ML20207K887

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Rev 1 to, Failure to Establish Procedures;Corrective Action Program Failure;Procedural Noncompliance
ML20207K887
Person / Time
Site: Sequoyah  Tennessee Valley Authority icon.png
Issue date: 12/18/1986
From: Gass K
TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20207K578 List:
References
SWEC-SQN-36, SWEC-SQN-36-R01, SWEC-SQN-36-R1, NUDOCS 8701090554
Download: ML20207K887 (12)
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. TVA EMPLOYEE CONCERNS REPORT NUMBER: SWEC-SQN-36 SPECIAL PROGRAM REPORT TYPE: Sequoyah Nuclear Plant Element REVISION NUMBER: 1 TITLE: Failure to Establish Procedures; Corrective Action Program Failure; Procedural Noncompliance REASON FOR REVISION: To incorporate TAS and SRP comments SWEC

SUMMARY

STATEMENT: The items in this report were identified by the Nuclear Regulatory Commission (NRC) and were included in the Stone & Webster Engineering Corporation (SWEC) systematic analysis. All items evaluated within this report were verified to be adequately addressed and SWEC concerns A02850802001-001

-003, and -004 were closed by NRC. Concerns A02850802001-002 -005, -006, and

-007 are now ready for closure.

PREPARATION PREPARED BY:

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, SIGNATURE DATE CONCURRENCES CEG-H: _ s/dme.v _ f.1ltlE(o SRP:Cbs,%w) #M . /}-)7-f2, SIGNATURE DATE f SIGNATU g / DATE APPROVED BY-MticaAf - it-e sa NiA ECSP MMAGER DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)

  • SRP Secretary's signature denotes SRP concurrences are in files.

2242T 8701090554 861222 PDR ADOCK 03000327 P PDR

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j ENPLOYEE CONCERNS TASK GROUP OTHER SITES CEG Element

Title:

Failure to Establish Procedures; Corrective Action Program Failure; Procedural Noncompliance SWEC Concerns: A02850802001-001 A02850802001-002 A02850802001-003 A02850802001-004 ,

A02850802001-005 A02850802001-006 i A02850802001-007 I

. Source Document: NRC Inspection Report 50-327, 328/85-17 Report Number: SWEC-SQN-36 I

a Evaluator: Yfeb M l'd BMM /f- /- M 6 i R. C. Birihell Date Reviewed By: N '

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J. J. Knightly Date i

Approved By: Y% /2// /fl.

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6 SWEC-SQN-36 Failure to Establish Procedures; Corrective Action Program Failure; Procedural Noncompliance I. Introduction During an Nuclear Regulatory Commission (NRC) inspection May 6 -

June 5, 1985, (reference 1) the NRC inspector identified three violations, ident ified an additional example of a previous violation and reviewed one previous unresolved item. These were addressed as issues in the Stone & Webster Engineering Corporation (SWEC) systematic analysis, as follows:

1. A02850802001-001 (Violation 50-327/85-17-04, 50-328/85-17-03),

Failure to Establish Adequate Procedures For Testing of Diesel Generator (DG) Relays

2. A02850802001-002 (Unresolved Item 50-327, 328/85-16-03), Lack of Timeliness of Corrective Action and Review of Nonconforming Conditions
3. A02850802001-003 (Violation 50-327/85-17-02) Failure To Follow Procedure and Radiation Work Permit
4. A02850802001-004 (Violation 50-327, 328/85-20-02) Failure to Establish Controls on Novement and Storage of Equipment within Regulated Areas (additional example of a previous violation).
5. A02850802001-005 (Violation 50-327/85-17-05, 50-328/85-17-04),

Failure to Follow Procedure

6. A02850802001-006 (Violation 50-327/85-17-04, 50-328/85-17-03),

Additional example of item 1 above

7. A02850802001-007 (Violation 50-327/85-17-04, 50-328/85-17-03),

Additional example of item 1 above Information on the background, corrective actions taken, verification methodology, verification analysis, completion status, and pertinent references for these four issues is included in this report.

II. Verification of SWEC Issues A. A02850802001-001. -006. -007 (Violation 50-327/85-17-04, 50-328/85-17-03). Failure to establish adequate procedures for testina of Diesel Generator (DG) Relays

1. Background

The NRC inspector identified the following violations:

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Page 1 of 10

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a. DPSO-SMI-IDG, " Relay Functional Tests of Diesel Generator Protective Relays," and MI-10.1, " Diesel Generator Inspector," were established to implement Technical Specification surveillance requirements.

