ML20237H685
| ML20237H685 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 08/27/1987 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8709030359 | |
| Download: ML20237H685 (10) | |
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a TENNESSEE VALLEY AUTHORITY CHATTANOO3A, TENNESSEE 374o1 SN 157B Lookout place l
AUG 271987 U.S. Nuclear Regulatory Commission ATTN:
Document Control Desk 4
Washington, D.C.
20555 Gentlemen:
In the Matter of
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Docket Nos. 50-327 Tuanessee Valley Authority
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50-328 SEQUOYAH. NUCLEAR PLANT (SQN) UNITS 1 AND 2 - NRC INSPECTION REPORT NOS.
50-327 -328/87 RESPONSE TO VIOLATION NOS. 50-327, -328/87-30-02 AND 50-327, -328/87.-30-07 Enclosed is our response to Gary G. Zech's July 20, 1987 letter to S. A. White that transmitted the subject Notice of Violations.
Enclosures 1 and 2 provide our response to the Notice of Violations. Enclosure 3 contains the list of commitments contained in enclosures 1 and 2.
TVA does not recognize any other items described herein as commitments.
If you have any questions, please telephone M. R. Harding at 615/870-6422.
To the best of my knowledge, I declare the statements contained herein are complete and true.
Very truly yours, TENNESSEE VALLEY AUTHORITY R. L. Gridley, irector Nuclear Safet and Licensing Enclosures cc:
See page 2 l-8709030359 870827 DR ADOCK 05000327 PDR ZG of An Equal Opportunity Employer
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o l U.S. Nuclear Regulatory Commission AUG 271987 cc'(Enclosures):
Mr. G. C. Zech, Assistant Director for Inspection Programs Office of Special Projects U."
Uuclear Regulatory Commission 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Mr. J. A. Zwolinski, Assistant Director j
for Projects Division of TVA Projects 1
Office of Special Projects U.S. Nuclear Regulatory Commission j
4350 East West Highway EWW 322 Bethesda, Maryland 20814 1
Sequoyah Resident Inspector l
Sequoyah Nuclear Plant 2600 Isou Ferry Road-Soddy Daisy. Tennessee 37379 l
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'l-ENCLOSURE 1 RESPONSE - NRC INSPECTION REPORT NOS. 50-327/87-30 AND 50-328/87-30 GARY G. ZECH'S LETTER TO S. A. WHITE DATED JULY 20, 1987 Violation 50-327 -328/87-30-02 TS Section 6.5.2 requires that the Nuclear Safety Review Board (NSRB). review specific activities and be cognizant over certain audit activities. This TS
.also requires that a quorum be present to conduct these activities.
i TS 6.8.1.a requires that written procedures be established and imple.Sonted for activities recommended in Appendix "A" of Regulatory Cuide 1.33, Revision 2, I
February 1978, which includes administrative procedures.
The established administrative guidance in Revision 12 of the NSRB charter requires that meeting minutes and review results be issued within 14 days to the Manager of Power with copies to the General Manager and the TVA Board.
1 Contrary to the above, the requirements of the TS are not being satisfied, in that, the current practice of using a ballot method (in lieu of discussion in a formal meeting) to conduct the TS required reviews and audit oversight does I
not ensure a quorum is present for those reviews and does not provido the
-required oversight.
Contrary to the above, the requirements of the NSRB charter are not being implemented, in that, the current practice is for the NSRB Chairman to provide meeting minutes and board recommendations only to the Manager, Office of Nuclear Power, and not to the TVA Board.
This is a Severity Level IV violation (Supplement I).
Admission or Denial of the Alleged Violation TVA admits both issues cited in the violation.
Reason for the Violation 1.
The NSRB is interested in providing only the most definitive advice to the Manager of Nuclear Power.
The NSRB was concerned that excessive processing of nonproductive reviews could possibly cause a dilution of serious consideration to subjects under review. Therefore, to avoid this possible problem, sequential (balloting) reviews without a documented collegial review were permitted.
2.
To give better evidence of official acknowledgment, the Manager of Nuclear Power decided that he should transmit the minutes to the TVA Board and General Manager.
NSRB procedures were modified, but the charter was not because this method of NSRB minutes distribution was considered to be a process above and beyond that required by the charter.
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Corrective Actions Taken and Results Achieved 1.
Reviews accomplished using the balloting method will be assessed for the need of a collegial review.
As a minimum, all technical specification changes using the balloting method will be rereviewed using the collegial method.
2.
The NSRB charter has been revised to reflect current practice.
Corrective Steps Which Will Be Taken to Avoid Further Violations, 1.
NSRB procedures will be revised to provide better evidence of collegial review of the topics listed in the technical specifications.
Concurrently, a review and potential revision of section 6 of the technical specifications are being undertaken with the intent of clarifying them, aligning them among TVA sites, and aligning them with standard technical specifications.
l 2.
No further actions other than those actions cited in the " corrective Actions Taken and Results Achieved" section are needed.
