUCLEAR REGULATORY COMMISSION ORIGINAL SIGNED BY KENNETH D. BARR Kenneth P. Barr, Acting Assistant Director for Inspection Programs TVA Projects Division Office'of Special Projects Dated at Atlanta, Georgia this o nc day of December 1987

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