ML20058N184
| ML20058N184 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 10/04/1993 |
| From: | Fenech R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9310080219 | |
| Download: ML20058N184 (10) | |
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t Tenre e Mey Autrety Post Oh um M0 SoodrDa sy, Temme 37379 2000 l
Robert A Finech Vo Resent kmgi Nucrar Pime October 4, 1993 l
i U.S. Nuclear Regulatory Commission ATTN: Document Control Desk
-j Washington, D.C. 20555 i
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, 328/93 REPLY TO NOTICE OF VIOLATION (NOV) 50-327, 328/93-33-01, -02,
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-04. -05 AND 50-327/93-33-08 AND NOTICE OF DEVIATION 50-327, 328/93-33-09 contains TVA's response to R. V. Crlenjak's letter to f
Mark O. Medford dated September 3,1993, which transmitted the subject NOV and Notice of Deviation. The subject letter contains five violations and one deviation. The first violation is associated with a design change that was implemented outside the established design change
.j process. The second violation involves an incorrect drawing that l
resulted in the isolation of both control air headers. The third I
violation is associated with the configuration control of compenents in j
temporary systems used to support safety-related systems. The fourth violation involves administrative reviews not being completed within I
procedural timeframes on technical specification (TS) surveillance instructions (sis). The fifth violation is associated with a TS SI, which measures the boron concentration of the refueling cavity, not being performed within the TS allowable timeframe. The deviation is associated with the failure to maintain the Final Safety Analysis Report current with actual plant configuration or processes.
The conditions associated with Violations 93-33-02 and 93-33-04 have been
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previously reported in accordance with 10 CFR 50.73 by Licensee Event Reports 50-327/93019 and 50-327/93021, respectively.
There are no new I
commitments associated with these violations. of this submittal contains the commitments associated with the other violations and the deviation.
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9310080219 931004 U-O PDR ADOCK 05000327 J
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t U.S. Nuclear Regulatory-Commission Page 2 October 4, 1993 j
i If you have any questions concerning this submittal, please telephone r
K. E. Meade at (615) 843-7766.
l Sincerely, (f -- " k Robert A. Fenech i
Enclosures l'
cc (Enclosures):
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 l
U.S. Nuclear. Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 l
Atlanta, Georgia 30323-2711 1
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3 ENCLOSURE 1 REPLY TO NRC INSPECTION REPORT NOS. 50-327, 328/93-33 R. V. CRLENJAK'S LETTER TO MARK 0. MEDFORD DATED SEPTEMBER 3, 1993 Vinlation 93 33:QB 2
"10 CFR Part 50, Appendix B, Criterion III, Design Control, requires in part, that design changes, including field changes, shall be subject to design control measures commensurate with those applied to the original design.
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" Site Standard Practice, SSP-6.1, Conduct of Maintenance, requires that deviations from design configuration be accomplished in accordance with AI-19 (Part VI) Modifications: Permanent Design Change Control Program, or SSP-12.4, Temporary Alterations Control Form.
" Contrary to the above, the licensee implemented a design change outside the established design control measures. Specifically, on January 25, 1992, modification of the heat trace circuitry on the Unit 1 emergency boration flowpath was performed by a work request.
"This is a Severity Level IV violation (Supplement 1)."
Reaann_for violation e
The cause of this violation was an inappropriate management decision to Install additional heat trace on the emergency boration line, using a work request rather than a temporary alteration control form (TACF).
This decision was based on the following:
(1) an incorrect assumption that the temporary heat trace was installed under an open design-change document; (2) recognition that the flow path was not required for technical specification (TS) operability as long as both paths from the refueling water storage tank were available; (3) a misinterpretation of the exceptions allowed by the plant procedure governing TACFs; and (4) a site goal to reduce the number of open TACFs.
t This condition was complicated by the scheduled modifications for the boron reduction TS change. These modifications will remove the need for heat tracing. Thus, the sense of importance was reduced with regard to repairing heat-trace equipment.
CorrectiRfitena_Ihat Have Been Taken and the_ResultLAchieved The Plant Manager has reviewed the lessons learned from this event with the appropriate plant management.
The plant procedure governing maintenance has been revised to require a review and evaluation of each work order that has been open for greater than one year. This will ensure that design changes are not being implemented in the work order / work request process.
