ML20112J505
| ML20112J505 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 04/02/1985 |
| From: | Domer J TENNESSEE VALLEY AUTHORITY |
| To: | Adensam E Office of Nuclear Reactor Regulation |
| References | |
| SQNNEB8501, NUDOCS 8504050183 | |
| Download: ML20112J505 (8) | |
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TENNESSEE VALLEY AUTHORITY CHATTANOOGA. TENNESSEE 374o1 400 Chestnut Street Tower II April 2, 1985 Director of Nuclear Reactor Regulation
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Attention:
Ms. E. Adensas, Chief Licensing Branch No. 4 Division of Licensing -
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U.S. Nuclear Regulatory Commission Washington, D.C.--20555 j
Dear Ms. Adensam:
In the Matter of
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Docket Nos. 50-327 i
Tennessee Valley Authority
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50-328 i-I As a result of recent NRC concerns expressed with regard to TVA actions pertaining to the nonconformance report on containment pressure post-accident i
monitoring accuracy (NCR SQN NEB 8501, R1), enclosed for your information and use is a chronology of events on the processing of NCR SQN NEB 8501.
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As of April 1, 1985, the pressure transmitters have been replaced.
If you have any questions concerning this matter, please get in touch with Jerry Wills at FTS 858-2683 Very truly yours, l
TENNESSEE VALLEY AUTHORITY
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j J. A. Domer Nuclear Engineer Sworn g nd subscr,4 bed before me this Cf dayof/4/)a[L 1985
$lYk i
i Notary Public
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My Commission Expires
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j Enclosure l
cc (Enclosure):
U.S. Nuclear _ Regulatory Commission i
Region II Attn:. Dr. J. Nelson Grace, Regional Administrator j
101 Marietta Street,'NW, Suite 2900
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Atlanta, Georgia.30323 i
Mr. Carl Stahle Sequoyah Project Manager U.S. Nuclear Regulatory Commission j Of-7920 Norfolk Avenue L
Bethesda, Mary 1snd' 20814 7
- An Equal Opportunity Employer I -.
ENCLOSURE CHRONOLOGY OF EVENTS FOR NCR SQNNEB8501 CONTAINMENT PRESSURE POSTACCIDENT MONITORING LIST OF ACRONYMS EP Engineering Procedure EQS Environmental Qualification Sheet FE/ER Failure Evaluation / Engineering Report JC0 Justification for Continued Operation LOCA Loss of Coolant Accident NAL Nuclear Safety Analysis Section NCR Nonconformance Report NEB Nuclear Engineering Branch NEB-Site Nuclear Engineering Branch - Site NLS Nuclear Licensing Section (OE)
NRC Nuclear Regulatory Commission NSS Nuclear Steam Supply Section NUC PR Office of Nuclear Power NUC SERV Division of Nuclear Services OE Office of Engineering OSG Operations Support Group PAM Postaccident Monitoring RES Regulatory Engineering Section for Sequoyah RHR Residual Heat Removal SQA Sequoyah Administrative Procedure WCAP Westinghouse Topical Report 0 $P e
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Nonconformance Report (NCR) SQNNEB8501 Chronology of Events January 15, 1985 - Based upon a review of NRC comments on Watts Bar related 7
to environmental qualification of Foxboro pressure transmitters, the qualification status of similar transmitters for Sequoyah was questioned. NCR SQNNEB8501 was initiated by OE-NEB-NSSS to document the concern in accordance with engineering procedure (EP) 1.26.
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January 17, 1985 - NCR reviewed by NEB-NSSS.
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January 18, 1985 - NCR signed by NEB-NSSS supervisor ; NEB-NSSS sent NCR to OE-NEB-OSG for further review / concurrence.
(NOTE: From January 18, 1985 to January 31, 1985, NCR was inadvertently retained'in the incoming mail. As such, it i
did not receive any further review during this time. Per i
EP 1.26, any NCR that has not received a determination of significance within 8 calendar days of identification is l
automatically ruled "significant." As noted below, this procedural requirement was met.)
January 31, 1985 - OE-NEB-OSG review accomplished; NCR determined to be "significant" NCR approved by assistant to Chief Nuclear Engineer.
February 1, 1985 - NCR SQNNEB8501 formally issued. Copy of NCR handcarried to NEB-Nuclear Licensing Section. NCR telecopied by NEB-NLS to NEB-Site for determination of responsible organization to prepare a failure evaluation / engineering report (FE/ER) in accordance with EP 1.48.
NEB-Site j
informed NEB-NLS that NEB-OSG would prepare the FE/ER. A request was sent by NEB-NLS to NEB-OSG to prepare the i
FE/ER by February 11, 1985 to support a submittal date of i
February 13, 1985 to the site.
(EP 1.48 required a FE/ER within 15 calender days.)
