ML20046B835

LER 93-017-00:on 930621,discovered 24-hour Telephone Notification Had Not Been Carried Out as Required by TS LCO 3.7.11.1 Action Statement (b)(2)(a) Due to Personnel Error. NRC Informed of Missed notification.W/930730 Ltr

ML20046B835
Person / Time
Site:	Sequoyah
Issue date:	07/30/1993
From:	Fenech R, Whittemore C TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-93-017, LER-93-17, NUDOCS 9308060285
Download: ML20046B835 (7)

Text

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A m________.- _ _ _ _ _ _ . . - . . . _ . - _ _ . . _ . . _ _ . . _ _ _ _ _ , . _

Tennessee Valley Aeonty, Post Off ce Box 2000. Soddy Daisy. lennessee 37379-2000 Robert A. Fenech vce President. SeQuoyah Nuclear Plant July 30, 1993 i

U.S. Nuclear Regulatory Commission ATTN: Document Control Desk f Washington, D.C. 20555 _

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Centlemen:

TENNESSEE VALLEY AUTHORITY - SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 -

DOCKET NOS. 50-327 AND 50-328 - FACILITY OPERATING LICENSES DPR-77 AND DPR LICENSEE EVENT REPORT (LER) 50-327/93017 The enclosed LER provides details of a technical specification (TS). . ,

limiting condition for operation action statement that was not complied with.

This event is being reported in accordance with 10 CFR 50.73(a)(2)(i)(b) as an operation prohibited by TSs.

Sincerely, ,

? 'M Robert A. Fenech Enclosure '

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U.S. Nuclear Regulatory Commission Page 2 July 30,1993 cc (Enclosure):

INPO Records Center

' Institute of Nuclear Power Operations 700 Galleria Parkway Atlanta,. Georgia 30339-5957 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, Suite 2900 Atlanta, Georgia 30323-2711

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NRC form 366 U.S. NUCLEAR REGULATORY COMMISSION Approved OMB No. 3150-0104 (6-89) Expires 4/30/92 tlCENSEE EVENT REPORT (LER)

FACILITY NAME (1) lDOCKETNUMBER(2) l_PAGL131-

,JtRVoyah Nuclear Plant (SON). Unj.t 1 1015l0l0l013 12 17 1110LL013 l

TI"LE (4) Failure to Comply with Technical Specification Limiting Condition for Operation Action Statement

_atd_ Notify NRC by Telephone Regardina the Auxiliary Buildino Fire Sup.pn ssion System Beina Nonfunctional

_EENT DAY (5) l LER NUMBER (6) l REPORT DATE (7) l OTHER FAHL111LS_JHV_QLyED_(8) l l l l l SEQUENTIAL l l REVISION l l l l FACILITY NAMES lDOCKETNUMBER(S)

MONTHl DAY lYEAR lYEAR l I NUMBER l l NUMBER IMONTHl DAY lYEAR l Seavovah. Unit 2 1015101010131218  ;

I I I l_I l_I I I I I I QLtiL2.L1LsL11 91 31 1011171 1 0_I O I OI 713Lol 9131 _Jsls10191DI i 1 t OPERATING l lTHISREPORTISSUBMITTEDPURSUANTTOTHEREQUIREMENTSOF10CFR5:  ;

HODE l l (Check one or more of the following)(ll)

(9) 1 61 l20.402(b) l__l20.405(c) l_l50.73(a)(2)(iv) l_]73.71(b)

POWER l l__l20.405(a)(1)(i) L 150.36(c)(i) l__l50.73(a)(2)(v) l_l73.7i(c)

LEVEL l l_l20.405(a)(1)(ii) l_l50.36(c)(2) L_l50.73(a)(2)(vii) l._l0THER(Specifyin ,

(10) 101 OLQj_l20.405(a)(1)(lii) lKKl50.73(a)(2)(i) l_l50.73(a)(2)(viii)(A) l Abstract below and in l_l20.405(a)(1)(iv) l_l50.73(a)(2)(li) L 150.73(a)(2)(viii)(B) i Text, NRC rorm 366A)