Contrary to the above, adequate procedures were not established in that DPSO-SMI-1DG did not specify Emergency Diesel Generator (EDG) local-remote switch position in the EDG cubicle nor in the control room prior to the completion of paragraph 9.A(4)4.1 and did not require that controlled test equipment (test rig) be used in the performance of step 9.A(3). This was identified as NRC vloistion 50-327/85-17-04, 50-328/85-17-03.

b. SQM-24, " Torque and Limit Switch Settings for Motor-Operated Valves," was established to comply with the above requirement for maintenance procedures on safety-related equipment.

Contrary to the above, SQM-24 did not incorporate the limit switch adjustment technique identified in MI-12.2, " Motor Operated Valve Adjustment Guidelines". This resulted in damage to two safety-related valves and a reactor trip. (This is SWRC item A02850802001-006, Additional example of violation 85-17-04).

c. SI-484, " Periodic Calibration of Reactor Vessel Level Instrumentation System (RVLIS) and RCS Wide Range Pressure Channels (P-403, P-406) (Refueling Outage) " was established to implement post-modification testing requirements.

! Contrary to the above, SI-484 was not adequately established l for configuration control in that the procedure did not

include measures to ensure that a sensing line common to RVLIS and Reactor Coolant System pressure transmitter PT-68-66 was isolated so as to preclude actuation of a pressure interlock for the Residual Heat Removal (RHR) isolation valves. This deficiency resulted in the

, unanticipated isolation of the RHR system because of a high pressure signal sensed by the transmitter during RVLIS fill,

. vent, and pressurization. (This is SWEC item A02850802001-007, additional example of violation 85-17-04).

2. Corrective Action Taken In response to this violation Sequoyah Nuclear Plant (SQN) stated (reference 2):
a. In revision 8 of DPSO-SMI-IDG, step 9A(4)4.1 was revised to specify the position of the local / remote selector switch.

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I Page 2 of 10

Because of the concern over the test equipment (test rig) not being controlled by the maintenance and test equipment program, the TVA Central Laboratories performec certification testing to qualify the test rig. Also DPSO-SMI-1DG was revised to include a step for recording test equipment data.

b. SQM-24 was cancelled axiowing only MI-11.2 to be utilized for adjusting torque and limit switches on motor-operated valves during modification or maintenance activities.
c. A permanent revision was approved and issued for SI-484 to include steps for preventing isolation of RHR suction during testing of the RVLIS system.
3. Verification Methodology The SWEC concerns identified for ECTG verification were stated as follows:

RIMS NUMBER ISSUE RIMS ITEM A02850802001 Failure to establish adequate RIMS-001 procedures for testing of diesel generator relays; Limit Switch adjustment for MOV; fill and vent of RPV level indicator system.

A02850802001 Another example of procedure RIMS-006 lack. Lack of necessary control on valve limit switch adjustment resulted in incorrect limit switch set and subsequent MF water valve f ailurer.

i A02850802001 Another example of failure to RIMS-007 provir,a an adequate procedure for test reactor vessel level l . instrumentation.

ECTG reviewed the SQN Compliance Licensing files for internal and external correspondence ralated to the issues, the applicable procedures, and the NRC status and tracking system for tho issues. This review of the pertinent documentation formed the basis for this verification activity.

4. Verification Analysis The ECTG review found that corrective actions were implemented as described in II.A.2 above NRC found the SQN response to be acceptable and closed the violation 50-327/85-17-04 and 50-328/85-17-03 in Report 86-19 (reference 4).

Page 3 of 10

5. Completion Status Based on SQN's compliance with requirements and NRC closure of the violation, no further action is needed on these items.

These SWEC concerns are closed.

B. A02850802001-002 (URI 50-327, 328/85-16-03), Lack of Timeliness of Corrective Action

1. Backaround The inspector reviewed TVA and vendor installation drawings against the field configuration of the battery racks for the 125V vital DC battery banks. The inspector found that gaps existed between the end cells and end stringers of vital batteries I, II, III, and IV. Continued review identified excessive delays in accomplishing correctiv2 action and an apparent failure by TVA to review nonconforming conditions at j one site for applicability to other TVA sites.

The NRC inspector stated that information was received indicating that a Nonconformance Report (NCR) was written on end j spacers on vital batteries for TVA's Watts Bar Nuclear Plant 4 (WBN) because of a letter received from the vendor, Gould, in May 1984. SQN has the same type of vital batteries as WBN, but SQN did not receive the information and initiate an evaluation until April 1985. This was identified by the NRC as unresolved 1 item 50-327, 328/85-16-03, Lack of timeliness of corrective

action and review of nonconforming conditions. An NRC order

! dated June 14, 1985 was issued to TVA requiring a complete l evaluation of nonconformance handling procedures and an appropriate corrective action plan for assuring timely review of nonconforming conditions at one site for applicability to other l TVA sites.

