ML20081C064

Responds to NRC Re Violations Noted in Insp Repts 50-327/95-02 & 50-328/95-02.Corrective Actions:Isolated Unit 1 Boronometer & Flow Element from Process Sys Flow

ML20081C064
Person / Time
Site:	Sequoyah
Issue date:	03/13/1995
From:	Adney R TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9503170098
Download: ML20081C064 (5)

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Tennessee VFey A.conty, Post Omce E x 2000. Soddy-Da'sy Tennessee 37379 March 13,1995 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 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 NOS. 50-327, 328/95 REPLY TO NOTICE OF VIOLATION (NOV) 50-327,328/95-02-01 Enclosed is TVA's reply to Ellis W. Merschoffs letter to 0.D. Kingsley, Jr., dated Febmary 9,1995, which transmitted the subject NOV. This NOV pertains to an inadequate procedure for control (installation and removal) of temporary test equipment.

TVA acknowledges that old plant configuration problems have contributed to plant events.

As a result, plant personnel are performing system evaluations to identify and resolve other potential conditions. Lessons learned from previous events have been incorporated into the system evaluation criteria. Actions being taken as part of the system evaluation are to resiew areas not normally walked down, review drawings to identify and resolve unclear drawings or drawings that contain special conditions such as flow straighteners, identify and evaluate conditions where test equipment has been installed for a prolonged time, identify and correct unauthorized modifications, and evaluate unusual or special configurations. These actions are being acomplished by walkdowns and document resiews as approporiate. Additionally, the Nuclear Assurance organization will perform an independent assessment of the system evaluation. This effort will sensitize site personnel to l any potential configuration issues and promote resolution to ensure that these conditions do not result in plant events. The above actions will be completed by June 9,1995.

Subsequent to the completion of these actions TVA will arrange a meeting with the NRC staff to discuss the results of the above actions.

! The enclosure to this letter is TVA's reply to the NOV, including any applicable

!- commitments relative to the violation.

1 4 vin n n t 1 l 9503170098 950313 PDR ADOCK 05000327 l1 Q PDR

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-.. .l U.S. Nuclear Regulatory Commission Page 2 'l March 13,' 1995 l If you have any questions concerning this submittal, please telephone R. H. Shell at - -!

(615) 843-7170.- l l

Sincerely, ,

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\ A_' .

d.J.edney Site Vice President i

Enclosure  !

cc (Enclosure):  ;

Mr. D. E. LaBarge, Project Manager  !

U.S. Nuclear Regulatory Commission {

One White Flint, North  ;

11555 Rockville Pike  !

Rockville, Maryland 20852-2739 r

NRC Resident Inspector  !

Sequoyah Nuclear Plant -i 2600 Igou Ferry Road  ;

Soddy-Daisy, Tennessee 37379-3624 l Regional Administrator U.S. Nuclear Regulatory Commission  !

Region II 101 Marietta Street, NW, Suite 2900 ,

Atlanta, Georgia 30323-2711 [

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. ENCLOSURE REPLY TO NOTICE OF VIOLATION NRC 1 3PECTION REPORT NOS. 50-327, 328/95-02 ELLIS W. MERSCHOFFS LETTER TO OLIVER D. KINGSLEY DATED FEBRUARY 9,1995 Violation 327,328/95-02-01 "10CFR Part 50, Appendix B, Criterion V requires, in part, that activ; ties affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances, and shall be accomplished in accordance with these instructions, procedures, or drawings.

"Centrary to the above, On or after June 1,1979, an activity affecting quality provided as a part of Preoperational Test Procedure TVA-28 was either not adequately prescribed by documented instructions, procedures, and/or drawings, or was not accomplished in accordance with documented instmetions, procedures, and/or drawings. The test activity required installation of temporary test lines and did not remove these test lines in the reactor coolant sample system to reestablish system configuration in accordance with the established design. This configuration resulted in a leak of reactor coolant on December 28,1994, due to a failure of one of these test lines.

