ML20043D992

Responds to NRC 900507 Ltr Re Violations Noted in Insp Repts 50-327/90-14 & 50-328/90-14.Corrective Actions:Util Reviewed Issue & Determined That Trains a & B Demonstrated Operable in Jan & Apr,Respectively of 1989

ML20043D992
Person / Time
Site:	Sequoyah
Issue date:	06/05/1990
From:	Medford M TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9006110342
Download: ML20043D992 (3)

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', TENNESSEE VALLEY AUTHORITY CHATTANOOGA TENNESSEE 37401

• 6N 38A Lookout Place Chattanooga, Tennessee 37402-2801 U.S. Nuclear Regulatory Commission JUN 051990 ATTN: Document Control Detk 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 N05, 50-327, 328/90 RESPONSE TO NOTICE OF VIOLATION 50-327/90-14-02 Enclosed is TVA's response to B. A. Wilson's letter to 0. D. Kingsley, Jr., dated May 7, 1990, which transmitted the subject notice of violation. This event was previously reported in Licensee Event Report 50-327/90007.

During the 90-14 inspection exit conducted on April 13, 1990, the SQN Plant Manager made a verbal commitment to evaluate receipt of spare parts, maintenance controls to ensure like-for-like replacement of equipment, and postmaintenance testing, as part of corrective actions to prevent recurrence of conditions similar to the installation of an incorrect containment spray pump impeller.

This review has been performed and it was concluded that current SQN programs and controls are adequate to minimize the potential for recurrence of this type c7 problem. The SQN procurement and receipt inspection program for replacem M t items has been significantly upgraded since the time of this procurement and has recently received favorable NRC review. This program should minimize the potential for incorrect components being installed in the plant in the future.

The maintenance procedures have also been enhanced in recent years to strengthen controls for verifying like-for-like replacement during maintenance activities; however, it is not expected that this type of small dimensional error would be identified during the normal replacement activity. The postmaintenance testing activities have also been strengthened to emphasize detailed review and evaluation of test data changes even if the acceptance criteria were met. It was the result of these improvements in data evaluation that this condition was identified by the SQN system engineer. In summary, no additional changes to existing programs are considered necessary.

If you have any questions concerning this submittal, please telephone M. A. Cooper at (615) 843-6651.

Very truly yours, TENNESSEE VALLEY AUTHORITY 90061 Oj;@j Mj$' ur.7 7 PDR Mark 0. Medford, Vice President O Nuclear Technology and Licensing Enclosure cc: See page 2

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• 1 U.S. Nuclear, Regulatory Commission JUN 051990 cc (Enclosure):

Ms. S. C. Black, Assistant Director '

for Projects TVA Projects Division ,

U.S. huclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 NRC Resident Inspector Sequoyah Nuclear Plant 2600 1900 Ferry Road Soddy Daisy, Tennessee 37379 Mr. B. A. Wilson, Assistant Director for Inspection Programs TVA Projects Division U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 i

1 ENCLOSURE ,

i RESPONSE TO NRC INSPECTION REPORT NOS. 50-327/90-14 AND 50-528/90-14 B. A. WILSON'S LETTER TO 0. D. KINGSLEY, JR. ,

DATED MAY 7, 1990 1

Violation 50-327/90-14-02

" Technical Specification 4.6.4.2.a requires that each hydrogen recombiner system shall be demonstrated operable at least once per six months by a functional test. Technical Specification 4.0.2 requires that each surveillance requirement shall be performed within the specified time interval

-with a maximum allowable extension not to exceed 25% of the surveillance interval.

Contrary to the above, the required functional test was not performed on the Unit 1, train A, hydrogen recombiner between Janverv 11, 1989 and October 15, 1989. This nine month interval exceeds both the six month requirement of Technical Specification 4.6.4.2.a and the allowable 25% extension permitted by Technical specification 4.0.2.

This is a Severity Level IV violation (Supplement I), applicable to Unit 1 only."

Admission or Dental of the Alleged Violation TVA admits the violation.

Reason for the Violation The root cause of this event has been attributed to personnel error on the part of personnel assigned the task of scheduling and distributing test packages to appropriate organizations responsible for performing the various surveillances.

Technical Specification (TS) Surveillance Requirement (SR) 4.6.4.2 requires each hydrogen recombiner to be demonstrated operable every six months.

Surveillance Instruction (SI) 151, "Six Month Test Requirement on Electrical Hydrogen Recombiner System " implements SR 4.6.4.2 and is scheduled to be performed for both Trains A and B of the hydrogen recombiner system every si x moni n . A review of the SI-151 surveillance performances revealed that in April 190 , only the B train test was perform d. A special test for the A train was performed in January 1989; however, it was clearly noted on the data package cover sheet that it was a special test and not to be used for scheduling. The documentation indicates that only the data sheets for the B train were distributed to the Operations Group for performance in April 1989. As a result, the Operations Group only performed the B train surveillance as instructed in the test package and returned the package as a complete performance. The scheduling personnel documented the SI as complete and did not schedule the performance of A train. There is no objective evidence available to indicate why only the B train test package was scheduled and distributed, nor why SI-151 was not recognized as only partially complete.

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Corrective Steps That Have Been Taken and Results Achieved TVA conducted a review of this issue and determined that Train A was demonstrated operable in January 1989, and Train B was demonstrated operable in April 1989. In October 1989 and April 1990, both trains were demonstrated operable. In each performance, the system was proven operable with no abnormalities. Therefore it can be concluded that the system would have functioned as required.

In July 1989, SQN changed the methodology used for scheduling periodic tests.

This current methodology separates the trains in the various surveillances so that scheduling of each train of each system will be tested independently.

The recurrence of an event where a surveillance test is performed on only one a

train of a system is prevented by this method of independently scheduling each train of each system.

Corrective Steps That Will Be Taken to Avoid Further Violations No further corrective action is necessary.-

Date When full Compliance Will Be Achieved SON is in full compliance.

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