I

2. Corrective Actions Taken l

TVA initiated immediate action maintenance requests (MRs) to

! install end spacers on the vital battery banks. The MRs were

. completed May 14, 1985, during the NRC inspection period and were documented as completed in the NRC inspection report (reference 1). Field Change Requests (FCR) numbers 3530 and 3536 were issued to accomplish updates of the applicable

{ drawings. The TVA evaluation report and corrective action plan

, was forwarded to NRC August 13, 1985 (reference 8). The report

. outlined an overall revamping of the nonconfctmance handling procedures including management controls to ensure prompt '

handling and appropriate review for applicability to other

- sites. TVA's commitment and general actions are also outlined in the Nuclear Performance Plan, section 2.5.1 (reference 9).

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Page 4 of 10

3. Vcrification Methodology The SWEC concern identified for ECTG verification was stated as follows:

A02850802001 Failure to modify and document RIMS-002 1 battery racks and cells per vendor notification and lack l of timeliness of corrective actions and review of nonconforming conditions.

ECTG reviewed the SQN compliance Licensing files for inteer.a1 and external correspondence related to the issue, and the NRC status and tracking system for the issue. This review of the l j pertinent documentation formed the basis for this verification '

j activity. -

4. Verification Analysis ECTG verified that the corrective actions were implemented as i

described in II.B.2 above. ECTG considers the SQN activities complete. At the time of these verification activities the NRC unresolved item had not yet been closed.

5. Completion Status No additional action is needed on this ites. Following NRC c

closure of the unresolved item 50-327, 328.85-16-03, this SWEC P concern can be closed.

C. A02850802001-003 (Violation 50-327/85-17-02), Failure to Follow Procedure and Radiation Work Permit:

1. Background

! Technical Specification 6.11 requires that procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR 20 and shall be approved, maintained I and adhered to for all operations involving personnel radiation exposure. These requirements are implemented by procedure RCI-1, " Radiological Hygiene Program," which requires each employee to adhere to Health Physics procedures and protective measures. One protective measure, Radiation Work Permit (RWP) 1-85-105, required a canvas hood be worn in addition to other a'

protective clothing while conducting activities in the unit 1 containment radiation area.

Contrary to the above, RWP 1-85-105 requirements were not implemented in that an individual was observed conductin$

activities in the unit 1 containment without the prescribed

! canvas hood. This was identified as NRC violation 50-327/85-17-02.

Page 5 of 10 a

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I j 2. Corrective Actions Taken 1 j In response to this violation SQN stated (reference 2):

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Upon completion of the inspections and while exiting (an) 3 elevated work area, the (TVA) inspector's hood fell off while

] moving through an unusually tight area. In order to ensure

} continued compliance with Radiation Control Instruction (RCI)-1, the individual has been re-inatructed in the proper procedures j to be followed in the event that protective clothing is lost or j damaged during work.

1 1 3. Verification Nethodology

( The SWEC concern identified for ECTG verification was stated as a follows:

A02850802001 Failure to follow radiation RIMS-003 l protection control procedure and radiation work permit by QA auditor and HP Tech, and l -

TVA to clarify procedure wording.

ECTG reviewed the SQN Compliance Licensing files for internal l and external correspondence related to the issue, the applicable

$ procedure, and the NRC status and tracking system for the f .

issue. This review of the pertinent documentation formed the l basis for this verification activity.

g 4. Verification Analysis 1

-ECTG verified that the NRC accepted TVA's corrective action and closed the violation 50-327/85-17-02 in report 86-15 (reference 5).

5. Completion Status i

j No additional action is needed on this item. Based on SQN's compliance with requirements and NRC closure of the violation, s : , this SWEC concern is closed.

I

! D. A02850802001-004 (Violation 50-327, 328/85-20-02), Failure to

: establish controls on movement and storage oculpment within regulated areas f

F

1. Background

, On June 4, 1985, during a plant tour, the inspector discovered

  1. an unattended contaminated tool in an unsealed yellow plastic p bag on EL 690 of the Auxiliary Building. Health Physics was  ;

called and the bag was surveyed. ECI-1, " Radiological Hygiene Control." established controls on t he movement and storage of equipment within regulated areas. These controls were not

,. implemented. This issue is included as a further example of a

{; violation described in IE Inspection Report 327,328/85-20.

S Page 6 of 10 f

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2. C_orrective Actions Taken [

In response to this violation SQN stated (reference 3);

a. The items identified were properly labeled as required by 10 CFR 20.203(f).
b. The items of noncompliance have been discussed at the daily plant staff meetings to ensure the plant management is aware of the problem areas.
c. A training seminar on labeling and/or storage requirements for radioactive materials will be given to the SQN Health  ;

Physics technician.  !

d. Implementing procedures will be reviewed and/or revised to agree with 10 CFR 20.203(f).
e. Health Physics technicians will be instructed to randomly survey plant areas to ensure labeling and/or storage requirements for radioactive materials are met.
f. A general employee handbook currently being prepar3d for SQN will include instructions for the proper disposition of radioactive material.

