ML20247D717

Responds to NRC Re Violations Noted in Insp Repts 50-327/89-07 & 50-328/89-07.Corrective Actions:Fuel Handling Instruction FHI-7 Revised & Administrative Instruction AI-58,App E Revised to Require Independent Reviewer Process

ML20247D717
Person / Time
Site:	Sequoyah
Issue date:	05/18/1989
From:	Michael Ray TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 8905250571
Download: ML20247D717 (14)

Text

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h TENNESSEE VALLEY AUTHORITY CH ATTANOOGA. TENNESSEE 37401

)

SN 157B Lookout Place MAY 181989 I

! U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Gentlemen:

In the Matter of. ) Docket Nos. 50-327 Tennessee Valley Authority ) 50-328 SEQUOYAH NUCLEAR. PLANT (SON) UNITS 1 AND 2 - NRC INSPECTION REPORT -

NOS. 50-327, 328/89-07'- RESPONSE TO NOTICE OF VIOLATION (NOV) 89-07-01 Enclosed is TVA's response to L. J. Watson's letter to 0. D. Kingsley, Jr.,

dated April 13, 1989, that transmitted the subject NOV. The due date for this response was extended to Ma~y 26., 1989, as discussed in a telephone conversation with Joe Brady and Marci Cooper on May 17, 1989.

Enclosure 1 provides TVA's response to the NOV. Enclosure 2 provides TVA's response to the request for additional information describing how the 10 CFR 50.70 requirement for resident inspectors' access is incorporated into the SQN radiological control program. Enclosure 3 contains the summary statements of commitments contained in this submittal.

If you have any questions concerning this submittal, please telephone M. A. Cooper at (615) 843-6651.

Very truly yours, TENNESSEE VALLEY AUTHORITY Hanage', Nuclear (iteMsing l w/

and Regulatory Affairs Enclosures cc: See page 2 8905250571 890510 7, DR ADOCK 0500 7 I l l

An Equal Opportunity Employer

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U.S. Nuclear Regulatory Commission hlfhf 18 }38@

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 Sequoyah Resident Inspector Sequoyah Nuclear Plant 2600 Igou~ Ferry Road Soddy Daisy, Tennessee 37379

ENCLOSURE 1 RESPONSE TO NRC INSPECTION REPORT N05. 50-327/89-07 AND 50-328/89 L. J. WATSON'S LETTER TO 0. D. KINGSLEY, JR.,

DATED APRIL 13, 1989 Violation 50-327, 328/89-07-01 "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 implemented.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 handwritten, 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.

l- c. Administrative Instruction A-9, Control of Temporary Alterations, i

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 is to be performed. The safety evaluation associated with TACFs 2-88-2019-500 and 1-88-22-500 stated that certain Bailey i

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 f~eedom was in the forward direction toward the door. The forward motion of the module was to be , restrained by a wire that was pulled snug tight across the front face of the 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.

d. System Operating Instruction 501-62.4, Chemical and Volume Control System, controls the regeneration of resin beds and the placement of resin beds in operation. S0I-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 S0I-62.4, because the condition of the resin bed was not ensured or documented. Consequently because 50I-62.4 did not require the performance of a resin bed ,

decontamination factor and the operator was not required to perform the reboration procedural requirement, the condition of the resin bed, when it was placed in service, was not controlled.

e. Abnormal Operating Instruction A01-3, 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 NOUE.

Contrary to the above, on Feoruary 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 inadvertent dilution which occurred in an uncontrolled manner. The licensee failed to declare a NOUE or enter the REP in accordance with A01-3. 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 condensate 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 implemented in that SQM-2 has no specific requirements for the work planner to perform a detailed electrical load distribution review

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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 inadvertent 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)."

Admission or Denial of the Alleged Violation (Example a)

TVA admits to the violation, in that the fuel transfer cart was not fully-inserted when the upending process was started. A discharged fuel assembly was in the cart, however, an examination revealed no damage to the fuel assembly.

