ML20012G327
| ML20012G327 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 02/16/1993 |
| From: | Fenech R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9302240015 | |
| Download: ML20012G327 (7) | |
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Tennessee Vaney Authonty. Post Offce Box 2000 Soddy-Daisy. Tennessee 37379-2000 j
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Roben A. Fenech
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Vee Residet. hqwyah Nxtear Plant
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, i February 16, 1993 U.S. Nuclear Regulatory Commission AITN: Document Control Desk Washington, D.C. 20555 q
4 Gentlemen In the Matter of
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Docket Nos. 50-327 Tennessee Valley Authority
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50-328 SEQUOYAH NUCLEAR PLANT (SQN) - NRC INSPECTION REPORT NOS. 50-327,
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328/92 RESPONSE TO NOTICES OF VIOLATION (NOVs) 50-327, 328/92-36-03 and 50-327, 328/92-36-04
.I contains TVA's response to Ellis W. Merschoff's letter to M. O. Medford dated January 15, 1993, which transmitted the subject.
NOVs. The first violation is associated with two handswitches, one in.
the 1B1-B and 1B2-B diesel generator day tank supply pump circuitry and-the other a refueling water storage tank heater switch, being in the i
wrong position. The second violation is associated with the failure to.
i perform American Society of Mechanical Engineers (ASME)Section XI
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pressure tests within the.timeframe specified by the ASME Section XI' code.
- contains a summary of commitments made in this. submittal.
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If you have any questions concerning this submittal, please telephone K. E. Meade at (615) 843-7766.
Sincerely, l
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T Robert A. Fenech I
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See page 2 l
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9302240015 930216 d-
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U.S. Nuclear Regulatory Commission Page 2 February 16, 1993 i
cc (Enclosures):
Mr. D. E. LaBarge, Project Manager
_j U.S. Nuclear Regulatory Commission
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One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852-2739 NRC Resident Inspector i
Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy-Daisy, Tennessee 37379 Mr. B. A. Wilson, Project Chief.
U.S. Nuclear Regulatory Commission
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Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323-0199 i
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ENCLOSURE 1 RESPONSE TO NRC INSPECTION REPORT NOS. 50-327/92-36 AND 50-328/92-36 ELLIS W. MERSCH0FF'S LETTER TO MARK 0. MEDFORD DATED JANUARY 15, 1993-Violation 50-32Z, 328/92-36-03
" Technical Specification 6.8.1 requires, in part, that written procedures l
te established, implemented and maintained for applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Quality Assurance Program Requirements, Revision 2, February 1978. Appendix A to Regulatory Guide 1.33 requires procedures for equipment control and operation of safety equipment.
"A.
Periodic Instruction 0-PI-OPS-000-006.0, FREEZE PROTECTION, Rev. 0.[ sic),-identifies equipment needing freeze protection,.
identifies the means of protection, and provides requirements to ensure equipment operability during the months needed.
Contrary to the above, Periodic Instruction 0-P"-OPS-000-006.0 was.
inadequate in that it did not provide for conf 3
(. ration control of 6
Refueling Water Storage Tank (RWST) immersion heater power supply switches. On December 24, 1992, it was discovered that handswitch 2-HS-63-132 which controls two of the four RWST immersion heaters was in the OFF position instead [ sic) the AUTOMATIC position. D2is resulted in the inoperability of these two Unit 2 RWST immersion j
heaters for an unknown period of time.
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System Operating Instruction SOI-82.2, DIESEL GENERATOR 1B-B, l
Rev. 39, specifies the normal pcsition of the handswitch for the t
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IB1-B and IB2-B diesel generator day tank supply pump to be in the AUTO position.
Contrary to the above, on approximately December 18, 1992, the licensee failed to follow procedure S0I-82.2.
On December 21, 1992, it was discovered that the handswitch for the 1B1-B and 1B2-B diesel generator day tank supply pump was in the OFF position instead of f
the AUTO position.
"This is a Severity Level IV violation (Supplement 1)."
Reason for the Violation The diesel generator (D/G) day tank supply pump handswitch was determined to have been mispositioned during manipulations performed by an~ assistant unit operator (AUO) while attempting to clear a main control room (MCR).
annunciator. The 1B-B D/G day tank high level alarm had annunciated in l
the MCR. The Unit 1 assistant shift operations supervisor (ASOS) requested that the AU0 attempt to clear the annunciator (i.e., drain the i
tank below the annunciator setpoint).
It was concluded that while
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draining the tank, the ADO placed the handswitch to the pumps in the OFF position.
The annunciator cleared shortly after draining was initiated, and the AUO who was performing multiple tasks at the time apparently failed to return the handswitch to the AUTO position.
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g The refueling water storage tank (RWST) immersion heater handswitch was found mispositioned while attempting to increase the RWST temperature after discovering temperature below the technical specification minimum t
value. The freeze protection procedure, which verifies that essential j
heaters are functioning properly, only checks the circuit breaker for the heater and not the handswitch position, f
Both of these conditions were determined to be caused by lack of procedural control. A procedure did not exist and was not developed to address clearing the D/G day tank high level alarm. Status of the fuel j
oil system was not previously controlled under the configuration control r
system; this led to an acceptance of making status changes without procedural controls.
