ML20196L615
| ML20196L615 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 07/01/1988 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8807080065 | |
| Download: ML20196L615 (5) | |
Text
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l 's TENNESSEE VALLEY AUTHORITY CHATTANOOGA. TENNESSEE 374ot SN 157B Lookout Place JUL 011988 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 (SQN) - NRC INSPECTION REPORT NOS. 50-327/87-66 AND 50-328/87 SYSTEM ALIGNMENT INSPECTION - REVISED RESPONSE TO VIOLATION Enclosed is our revised response to Kenneth P. Barr's December 21, 1987 letter to S. A. White that transmitted a notice of violation 50-327, -328/87-66-01.
This revised response clarifies the process by which Administrative Instruction (AI) 58 was reviewed and approved.
If you have any questions, please telephone M. J. Ray at 615/870-6422.
Very truly yours, TENNES EE VALLEY AUTHORITY R.
ridley, Dire or Nuclear Licensi and Regulatory Affairs cc (Enclosure):
Mr. K. P. Barr, Acting Assistant Director for Inspection Programs TVA Projects Division U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Ms. S. C. Black, Assistant Director for Projects TVA ?rojects Division U.S. Nuclear Regulatory Commission One White Flint, North
@l 11555 Rockville Pike Rockville, Maryland 20852 Sequoyah Resident Inspector l
Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy Daisy, Tennessoo 37379 8807080065 880701 PDR ADOCK 05000327 i
An Equal Opportunity Employer Q
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50-327/87-66 AND 50-328/87-66 6- '
KENNETH P. BARR'S LETTER TO S. A. WHITE DATED DECEMBER 21, 1987 Violation 50-32J. -328/87-66-01 "A.
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 administrative procedures The requirements of TS 6.8.1 are implemented by Administrative Instruction AI-2 titled ' Authorities and Responsibilities for Safe Operation and Shutdown', Administrative Instructior AI-4 titled
' Preparation, Review, Approval and Use of Plant Instructions', and Administrativo Instruction AI-30, titled ' Nuclear Plant Method of Operation.'
Operation Section Administrative Letter OSLA-58, titled
' Maintaining cognizance of Operational Status - Configuration Control',
implements the requirements of AI-2 and AI-30 for maintaining configuration control.
Contrary to the above, prior to October 30, 1987, the licenseo failed to adequately establish, implement, and maintain proceduros for configuration control as follows:
1.
The licensee failed to adequately specify when configuration control should start in that OSLA-58 requires the unit's lead operator to maintain configuration control records only after the System Operating Instruction (SOI) checklists are complotod, but not while the checklists are in progress.
2.
The licenseo failed to specify in AI-2 or OSLA-58 an appropriate method for deviating from SOI checklists in that deviations to SOI checklists were not considered as procedure changes. Because of this, the licensee did not use the appropriate critoria or approval level for processing deviations.
3.
The licensee failed to adequately impicment the requirements in AI-4 and OSLA-58 for tho use of working copies of SOI checklista in that the completed working copy for 301 valve checklist 68.1A indicated a
the checklist was not properly performed while the final copy did not.
AI-4 requires that information be transferred from the working copy to the final copy after the completion of work.
4.
The licensee failed to implement the requirements in OSLA-58 for recording of deviations from SOI checklists in that the designated unit operator was not placing the date next to his initials when deviating an item on the status filo copies of checklists as required by OSLA-58.
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The licensee failed to implonant the ' requirements 'in OSLA-58 for maintatning configuration control after SOI checklists are complete in that the documented positions in the configuration control system for the four Reactor Coolant Pump Seal Return Flow Control Valves, the Excess Letdown Heat Exchanger Supply Containment Isolation Valve, and the three Boron Injection Tank recirculation valves disagreed with the actual positions.
6.
The licenses failed to implement the requirements in OSLA-58 for processing a revision to SOI checklist 63.1d in that the configuration los entries for RHR supply valves 2-FCV-74-1 and 2-FCV-74-2 were cleared when the checklist revision was received without reperforming the portion of the checklist that had been revised. This resulted in the, documented positions in the configuration control system being in disagreement with the actual positions.
This is a Severity Level IV violation (Supplomont I)."
Admission or Denial of the Violation TVA admits the violction and all examples stated.
