ML20247F175
| ML20247F175 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 05/10/1989 |
| From: | Michael Ray TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8905300017 | |
| Download: ML20247F175 (7) | |
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TENNESSEE VALLEY AUTHORITY CH ATTANOOGA. TENNESSEE 37401 SN 1578 Lookout Place MAY 101989 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Hashington, D.C.
20555 Gentlemen:
In the Matter of
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Docket Nos. 50-327 Tennessee Valley Authority
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50-328 SEQUOYAH NUCLEAR PLANT (SQN) UNITS 1 AND 2 - NRC INSPECTION REPORT NOS. 50-327. 328/88 REPLY TO NOTICE OF VIOLATION Enclosed is TVA's response to L. J. Watson's letter to 0. D. Kingsley. Jr.,
dated April 10, 1989, which transmitted violation 50-327, 328/88-50-01.
4 provides TVA's response to the notice of violation.
Summary 1
statements of commitments contained in this submittal are provided in l.
If you have any questions concerning this submittal, please telephone M. A. Cooper at (615) 843-6651.
Very truly yours, TENNESSEE VALLEY AUTHORITY
@[O[ M Manager, Nuclea/ [icensing rt and Regulatory Affairs Enclosures cc:
See page 2 l
fgol 8905300017 890510 l
DR ADOCK 05000327 I
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i PDC An Equal opportunity Employer
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~U.S.' Nuclear' Regulatory Commission-nAAY-101989 cc (Enclosures):
Ms. S.'C. Black, Assistant Director for' Projects.
TVA Projects. Division U.S. Nuclear Regulatory Commission One White. Flint, North 11555 Rockville Pike-Rockville, Maryland 20852 p
~Mr. B..A. Wilson, Assistant Director for-Inspection Programs TVA Projects Division U.S. Nuclear Regulatory Commission Region II-101 Marietta Street, NW, Suite 2900 Atlanta,; Georgia 30323 Sequoyah Resident' Inspector Sequoyah' Nuclear Plant 2600.Igou Ferry Road Soddy Daisy, Tennessee 37379 l.
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ENCLOSURE 1 PESPONSE TO NRC INSPECTION REPORT N05. 50-327/88-50 AND 50-328/88-50 L. J. HATSON'S LETTER T0 t. D. KINGSLEY, JR.,
1 DATED APRIL W, 1989 i
Violation 50-327, 328/88-50-01 "10 CFR 50, Appendix B, Criterion XVI, Corrective Action, states that, measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.
In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action I
taken to preclude repetition.
The identification of the significant condition adverse to quality, the cause of the condition, and the corrective action taken shall be documented and reported to appropriate levels of management.
Violation 327,328/87-30-01 was issued in March 1988 to address a lack of control over plant evolutions and the status of systems and equipment.
The NRC issued the Notice of Violation to obtain the management attention necessary to resolve the underlying problem.
This previous citation included a system realignment without written or formally-approved instructions; i
realignment of valves without procedures or configuration control; and performance of a surveillance instruction without appropriate instrumentation.
The licensee's corrective action for the violation, including strengthening administrative procedures to require procedural adherence and training of plant personnel on the procedures had been completed.
Contrary to the above, the licensee failed to preclude repetition of Violation 327,328/87-30-01 in the radioactive waste area after having tompleted corrective action.
Lack of control over plant evolutions, system status and equipment status was still evident in the radioactive waste area in that:
1.
multiple evolutions were performed outside of approved plant procedures during spent resin transfers from January 11-19, 1989; 2.
known inadequate drawings were utilized - affecting procedural controls of the temporary resin interface valve; and 3.
known design deficiencies were not corrected - causing recurring radiation hot spots in excess of one Rem per hour to be created.
The existing conditions combined with evolutions performed outside of approved procedures allowei an unwarranted personnel contamination.
This is a Severity Level IV Violation (Supplement I)."
Comment The root cause of the three examples identified in this violation and general findings documented in the inspection report was a lack of upper level
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management attention in the area of the Water and Waste Processing Group (HWPG). During the concentrated efforts to restart SQN, the WHPG organization
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l-and radiological waste systems were not as closely scrutinized as other areas l
because they.were not within the typical restart scope, i.e., these systems and activities were not required for safe' shutdown or accident mitigation.
Additionally, although HHPG was part of the Operations organization, it generally functioned as a separate entity; this contributed to a lack of implementation of overall operation upgrades and initiatives into the WWPG organization..These factors contributed in some cases to a casual attitude in personnel regarding use of procedures and acceptance of procedural and hardware deficiencies.
i Upon recognition of this situation, SQN management has initiated comprehensive actions to resolve identified problems and generate an overall upgrade of conduct of activities in the waste processing area. Actions include strengthened management oversight, extensive personnel training, procedural upgrades, and design deficiency reviews.
Details of actions taken are addressed in the response to the specific violation examples below.
Admission or Denial of the Alleged Violation (Example No. 1)
TVA admits the violation.
Reason for the Violation (Example No. 1)
As stated in the introduction.