4 February 4, 1985 - OE-NEB-Site handcarried an advance copy of the NCR to SQN-RES. NEB-OSG received NCR copy and FE/ER preparation j
requests. SQN-RES informed by OE-NEB-OSG that FE/ER would i
I probably be category II based upon an in-house report which indicates that the primary containment can withstand pressures much greater than its design. SQN-RES contacted j
OE-NEB-NAL about checking into the location specific dose for the presseue transmitters.
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. j February 5, 1985 - OE-NES-OSG initiated FE/ER preparation. SQN-RES contacted j
OE-NEB-NSSS about nonconformance in general. OE-NEB-NSSS provided the status of the nonconformance on the pressure transmitters (similarity, qualified life, accuracy, etc.)
and stated that OE-NEB-NSSS would continue to firm up the overall requirements of the system (total number of j
required transmitters and use of different channels).
February 11, 1985-Draft version of FE/ER (initially determined as Cate00ry II) telecopied by NEB-OSG to NEB-Site for comments.
I February' 12, 1985 - Telecopy of draft FE/ER reviewed by NEB-Site. From the
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review, it was judged that the FE/ER would have to be reclassified to Category III since the justification provided in the draft FE/ER could not support a Category II determination.
February 15, 1985-SQN-RES contacted OE-NEB-NAL on transmitter's qualification dose. OE-NEB-NAL indicated that dose reduction had been achieved in the past for other i
equipment and that SQN-RES should find out what dose levels results in a transmitter accuracy greater than j
110%. SQN-RES contacted OE-NEB-NSSS to get this information. OE-NEB-NSS indicated that temperature also i
resulted in transmitter accuracy greater than ;10%.
i SQN-RES called OE-NEB-NAL and stated that a reduction in location specific dose would not resolve issue since 2
temperature is also a problem.
February 20, 1985-OE-NRB-Site handcarried the draft FE/ER to NEB-OSG noting i
that the FE/ER should be Category III. This FE/RR'was discussed with NEB-OSG managen.ent; based on this discussion, it was agreed that the FE/ER would be i
designated as Category III.
NOTE: At this time, the 15 calendar day timeframe i
specified in EP.1.48 for issuing a FE/ER had been exceeded.
NOTE: During this week OE-NEB-OSG had several conversations with SQM-RES concerning what operating procedures were applicable to the pressure transmitters.
SQN-RES also informed NEB-OSC that consideration should be given to: (1) the accuracy of the transmitters during the time at which the transmitters information is needed and (2) the transmitters are located in the annulus and not directly subjected to the harsh environment of the high energy line break LOCA. inside containment.
February 21, 1985 - NEB-OSG telecopied draft Category III FE/ER to NEB-Site for comments.
February 22, 1985-NEB-Site agreed with Category III FE/ER determination was noted to NEB-OSG.
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. Februcey 25, 1985-NEB-OSG signed FE/ER.
February 27, 1985 - NEB-OSG reviewed and signed FE/ER.
February 28, 1985 - Copy of FE/ER recevied from NEB-OSG by NES-NLS.
FE/ER telecopied to NES-Site for Nuclear Discipline Proej t Engineer and Design Project Manager concurrence. Also, i
the FE/ER given to NEB-OSG for concurrence.
March 1 1985 -
NEB OSG concurred with the FE/ER.
March 4, 1985 -
NEB NLS reviewed and concurred with'the FE/ER. NEB-Site i
called to indicate NEB-Site concurrence (FE/ER coversheet with concurrence also telecopied to NEB-NLS).
NEB-OSG signed original copy of FE/ER for Nuclear Discipline Project Engineer and Design Project Manager. NEB-NLS telecopied an advance copy of the FE/ER to SQN-RES.
FE/ER approved by NEB management.
March 5, 1985 -
SQN-RES received an advance copy of FE/ER and NCR.
SQN-RES evaluated consequence and concluded that given an accuracy of 115%, the operator might not put a RHR train in the spray mode until the pressure inside containment had reached approximately 11.9 psig. SQN-RES talked to I
OE-NEB and discussed how NCR should be handled.
Since the NCR was related to environmental qualification concerns (NUREG-0588), it was decided that OE should proceed to prepare a justification for continued operation (JCO) for i
the transmitters listed on the NCR.
FE/ER dated and stamped for formal transmittal to Sequoyah Site Director.
March 7, 1985 -
SQN-RES contacted OE-NEB-NSSS.
OE-NEB-NSSS stated that fully qualified transmitters (independant of similarity analysis) had been procurred for WBN and were available for SQN and that OE-NEB-NSSS would send an extra copy of WCAP-8541 (Westinghouso qualification report for the transmitters) and a copy of Equipment Qualification Sheet (EQS) SQN-NEB-30-26, R3.
NEB formally released and distributed FE/ER.