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Conecliye_ Actions _.Ihat Will be Taken to Avoid Further__ Violations The subject heat-trace circuit will be repaired before the restart of Unit 1 from the current outage.
Date_Witen Full Compliartce Will be_ Achieved SQN will be in full compliance with the stated violation before restart of Unit 1 from the current outage.
Einlation 93-33-02 "10 CFR Part 50, Appendix B, Criterion III, Design Control, requires in part, that measures shall be established to assure that applicable regulatory requirements and the design basis, as defined Section 50.2 and as specified in the license application, for those structures, systems, and components to.which this appendix applies are correctly translated into specifications, drawings, procedures, and instructions.
" Contrary to the above, systems and components were found to be incorrectly translated into the following Category 1 drawing:
" Drawing 47W848-2, Compressed Air System Flow Diagram, contained drawing transition flags that mislabeled compressed air system headers A and B.
This drawing error resulted in the inadvertent isolation of both control i
air headers in the auxiliary building on July 13, 1993, while establishing a clearance for work involving a moisture element. The isolation resulted in an Engineered Safety Features actuation in that containment isolation valves associated with the ice condenser and radiation monitor systems closed.
"This is a Severity Level IV violation (Supplement 1)."
Eeason for Violation 1
This violation was caused by a drafting error on the subject drawing in 1977. Because of the number of components associated with the two air headers in the system, the representation of the headers required two separate drawings. The standard drafting procedure was to utilize
" flags" that indicated the drawing number and grid location of piping that was being continued from one drawing to another.
In this case, the flags were inconsistent with the actual plant configuration.
In going f rom one drawing to the other drawing, the flag f rom one header was swapped in error to the opposite header.
Correclixe_Slers_That_Kave Been.laken and the_Res.ulls_Achinyrd l
The affected drawing has been revised to correct the subject discrepancy.
The transition flags on the drawings associated with the control air, j
service air, raw cooling water, raw service water to the HPFP, and HPFP systems have been walked down to ensure that no further discrepancies exist. These systems were selected because of their complexity (i.e.,
number of drawing sheets), physical plant arrangement (e.g., general i
building headers), and the f act that these systems were not previously I
I i reviewed during the design baseline verification program. The walkdowns did not identify any additional drawing flag discrepancies.
One additional drawing flag discrepancy was identified by Operations
-l personnel during a review of the control air system drawings. This discrepancy involved a combination of errors that were not identified in the original walkdowns. A walkdown of those drawings originally reviewed by the personnel who failed to identify this additional drawing discrepancy was initiated to ensure that no further problems existed. No i
discrepancies were identified.
Corrantive Actions That Will be Taken to Avoid Further Violations l
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The corrective actions described above will serve as recurrence control for this condition.
DalLHhen Full Compliance Will be Achieved SQN is in full compliance with the stated violation.
Vinlation 93-33:01 I
" Technical Specification 6.8.1 requires, in part, that written procedures be established, implemented and maintained for applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Quality Assurance Program Requirements, Revision 2, February 1978. This includes procedures required for the safe operation and refueling of nuclear power j
plants.
Implicit in these requirements is that the applicable procedures be adequate.
" Site Standard Practice SSP-12.2, SYSTEM AND EQUIPMENT STATUS CONTROL, I
Revision 4, implements the requirements of Technical Specification 6.8.1 in that it establishes configuration control for systems and components important to safety.
" Contrary to the above SSP-12.2 was inadequate, in that, a temporary pressurization system for the reactor cavity pneumatic seal was not being controlled via the requirements of SSP-12.2.
The temporary seal was
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utilized to support safety-related core alterations during the Unit 1 i
Cycle 6 (April - August 1993) refueling outage without adequate configuration controls on the reactor cavity seal air supply components.
j "This is a Severity Level IV violation (Supplement 1)."
Rena.on for violation This violation was caused by a personnel error in that inadequate configuration control was maintained during the subject event. The plant procedure governing configuration control of a maintenance activity required the personnel involved to maintain and document configuration control of the work order.
This was not accomplished. The factor contributing to this violation was that the personnel involved lacked training and experience with the work order process. The subject personnel were from the corporate office and, thus, were not as familiar with the requirements of the work order process as site personnel.