Corrective Steps That Have Been Taken and Results Achieved (Example No. 1)
The individual. involved in this specific incident has been counseled and given guidance in procedural requirements of Administrative Instruction 4,
" Preparation, Review, Approval and Use of Site Procedures / Instructions," which directs personnel to stop activities that cannot be accomplished in accordance with procedures and to initiate revisions.
The event has also been reviewed with WWPG employees and management personnel, and the importance of procedural compliance was stressed.
The event has been reviewed with radiological control employees to emphasize the importance of thorough communication and understanding of ongoing activities to ensure radiological protection of plant employees.
The specific procedure, System Operating Instruction (50I) 77.3, " Waste Processing," associated with this evant was subjected to an extensive revision and validation and verification process prior to resuming resin transfer activities.
Resin transfer activities are now accomplished in accordance with a detailed step-by-step procedure. A detailed review and validation of other procedures used by the WHPG have beer performed to ensure existing procedures are technically adequate for conduct of current activities. These same procedures are to be revised to enhance the performance of WWPG activities.
WWPG management is actively involved in day-to-day operation of WWPG
' activities.. Managers are walking their spaces, observing work activities in progress, and continually stressing compliance with procedures.
Disciplinary l
actions will be taken if procedural noncompliance are identified.
Corrective Steps That Will Be Taken to Avoid Further Violations (Example No. 1) l An in-depth training program for WWPG employees has been established.
This training is intended to provide WWPG management and employees a thorough understanding of how the' radiological waste systems work and the logic behind the methodology of the current procedures.
If improved methods of operation are identified during this training, procedure revisions will be initiated.
The training is also intended to stress the importance of strict adherence to-procedures and to reinforce that work should be stopped and procedures revised if they are discovered to be inadequate.
This program will be ongoing during requalification training.
Initial training on existing procedures has been completed, and training on the enhanced procedures will be completed by -
January 2, 1990.
Date When Full Compliance Will Be Achieved (Example No. 1)
TVA is in full compl~1ance.
Admission or Denial of the Alleged Violation (Example No. 2)
TVA admits the violation.
Reason for the Violation (Example No. 2)
This valve was a temporary interface valve installed during the initial operation of unit I while unit 2 was still under construction. After the licensing of unit 2, the valve was to be removed. A review of past design change requests (DCRs) written against this system indicated that this valve was identified in 1983, but DCR-L-1881 was cancelled before implementation.
Corrective Steps That Have Been Taken and Results Achieved (Example No. 2)
WWPG submitted drawing deviation 89DD4209, and the as-installed temporary interface valve has now been added to design drawing 47W830-3 as a permanent valve.
Procedure 501-77.3 will be revised to reflect the permanent valve number by July 8, 1989.
Corrective Steps That Will Be Taken to Avoid Further Violations (Example No. 2)
A review of both outstanding and cancelled DCRs related to the radiological waste processing system will be performed to reevaluate the need and impact of operation.
This review will be completed by October 1, 1989. Additionally, TVA is evaluating existing equipment to determine what, if any, additional controls or modifications are needed to ensure adequate control is maintained during systems operations.
A walkdown of the systems was performed and interviews were held with the WWPG personnel to ascertain if other temporary valves existed.
The walkdowns did not identify any additional temporary valves, and personnel interviewed did not know of any other unidentified valves in the radiological waste systems.
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Date When Full Compliance Will Be Achieved (Example No. 2)
TVA is in full compliance.
Admission or Denial of the Alleged Violation (Example No. 3)
TVA admits the violation.
Reason for the Violation (Example No. 3)
As previously described, the lack of management attention resulted in personnel acceptance of deficient conditions.
In this specific case, TVA has determined that flushing through valve FCV-77-400 after resin transfer eliminates hot spots, and no design change is required.
~ Corrective Steps That Have Been Taken and Results Achieved (Example No. 3)
The procedure, 50I-77.3, has been revised to require flushing of the dead leg in the system.
Corrective Steps That Will Ce Taker to Avoid Further Violations (Example No. 3)
As previously described, a review of both outstanding and canceiled DCRs related to the radiological waste processing system will be performed to reevaluate the need and impact on operation.
This review will be completed by October 1, 1989.
Additionally, TVA is evaluating existing equipment to determine what, if any, additional controls or modifications are needed to ensure adequate control is maintained during system operations.
Problems described in the inspection report regarding the spent resin storage tank level indication will be evaluated and addressed as part of the previously described review.
Date When Full Compliance Will Be Achieved (Example No. 3)
TVA is in fui, compliance.
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I ENCLOSURE 2
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LIST OF COMMITMENTS 1.
An in-depth training program for WWPG employees has been established.
This program is scheduled to be completed by January 2, 1990.
2.
A review of both outstanding and cancelled DCRs related to the radiological waste processing system will be performed to reevaluate the need and impact on operation.
This review will be completed by October 1, 1989.
3.
501-77.3 will be revised to reflect the permanent valve by July 8, 1989.
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