Reason for the Violation An inadoquato instruction letter (Operations Section Letters Administrative 10SLA) 58), coupled with a lack of management attention to the system alignment and configuration control program, was the cause of this violation.
Corrective Steps That Have Been Taken Corrective actions taken with respect. to this violation include the conversion of OSLA-58 to Administrative Instruction (AI) 58.
This conversion included addressing the procedural problem areas identified in this violation.
Additionally, AI-58 was reviewed through the independent qualified reviewer process and approved by appropriate responsible managoe.
Management personnel were assigned to directly supervise the system alignment program, and training was given to all personnel involved in this program regarding the importanc.: of following procedures. OstA-107 was performed on all AI-58 Appendix A checklists before their performanco.
Correctivo Steps That Will Bo Taken to Avoid Further Violations The corrective actions taken with respect to this violat. ion should be sufficient to provent further violations of this naturo.
Dato When Full Compliance Will Do Achieved All correctivo actions referenced in this responso have been completod.
Specific correctivo actions for the examplos of the violation are given below.
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"The licensee failed to adequately specify when configuration control should start in that OSLA-58 requires the unit's lead operator to maintain configuration control records only af ter the System Operating Instruction (301) checklists are completed, but not while the checklists are in progress."
Corrective Steps That Have Been Taken OSLA-58 was converted to AI-58; AI-58, revision 1, section 3.2.f, specifically requires configuration control to be maintained throughout the performance of an SOI checklist.
Additionally, involved permanent and temporary SQN Operations Group employees have recolved training on AI-58.
This training was conducted before employees used the revised procedure.
Example 2 "The licensee failed to specify in AI-2 or OSLA-58 an appropriate method for deviating from SOI checklists in that deviations to SOI checklists were not considered as procedure changes. Because of this, the licensco did not use the appropriate criteria or approval lovel for processing deviations."
Corrective Steps That Have Been Taken AI-58 addresses checklist deviations in section 3.5.
The method of deviation meets approval and implementation criteria of technicel specifications 6.8.3 and 6.5.1A.la.
Deviations now receive the samo level of review as a temporary procedure chango.
Involved operations Group employees have been trained on the deviation process.
Examplo 3 "The licensee failed to adequately implement the requirements in AI-4 and OSLA-58 for the use of working copics of SOI checklists in that the completed working copy for SOI valvo checklist 68.1A indicated the checklist was not properly performed whlic the final copy did not.
AI-A requires that information be transferred from the working copy to the final copy after the completion of work."
4 Correctivo Steps That Have Been Taken An assistant shift supervisor was assigned to directly superviso this activity, and involved employees woro retrained on procedural compliance.
Examplo 4 "The licenseo failed to implement the requirements in OSLA-58 for recording of deviations from Sol checklists in that the designated unit operator was not placing the dato next to his initials when deviating an item on the status filo copios of checklists as required by OSLA-58."
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Employees involved were counselled on the importance of adhering to
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. management member were selected to supervise system and valve alignment verification reperformance.
Example 5 "The licensee failed to implement the requiroments in OSLA-58 foe maintaining configuration control after SOI checklists are complete in that the documented
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positions in the configuration control system for the four Reactor Coolant Pump Seal Return Flow Control Valves, the Excess Letdown Heat Exchanger Supply containment Isolation Valve, and the three Boron Injection Tank recirculation valves disagreed with the actual positions."
Corrective Steps That Have Been Taken Management personnel were assigned to directly supervise the system alignment activities, and involved employees woro retrained regarding the importance of following procedures.
Additionally, the issuance of AI-58, which addresses the identified program deficiencies, should aid in preventing further violations of this nature.
Example 6 "The licensee failed to implement the requirements in OSLA-58 for processing a revision to SOI checklist 63.1d in that the configuration los entries for RllR supply valves 2-FCV-74-1 and 2-FCV-74-2 woro cleared when the checklint revision was received without reperforming the portion of the checklist that had been revised. This resulted in the documoated positions in the configuration control system being in disagreement with the actual positions."
Corrective Steps That Have Been Taken Management personnel were assigned to directly supervisc the system alignment activities, and involved employees waro retrained regarding the importance of following procedures.
Additionally, the issuance of AI-58, which addresses the identified program deficiencies, should aid in proventing further i
violations of this naturo.
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