ML20247L298
| ML20247L298 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 07/26/1989 |
| From: | Medford M TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8908010206 | |
| Download: ML20247L298 (8) | |
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a TENNESSEE VALLEY AUTHORITY j
CHATTANOOGA. TENNESSEE 37401 6N 38A Lookout Place JUL 261889 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk-Washington, D.C.
20555.
4 Gentlemen:
-In the Matter of.
)
Docket Nos. 50-327
. Tennessee Valley: Authority
)-
50-328
~SEQUOYAH NUCLEAR PLANT (SQN) UNITS 1 AND 2 - NRC INSPECTION REPORT NOS.'50-327., 328/89 REPLY.TO NOTICE OF VIOLATION Enclosed is TVA's response to B. A. Wilson's letter to 0. D. Kingsley, Jr.,
- dated June 26, 1989, which transmitted violations 50-327, 328/89-15-02 and'-03. provides TVA's response to the notice of violation. Summary statements of. commitments contained in this submittal.are provided in
- Enclosure 2.
If you have any questions concerning this submittal, please telephone M. A. Cooper at:(615) 843-6651.
Very truly yours, TENNESSEE VALLEY AUTHORITY.
hY Mark 0. Medford Vice President and Nuclear Technical Director Enclosures cc: See page 2 8 t 8908010206 890726 4
PDR ADOCK 05000327 O
FDC An Equal Opportunity Employer
_ _ __- _. ________- ________ a
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~- -
j
'U.S. Nudlear Regulatory:: Commission dOb $6M 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 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 NRC' Resident Inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy Daisy, Tennessee 37379
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ENCLOSURE 1 RESPONSE T0 NRC INSPECTION REPORT NOS. 50-327/89-15 AND 50-328/89-15 B. A. WILSON'S LETTER TO 0. D. KINGSLEY, JR.,
. DATED JUNE 26, 1989 Violation 50-327, 328/89-15-02 "A.
Technical Specification 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 procedures.
The requirements of TS.6.8.1 are implemented in part by the following procedure:
IMI 134, Configuration Control of Instrument Maintenance Activities, states that the technician performing a work activity shall list and initial any configuration changes in order on the IMI-134 data sheet.
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- These changes include jumpers, wire. lifts, inhibits, temporary instrument settings, unbolting flanges, disconnecting tubing and pipe fittings, temporary connections, etc.
The technician is to list these items'in sufficient detail to uniquely identify each item.
Contrary to the above, the configuration of RM 90-404 with respect to the detector cable was not correctly controlled as required by IMI-134 in that: configuration changes had been made without initiating the changes on the IMI-134 data sheet.
I This is a Severity Level IV violation (Supplement I)."
Admission or Denial of the Alleged Violation TVA admits the violation.
Reason for the Violation The instrument technicians were unsure of their responsibilities while performing work under the direction of the system engineer and the vendor representative.
l Corrective Steps That Have Been Taken and Results Achieved The individuals involved have been counselled and are now aware of their responsibility to maintain the configuration control log (Instrument
. Maintenance Instruction [IMI] 134 data sheets).
Corrective Steps That Will Be Taken to Avoid Further Violations Maintenance management will provide training to maintenance personnel emphasizing the importance of configuration control. This training will be completed by September 15, 1989.
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- Date When Full Compliance Will Be Achieved TVA is in full compliance.
Cover Letter Request By cover letter, NRC requested response to associated weaknesses identified in the inspection report and what actions have been taken concerning the weaknesses.
The following restates the identified weaknesses and discusses corrective actions taken to resolve the weaknesses.
Identified Weakness Work was completed over several days with no one person in charge."
Response
This activity was conaucted over several days with involvement of system engineering, the vendor, and instrument maintenance.
Secau.. of the extended duration and involvement of several individuals, the senior instrument foreman lost ownership of the task.
Responsibility for the execution of troubleshooting activities lies with the foreman, although the system engineer and vendor may act as technical consultants to the foreman.
The specific individuals involved in this activity have been counselled, and their job responsibilities have been emphasized by management.
Maintenance management will reinforce through discussion with maintenance personnel the role and responsibilities of the department foreman; this action will be completed by September 15, 1989.
Identified Weakness There was no indication of what trouble shooting activities were performed by the several shifts and crews that worked on the components.
No post maintenance test was identified and an adequate post maintenance test will be difficult in consideration of the loss of control of trouble shooting activities."
Response
Troubleshooting activities were controlled but not tdequately documented in the troubleshooting log.
It is the responsibility of the craftsmen to maintain a log, which correctly outlines the steps that have been accomplished during the troubleshooting process. This weakness has been discussed with the individuals involved.
The troubleshooting, with the exception of the log taking, was performed in accordance with Sequoyah Standard Practice SQM2.2,
" Maintenance Management System Troubleshooting," as specified by the planning of the work package.
Normally, a postmaintenance test (PMT) is not initially specified on a troubleshooting wc,rk request (WR).
In accordance with SQN's maintenance program, corrective maintenance with only minor exceptions is not performed on a troubleshooting WR; after the root cause of the problem is determined, the WR must be replanned.
It is during this replanning for corrective action that the WR troubleshooting actions are reviewed and the
l appropriate PMT specified.
Without accurate field troubleshooting log l
i entries, PMT specification does become difficult, at best.
In the subject case, the systen engineer and the vendor as well as the craft had reviewed the work scope. The specified PMT was calibration in accordance with SI-480.2 verification that the channel responded to a source check and that all alarms were cleared when the equipment was returned to service.