Reason for the Violation (Example a)

-The individual that was operating the pit side upender failed to follow the procedure for visually verifying that the cart was against the stop on the spent fuel pit side. Equipment problems, such as the pit side upender load cell inaccurately indicating a " frame up" light when the upender was actually.

.down and the torque switch tripping problem, contributed to the error. In addition, the procedure, Fuel Handling Instruction (FHI) 7. " Refueling Operation," was not clear that a signoff was required on the pit side.

The previous violation (328/84-36-01) corrective action was to ensure proper alignment of the reactor side upender with the transfer canal guide pins were installed for the upender. To provide visual verification, a television camera will be used to verify the conveyor at the reactor side upender stop and clearance from the fuel transfer canal as specified in FHI-7. The television cameras were not installed to verify the upender cart position on the spent fuel pit side. Instead, FHI-7 required the upender operator to visually verify the cart position before upending. Had this visual verification been properly implemented, the incident could have been avoided.

The damage to the fuel transfer cart was caused by personnel error in failure to follow procedure. The corrective action planned to prevent further occurrence will decrease the potential for personnel error.

Corrective Steps That Have Been Taken and Results Achieved (Example a)

The vendor contract individual operating the upender was relieved of duty, and the event was reviewed and discussed with the other fuel handling crew members. The load cell on the pit side was repaired to properly indicate upender position, and the torque switch was repaired. FHI-7 was revised to require two-party signoff on verification of cart-at-stop on both the spent fuel pit side and the reactor cavity side. These actions permitted the completion of core off-loading and core reloading safely and without further incident.

Corrective Steps That Hill Be Taken to Avoid Further Violations (Example a)

A thorough review of the system, using vendor support and SQN Nuclear Engineering support, will be conducted prior to the next refueling operation.

Additionally, a more reliable method to prevent upending of a bundle, unless the cart is correctly positioned, is to be installed /provided before the next refueling effort. Condition adverse to quality report (CAQR) SQP890083 was initiated to correct and track the issue.

Date When Full Compliance Will Be Achieved (Example a) l TVA is in full compliance.

Admission or Denial of the Alleged Violation (Example b)

TVA admits the violation.

Reason for the Violation (Example b)

Plans were made to depressurize the Unit 2 upper head injection (UHI) nitrogen accumulator. The normal depressurization of the accumulator is through a valve located near the top of the accumulator. The normal ~ process utilizes

' System Operating Instruction (S0I) 87.1, " Upper Head Injection Accumulator,"

procedure; however, this is a very slow process requiring approximately 15 days to accomplish. A decision was made to depressurize the accumulator by a faster method through a valve located at the bottom normally used as a drain. A sample taken from the top of the accumulator gas showed no signs of contamination that would prevent its release to the atmosphere.

Administrative Instruction (AI) 58, " Maintaining Cognizance of Operation Status - Configuration Status Control," Appendix E (which gives directions for use of handwritten instructions), was used to write an instruction to depressurize the nitrogen accumulator in a controlled but off-normal manner.

A hose from the valve at the bottom of the accumulator to the yard area was used to route the gas outside to the atmosphere. In depressurizing the tank from the bottom, a small amount of condensation was expected; however, after approximately 60 seconds of operation, 100 gallons of water was discharged through the hose and sprayed on the ground. The Operations personnel realized that this was unacceptable and isolated the valve. Radiological Control was notified, and cleanup efforts began. The next day, a different and new handwritten procedure routed the hose to a building sump where a small but unknown volume of condensate was discharged during venting of the accumulator.

The root cause of the incident was that AI-58, Appendix E, did not provide adequate control over the review process before implementation of the handwritten instruction. As a result, adequate consideration of the potential effects of the activity did not occur, and contrcls were not incorporated into the instruction.