I 120.405fa)(1)(v) I 150.73(a)(21(iii) I 150.73(a)(2)(x) l LICEtl3EL_CDNIACT FOR THIS LER (12)

NAME l TELEE11QNE NUMBER lAREACODEl +

C. H. Whittemore. Compliance Licensino l6111518l4131-l712l110 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPQRT (13) l l l l REPORTABLE l l l l l l REPORTABLE l CAUSIjSX11EliLc0MtDNENT IMANUFACIVRERl TO NPRDS [ ICAUSEjlyJIftil COMPONENT lMANUfACI1LRERl TO NPRDS l l I I I I I I I I I I 1 I I I I I i 1 1 I I I I I I l i I I I I I I I I I I I I I I I I I I I .

I I I I I I I I I I I I I I I I I I I I I i l I i

• SUPPLEMENTAL R_EPORT EXPECTED (14) l EXPECTED lMQMTHlDAYlYEAR

_,_ l_ l SUBMISSION l l l ,

! YES (If ves. complete EXPECTED _ SUBMISSION DATE) l X l NO l DATE (15) l l l l I I i I

ABSTRACT (Limit to 1400 spaces, i .e., approximately fif teen single-space typewritten lines) (16) i On July 2, 1993, with Unit 1 in Mode 6 for the Cycle 6 refueling outage and Unit 2 in Mode 5 for a maintenance outage, it was discovered that a 24-hour telephone notification to NRC had not been carried out as required by Technical Specification (TS) Limiting  :

Condition for Operation (LCO) 3.7.11.1 Action Statement (b)(2)(a). The TS requires that '

a backup suppression system be established and that NRC be notified any time the high ~!

pressure fire protection (HPFP) water suppression system is inoperable. A portion of '

the auxiliary building HPFP water suppression system had been taken out of service for a planned maintenance activity. Appropriate compensatory measures had been established.

The cause of the event was personnel error because of an inadequate review of the LCO action statement. Upon discovery, the notification was made and an incident investigation was initiated. The maintenance activity was completed and the system was returned to service on July 3, 1993.

I l

I l

NRC form 366(6-89) i

, NRC-Form 366A U.S. NUCLEAR REGULATORY COMMISSION Approvod OMB No. 3150-0104 (6-89) Expires 4/30/92

, LICENSEE EVENT RET 9RT (LER)

. TEXT CONTINUATION FACILITY NAME (1) lDOCKETNUMBER(2)} LER NUMBER (6) l l PAGE (3) l l l l SEQUENTIAL l l REVISION l l l l l Sequoyah Nuclear Plant (SQN), Unit 1 l jlEARl i NUMQIR l l NUMBER l l l l l 10lSJQ[Qj013 12 17 19 13 l-l_0 l 1 1 7 l-l O_l 0 1 01 2j.Qfj_QJ_L TEXT (If more space is required, use additional NRC Form 366A's) (17)

I. PLANT CONDITIONS Unit I was in Mode 6 for the Unit 1 Cycle 6 (U1C6) refueling outage (RFO) and Unit 2 was in Mode 5 for a maintenance outage.

II. DESCRIPTION OF EVENTS A. Eyent At approximately 1530 Eastern daylight time (EDT) on July 2, 1993, it was discovered that Limiting Condition for Operation (LCO) Action Statement 3.7.11.1.b.2 had not been completely complied with in that a notification to NRC, i.e., a 24-hour telephone call, had not been carried out as required by technical specifications (TSs). On June 21, 1993, Operations personnel tagged out a section of the auxiliary building high pressure fire protection (HPFP) system to allow maintenance to be performed on fire suppression piping. This section of piping contained several TS-required hose stations and sprinkler systems. LCOs 3.7.11.2 and 3.7.11.4 were entered, and compensatory measures in the form of fire watches and backup fire suppression were established at 2100 EDT on June 21, 1993, to reflect the hose stations and sprink..er systems being nonfunctional. LCO 3.7.11.1 for the fire protection suppression water -

