ML20041F765

Responds to NRC 820118 Ltr Re Violations Noted in IE Insp Repts 50-327/81-39 & 50-328/81-48.Corrective Actions: Established Recorder Surveillance Program & Corrected Defective Trip Logic

ML20041F765
Person / Time
Site:	Sequoyah
Issue date:	02/19/1982
From:	Cross J TENNESSEE VALLEY AUTHORITY
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20041F754	List: ML20041F765
References
NUDOCS 8203170394
Download: ML20041F765 (6)

Text

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o TENNESSEE VALLEY AUTHORITY CHATTANOOGA. TENNESNkkIdF41p{r ;

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February 19, 1982 E2 Ff B 23 P2; $0 U.S. Nuclear Regulatory Commission Region II Attn: James P. O'Reilly, Regional Administrator 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303

Dear Mr. O'Reilly:

SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 - NRC/0IE REGION II INSPECTION REPORT 50-327/81-39 AND 50-328/81 RESPONSE TO VIOLATION The subject OIE inspection report dated January 18, 1982 cited TVA with two Severity Level IV Violations and two Severity Level V Violations. Enclosed is our response to the subject inspection report. In a telephone conversa-tion on February 17, 1982, J. Crlenjak of your staff agreed to extend the deadline until February 19, 1982.

If you have any questions, please get in touch with L. M. Mills at FTS 858-2778.

To the best of my knowledge, I declare the statements contained herein are

-complete and true.

Very truly yours, TENNESSEE VALLEY AUTHORITY

. L. Cross, Executive Assistant to the Manager of Power Enclosure cc: Mr. Richard C. DeYoung, Director (Enclosure)

Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, DC 20555 8203170394 820309 PDR ADOCK 05000327 0 PDR An Equal Opportunity Employer

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ENCLOSURE RESPONSE - NRC INSPECTION REPORT NOS. 50-327/81-39 AND 50-328/81-48 R. C. LEWIS' LETTER TO H. G. PARRIS DATED JANUARY 18, 1982 Item A (50-327/81-39-02) 10 CFR 50, Appendix A, Criterion 22 " Protection System Independence" and FSAR section 7.2 " Reactor Trip System" require that the effects of normal operating, maintenance, and testing do not result in loss of the protective function.

Contrary to the above, on November 4,1981, the potential existed for a.

compromising the approved safety design of the plant, due to the violation of the separability requirements, in that temporary test leads were connacted from test points in two different and redundant reactor protection channels to a common strip chart recorder.

This is a Severity Level V Violation (Supplement I.E.).

1. Admission or Denial of the Alleged Violation TVA admits the violation occurred as staced.

2. Reasons for the Violation if Admitted On March 10, 1981, temporary alteration control forms (TACFs) were issued to install recorders at the test points for three pressurizer level instruments and one pressurizer pressure instrument. Subsequent review of TACFs by the Plant Operations Review Committee (PORC) established that connection of recorders via test points did not constitute an alteration or modification to the plant. The practice adopted at this time was to use a maintenance request (MR) to install recorders and maintain a record of all recorder connections and disconnections by use of an instrument maintenance log. In setting this policy, PORC did not consider or specifically analyze the situation where multiple protection sets are connected into a single recorder. Therefore, subsequent testing resulted in multiple protection sets being connected into a common strip chart rccorder without PORC's knowledge or evaluation.

3. Corrective Steps Which Have Been Taken and the Resulta Achieved (1) The recorders were disconnected immediately following discussions with the NRC representatives.

(2) Possible failures of the protection sets discovered connected were analyzed for their effect on plant safety. This evaluation determined that reactor protection was not compromised.

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Page 2 (3) The instrument maintenance log has been expanded into a formalized program.

(4) A surveillance program has been established to inspect the recorders once per shift if recorders are installed for long-term monitoring.

(5) Unit 2 startup tests were reviewed to ensure these new requirements would be followed during unit 2 startup.

4. Corrective Steps Which Will Be Taken To Avoid Further Violations (1) Future multiple protection sets connected to a single recorder or multiple recorders connected to a common ac power source will require .

a failure analysis and PORC approval before testing, but a single protection set to a single recorder may be controlled by the existing system.

(2) In order to prevent pinching of cables from the test points, cables will be routed out of the top lof the cabinet. Where cabinet construction does not allow cables to be routed out the top, the protection set door will remain open when a recorder is connected to the instruments in the cabinet and a sticker placed on the door alarm window noting " Test in Progress." When cables are disconnected from the recorder they will also be disconnected from the instrument in the cabinet.

5. Date When Full Compliance Will Be Achieved Full compliance was achieved November 9, 1981.

Item B (50-328/81-48-01)

Technical Specification 6.8.1.c requires that written procedures shall be established, implemented and maintained covering surveillance and test activities of safety-related equipment.