Corrective Steps That Have Been Taken and Results Achieved (Example b)

AI-58, Appendix E, has been revised to require the independent qualified reviewer process prior to implementation. Accordingly, this would provide for Radiological Control section review of the instruction written in response to 1

, the request of the shift operations supervisor (SOS) to vent an accumulator.

I Also, S01-87.1 has been revised to rigidly control the depressurization of the UHI accumulators. The procedure now requires direct involvement of the l

Chemistry, Radiological ContTol, 7.ndustrial Safety, and Operations sections in the venting evolutions.

Corrective Steps That Will Be Taken to Avoid Further Violations (Example b)

S01-87.1 now provides the proper guidance for safely depressurizing the UHI accumulator. This revision precludes the need to use the AI-58, Appendix E, procedure. The AI-58, Appendix E, procedure has been revised to enhance the controls over the usage of this procedure. In addition, a CAQR (SQN890143) was issued to correct, trend, and track this violation.

Date When Full Compliance Will Be Achieved (Example b)

TVA is in full compliance. -

Admission or Denial of the Alleged Violation (Example c)

TVA admits the violation.

Reason for the Violation (Example c)

The following contributed directly or indirectly in causing the violation:

(1) The unreviewed safety question determination (USQD) was not clearly worded in that it inferred the rear mounting clip engagement with the module was a requirement for seismic integrity, although the as-built condition did not result in all modules being engaged by the rear clip; (2) personnel error in not clearly and explicitly defining required plant configuration including TACF configuration instructions in the USQD; (3) inadequate communications between TACF/USQD preparers and instrument maintenance implementors; and (4) installer unfamiliarity with the cable / crimp arrangement resulted in j inconsistencies in as-built snugness of the cables across the modules. As a result, the existing plant condition was not totally consistent with the USQD statements; also, a unique set of implementation problems developed in the installation of the cables (reference licensee event report 2-88041 for additional details).

Corrective Steps That Have Been Taken and Results Achieved (Example c)

A revised TACF/USQD was issued February 1, 1989, to validate the adequacy of the as-built configuration. Subsequently, workplans were implemented on Units 1 and 2 to remove the aircraft cables and install permanent as-designed holddown bars. Concerns subsequently identified regarding the design installation have been evaluated and determined to not affect safe shutdown capabilities.

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Corrective Steps That Will Be Taken to Avoid Further Violations (Example c)

Sensitivity to 10 CFR 50.59 issues resulted in TVA incorporation of recent 10 CFR 50.59 program upgrades. Enhanced training included emphasis on rigorous review of design basis and inclusion of a detailed description of requirements or assumptions. This training has been ongoing since March 1989. All instrumentation and controls engineers involved in this issue have received this training. TVA is continuing to monitor program implementation and will determine, based on evaluation of results, if and where additional program improvements are warranted. '

While considerable progress has been made in improving engineering support of plant operations, TVA has additionally focused management attention on the interface between. plant and engineering organizations to ensure adequate feedback exists in relation ~to acceptability of deliverables. Details regarding this effort and evaluation will be provided to NRC in TVA's response to Violation 50-327, 328/89-09-03, which is scheduled for June 8, 1989.

Date When Full Compliance Will Be Achieved (Example c)

TVA is in full compliance. l Admission or Denial of the Alleged Violation (Example d)

TVA admits the violation.

Reason for the Violation (Example d)

Verification of proper lithium concentration in the Unit I reactor coolant system (RCS) was requested by the Chemistry laboratory. Chemical and volume control system mixed bed demineralized 1B was placed in service to allow the verification. Before being placed in service, an attempt was made to determine the boron concentration in the mixed bed. The resin status sheet associated with the IB mixed bed was not completely filled out indicating the boron status. The controlling procedure, 50I-62.4, "CVCS Purification System," did not require adequate verification of the resin bed status prior to placing it in service. The operating supervisor made an erroneous assumption that the boron concentration was at or above that in the RCS based on another employee's memory that the bed had previously been in service since Unit I startup. This error, compounded by an inadequate procedure, resulted in an unplanned dilution and, coupled with a manual rod control, produced a slight temperature and power transient.