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Date When Full Compliance Will Be Achieved 1.
Rereviews of technical specification revisions will be completed by September 18, 1987. NSR3 procedures will be revised by January 1, 1988.
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ENCLOSURE 2 RESPONSE - NRC INSPECTION REPORT NOS. 50-327/87-30 AND 50-328/87-30 CARY C. ZECH'S LETTER TO S. A. WHITE DATED JULY 20, 1987 Violation 50-327. -328/87-30-07 Technical Specification (TS) 6.8.1 states that written procedures shall be established, implemented and maintained covering surveillance and test activities of safety related equipment.
1.
Special Test Instruction (STI)-17 was established to demonstrate, through DC high voltage tests, the integrity of the insulation on selected 1E cables in a vertical drop configuration.
Contrary to the above, STI-17 was inadequately established, in that on April 22, 1987, it was performed to test certain Silicone Rubber insulated conductors without requiring the technicians to disconnect the lower rated Conax connectors that were inadvertently left in the circuit.
2.
Surveillance Instruction (SI)-196, Periodic Calibration of Upper Head Injection System Instrumentation, Step 3.4, states that during the performance of the stroke timing test, 'The three (3) valves not under test should be closed, gagged, and the gag motors de-energized.'
Contrary to the above, during a May 27, 1987 performance of SI-196, valve 2-FCV-87-21 was stroke time tested in Section 6 of the procedure and the gag motors to 2-FCV-87-22, 23 and 24 were not de-energized.
3.
Work Plan (WP) 12298, following cable rerouting in the Unit 2 west valve room, specified testing to be performed in order to verify the proper functioning of valve 2-FCV-1-16.
Accordingly, steps 5, 6 and 9 of the specified test required the following:
Step 5 Start handcranking 2-FCV-1-16 to the open position. At approximately 5% valve travel from the closed position, verify the red and green lights are on.
Step 6 Continue handcranking 2-FCV-1-16 to the open position. At approximately 95% valve travel from the closed position, verify the following.
Red light on, green light off.
Status monitor relay Al-6 is de-energized.
Status monitor relay Al-5 is still energized.
Open motor starter has dropped out.
Step 9 With the close motor starter still picked up, verify the following sequence of steps for 2-FCV-1-16.
a.
Momentarily open the contacts on limit switch (LS)-8 and verify the close motor starter does not drop out.
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Momentarily open the torque switch close contacts and.
verify the close motor starter does not drop out.
c.
Simultaneously open the contacts on LS-8 and the torque switch close contacts and. verify the close motor starter drops out.
Contrary to the above, on May 29,1987, steps 5 and 6 were performed with the valve being operated manually without indication of the approximate (5% and 95%) valvo position.
Contrary to the above, on May 29,1987, steps 9.a and 9.c were performed util'. zing the wrong Limit Switch (LS-15 instead of LS-8) and a test def1 lency was not written.
This is a Severity Level IV violation (Suppicment I).
Admission or Denial of the Alleged Violation Item 1.
TVA admits to having an inadequate test procedure. However, it should be noted that the Conax connectors were of the same voltage rating as the conductors, contrary to the statement in the violation.
Item 2.
TVA denlos the alleged violation as stated.
Item 3.
TVA admits the violation with respect to functionni test steps 5 and 6 of workplan (WP) 12298 not being followed, and with respect to functional test steps 9.a and 9.c of WP 12298 being performed on the wrong limit switch and a test deficiency not being written upon discovery of the error.
Reason for the Violation Item 1.
Special Test Instruction (STI)-17, "DC High Voltage Test for Selected Unit 2 1E Cables in Vertical Drop Configuration," was inadequately established in that it was performed to test certain silicone rubber insulated conductors without requiring the disconnection of the Conax connectors. The connectors and conductors were of the same voltage rating; however, the test voltage utilized was established as volts per millimeter (mm) of insulation of the conductors (45 mm nominal) and should not have been applied to the insulation of the connectors (9 mm nominal), which were inadvertently left in_the circuit by the instruction.
The reasons for not initially identifying that the Conax connectors were in the circuit are:
a.
The drawings used in writing the instruction did not show the Conax connectors, b.
The drawing listing the tabulation of installed Conax connectors was not researched.
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Reason for the Violation (cont'd) c.
The Conax connectors were not noted by the walkdown personnel verifying the installation.
d.
personnel involved during implementation of STI-17 did not note the Conax connectors were installed in the circuit to be tested.
Item 3.
The test director stationed in the main control room (MCR) failed to communicate effectively with the test performer at valvo 2-FCV-1-16 1
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position.
In addition, the test performer failed to follow the procedure by erroneously testing the wrong limit switch and, upon discovery, failed to write a test deficiency because of inadequate L
guidance on test deficiency definition, i
Corrective Steps Which Have Been Taken and Hesults Achieved Item 1.
STI-17 was revised on June 18, 1987, to remove the Conax connectors from the circuits to be tested.
