ML20082N745

Forwards Response to NRC Re Violations Noted in Insp Repts 50-327/94-41 & 50-328/94-41.Corrective Actions: Shut Down All Work Associated W/Spent Fuel Pit Rerack Project in Jan 1995

ML20082N745
Person / Time
Site:	Sequoyah
Issue date:	04/21/1995
From:	Adney R TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9504250364
Download: ML20082N745 (5)

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April 21, 1995 t

I U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Gentlemen In the Matter of ) Docket Noc. 50-327 Tennessee Valley Authority ) 50-328 SEQUOYAH NUCLEAR PLANT (SQN) - INSPECTION REPORT NOS. 50-327, 328/94 i REPLY TO NRC LETTER DATED FEBRUARY 27, 1995 Enclosed is TVA s response to the letter from Stewart D. Ebneter to Oliver D. Kingsley, Jr., dated February 27, 1995.

The violation involves the failure to follow procedures and inadequate

' procedures. Example 1 of the violation is associated with the fuel handling supervisor not being present in the spent fuel pit area during the shuffle of spent fuel. Example 2 of the violation involves inadequate procedures that did not provide adequate precautions or instructions regarding the retrieval and storage of the spent fuel handling tool in its storage rack.

TVA previously acknowledged Example 1 of the subject violation in the January 30, 1995, response.

As requested in the subject letter, other standing orders or processes that could circumvent administrative requirements have been reviewed for the extent of condition associated with Example 1 of the violation and no other cases wore found where administrative requirements were circumvented.

TVA acknowledges that Example 2 of Violation 50-327, 328/94-41-01 occurred as stated. Corrective actions are discussed in the enclosure. l In the January 30, 1995, response, TVA stated that the AUO operating the l hoist had previously performed this operation numerous times without incident. This information was incorrect. Although the operation had been performed over a period of 15 years without any known incident, the AUO in question had only performed this operation two times previous to this event.

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U.S. Nuclear Regulatory Commission Page 2 April 21, 1995 The subject letter also requests information for the event involving the debris canister lifting tool which occurred on December 5, 1994, and was discussed as an additional example of Violation 50-327, 328/94-41-01, Example 2, in Inspection Report 50-327, 328/94-45. Corrective actions which included replacing the broken cable with a stainless steel cable and a stainless steel clamping device and revising Fuel Handling Instructions (FHIs) 2 and 3 to include functional testing and use of the debris canister tool were complete by December 9, 1994.

As coordinated with the NRC staff, this response has not been submitted within the 30-day timeframe specified in the February 27, 1995, letter.

A date of April 21, 1995, was coordinated with the NRC staff for submittal of this response. This date was necessary because of a meeting between TVA and NRC, which was held at Region II on April 12, 1995, regarding this issue.

If you have any questions concerning this submittal, please telephone S. D. Gilley at (615) 843-7427.

Sincerely, 4

j R. . Adney Site Vice President Enclosure cc (Enclosure):

Mr. D. E. LaBarge, Project Manager U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852-2739 NRC Resident Inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy-Daisy, Tennessee 37379-3624 Regional Administrator U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suxte 2900 Atlanta, Georgia 30323-2711

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ENCLOSURE NRC' INSPECTION REPORT NOS. 50-327, 328/94-41 REPLY TO STEWART D. EBNETER'S LETTER TO OLIVER D. KINGSLEY, JR.

DATED FEBRUARY 27, 1995 Violation 50-327. 328/94-41-01

" Technical Specification 6.8.1 requires, in part, that written procedures shall be established, implemented,' and maintained covering the activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Appendix,A of Regulatory Guide 1.33 includes administrative procedures for authorities and responsibilities for safe plant. operation and general plant operating procedures for refueling equipment operation. Implicit in these requirements is that the procedures be adequate.

" SSP-12.1, conduct of Operations, Revisions 10, was established, in part, to delineate the responsibilities of the Fuel Handling Supervisor. .

Section 3.1.15 requires that the Fuel Handling Supervisor be present during any fuel movement, including fuel shuffle.

"FHI-3, Movement of Fuel, Revision 26, was established, in part, to -i provide prerequisites, precautions, and instructions for the transfer of fuel assemblies within the auxiliary building.

" Contrary to the above:

1. Procedure SSP-12.1, was not implemented in that on November 25, 1994, the Fuel Handling Supervisor was not present in the spent fuel pit area during the shuffle of spent fuel.

2. Procedure FHI-3, was inadequate in that it did not provide adequate~

precautions or instructions regarding the retrieval and storage of the spent fuel handling tool in its storage rack.

"This is a severity level IV violation (supplement 1)."

f Reason for the Violation Example 2 TVA originally responded to the violation in a letter dated January 30, 1995, in which TVA denied Example 2 of the violation. In the denial, TVA concluded that inattention to detail was the cause of this event. By  ;

letter dated February 27, 1995, NRC rejected TVA's position regarding the denial of Example 2. As discussed in a meeting between TVA and NRC on April 12, 1995, TVA has subsequently reevaluated the event and concluded. ,

that the causes of this violation went beyond inattention to detail by ,

the operator. The inattention to detail was discussed in TVA's initial response of January 30, 1995.

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Investigation revealed several reasons for the occurrence of the violation. One of the causes for this violation was the unfamiliarity with the task on the part of the AUOs. The AUO performing the lifting of the tool had only performed this task two times prior to this event.

Most of the AUOs assigned to this pro,4ect had very little experience at SFP manipulations. This task had previously been performed by contract personnel and licensed operators. Another cause was that the training given to the AUOs and fuel handling supervisors at the beginning of the project did not incorporate the specifics of retrieving the tool. The ,

I training was centered around the movement of fuel, utilizing the fuel handling tool. In addition, a fuel handling supervisor was assigned to the project on a part-time basis. The fuel handling supervisor was not i present when the events occurred. The presence of direct supervision f during the maneuvering of the fuel handling tool should have increased l overall alertness and helped to increase awareness to the possibility of j this unexpected' problem.  !

Corrective Steps That Have Been Taken and the Results Achieved TVA shut down all work associated with the spent fuel pit rarack project  ;

in early January 1995 as a result of several problems that occurred with the. project.

The Site Vice President requested that an independent team be assembled to examine the problems and the project as a whole. As a result of these efforts, floor managers were established who would be present on the refuel floor during the performance of significant work associated with the rarack project.

A standing order had been issued which stated that a senior reactor operator was not required to be continually at the spent fuel pit site during the shuffle of spent fuel for the rerack project. This standing order was in direct conflict with SSP-12.1, which requires the fuel handling supervisor be present during fuel shuffle. In the response to violation 50-327, 328/94-41-01, Example 1, dated January 30, 1995, TVA stated that the standing order that allowed the fuel handling supervisor to be at other locations other than the spent fuel pit was revoked. In addition to correcting the root cause of Example 1 of the violation, this action also increases awareness and alertness of AUOs by providing direct supervision for spent fuel pit activities. Therefore, this action also serves as a corrective action for Example 2.

Spent fuel tool retrieval has been added to the fuel handling AUO Qualification Cards and to the refuel SRO Qualification Cards.

The spent fuel handling tool storage rack has been relocated to the bridge which is above the elevation of the spent fuel storage racks and is clear of other obstructions.

Corrective Steps That Will be Taken to Avoid Future Violations Corrective actions to prevent future violations are complete as stated above.

_3 Date When Full Comoliance Will be Achieved The completed corrective actions stated above bring TVA into full compliance.

Commitments None.

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