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I Corrntiye Steps That Have Been Taken_and the Results Achieved j
The lessons learned from this event have been discussed with Maintenance personnel.
Special emphasis was made as to each person's responsibility in maintaining and documenting configuration control during maintenance activities.
i Corrgstive Actions That Will be Taken to Avoid Further Violations The appropriate corporate personnel in the outage organization will be trained in the configuration control and work order processes.
A policy on configuration-control requirements, relative to temporary systems and devices, will be developed to ensure that proper configuration is maintained during all activities.
D_ ate When Full Compliance Will be Achieved SQN is in full compliance with the specific violation. Additional l
corrective actions are being taken to prevent recurrence of this type of event.
Vinlation 93-31:Q5
" Technical Specification 6.8.1 requires, in part, that written procedures be established, implemented and maintained for applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Quality Assurance Program Requirements Revision 2, February 1978.
This includes procedures required for the safe operation and refueling of nuclear power plants.
Implicit in these requirements is that the applicable procedures be adequate.
" Site Standard Practice SSP-8.2, SURVEILLANCE TEST PROGRAM, Revision 1, implements the requirements of the licensee's surveillance program.
i "Section 3.5.3 of SSP-8.2 describes the process for reviewing completed surveillance instructions packages.
Item 3.5.3.H requires that Technical Specification related packages be returned to the surveillance instruction Scheduling Group within 10 calendar days following completion of the surveillance.
" Contrary to the above, in July 1993, the NRC identified that the I
licensee failed to meet the required 10 calendar day review time for eight surveillance instruction packages.
"This is a Severity Level IV violation (Supplement 1)."
Reason for violation I
This violation was caused by ineffective management of work priorities.
Management allowed outage-related work activities to command a higher priority than the review required for the subject surveillance instructions. Therefore, the review of the surveillance instructions was t
not performed within the timeframe required by plant procedures.
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Carrective Steps That Have Benn_Taken and the Results Achieved The Site Vice President has counseled line management on the importance i
of complying with plant procedures and managing work priorities.
l The status of the surveillance instruction review process has been
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examined' daily during the current restart efforts and will be continued monthly after restart as part of the SQN postrestart plan.
Corrective Actions That Will be Taken to Avoid Further Violations The corrective actions taken will serve as recurrence control.
In addition, as an enhancement, the plant procedure governing the review of surveillance instructions will be evaluated to ensure that the timeframe of reviews and the reviews themselves are appropriate.
Dsitr_When_ full _Cnmpliance Will be Achley_ed SQN is in full compliance with the stated violation. Additional corrective actions are being undertaken to prevent recurrence of this condition.
Violation 93-33-04
" Technical Specification Surveillance requirement 4.9.1.2 states that the boron concentration of the reactor coolant system and the refueling canal shall be determined by chemical analysis at least once per 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The purpose of this requirement is to maintain and verify a uniform boron concentration in the water having direct access to the reactor vessel.
" Contrary to the above, on July 17, 1993, with Unit 1 in Mode 6 and the refueling cavity flooded, the licensee failed to perform the required TS surveillance to measure boron concentration in the Unit I refueling canal.
"This is a Severity Level IV violation (Supplement 1)."
Reassn for Violation This violation was caused by inadequate communication between Chemistry and Operations personnel. A telephone conversation between the two groups resulted in the terms " refueling canal" and " transfer canal" being i
used interchangeably. Chemistry personnel asked if the refueling canal was drained, and Operations personnel responded that the transfer canal was drained. Based on this conversation, Chemistry personnel believed that the refueling canal was drained and, thus, did not obtain the TS-required sample to be analyzed.
Entrentive_S_tsps That Have Been Taken and the Results Achieved Upon discovery of the condition, a sample of the refueling canal was l
ob tained. The results of the sample confirmed that the boron e
concentration of the refueling canal was within TS requirements.
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Carrnctive Actions That_ Hill be Taken to Aypid Further Vinlations j
The Chemistry surveillance instruction will be revised to clarify the circumstances under which the refueling canal is required to be sampled j
and analyzed.
Date When Full Compliance Will be Achievad SQN is in full compliance with the stated violation. Additional corrective actions are being taken to prevent recurrence of this event.
i DeYia_ tion 93-33-09 l
"Sequoyah Nuclear Plant Final Safety Analysis Report (FSAR), Section 9.3.2.2, System Description, identifies the physical configuration and capability of the Process Sampling System.