Corrective Steps That Have Been Taken and Results Achieved (Example d)

The individual responsible for placing the mixed bed in service was counseled with emphasis on thoroughly evaluating potential effects of planned evolutions in addition to procedural requirements. A review was conducted of the SQN I

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operating' instructions that align any type of makeup or recirculation to the RCS. Thes'e instructions have been appropriately revised to include j t ' requirements for sampling the water immediately prior to aligning it to the  !

RCS. The instructions have liso appropriately been revised to require status logs for all tanks and demineralizers to be maintained currcnt in the main control room. Additionally, a CAQR (SQN89016) was initiated to correct,

- track, and trend this issue.

Corrective Steps Tha't Will Be Taken to Avoid Further Violations (Example d)

Operating instructions that align any type of makeup now have requirements for sampling of the water immediately prior to aligning it to the RCS.

Date When Full Compliance Will Be Achieved (Example d)

TVA is in full compliance.

Admission or Denial of the Alleged Violation (Example e)

TVA admits the violation.

Reason for the Violation (Example e) '

The SOS responded to the dilution event described in Example d without reference to Abnormal Operating Instruction (A0I) 3, " Uncontrolled RCS Boron Concentration Changes." From recent review, the SOS knew A01-3 did not contain additional relevant steps beyond those already taken to mitigate the event. The SOS recognized that the radiological emergency plan (REP) contained emergency plan classification logic for an " uncontrolled dilution";

however, the SOS did not consider the event to constitute an uncontrolled dilution because the dilution had been promptly recognized, the source isolated, and effects mitigated.

During the subsequent event investigation, investigation team members reviewed A01-3 and noted direction to implement the REP. The applicable section of A01-3 was titled " Inadvertent Dilution," and step H stated, " Implement REP per EPIP-i, Boron Dilution."

Corrective Steps That Have Been Taken and Results Achieved (Example e)

While the terminology was inconsistently applied, leading to differences in interpretations, a conservative decision was made to retroactively enter the REP and declare a notification of unusual event (NOUE). NRC was notified on February 9, 1989, 38 hours4.398148e-4 days <br />0.0106 hours <br />6.283069e-5 weeks <br />1.4459e-5 months <br /> after the event.

Inconsistent terminology has been corrected by revising A0I-3 wording

" inadvertent dilution" to " uncontrolled dilution" consistent with Emergency Plan Implementing Procedure (EPIP) I wording. Any dilution that is not planned and/or does not occur within reasonably expected tolerances will be

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considered an uncontrolled dilution. The REP will be initiated until

, evaluation of the condition warrants exit of the REP or reclassification of

the event. This~ interpretation will be addressed in a night order to be issued by May 16, 1989. -

' Correc'tive Steps That Will Be Taken to Avoid Further-Violations (Example e)

TVA believes determination of emergency plan classification must be made by use of the logic procedures combined with the sound judgement of the SOS and/or Site Emergency Director. While that judgement is vital to safe

- operation of.the facility, it inherently introduces potential for inconsistency.

Two other violations have occurred over the last year involving lack of timely declaration of an NOVE. Violation 88-33-01 addressed a lack of timely declaration of an NOUE following receipt of a seismic alarm in the main control room. Violation 88-34-01 addressed lack of timely declaration of an -

NOVE following identification of excessive RCS leakage. In each of these cases, there.were peripheral circumstances requiring evaluation and judgements .

made during the evaluation as to whether an NOUE should be declared. In each of these cases, the decision was ultimately made to declare the NOUE even when uncertainty existed. Specific a~ctions have been taken to provide additional guidance and/or clarity with reference to each of the three violation occurrences as described in their associated violation responses.

