ML20113E171
| ML20113E171 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 03/15/1985 |
| From: | Domer J TENNESSEE VALLEY AUTHORITY |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20113E139 | List: |
| References | |
| NUDOCS 8504160203 | |
| Download: ML20113E171 (6) | |
Text
F o
e TENNESSEE VALLEY AUTHORITY CHATTANOOGA. TENNESSEE 374ot 400 Chestnut Street Tower II ch 55, *1N U.S. Nuclear Regulatory Commission Region II ATTN:
Dr. J. Nelson Grace, Regional Administrator 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323
Dear Dr. Grace:
Enclosed is our response to R. D. Walker's February 13, 1985 letter to H. G. Parris transmitting IE Inspection Report Nos. 50-327/84-38 and 50-328/84-38 for our Sequoyah Nuclear Plant which appeared to have been in violation of NRC regulations.
If you have any questions, please get in touch with R. E. Alsup at FTS 858-2725.
To the best of my knowledge, I declare the st.atements contained herein are complete and true.
Very truly yours, TENNESSEE VALLEY AUTHORITY f
- w. A. Damer Nuclear Engineer Enclosure cc (Enclosure):
Mr. James Taylor, Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Records Center Institute of Nuclear Power Operations 1100 Circle 75 Parkway, Suite 1500 Atlanta, Georgia 30339 8504160203 850329 PDR ADOCK 05000327
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G pon An Equal Opportunity Employer 3
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RESPONSE - NRC-OIE INSPECTION REPORT NOS. 50-327/84-38 AND 50-328/84-38 R. D. WALKER'S LETTER TO H. G.'PARRIS DATED FEBRUARY 13, 1985 Items 327/84-38-01 and 328/84-38-01 10 CFR 50, Appendix B, Criterion XI " Test Control" as implemented by the licensee's approved QA program (Topical Report TVA-TR-75-1) section 17.2.11
" Test Control" requires that testing be performed to demonstrate that critical structures, systems, and components (CSSC) will perform satisfactorily in service and malfunctions are identified in a timely manner.
Contrary to the above, in the instances cited below, the licensee failed to
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perform adequate testing of components to identify deficiencies.
1.
In December 1982, Units 1 and 2 P-11 block switches received inadequate post-modification testing in that not all switch functions were tested which precluded detection of a deficient switch operation regarding an undesirable, comentary actuation of the switch to the reset (unblock) position. On December 16, 1984, cycling of the P-11 block switch while the Unit 2 was in mode 3 resulted in an inadvertent actuation of the safety injection system.
2.
On. December 22, 1982, the licensee failed to perform an adequate post modification test for Unit 1 post-accident radiation monitors located on the Reactor Coolant Drain Tank sump line and the Reactor Building Floor and Equipment Drain sump line. Adequate testing for satisfactory performance of the radiation monitors and associated valves designed for closure on high radiaiton would have detected incorrect instal-lation of the radiation monitors. This discrepancy was identified on
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November 20, 1984. Post-accident radiation monitors are required by Licensee Condition 2.C.(22).F., however, incorrect installation of
~f subject radiation monitors did not compromise containment isolation function under accident conditions.
ls This is a Severity Level IV violation (Supplement I).
1.
Admission or Denial of the Alleged Violation TVA admits tk.a violation occurred as stated.
. 2.
Reasons for the Violation if Admitted Sequoyah Nuclear Plant has established a task force to study postmodi-fication test (PMT)/ functional test activities at Sequoyah. The team consists of engineers from the Quality Assurance Staff, Systems /
Postmodification Test Group, and the Division of Nuclear Services.
The task force will evaluate PMT and functional test activities from a qualitative and quantitative standpoint to determine the generic impli-cations of this violation.
It will also address root causes to any findings and will make recommendations of corrective actions for plant management to take to upgrade this program.
The thrust of the task force will be to evaluate ECNs/DCRs completed since 1980 and determine if postmodification or functional testing should have been performed. Further, it will determine the adequacy of selected tests which were performed and evaluate test problems identified for corretive action controls. An evaluation will also be made of plant instructions controlling postmodification/ functional tests.
This task force will have completed its work with a report to plant management by May 1, 1985. Upon completion of the report and review by plant management, a followup report on this violation will be made by May 31, 1985. This followup report will address root causes, corrective
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actions to prevent recurrence, and dates those actions will be complete.
3.
Corrective Steps Which Have Been Taken and Results Achieved See item 2.
4.