Contrary to the above, written procedures for surveillance of safety-related equipment were not implemented in that on November 5,1981, during the performance af SI-90.82 (IMI-99-SSPS) " Monthly Functional Test of Solid State Protection System" a bad logic point was identified in the "A" train logic and it was not corrected prior to proceeding with the test and the shift engineer was not immediately notified. Both were procedure requirements. This violation was identifi0d by the licensee on November 6,1981.

This is a Severity Level IV Violation (Supplement I.D.3).

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. 3 Page 3 Item C (50-328/81-48-02)

Technical Specification 3.3.1, Table 3.3-1 requires that the Reactor Trip System Automatic Trip Logie shall be operable in Mode 2 (Startup).

Contrary to the above, the "A" train Reactor Trip System Automatic Trip Logic was not operable in Mode 2 on November 5 and 6,1981, in that the overpower delta temperature function was identified as defective. The defect was identified on November 5.during performance of Surveillance Instruction SI-90.82 prior to entering Mode 2 and was not corrected until November 6 after approximately twelve hours. This violation was identified by the licensee on November 6, 1981.

This is a Severity Level IV Violation (Supplement I.D.3). -

1. Admission or Denial of the Alleged Violations TVA admits the violations occurred as stated in items B and C.

2. Reasons for the Violation if Admitted On November 5,1981, with unit 2 in mode 3, an instrument mechanic initiated a maintenance request (MR) to correct defective logic in the train "A" solid state protection system (SSPS) overpower delta T which was found during the performance of SI-90.82, Reactor Trip Instrumentation Monthly Function Test (SSPS). The instrument maintenance foreman attempted to notify the shift engineer of the inoperable channel; but because of the unavailability of the shift engineer at the time of the phone call, no notification was acccomplished. The foreman was unaware that notification could be made to the shift engineer's designated assistant shift engineer-senior reaccor operator. Instrument personnel then returned the system to service and proceeded with the test without repairing the system.

The control room personnel were not made aware of the inoperable channel and, therefore, proceeded with plant startup and entered mode 2 at 2225 CST on November 5, 1981. On the following day, November 6,1981, maintenance personnel discovered the situation and, at 0900 CST, informed the shift engineer of the defective logic and relevant events of the preceding day.

3. Corrective Steps Which Have Been Taken and the Results Achieved The channel was declared inoperable upon notification to the shift engineer. The defective logic was corrected and the channel declared operable at 0925 CST on November 6, 1981.

4. Corrective Steps Which Will Be Taken To Avoid Further Violations Maintenance foremen have been instructed that the shift engineer or his designated alternate (assistant shift engineer-senior reactor operator) must be notified of defective equipment found during performance of surveillance instructions. The applicable procedures have been revised to i specify instructions in each section for correction of defective logic before returning equipment to service.

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5. Date When Full Compliance Will Be Achieved Full compliance was achieved December 30, 1981.

Item D (50-327/81-39-01 and 50-328/81-48-03) 10 CFR 50, Appendix B, Criterion III and section 17.2 3 of TVA-TR75-1, the licensee's accepted Quality Assurance Program Description, requires that modifications to critical structures, systems, and components (CSSC) shall be controlled to assure that "as-built" quality is not degraded.

Contrary to the above, modifications to CSSC were not controlled in that in April 1980, temporary drain valves were added to the vent condensers of the -

beric acid evaporators (CSSC) without proper authorization as described in Administrative Instruction AI-19 " Plant Modifications." The valve was added to the "B" boric acid evaporator using a maintenance request in accordance with AI-9 " Control of Temporary Alterations" but the modification has remained in effect for over sixty days without the issuance of a design change request as required. The unauthorized modification resulted in lack of configuration control by the operations group and a leak of radioactive material into the auxiliary building on November 10, 1981.

This is a Severity Level V Violation (Supplement I.E.).

1. Admission or Denial of the Alleged Violation TVA admits the violation occurred as stated.

2. Reasons for the Violation if Admitted A temporary alteration control form (TACF) was not issued for the "A" boric acid evaporator drain valve due to personnel misunderstanding that the TACF issued for the "B" boric acid evaporator package covered both modifications, which it did not. A design change request (DCR) was not issued within the 60-day guideline of AI-9 on the addition of drain valves to the boric acid evaporator vent condenser due to the plant personnel awaiting more operating experience on the evaporators. This additional operating experience would have allowed the proper evaluation of the operational performance of the proposed modificatio'n in preventing the vent condensers from becoming air bound during evaporator startup.

3. Corrective Steps Which Have Been Taken and the Results Achieved (1) A TACF (82-48-62) was issued for the "A" boric acid evaporator vent condenser drain valve.

(2) The two drain valves, one on each evaporator, have been included on the valve checklists in SOI-62.6.

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4. Corrective Steps Which Will Be Taken To Avoid Further Violations Personnel have been instructed to ensure TACFs are prepared on all temporary conditions. AI-9 has been revised to allow plant personnel time to evaluate the need for_ a DCR by operating and observing the modified equipment.

A generic DCR is being prepared which covers this modification and several others recommended by Westinghouse.

5. Date When Full Compliance Will Be Achieved Full compliance was achieved February 10, 1982.

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