This PMT fully checked the operation of the instrument. Maintenance management will reinforce through discussion with maintenance personnel the need to maintain accurate troubleshooting logs by September 15, 1989.
Identified Weakness Configuration control with respect to the processor portion of the RM was not adequace in the cases of the CPU III 10889-01, and I/O boards.
These boards were placed into and out of the equipment without record or control of the work activities."
Response
The IMI-134 configuration control sheet should reflect changes made to the permanent components of the device or system. In this instance, several test components were placed into the device (i.e., circuit boards, cables) for troubleshooting purposes.
During the review of the identified weakness, it was additionally discovered that configuration log sheet No. 4 had been lost.
Based on subsequent discussion with responsible craft personnel, the log sheet has been reconstructed to provide a record of what troubleshooting was performed.
Identified Weakness Several components were stored within the electrical cabinet portion of the RM.
These included tools, spare connecting pins, and spare cables.
In addition, cigarettes were also stored within the electrical cabinet portion of the RM."
Response
During the troubleshooting and maintenance activities, the radiation monitor (RM) was out of service. The tools and spare cables in the RM cabinet were directly associated with the ongoing maintenance work and would be removed in accordance with the housekeeping procedure, Sequoyah Standard Practice SQA66, as required by the work request.
The cigarettes identified by the inspector should not have been placed in the cabinet. The individual has been counselled on keeping personal items in their proper place.
This item will be discussed in the referenced training.
Identified Weakness One of the tools stored in the electrical cabinet portion of the RM was a Winchester crimper.
This tool belonged to the vendor and was not controlled or calibrated under the licensee's crimper program.
In addition, several spare connecting pins were identified in the cabinet that did not have corresponding documentation in the work package."
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Response
i This item was discussed with the vendor representative.
The vendor representative stated that the crimper was not used during the work activity l
nor were any of the connecting pins used. Maintenance is developing a checklist to be used when vendor representatives are onsite.
Included in this checklist will be line items to discuss with the vendor the scope of his responsibilities; inform the vendor that if any measuring and test equipment (M&TE) is required for the work activity, the M&TE will be processed through TVA calibration laboratories; and inform the vendor that par ts, if any, will be received through Power Stores.
The vendor checklist will be developed and
,J implemented by September 15, 1989.
Violation 50-327, 328/89-15-03 "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.
This includes maintenance, operating, surveillance, and fuel handling procedures.
Contrary to the above, the licensee failed to establish and implement adequate procedures for power operation to maintain Thermal Power within l
license limits during steady state operation.
This is a Severity Level V violation (Supplement I)."
Admission or Denial of the Alleged Violation TVA admits the violation.
Reason for the Violation 4
To ensure operation within licensed power level and still operate the SQN units as close to the licensed power as reasonably possible, plant management issued Technical Specification Interpretation No. 119 to provide guidance on how to determine and maintain 100 percent thermal power operation. The guidance was based on consideration of typical operating power fluctuau ons induced by such factors a, grid perturbations and control system rssponses and on NRC memorandum discussion of " Licensed Power Level" dated August 22, 1980.
The guidance indicated that thermal power should be monitored using an 8-hour shift average of the secondary-side heat balance calculated power (P-250 plant process computer point U1118). At that time, there was no procedural controls to require the unit operator (U0) to formally record or track thermal power, only that he ensure that the 8-hour shift average did not exceed 3,411 megawatts thermal (MH ).
TVA did not formally define the 8-hour shift, nor were the 8-hour shift averages documented.
I Corrective Steps That Have Been Taken and Results Achieved In response to questions raised by NRC resident inspectors, plant management removed the technical specification interpretation from the main control room, began monitoring thermal power based on Nuclear Instrumentation System, and
restricted operation such that any power fluctuation peaks remained below 3,411 MW until questions could be adequately resolved. TVA then began an investigation and conducted discussions with Westinghouse Electric Corporation
'to determine the most prudent way to monitor and control thermal power.. Based on this investigation, the following changes have been made:
1.
General Operating Instruction 5, " Norma 1' Power Operation," Revision 39, requires:
a.
The U0 to monitor core thermal power using the P-250 calculated value.
This method was reviewed and found acceptable by NRC during inspection 89-16.
b.
The U0 to trend U1118 (instantaneous thermal power) using an analog trend recorder located in the main control room unit horseshoe.
c.
The U0 to take prompt manual action to reduce thermal power to 3,411 MW, or below upon observing an upward trend in thermal power above 3,411 MW.
6 d.
The U0 to establish 100 percent equilibrium power operation and then set the turbine governor valve limiter such that secondary.ide transients will be less likely to result in power excursion; above 3,411 MW..
2.
Administrative Instruction 6, " Log Entries and Review," Revision 19, requires the U0 to formally record thermal power in order to ensure that the average thermal power does not exceed 3,411 MW, for two consecutive hours or for any 8-hour shift. Shifts are defined as starting at 0700, 1500, and 2300.
TVA considers that the above guidance provides adequate direction for conservative operation and will ensure operation in compliance with technical specifications and within the assumptions of the safety analysis.
Corrective Steps That Will Be Taken to Avoid Further Violations No further action is required.
Date When Full Compliance Will Be Achieved TVA is in full compliance.
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ENCLOSURE 2 List of Commitments I
1; Maintenance management will provide training to maintenance personnel by September 15. 1989, to emphasize the importance of configuration control and the need to maintain accurate troubleshooting logs, and to reinforce the role.and responsibilities of the department foreman.
2.
Maintenance will develop and implement a vendor checklist by September 15, 1989.
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