Corrective Steps Taken to Avoid Further Violation See item 2.
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Date When Full Compliance Will Be Achieved See item 2.
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~~ Items 327/84-38-02 and 328/84-38-02 10 CFR 50, Appendix B, Criterion V requires the licensee to establish measures to assure that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances.
Contrary to the above, the licensee failed to prescribe activities affecting quality by documented procedures of a type appropriate to the circumstances in that a potential nonconformance concerning post-accident radiation monitors which was identified on November 20, 1984, was not promptly documented.
The nonconformance was documented sixteen days af ter identification on December 6, 1984.
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- This is a Severity Level V violation (Supplement 1).
This violation applies to both units.
1.
Admission or Denial of the Alleged Violation TVA admits a violation occurred, however, TVA believes the violation resulted from a lack of management control which did not ensure the timely reporting of the potential nonconformance.
2.
Reasons for the Violation if Admitted TVA's review has concluded that the problem described in this report is attributed to the lack of management control and employee awareness by the involved parties. Office of Engineering procedure OE-EP 1.26 adequately prescribes the procedure for initiating potential nonconfor-mance.
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3.
Corrective Steps Which Have Been Taken and Results Achieved l
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The Office of Engineering (OE) Project Manager at Sequoyah Nuclear Plant and the involved parties in OE (Knoxville) have been instructed to l
familiarize their employees on the timeliness requirements of j
documenting and reporting potential nonconforming conditions.
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- 4.
Corrective Steps Taken To Avoid Further Violations Employees in the Nuclear Engineering Branch and OE personnel at the site will be instructed on the timeliness of reporting potential nonconformances and the requirement for immediately assessing the impact of the potential nonconformance on continued plant operation and/or limiting conditions for operation as defined in the technical specifications by April 12, 1985.
5.
Date When Full Compliance Will Be Achieved Full compliance was achieved on December 6, 1984.
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Items 327/84-38-03 and328/84-38-03 10 CFR 50, Appendix B, Criterion IVI " Corrective Action" as implemented by the licensee's approved QA program (Topical Report TVA-TR 75-1) section 17.2.16
" Adverse Conditions and Corrective Action" requires that in the case of significant conditions adverse to quality, measures shall be taken to assure that the cause of the condition is determined and corrective action is taken to preclude repetition.
Contrary to the above, the licensee has taken inadequate corrective action to preclude repetition of inadvertent safety injections due to a switch malfunction.
The Design Change Request (DCR) process initiated on June 26, 1980, was deficient in that it did not properly determine the cause of the problem and simply required replacement of the same type of existing switches.
The DCR was implemented on Unit 1 in February 1983 and on Unit 2 in December 1982.
On December 16, 1984, Unit 2 experienced another inadvertent
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safety injection due to the same switch malfunction.
This is a Severity Level IV violation (Supplement 1).
This violation applies to both units.
1.
Admission or Denial of the Alleged Violation TVA admits the violation occurred as stated.
, 2.
Reasons for the Violation if Admitted As stated in the inspection report, the handswitch problem was identi-fled during startup testing for unit 1 in September 1979, and a DCR was initiated to replace the existing switches. Subsequently, coordination between EN DES and Westinghouse resulted in a determination that no design change of the existing equipment was needed, and that the original handswitches were most likely defective. New handswitches were installed of the same design, however, this did not resolve the problem of the switch springing back past the neu' tral position to reset.
The primary cause is attributed to the poorly written DCR and ineffective coordination between the plant, EN DES, and Westinghouse.
A secondary cause is the lack of adequate testing subsequent to replacement of the handswitches.
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3.
Corrective Steps Which Have Been Taken and Results Achieved Existing administrative controls cautioning against the releasing of f
the handswitches are still in effect, and these requirements have been reemphasized to plant operators as a result of the December 16, 1984, event. The original DCR was reopened and a new ECN (6339) has been issued to modify the circuitry to prevent a " reset" after the switches are released from the block position.
Coordination of operational problems is being handled at the plant site since the reorganization in 1984 which moved key OE personnel to the plant site, and the control for such groups comes under the direction of the Site Director. This move will provide adequate management attention to operational problems, and, with OE personnel onsite, uncertainties of proposed modifications will be resolved more accurately and timely.
4.
Corrective Steps Taken To Avoid Further Violations See item 3.
2 5.
Date When Full Compliance Will Be Achieved Full compliance will be achieved upon implementation of ECN 6339.
ECN 6339 is expected to be implemented by April 30, 1985.
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