March 8, 1985 -
SQN-RES contacted OE-NEB-OSG who indicated that OE could i
provide a satisfactory safety evaluation and not impact the plant and that he would check on status of FE/ER package. Site Director's office received foemal transmittal of FE/ER package.
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. March 11, 1985 -
Formal copy of FE/ER and NCR transmitted from OE-NEB received by SQN-RES.
Evaluation required by procedure SQA-118 (3 working-day time limit) initiated. SQN-RES contacted OE-NEB-Site and requested that OE proceed with
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'l preparing a safety evaluation on this condition. SQN-RES contacted NUC SERV Instrumentation on instrumentation j
requirements. Based on evaluation of NCR and FE/ER package by SQN-RES, the SQN Compliance Staff determined I
that plant shutdown per the technical specifications would be required unless an acceptable JCO could be provided. A meeting was held between the compliance Staff OE-NEB-OSG, i
and SQN-RES to discuss severity of this item and technical specification requirements. OE was to return and i
reevaluate the transmitters. A meeting was held within
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NEB-OSG to discuss possible narrowing of operating bounds j
during an accident to prevent exceeding containment design limits.
Information from this meeting was passed along to SQN-RES.
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March 12, 1985 -
SQN-RES contacted NEB personnel regarding transmitter i
accuracies noted in FE/ER.
The following points were j
discussed:
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Review of WCAP-8541 indicated that the footnote in i
Table 2 (which imposed an additional 7-1/2 percent inaccuracy) had been inappropriately applied; 1
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Review of EQS revision 3 on pressure transmitters which indicated that the accuracy concern had been previously addressed and found adequate; 3.
EQS revision 3 confirmed that the similarity comparison was being made to an instrument tested in a LOCA environment; and 4.
The accuracy was always in the negative direction (i.e., the indicator would read low).
As such, it was decided that the transmitters could be i
justified for continued plant operation based on similarity with other qualified Foxboro transmitters.
i, Based on the above information, NEB NSSS was requested by OE-NEB-OSG to prepare JC0 for this equipment.
March 13, 1985 -
Subsequent to reviewing EQ records, NEB-NSSS prepared revision 4 to EQA, SQN NEB-30-26 and issued it.
The JC0 for the transmitters was provided as part of the revised
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EQS. The JC0 was'provided to SQN-RES and NEB-OSG; Revision 1 to the FE/ER was initiated.
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4 March 14,.1985 -
SQN-RES notified OE-NEB that based on the revised EQS, the original FE/ER would be returned (per SQA118) to OE for correction.
(Documented in memorandum dated March 22, 1985).
NOTE:
Due to the return of the FE/ER and preparation of a JCO, a safety evaluation would not be required from OE.
March 15, 1985 -
At a site meeting on environmental qualification issues, SQN-RES informed NEB that only 2 of the 4 transmitters listed on the NCR were required for postaccident monitoring (the issue of concern as noted in the FE/ER).
March 18, 1985 -
Revision 5 to EQS NEB-30-26 issued by NEB-NSSS to account for only 2 of the 4 transmitters being required for postaccident monitoring. Revision 1 to the FE/ER (now Category II) signed by NEB-OSG.
March 19, 1985 -
NEB-OSG signed Revision 1 to the FE/ER.
March 20, 1985 -'
NCR SQKNEB8501 revised to account for only 2 of the 4 transmitters being required for Postaccident Monitoring (PAN). New revision signed.
March 21, 1985 -
Revision 1 to NCR approved by NEB Management and issued.
Revision 1 to the NCR and FE/ER received by NEB-NLS and telecopied to NEB-Site for Nuclear Discipline Project Engineer and Design Project Manager concurrence. NEB-NLS concurrence received.
Later that day, due to minor changes in FE/ER verbage, a new FE/ER cover sheet was prepared by NEB-OSG. Concurrence was received from NEB-Site, OE-NEB-OSG, NEB-NLS, and NEB-OSC (based on input that Nuclear Discipline Project Engineer and Design Project Manager had approved). Revised FE/ER package telecopied to OE-NEB-Site. Revision 1 of the FE/ER fomally approved by NEB management.
March 22, 1985 -
Revision 1 of FE/ER dated and stamped for submittal to SQN Site Director. Advanced copy of FE/ER received by SQN-RES from NEB-Site. Also, per request from NRC, NUC PR telecopied advance copies of both revisions of the FE/ER to NRC-Region II.
March 25, 1985 -
Revision 1 to the FE/ER package received at Site Director's Office.
March 26, 1985 -
SQN-RES received the FE/ER R1 package and initiated review (3-day time limit) per procedure SQA118.
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March 27, 1985 -
FE/ER and safety evaluation prepared by RES in accordance with SQA118 sent by SQN-RES to NUC PR-Compliance Section for disposition, meeting the time requirement for review per procedure SQAll8.
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