ML20244D048

Notice of Violation from Insp on 890205-0305.Violations Noted:On 890211,attempt to Raise Upender Resulted in Bent Fuel Assembly & Handwritten Procedure Did Not Adequately Describe Work Activities to Be Performed

ML20244D048
Person / Time
Site:	Sequoyah
Issue date:	04/13/1989
From:	Linda Watson Office of Nuclear Reactor Regulation
To:
Shared Package
ML20244D044	List: IR 05000327/1989007 ML20244D041 ML20244D048
References
50-327-89-07, 50-327-89-7, 50-328-89-07, 50-328-89-7, NUDOCS 8904210120
Download: ML20244D048 (3)

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• ENCLOSURE 1

' NOTICE OF VIOLATION Tennessee. Valley Authority Docket Nos. 50-327, 50-328

, Sequoyah . License Nos. DPR-77, DPR '

During the Nuclear Regulatory Commission (NRC) routine' inspection _ conducted .

on February 5 . March 5,1989, a violation of NRC requirements was identified.

In- accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions,"'10 CFR Part 2, Appendix'C (1988), the violation.'is listed.

below:

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 maintenance,. operating, surveillance, and fuel handling procedures. The requirements of TS 6.8.1.

are implemer:ted in part by the following procedures:

a. Fuel. Handling Instruction FHI-7, Refueling Operation, as revised by instruction; change ' form ICF 89-0149, requires the fuel handling operator to verify that the fuel handling cart is fully . inserted before upending the fuel assembly.

Contrary 'to the above, on February 11, 1989 an attempt to raise the:

upender without first having the fuel transfer cart fully inserted was made. The result of this action was a bent fuel assembly. This is a. repeat Violation of 328/84-36-01.

.b. Administrative Instruction AI-58, Maintaining Cognizance of Operating Status, allows handwritten instructions to be prepared and used for

. performing evolutions not covered by an approved procedure. It was determined by the licensee that S0I-87.1, UHI Accumulator, did not apply to the required UHI venting activities. As a result a hand-written, untitled, unnumbered procedure was- written to vent the UHI accumulator through drain valve 2-87-555.

Contrary to the above, on January 21, 1989 the handwritten procedure that was established and implemented did not adequately describe the work activities to be performed. This handwritten procedure was not adequately established in that it did not address whip restraints on the hose. used to drain the accumulator, address the presence of contaminated water in the accumulator or control its spread or routing to an appropriate sump.

c. Administrative Instruction A-9, Control of Temporary Alterations, requires that a safety evaluation be performed to support temporary modifications in the plant and the alteration be installed exactly as described in the temporary alteration control form (TACF). NEP 6.6, 10.CFR 50.59, Safety Evaluation, describes how a safety evaluation 8904210120 890413 PDR ADOCK 05000327 Q PDC  ;

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Tennessee. Valley Authority. 2 Docket Nos. 50-327,- 50-328 .

Sequoyah' License Nos. DPR-77, DPR-79 I a.

. is - to be performed. The safety evaluacion associated with TACFs 2-88-2019-500 and 1-88-22-500 stated ' tiat . certain Bailey- meter modules would be restrained in .the vertical direction by a clip at

'the rear of the. retaining pan and that the only degree of freedom was in the forward direction toward the door. The forward motion of the' ,

module w;; to be restrained by a. wire that was pulled snug tight across the front face ofLthe module and crimped.

. Contrary to the above, several Unit 2' Bailey meter modules. were

. identified with retaining wires that did not . prevent the forward-movement of the module or maintain the module in contact with' the rear pan clip.

System Operating Instruction 501-62.4, Chemical and Volume ' Control

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System, controls the regeneration of resin beds and the placement of; resin beds in operation. S01-62.4 requires that the resin bed be properly lithiated and borated prior to use.

Contrary .to the above, on February 7,1989, the licensee placed an unborated resin bed in service which resulted in a power transient.

and required emergency boration of the RCS. This resulted .from a failure to adequately . implement 501-62.4, because the condition'off the resin bed was not ensured or documented. Consequently because S0I-62.4 did not require the performance of a resin bed decontamina-tion factor and the operator was not required to perform the rebora-tion procedural requirement, the condition"of the resin bed, when it was placed in service, was not controlled.

e. Abnormal Operating Instruction AOI-3, Malfunction of Reactor Makeup Control, states that in an inadvertent dilution the operator is to implement the Radiological Emergency Plan per IP-1, Boron Dilution.

The REP states that an uncontrolled dilution is to be classified as a

' Notification of an Unusual Event (NOUE). IP-1 states that the NRC is to be notified in the case of the declaration of an NOVE.

Centrary to the above, on February 7,1989, the licensee placed a resin bed in service resulting in a power transient and requiring emergency boration of the RCS. This is considered to be an inadver-tent dilution which occurred in an uncontrolled manner. The licensee failed to declare a NOUE or enter the REP in accordance with A0I-3.

This is a repeat violation and was previously identified in Violation 327,328/88-34-04.

f. Standard Maintenance Practice SQM-2, Maintenance Management System, contains the requirements for work . request guided activities. Work request WR 328429 was written to trouble shoot and repair a conden-sate dump-back flow recorder that was located on a rear panel in the main control room.

Contrary to the above, SQM-2 was not adequately established or imple-mented in that SQM-2 has no specific requirements for the work planner to perform a detailed electrical load distribution review 4

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. Tennessee Valley Authority 3 Docket Nos. 50-327, 50-328

'Sequoyah License Nos. DPR-77, DPR-79

.when preparing a WR and WR 328429 was prepared without incorporation of adequate controls for the work activities performed on energized circuits. .This resulted in an -inadver+.ent reactor trip and plant transient when, on February 10, 1989, activities were performed on energized circuits under WR 328429.

These examples constitute a. Severity Level IV Violation (Supplement I).

Pursuant to the provisions of 10 CFR 2.201, Tennessee Valley ' Authority is hereby required to submit a written statement or explanation to the Nuclear Regulatory Commission,: ATTN: Document Control Desk,. Washington, DC 20555, with a copy to Lthe Associate Director for Special Projects, Office of Nuclear Reactor Regulation and a copy to the NRC - Resident Inspector, Sequoyah, within 30 days of'the date of the letter-transmitting

-this Notice. This' reply'should be clearly marked as a " Reply to-a Notice of Violation" and should include [for each violation]: . (1) admission or denial of the violation, (2) the reason for the violation if admitted, (3)-

the corrective steps wh <ch have been taken and the resultsEachieved, (4) the corrective steps which'will be taken to avoid furtherlviolations, and-(5) the date when full compliance will be achieved. Where good cause is shown, consideration. sill be given to extending -the response time. -If an adequate reply is not received within the time specified in this Notice, .

an - order ' may be ' issued to show cause why the' license should not be modified, suspended, or revoked or why such other action as may be proper should not be taken.

THE NUCLEAR REGULATORY COMMISSION.

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Linda J. Watson, Acting Assistant Director for Inspection Programs TVA Projects Division Office of Nuclear Reactor Regulation l u l Dated at Atlanta, Georgia this 134 day of April 1989 l

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