TVA has reviewed these three violations to determine if common root causes exist and whether generic actions are warranted. As previously stated, judgement is a necessary component in event classification. Appropriate conservatism and consistency must be maintained with these judgements. TVA discussed emergency classification procedures with other Region II plants to ensure consistency of the SQN procedures with other plants and with NRC interpretation of the type of events or thresholds that should exist for declaration of an NOUE. TVA found that SQN's EPIPs were generally consistent with the other plants in the region. However, minor changes are being made to improve clarity and facilitate procedure use. TVA believes requalification training is an appropriate forum to discuss and train on these types of events in an attempt to standardize judgements between SOSs and ensure implementation of appropriate conservatism in those judgements. Review of these three violations will be incorporated into the licensed annual requalification program (weeks 5 and 6) as examples of cases where judgement must be exercised and clear identification of the appropriate conservatism that should be exercised in these cases.

As related above and in TVA's response to violations 88-33-01 and 88-34-04, actions have been taken to address the specific issues that contributed to each of these violations. The causes for lack of timely declaration of an NOUE were different in each case. Actions taken in respense to an individual violation would not be expected to prevent the same result from different circumstances. TVA believes the SQN emergency procedure classification logic is consistent with regional and NRC standards. TVA will continue to strive for appropriate consistency and conservatism in evaluation and application of emergency classification.

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'Date When Full Compliance Will Be Achieved (Example e) l TVA is in full compliance. .

Admission or Denial of the Alleged Violation (Example f)

TVA admits the. violation.

Reason for the Violation (Example f)

Personnel error was primarily responsible for the violation. The instrument mechanic, after repairing the recorder and reinstalling it in the case, decided to separate the power. leads a little more than what they originally were. The mechanic did not realize that a mistake at this point could possibly short the recorder ~ power supply and that this was the common power supply-to three feedwater level control valves. The work request planners failed to specify the precautions required to prevent this incident as required by SQN Standard Practice SQM2, " Maintenance Management System," for work on energized equipment. (Additional details regarding this event are provided in Licensee Event Report [LER] 1-89005.)

Corrective Steps That Have Been Taken and Results Achieved (Example f)

This event was discussed with Instrument Maintenance planners, technicians, and engineers. Personnel involved in this incident have been instructed in the cautions required to be taken for working on energized equipment and instructed that,.whenever possible, energized equipment should be deenergized prior to performing. corrective maintenance.

Corrective Steps That Will Be Taken to Avoid Further Violations (Example f' i

SQM2 and SQM2.2, " Maintenance Management System Troubleshooting," will be f revised to clarify the requirements for working on energized equipment. This will require that equipment be deenergized if possible; and, when the planners determine this is not feasible, precautions will be listed stating the potential effects that could be experienced in the event of personnel error or mistake.

Also, as stated in LER 1-89005, information on generic problems associated with multiple power feeds for instrumentation will be incorporated into Instrument Maintenance initial training through the industry /SQN experience review familiarization lesson plan. Additionally, TVA is evaluating the extent of similar' situations regarding common power supplies and possible design changes to reduce potential for this type of occurrence.

Date When Full Compliance Will Be Achieved (Example f)

TVA will be in full compliance by June 30, 1989, upon revision to SQM2 and SQM2.2.

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r ENCLOSURE 2 TVA recognizes the requirement of 10 CFR 50.70 to afford NRC inspectors unfettered access, equivalent to access provided regular plant employees, following proper identification and compliance with applicable access control measures for security, radiological protection, and personal safety.

l TVA also recognizes and accepts the responsibility as prescribed in 10 CFR Part 20 to establish and implement measures to protect the health and safety of. individuals and effectively control personnel exposures. This l protection extends to every person onsite at the licensed SQN facilities. To accomplish this task, procedures have been established W implemented to j

limit entry into the radiologically controlled area by designated access points and then only when individuals are appropriately included on a radiation work permit (RWP)' .