C. Verification Methodology The SWEC concern identified for ECTG verification was stated as follows:

A02850802001 Radiological hygiene control RIMS-004 i procedure establishing control on movement and storage of ,

equipment in regulated area not implemented.

ECTG reviewed the Sequoyah Compliance Licensing files for internal I , and external correspondence related to the issue, the applicable procedure, and the NRC status and tracking system for the issue.

This review of the pertinent documentation formed the basis for this verification activity.

[

1. Verification Analysis

! ECTG verified that the NRC accepted TVA's corrective action and

closed the violation 50-327, 328/85-20-02 in report 86-04 (reference 6).
2. Completion Status Based on the SQN corrective actions, compliance with requirements, and NRC closure of the violation, no further action on this item is requiced. This SWEC concern is closed, f

Page 7 of 10 I ,

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E. A02850802001-005 (Violation 50-327/85-17-05, 50-328/85-17-04),

Failure to follow procedures ,

1. Background

Technical Specification 6.8.1 states that written procedures shall be established, implemented, and maintained covering the procedures referenced in appendix A of NRC Regulatory Guide 1.33, revision 2, February 1978. Procedure NI-10.1, " Diesel Generator Inspection," was established to implement requirements for Emergency Diesel Generator surveillance testing. NI-10.1 paragraph 5.3.1.2.2.5 requires technicians to set up test equipment before diesel engine start and paragraph 5.3.1.2.4 requires the technician to verify receipt of the " Engine Running" annunciation at 850 rpm engine speed.

Contrary to the above, as of May 21, 1985, MI-10.1 was not implemented in that technicians did not set up their test equipment before engine start and the technician erroneously recorded 850 rpm as the annunciation speed when the annunciation actually energized at about 875 rpm.

2. Corrective Actions Taken In response to this violation SQN stated (reference 2):

NI-10.1 has been revised to change the note to clarify its purpose.

a. Temporary changes 85-0633 and 85-0828 were written to provide a more detailed instruction for communications between the technicians and the operator while raising the engine speed to 850 rpm.
b. On recent performances of MI-10.1, step 5.3.1.2.4 engineering support was provided for the technician to implement the necessary communications with the operator outside of the running engine chamber for raising engine speed very slowly to 850 rpm.
c. The aforementioned temporary changes reworded the specified 850 rpm to allow for approximately 850 rpm. The wording, "approximately 850 rpm," was already includsd on the data sheet at the time the violation occurred.

Page 8 of 10

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3. Verification Methodology  ;

The SWEC concern identified for ECTG verification was stated as follows:

4 A02850802001 Technician did not follow RINS-005 procedure as test equipment set up after engine start and failed to document correct engine speed.

Lack of personal compliance to procedure.

ECTG reviewed the SQN Compliance Licensing files for internal and external correspondence related to the issue, the applicable procedure, and the NRC status and tracking system for the issue. This review of the pertinent documentation formed the basis for this verification activity.

4. Verification Analysis ECTG verified that corrective actions were accomplished as described in II.E.2 above. The !!RC accepted TVA's corrective action (reference 7). However, this item will remain open pending NRC verification and closure. SQN corrective actions are completed.
5. Completion Status i

No further action on this item is required. Following NRC closure of the item, this SWEC concern can be closed.

III. References

1. NRC Inspection Report 50-327, 328/85-17, dated July 30, 1985, R. D. Walker to H. G. Parris l 2. TVA response to NRC Inspection Report 50-327, 328/85-17, dated August 28, 1985, D. E. McCloud to J. N. Grace l
3. TVA response to NRC Inspection Report 50-327,328/85-20, dated July 19, 1985, J. A. Domer to J. N. Grace
4. NRC Inspection Report 50-327, 328/86-19, dated Nay 13, 1986, J. A. 01shinski to S. A. White
5. NRC Inspection Report 50-327, 328/86-15, dated April 4, 1986 J. A. 01shinski to S. A. White
6. NRC Inspector Report 50-327, 328/86-04, dated March 27, 1986, J. A. 01shinski to S. A. White Page 9 of 10
7. NRC Letter, "NRC Inspection Report 50-327, 328/85-17", dated September 26, 1985, D. Walker to H. G. Parris
8. TVA Letter, "Sequoyah Nuclear Plant Units 1 and 2 Browns Ferry Nuclear Plant Units 1, 2, and 3," dated August 13, 1985, H. G. Parris to J. N. Grace
9. Revised Sequoyah Nuclear Performatice Plan, dated June 17, 1986 Page 10 of 10 L_ j
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