It is expected that procedural requirements would have prevented these switches from being mispositioned by requiring sign-off verification steps. The freeze protection procedure was i
inadequate in that it did not ensure that the RWST heater handswitches were in the proper position.
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Corrective Stepa_Ihat_Hav.e Been Taken_and the Results Achieved The subject handswitches were repositioned upon discovery.
The AUO involved in the D/G handswitch event was given appropriate disciplinary action.
t Refresher training has been provided to Operations concerning the D/G fuel oil transfer system, including emphasis on transfer pump handswitch operation.
Periodic Instruction 0-PI-OPS-000-006.0, " Freeze Protection," has been revised to include a check of the handswitches for the RWST immersion heaters.
t Several actions have also been tchen related to the control of r
configuration beyond the specific cited events. A configuration.
verification of main control room handswitch positions has been
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performed, as well as a configuration verification of 25 components in safety-related systems. Minor discrepancies were identified and immediately corrected.
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Additionally, Operations' management is meeting with operators as part of the requalification training cycle to stress the need for procedural
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compliance and to stress the need for performing actions, including configuration changes, within the guidelines of established processes.
t Corrective Slepa_ThaLH111_he_Inhen to Avoid Further Violations
.j The annunciator response procedure associated with the day tank high
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level annunciator will be revised to include instructions on how to clear the subject annunciator.
System Operating Instruction 82, Section G will be revised to include I
specific steps on how to drain the D/G day tanks.
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A review of each system identified by the plant configuration control procedure was performed to identify components requiring the need for configuration control. Additionally, interface systems and subsystems were reviewed for inclusion into the configuration control procedure.
This review also evaluated existing Operations procedures to ensure that adequate configuration control is provided for each system.
Recommendations from this effort are being reviewed by Operations' management and, where appropriate, are being addressed in the configuration management program.
Additionally, Operations is performing.a verification of the configuration of accessible safety-related components.- The need to perform a verification of secondary plant component configuration is being evaluated.
Date When Full Compliance _Will be Achieved TVA is in full compliance for the specific examples cited by NRC. As described above, additional actions are underway to improve the control of configuration at SQN.
Einlation 50-3224_328/92-36-04
" Technical Specification 4.0.5 delineates inservice inspection and testing requirements of ASME Code Class 1, 2, and 3 components. These requirements specify that inservice inspection of ASME Code Class 1, 2, and 3 components and inservice testing of ASME Code Class 1, 2, and 3 pumps and valves shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50, Section 50.55a(g), except where specific written relief has been granted by the Commission pursuant to 10 CFR 50, Section 50.55a(g)(6)(i).
"ASME,Section XI, Table IWD-2500-1, requires a visual inspection (VT-2) as a part of an inservice pressure test of safety-related components within each of the three inspection periods during each 10 year inservice inspection interval.
" Contrary to the above, on December 22, 1992, required pressure tests on various safety-related systems (e.g., containment spray, essential raw cooling water, auxiliary feedwater, safety injection, and spent fuel pit) had not been performed during the second inspection period of the first 10 year surveillance interval. This condition existed since the end of the second inspection period which occurred on September 15, 1991 and February 21, 1992, for Units 1 and 2, respectively.
"This is a Severity Level IV violation (Supplement 1)."
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N ENCLOSURE 2 Commitments F
l violation 50-327/92-36-03 1.
The annunciator response procedure associated with the day tank high level annunciator will be revised by March 1, 1993, to include j
instructions cm how to clear the subject annunciator.
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System Operating Instruction 82,.Section G will be revised by March 1, 1993, to include specific steps on how to drain the diesel generator day tanks.
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Violation 50-327/92-36-04~
No new commitments are identified beyond those contained in Licensee
- l Event Report 327/92026, dated January 21, 1993.
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. _4 Reason for the Violation The f ailure to perform American Society of Mechanical Engineers (ASME)
Section XI testing resulted from the Section XI program not being well l
defined, controlled, or dccumented.
Lack of program definition and i
structure resulted in dependence on the experience and knowledge of specific individuals involved. Multiple organizational and personnel changes associated with program implementation occurred in the 1987-1992 timeframe.
These factors resulted in ineffective program implementation.
Additional details concerning this condition were reported to NRC in Licensee Event Report 50-327/92026 dated January 21, 1993.
Corrective Steps That Have Been Taken and the Results Achieved The required Section XI in-service or functional pressure testing has been completed.
This testing, which was a visual inspection at system operating pressure, verified that no unidentified leaks existed.
Corrective Steps That Will be Taken to Avoid Further Violations Technical Support personnel are currently reviewing the remaining activities to be performed during the current 10-year interval.
This review will identify and schedule all remaining ASME Section XI pressure tests for the 10-year interval.
i Technical Support will revise Site Standard Practice 8.5,."ASME Section XI Program," to define the implementation of a structured _ program that institutionalizes adequate scheduling and tracking of tests to ensure compliance with the ASME Section XI pressure test requirements.
t Self-assessments are on-going as part of the overall site performance improvement effort to identify other program implementation weaknesses.
This is intended to identify both programs that are not being effectively I
implemented and processes that lack adequate programmatic structure to ensure long-term continuity.
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Date_When-Full Compliance Will be Achieved TVA is in full compliance.
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