In an effort to reduce exposures and provide improved protection to site personnel, TVA implemented a program change to eliminate general RHPs and require individuals to request new, more specific RWPs. As a result, the subject inspector found that the existing RWP did not address the inspection activities he wished to perform and was informed that a new RHP should be requested as outlined in Radiological Control Instruction (RCI) 14, " Radiation Work Permit (RHP) Program." TVA acknowledges that the program changes had not been specifically conveyed to the resident inspectors'before this occurrence, ,

and therefore a delay was encountered to obtain access before beginning the desired inspection activities. Upon notification of this situation, the Radiological Control (Rad Con) Superintendent personally resolved the situation, and access was provided within 45 minutes. Rad Con subsequently initiated and issued a standing RHP to the NRC inspectors that allows for inspections of most radiological areas consistent with safe practices. The resident inspector has reportedly experienced no problems accessing the RCA since the initiation of the standing RHP. Once issued, a request for a new RWP should not be needed until the first of next year (annually).

While TVA regrets the inconvenience these changes may have caused, TVA believes the changes are in the best interest of radiological safety (for TVA and non-TVA individuals), consistent with the objectives and requirements of 10 CFR Part 20. TVA does not believe the change in the Rad Con program reduced inspector access required under 10 CFR 50.70 in that the change did not constitute unreasonable access control measures (in consideration of either NRC or TVA needs), and these changes were not implemented in a manner more restrictive than afforded regular plant employees.

NRC resident inspectors have expressed concerns that the program change would require the NRC inspectors to personally request an RWP and that the normal time for processing this request could impede an immediate need for observation / inspection of activities. TVA believed the procedure wordlag to j have provided adequate latitude for either the inspector to have requested an i RWP (similar to requirements for requesting dosimetry) or for another organization such as Rad Con to have initiated the RHF for the inspector as has occurred in this casc. A 24-hour timeframe is specified in the procedure for requesting an RHP although wording is provided to allow for more immediate initiation when warranted.

Again, TVA believed the wording to accurately depict the normal method by which RWPs are to be requested and initiated but provided adequate flexibility to address special situations or needs such as those that were encountered for l the subject inspector. -

As previously stated, a standing RWP has been initiated, and this has resolved immediate access needs. To address NRC's concerns regarding future program changes and to provide additional clarity, TVA will revise RCI-14 by September 1, 1989, to specifically define how RWPs will be initiated for NRC inspectors to minimize impact to inspection needs while continuing to be consistent with safe radiological practices. This revision will be annotated as a commitment in accordance with procedure revision requirements; this will provide long-term assurance that this issue is appropriately addressed or evaluated l during future program changes.

ENCLOSURE 3 l

l . LIST Of COMMITMENTS 1

l 1. A review of the fuel transfer system, using vendor and SQN Nuclear Engineering support, wili be conducted prior to the next refueling outage.

2. A more reliable method to prevent upending of a bundle unless the cart is correctly positioned is to be installed /provided prior to the next refueling effort.

3. SQN Standard Practice SQM2 will be revised to clarify the requirements for working on energized equipment. SQM2 will be revised by June 30, 1989.

4. SQM2.2 will be revised to clarify the requirements for working on energized equipment. SQM2.2 will be revised by June 30, 1989.

5. TVA will revise RCI-14 by September 1, 1989, to specifically define how RWPs will be initiated for NRC inspectors to minimize impact to inspection needs while continuing to be consistent with safe radiological practices.

6. Review of the three violations (88-34-01, 88-34-04, and 89-07-01, Examples D and E) will be incorporated into the licensed annual requalification program (weeks 5 and 6 of 1989).

7. A night order will be issued by May 16, 1989, addressing the interpretation that any dilution that is not planned and/or does not occur within reasonable expected tolerances will be considered an uncontrolled dilution.

8. While considerable progress has been made in improving engineering support of plant operations, TVA has additionally focused management attention on the interface between plant and engineering organizations to ensure adequate feedback exists in relation to acceptability of deliverables.

Details regarding this effort and evaluation will be provided to NRC in TVA's response to Violation 50-327, 328/89-09-03 by June 8, 1989.

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