The affected circuits cited above were retested in this configuration. Work request (WR) B232141 was issued to replace the Conax connectors that were subjected to the test voltage.
As a result of several inspection report findings (notably Inspection Report Nos. 50-327, -328/87-24, 50-327, -328/87-36, and the subject violation's inspection report), a site directive was issued on June 18, 1987, detailing the requirements for conduct of testing.
Subsequently, Administrative Instruction (AI)-47, " Conduct of Testing " was developed and issued on July 15, 1987, to provide guidance and requirements for personnel involved in the performance of test activities and to ensure testing activities are uniformly controlled and performed. Training of appropriate personnel has been conducted.
Item 3.
The test director and test performer have been required to read AI-47 with emphasis on Section 8.0, " procedural Adherence." In addition, the Modifications test directors have been trained on the i
requirements of AI-47.
The functional test steps are not required to be performed again based on the following:
A.
The test director observed the following sequence of events in the MCR:
1.
With the valve at the closed position, the green position indication light only was illuminated, in accordance with correct design.
2.
After giving the command to handcrank the valve to the open position, both red and green lights were illuminated, in accordance with correct design.
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With the valve at the open position, the red position indication.
light only was illuminated.
4.
Confirmation was made that the motor starter was deenergized, and that the status monitor relays Al-S and Al-6, were energized and deenergized, respectively.
B.
The test performer stationed at the valve observed the following sequence of events:
- 1.. As the valve was being handcranked to the open position from the fu11' closed position, at approximately 5-percent travel, rotors 2 and 4 changed state.
2.
As the valve was nearing the full open position, at approximately 95-percent travel, rotors 1 and 3 changed state.
C.
The Electrical Maintenance Section performed Maintenance Instructions (MI)-11.2A, "Limitorque Actuator Corrective Maintenance procedure for SB-00, SHB-000, and SMB-00 Actuators," and MI-10-43, " procedure for Testing Motor Operated Valves Using MOVATS System," in accordance with WR B221840 following completion of the functional test.
D.
Operations Section personnel performed Surveillance Instruction (SI)-166.6, " Testing of Category
'A' and
'B' Valves After Maintenance Or Upon Release From A Hold Order," for stroke time measurement.
With regard to not adhering to step 9 of the functional test, while the test was ongoing the step was repeated successfully using the correct limit switch. A subsequent test deficiency was written against the previous nonadherence.
i As a result of several inspection report findings (notably Inspection Report Nos. 50-327, -328/87-24, 50-327, -328/87-36, and the subject 1
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violation's inspection report), a site directive was issued on l
June 18, 1987, detailing the requirements for conduct of testing.
Subsequently AI-47, " Conduct of Testing," was developed and issued on July if, 1987, to provide guidance and requirements for personnel involved in the performance of test activities and to ensure testing activities are uniformly controlled and performed.
Training of appropriate personnel has been conducted.
Corective Actions Which Will Be Taken To Avoid Further Violations l
Item 1.
As an enhancement to the design process, wiring diagrams now being generated show installed splices and connectors.
Test data from present testing provides further information on splice and connector installation that can be used during future design and testing.
Itcm 3.
The issuance and training of appropriate personnel to the requirements of AI-47 should prevent further occurrences as cited.
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- l Date When Full Compliance Will Be Achieved Item 1.
Full compliance has been achieved with the revision to STI-17 and issuance of and training to AI-47.
Item 3.
Full compliance has been achieved.
Reason For Denial Gtem 2.
The procedural step of SI-196 cited in the violation as not being followed contains the word "should." As specified in American l
National Standard Institute N18.7-1976, " Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants,"
and TVA's Quality Assurrnce Manual, Part I, Section 1.6,
" Definitions," the woro "should" is used to denote a recommendation.
The statement of the procedure cited as being vinlated could not have been violated since the actions are recommendations. Therefore, this i
violation is denied.
TVA does a5ree it is prudent, when testing one upper head injection valve per SI-196, that the other three valves that are not being tested be required to be closed and gagged, and the gag motor deenergized so as not to provide a mechanism for invalidating the test.
Therefore SI-196, step 3.4, was revised on July 17, 1987, to change the word "should" to "shall," thereby requiring the three upper head injection valves not being tested to be closed and gagged, and the gag motors doenergized.
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In addition, an enhancement has been made, via requirements l
incorporated into AI-47, which provides that "If a prerequisite, precaution, or instruction step has 'should' as the action / requirement, documentation of the evaluation made is required if the action / requirement is not followed."
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ENCLOSURE 3 LIST OF COMMITMENTS l
1.
NSRB rereviews of technical specification revisions will be completed by September-18, 1987.
2.
NSRB procedures will be revised by January 1, 1988, to reflect discussion'
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review as being required versus ballot review for NSRB topics.
1 3.
NSRB charter will be revised by September 1, 1987,'to delineate the
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current practice for distribution of NSRB meeting minutes.
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