system should also have been entered. However, the LCO was not entered, and the telephone call required by the_LCO 3.7.11.1 action statement was not made. On June 22, 1993, at 1541 EDT, the day-shift assistant shift operations supervisor (ASOS) entered Loos 3.7.11.1 and 3.7.11.4 to reflect an increased maintenance work scope; valves designated as isolation valves on the original action plan were leaking through. The LCO action statement requiring that NRC be notified by telephone was again not carried out. On July 2, 1993, when the day-shift shift operations supervisor (SOS) and Fire Protection Manager were discussing a related matter,'the error was discovered. Upon discovery, the appropriate LCO action. statement requirements were complied with.

B. InDperable StInnt.ures. Components. or Systems That Contributed to the Event None.

C. Dates and Aoproximate Times of Major Occurrente.R June 21, 1993 Initial hold tags were attached to isolation valves to isolate at 2100 EDT a section of piping that contained the pin hole leaks. LCOs 3.7.11.2 and 3.7.11.4 were entered. Appropriate compensatory measures were established. The telephone notification to NRC was not made because LCO 3.7.11.1 was not entered.

NRC form 366(6-89)

', NRC'Torm 366A U.S. NUCtEAR REGULATORY COMMISSION Approved OMB No. 3150-0104 (6-89) Enpires 4/30/92

. LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACItITY NAME (1) lDOCKETNUMBER(2)I LER NUMBER (6) I l PAGE (3) l l .l l SEQUENTIAL l l REVISION l l l l l Sequoyah Nuclear Plant (SQN), Unit 1 l lYEAR l l NUMBER l l NUMBER [ l l l l 10lil01QJQl3 12 17 19 13 l-l Q_] 1 I 7 l _l. O I O Q j_310Tl 01 5 TEXT (If more space is required, use additional NRC Form 366A's) il7)

June 22, 1993 An additional section of the fire suppression system was at 1541 EDT added to the original maintenance work order. LCOs 3.7.11.1 and 3.7.11.4 were cntered for the additional section of the fire suppression system that was made nonfunctional. The telephone call was not made because this was considered an extension to the orginal LCOs.

June 22, 1993 After reviewing the previous shift's log entry concerning the at 1945 EDT 3.7.11.1 entry and discussing the issue, the night shift ASOS entered 3.7.11.1 for the initial scope of maintenance activity. The LCO entry was noted as a late entry for June 21, 1993 (the telephone call was not made).

July 2, 1993 The error of not making the telephone call on June 21, 1993, at 1000 EDT was discovered when two SOSs and the Fire Protection Manager were discussing the entry into LCO 3.7.11.1 for a similar issue.

July 2, 1993 NRC was notified by telephone regarding the June 21, 1993, at 1600 EDT event where a section of the auxiliary building fire suppression system was taken out of service and rendered nonfunctional.

July 3, 1993 Af ter being repaired, the IIPFP piping was returned to at 2048 EDT service, and LCOs 3.7.11.1, 3.7.11.2, and 3.7.11.4 were exited.

D. Other Systems or Secondary Functions Affected None - No other system was involved.

E. Method of Discovery The error was discovered when two SOSs and the Fire Protection Manager were discussing the entry of 3.7.11.1 for a similar issue.

F. Operation Action Upon discovery of the error, the Operations Manager informed the appropriate  ;

personnel and notified NRC by telephone. l G. Safety System Responaga l None - No safety system response was required.