"This is a Severity Level IV violation (Supplement 1)."

Reason For The Violation The cause of the violation was an inadequate preoperational test procedure. The test procedure did not contain guidance for control (installation or removal) of temporary test equipment. Because of the old age of the test procedure, it could not be determined why the procedure did not contain adequate controls.

A preoperational test was performed on the boronometer flow element between 1978 and 1980. The test instruction addressed measuring flow across the boronometer flow element by the use of a difTerential pressure gauge. Through a review of the procedure, it was determined that no guidance was provided for the installation of the gauge or restoration of the permanent plant equipment. A review of the condition determined that a test instrument was connected to outlets on either side of the flow element by the use of plastic (Poly-Flow) tubing on Unit I and copper tubing on Unit 2. It was also determined that the equipment was tested several times without meeting the test acceptance requirements. It is

' speculated that upon completion of Unit I test activities, the test instrument was removed, and the Poly-Flow tubing was inadvertently left in place. This condition was contrary to design drawing requirements, which required caps to be installed at the flow element outlets. An inspection of the Unit 2 flow element revealed that caps were installed; however, the material of the installed caps was not as specified on the design drawings.

The fact that the boronometer had not operated correctly from the time ofinstallation and was therefore nonfunctional contributed to the duration of the condition. Because the equipment was nonfunctional, walkdowns of the boronometer and its associated equipment were not performed.

Corrective Steos That Have Been Taken And The Results Achieved The immediate action associated with the leaking Poly-Flow tubing was to isolate the Unit 1 boronometer and its flow element from the process system flow. Additionally, the Unit 2 boronometer equipment was examined to determine if a similar condition existed.

As a result, the Unit 2 boronometer flow element was also isolated from the process system flow. Further, the walkdown of the Unit 2 boronometer determined a material inconsistency for the caps installed on the flow element. Work documents were initiated to remove the Ploy-Flow tubing on the Unit I flow element and to correct the cap material on the Unit 2 flow element.

Corrective Stens That Will Be Taken To Avoid Further Violations To address the more generic condition of unauthorized or unanalyzed alterations to the plant, the following actions are being taken.

1. Lessons learned from previous events that resulted form old plant configuration problems have been incorporated into a system evaluation criteria. The system evaluation is being used to identify and resolve other potential conditions. The system evaluations are being performed by Technical Support personnel.

2. Areas not normally walked down are being reviewed by the use of existing documents or walkdowns as appropriate.

3. Drawings are being reviewed to resolve unclear drawings or drawings containing special conditions such as flow straighteners.

4. Conditions where test equipment has been installed for a prolonged time are being identified and evaluated.

5. Unauthorized modifications and unusual or special configurations are bcing identified and corrected.

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6. The Nuclear Assurance organization will perform an independent assessment of the i system eUaluation effort These actions will sensitize site pernnnel to any potential configuration issues and promote resolution to ensure that these conaitions do net result in plant events. The system . ti evaluations have been completed, and TVA is prcsently documenting the evaluations, the -  !

basis for any exceptions identified, and the work document references for the restoratbn of-~- I abnormal configurations. The Nuclear Assurance independent assessment will be completed by June 9,1995. ~!

. Separate from the above~ effort, a listing of known nonfunctional plant equipment will be developed by March 24,1995. An evaluation of the listing of nonfunctional plant i equipment will be performed by May 12,1995, to determine the appropriate disposition for each item. >

Date When Full Compliance Will Be Achieved TVA will be in full' compliance by June 9,1995, after the completion of the corrective ,

actions. j Commitments

1. A listing of kn3wn nonfunctional plant equipment will be developed by Marc

• 14, 1995. 'l

2. An evaluation of the listing of nonfunctional plant equipment will be performed by May 12,1995, to dete: wine the appropriate disposition for each item.

3. The site Nuclear Assurance organization will perform an independent assessment of the '  !

system evaluation effort by June 9,1995.

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