"Section 9.3.2.5, Instrumentation Applications, identifies the applications for which the sampling system is designed.
" Table 9.3.2-1, Process Sampling System Sample Locations and Data, lists for each sample the system, sample location, system design temperature and pressure, and sample type.
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"Sequoyah Nuclear Plant Final Safety Analysis Report (FSAR), Section
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7.7.1.3.1, Monitoring Functions Provided by the Nuclear Instrumentation System for power range Channels, identifies the physical configuration of the power range channel recorders.
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" Contrary to the above, the actual physical configuration and operation l
of the Process Sampling System and the Nuclear Instrumentation System differed from that described in the FSAR, as evidenced by the following examples:
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A.
Not all sample lines originating within containment have air-operated valves installed,.as described in Section 9.3.2.2 of the FSAR. Work 4
Packages WP-1515 and WP-1516, were completed in 1990 to install solenoid operated valves in the steam generator blowdown sampling system.
B.
No portable sample analyzer equipment is available to measure boron concentration in the reactor coolant system, as described in the Section 9.3.2.2 of the FSAR.
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FSAR Section 9.3.2.2 states that boron concentration monitors (one per unit) are located in the hot sample room, and the readout is recorded in the main control room. These monitors are currently l
abandoned in place, and thus are non-functional.
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D.
Hot sample room primary samples are not analyzed for pH, as stated in Section 9.3.2.2 of the FSAR.
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E.
Automatic analyzers and/or recorders do not analyze silica or sodium, as stated in Section 9.3.2.5 of the FSAR. The equipment associated with these variables are abandoned or out of service.
F.
Specific components of the condensate demineralizer, Waste and Auxiliary Waste Evaporator systems, and Waste Treatment system, as described in FSAR Table 9.3.2-1, Sheets 1 - 10, are abandoned or out i
of service.
In adoition, sampling points currently being used by chemistry laboratory technicians are absent from the itemized list in Table 9.3.2-1.
G.
Power range channel recorders installed in the control room to record overpower excursions up to 200 percent of full power have not been operable for over 2 years."
Renaon for Deviation The cause of this deviation was a general lack of sensitivity in the use of the FSAR by SQN personnel as a reference for day-to-day activities.
This resulted in incomplete reviews of the FSAR for impact from modifications, an unbalanced review process that addressed FSAR adequacy from an as-designed basis versus an as-operated basis, and a lack of guidance or operating philosophy in regard to obsolete or out-of-service equipment, which is described in the FSAR.
Corrective Steps That Have Been Taken and the Results Achieved During the system readiness reviews in preparation for Unit 2 restart, the SQN Management Restart Review Committee reviewed the accuracy of the FSAR with each system engineer to ascertain discrepancies and increase sensitivity to maintenance of the FSAR. Discrepancies identified during that process were immediately processed as FSAR changes in accordance with the site FSAR change procedure.
A site dispatch was issued to all personnel in order to remind everyone of the importance of maintaining an accurate FSAR in accordance with plant procedures.
The process governing FSAR amendments has been revised to ensure that the FSAR is being revi9wed from an as-operated basis.
g Corrective ActiRDs That Will be Taken to Avoid Further Deviations The specific deviations noted will be corrected in the next FSAR update.
i lhLt.c_When_Eull Complianre_Will be Achieved l
Full compliance with this deviation will be achieved upon submittal of the next FSAR update.
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E ENCLOSURE 2
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c Comi_tmentE 1.
The heat-trace circuit associated with the emergency boration line l
will be repaired before the restart of Unit 1 from the current outage.
2.
The appropriate personnel in the Outage organization will be trained in the configuration control and work order processes by December 1, 1993.
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3.
A policy on configuration-control requirements relative to temporary
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systems and devices will be developed by December 15, 1993, to ensure that proper configuration is maintained during all activities.
4.
SSP-8.2, " Surveillance Test Program," will be evaluated by October 15, 1993, to ensure that the timeframe of reviews and the reviews of surveillance instructions are appropriate.
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The deviations noted in the Notice of Deviation will be corrected in the next Final Safety Analysis Report (FSAR) update.
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