NRC F orm %6(6-89) l

.. NR form 366A U.S. NUCLEAR REGULATORY COMMISSION Approved OMB No. 3150-0104 (6-89) Expires 4/30/92 LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITY NAME (1) lDOCKETNUMBER(2) l LER NUMBER (6) l l PAGE (3) l l l l SEQUENTIAL l l REVISION] l l -l l Sequoyah Nuclear Plant (SQN), Unit 1 l lYEAR I l NUMBER .l_ l NUMilIRl l l l l l015faj0l013 l2_171913 l-l 01 1 17l-l01 0lOl_4l0Fl0l5 TEXT (If more space is required, use additional NRC Form 366A's) (17)

III. CAUSE OF EVENT A. Ituediata_Cauan The immediate cause of the event was the failure to comply with the LCO action statement in its entirety.

B. Rnot Cause The root cause of this event is personnel error because of an inadequate review of Gie LCD setion statement on the part of Operations' personnel. ,

C. Can.tributing Cault TS 3.7.11.1 is written with the intent of notifying NRC when a major fire suppression header or pump is nonfunctional because of an unexpected loss of equipment or accident. However, literal compliance of the TS requires a 24-hour telephone call when any part of the fire suppression system (withir. '

the LCO description) is taken out of service and made nonfunctional even for .:

preplanned maintenance activity. The logic of this type of action le not consistent with the safety significance of the issue, nor with the action statements of other LCOs outside the Fire Protection arena.

IV. ANALYSIS OF EVENT Maintenance was being performed via approved plant procedures with an action plan r in effect. The appropriate TS LCO action statement compensatory measures were in place, with the exception of the 24-hour telephone call to NRC. Therefore, it can i be concluded that there were no adverse consequences to plant personnel or to the public as a result of this event.

V. CORRECTIVE ACTIONS A. 11amediate Corrective Action Upon discovery of the missed notification, NRC was informed by telephone of the condition of the fire suppression system in the auxiliary building and also of the missed notification. The telephone call was confirmed by f acsimile on the next working day. Additionally, an incident investigation i was initiated to determine the cause of the event and to formulate corrective action to prevent recurrence.

WRC Form 366(6-89) l

$ Nil { Form 366A U.S. NUCLEAR REGUtATORY COMMISSION Approved OMB No. 3150-0104 (6-89) Expires 4/30/92

. LICENSEE EVENT REPORT (LER)

• TEXT CONTINUATION FACItITY NAME (1) lDOCKETNUMBER(2)j LER NUMBER (6) l l PAGE (3) l l l l SEQUENTIAL l l REVISION l l l l l Sequoyah Nuclear Plant (SQN). Unit 1 l 1YI.AR_1_ l NUtjQER l 1 NUM31R_1 l l l l 1215j1[QJD l 3 12 17 19 13 l-l 0 1 1 l 7 l-LD l 0101Sl0Fl015 TEXT (If more space is required, use additional NRC Form 366A's) (17)

B. Corrective Action to Prevent Recurrence The Operations Superintendent has issued a policy order to Operations personnel describing their responsibility to ensure TS compliance.

The Fire Protection Manager has submitted a training letter describing this event to Operations Training for issue to all ASOS/ SOS personnel.

The Fire Protection Manager has submitted a TS change request to revise the fire protection TS action statement reporting requirements.

VI. ADDITIONAL INFORMATION A. Eailed Componenta None - This was a planned work activity to repair through-the-wall pin hole i leaks in the fire suppression piping.

B. Previous Similar Events A search of the LER and the Nuclear Experience Review databases was conducted for previous or similar events. The results of this search revealed 29 items, only one of which occurred at SQN. This one item (LER 327/91014) was reviewed and found not to be relevant to the present event.

A search of the specia! reports generated at SQN from 1987 to the present was conducted. This search revealed that 112 reports had been submitted to NRC primarily for fire protection issues. Only 13 of the reports submitted to the commission involved TS LCO 3.7.11.1. Each of these 13 reports was reviewed for the purpose of establishing whether any of the reporting requirements had been untimely. Each and every report documented that the telephone and facsimile notifications had been timely and in compliance with the TS action ,

statements.

In summary, this event can be classified as an isolated incident with no previous or similar issues involving corrective actions that could have or should have prevented this event.

VII. COMMITMENTS None.

j I

NRC f orm 366(6-09) I