ML20086D037
| ML20086D037 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 11/19/1991 |
| From: | Joshua Wilson TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9111250218 | |
| Download: ML20086D037 (5) | |
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A November 19, 1991 U.S. Nucicar kegulatory Commission ATTN Document Control Desk Washington, D.C.
20555 Gentleten:
In the Matter of
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Docket Nos. 50-327 Tennessee Valley Authority
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50-328 Sl;QUOYAll NUCLEAR P1 ANT (SQN) - NRC INSPECTION REIORT 50-321, 328/91 RESPONSE TO NOTICE OF VIDIATION (NOV) 50-327, 128/91-22-01 provides '1VA's restonse to B. A. Wilson's letter to D. A. Nauman dated October 21, 1991, which trant,mitted the subject NOV regarding the control of transient fire loads in safety-related areas.
Summary statements of connittnents contained in this submittal are provided in Enclosure 2.
If you have any questions concerning this submittal, please telephone M. A. Cooper at (615) 843-8924.
Sincerely,
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L. Wilson Enclosure cet See page 2 I
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2 U.S. Nuclear Regulatory Conunission Novernber 19, 1991 cc (Enclosure):
Mr. D. E. LaBarge, roject Manager U.S. Nuclear Regul atory Conunission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 NRC Resident Inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy-Daisy, Tennessee 37379 Mr. B. A. Wilson, Project Chief U.S. Nuclear Regulatory Conunission Region 11 101 Marietta Street, IN, Suite 2900 Atlanta, Georgia 30323 1
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ENCLOSURE 1 RESPONSE TO NRC INSPECTION REPORT NOS. 50-327/91-22 AND 50-328/91-22 B. A. WILSON'S LETTER TO DAN A. NAUMAN DATED OCTOBER 21, 1991 ViolatiotL50-3.2L_32B/91:22-91
" Technical Specification 6.8.1 requires that procedures recommended in Appendix A of Regulatory Guide 1.33. Revision 2, be established, implemented and maintained. This includes procedures covering Fire Protection Program impl ement a t ion. The requirements of TS 6.8.1 are implemented in part by the following procedure "PilYSI-13, Fire Protection Program, Revision 59 Section 5.1.4 of Appendix E, requires, in part, that equipment or supplies shipped in untreated combustable
[ sic] packaging may be unpacked in safety-related areas only if (1) an Appendix E Permit has been obtained and approved by the Site Fire Protection Engineer. (2) a continuous fire watch has been established, and (3) a valid reason exists for their (the containers) not being unpacked in non safety-related areas.
" Contrary to the above, it was identified on September 18, 1991 that several untreated wooden crates, loading palets [ sic), and other combustables [ sic) associated with refurbishment of the P-B ERCW pump were brought into a safety-related area without a PHYSI-13 Appendix E Transient Fire Permit being appropriately issued.
In addition, a continuous firewatch was not speciflen11y established for the subject combustable [ sic] materials upon entry into the safety-related area and the reason for not unpacking the containers in a non safety-related area was not established. A firewatch happened to be in the area for another purpose.
"This is a Severity Level IV violation (bupplement V)."
Reasonlor_thtViolation The overhauled essential r.tw cooling water (ERCW) pump had been returned to Sequ-yah Nuclear Plant (SQN) from the pump vendor in crates constructed of untreated lumber. The pump parts were not uncrated upon receipt at SQN; instead they were left in their crates to protect them during handling, rigging, and intorage.
The untreated lumber crates were taken into the ERCW building without an appropriate transien' fire load permit on September 18, 1991.
It is management's expectations that combuscibles will not be brought into safety-related areas without the proper controls in placi 1.e.,
transient fire load permit obtained and a fire watch established.
These expectatious are well defined in the fire protection procedure. The Mechanical Maintenance general foreman's failure to obtain a transient fire load permit was an oversight in view of the fact that this is a routine day-to-day procers and he was knowledgeable of the requirements. Thus, the cause of this violation was x
a failure to follow procedures because of inattention to detail.
Corrective ' ters_That flave 3een_Tokenand_Ilesults Achieved J
immediate corrective action was taken by obtaining a transient fire load permit and establishing a dedicated continuous fire watch f or the wooden crates and other combustibles.
Plant management performed a walkdown of other safety-related structures to verify proper control of combustibica. No unauthorized wood was found, i.e.,
all wood had a transient fire load permit and continuous fIrewatch established, es appropriate.
The gei.eral foreman resp lble for the lucident was counseled for inattention to detail and falling to.ollow procedures.
The Maintenance Manager issued a training letter on November 8, 1991, to Maintenance's and Modifications' personnel discussing the general requirements of the SQN transient fire load permit program.
Corrective.Sters_ThaLWill lic. Taken. to_ Avoid further__ Violations TVA has reviewed this event and has concluded that the tranalent iire lond program is adequate; however, the program could be further enhanced.
Enhancements to the transient fire load program will be inade by including transient fire load inspections in Site Standard Practice (SSP) 12.7 "llousekeeping/ Temporary Equipmeat Control." SSP-12.7 will be issued and will require plant management to walk down salety-related stru:turec on a regular basis.
During these walkdowns, transient fire loads wl)1 be inepected for compliance to the transient fire load permit program ar stated in PIIYSI-13.
Further enhancements will be made to the transient fire lead permit program by installing signs at entrances to safety-related billdings to remind personnel that transient fire load permits may be required when combustibles are taken into the structure.
Signs will be installed by January 2, 1992.
Date_When_ full. compliance _Will 13e. Achieved SQN is in full comp 1 lance.
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ENCLOSURE 2 List of Commitments 1.
SSP -12.7. "liousekeeping/ Temporary Equipment Control." will be issued and will require plant management to walk down safety-related structures on a regular basis. During these walkdowns, transient iire loads will be inspected for compliance to the tranalent f f re load pennit program as stated in I'llYSI-13.
This procedure will be issued by January 2, 1992.
2.
Signs will be installed at entrances to safety-related buildings to remind personnel that transient fire load permits may be required when combustibles are taken into the structure. Signs will be installed by January 2, 1992.
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