ML20150E546

Notice of Violation from Insps on 870406-0505 & 0506-0612. Violations Noted:On 870201,sys Realignment Improvised W/O Written or Formally Approved Instructions & on 870201,five Valves Shut Down W/O Entry Into Configuration Log

ML20150E546
Person / Time
Site:	Sequoyah
Issue date:	03/14/1988
From:	Richardson S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20150E545	List: ML20150E540 ML20150E546
References
NUDOCS 8804010060
Download: ML20150E546 (3)

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ENCLOSURE

. NOTICE OF VIOLATION -

Tennessee Valley Authority Docket.Nos. 50-327, 50-328 Sequoyah I and 2 License Nos. DFR-77, DPR-79 During the Nuclear Regulatory Connission (NRC) inspections conducted on April 6

- May 5, 1987, and May 6 - June 12, 1987, violations of NRC requirements were identified. The violations, which involve multiple examples of inadequate procedure implementation, demonstrate a lack of contTol over testing evolutions and system and equipment status. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1987), the violations are set forth below:

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a) Technical Specification 6.8.1 requires that written procedure.s be established, implemented, and maintained covering safety-related activities addressed in Appendix "A" of Regulatory Guide 1.33, Revision 2, February 1978.

Administrative Instruction (AI)-30, "Nuclear Plant Method of Operation,"

Section 2.2, requires tFat when a condition exists that could adversely affect personnel or equipment safety while an instruction is being followed, and sufficient time is available, normal change and revision nethods of AI-4, "Preparation, Review, Approval and Use of Plant Instructions," are to be used.

Contrary to the tbove, on February 1,1987, the unit operator did not use the formal change process of AI-4 to revise SI-166.3. Instead, a system realignment was 'mprovised, without written or formally approved instructions.

b) OSLA 58, "Maintaining Cognizance of Operational Status," Section E.1.,

requires that all outages or deviations associated with listed systems be logged in the configuration log. Entries are to be made regardless of length of outage time.

Contrary to the above,1) on February 1,1987, five (5) valves were shut in an attempt to isolate the SG maintenarce area fron the RWST without entry in the configuration log as required, and 2) April 29,1987 vent valve 1-HCV-68-594 was opened, and this deviation from the normal valve alignment was not entered in the configuration log.

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Tennessee Valley Authority 2 Docket Nos. 50-327, 50-328 Sequoyah 1 and 2 License Nos. DPR-77, DPR-79 c) SI-102 M/M, "Diesel Generator Monthly Mechanical Inspections," requires that the air start system manual isolation valves be closed during the

. performance of steps 6.? - 6.16 for personnel safety and-SI-166.36, "Diesel Starting Air Valve Test," states that no more than one manual isolation valve may be closed at any one time when installing pressure gauges.

Contrary to the above, on May 28, 1987, SI-102 M/M and SI-166.36 were run concurrently and all four Emergency Diesel Generator (EDG) starting air manual isolation valves were closed simultaneously for the installation of SI-166.36 pressure gauges.

d) Al-3, "Clearance Precedures," Section 5.2.1.1, states that a Hold Order clearance (red tag) is the means to ensure lires or equipment remain 2-energized, depressurized, and isolated so work can be safely perforned and equipment protected.

AI-3, Section 3.1.8, requires that a caution tag identify the abnormal

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conditions and may include special instructicns to the operator.

Al-3, Section 5.1.4 and 5.3.3, require that the clearance be issued to the person requesting the clearance and respcnsible for the work.

Contrary to the above, the clearance activities associated with the steam generator work discussed in items a) and b) above were not performed in accordance with AI-3.

e) Surveillance Instruction (SI)-45.1, "Essential Raw Cooling Water Pumps," requires the licensee to maintain bearing cooling water flow between 5 gom and 13.5 gpm.

Contrary to the above, on December 2, 19E6, December 14,1986, and May 22, 1987, this procedure was performed without appropriate instrumentation to verify this flow rate. Consequently, recent and past performances of SI-45.1 have not included a quantitative check of the bearing cooling water flow as required.

f) SI-46.3, "Component Cooling Water Pump 2A-A," requires that if the unit is on Residual Heat Removal (RHR) cooling, the heat exchanger in use for cooling is not to be used for the pump test.

Centrary to the above, on May 27, 1987, 51-46.3 was entered and aligned using the "A" RHR heat exchanger when the "A" train of RHR was in service for decay heat removal.

This is a Severity level IV violation (Supplement I).

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

Sequoyah I and 2 License Nos. DPR-77, DPR-79 '

Pursuant to the provisions of 10 CFR 2.201, the Tennessee Valley Authority is hereby required to submit a written statement in explanation to the U.S.

, Nuclear Regulatory Connission, ATTN: Document Control Desk, Washington, DC 20555 with a copy to the Director, Office of Special Projects, and a copy to the NRC Resident Inspector within 30 days of the date of the letter transmitting this Notice. This reply should be clearly marked as "Reply to a Notice of Violation" and should include for each violation: (1) the reason for'the violation if admitted, (2) the corrective steps that have been taken and the results achieved (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved.

Where good cause show, consideration will be given to extending the response time.

FOR THE NUCLEAR REGULATORY COMMISSION tw b. 'llalu:u c& .

Steven D. Richardson, Acting Director TVA Projects Division Office of Special Projects Dated at Rockville, Maryland this g e day of taa.cb ,t4 k

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