ML20126F991
| ML20126F991 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 12/23/1992 |
| From: | Fenech R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9301040012 | |
| Download: ML20126F991 (4) | |
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Tennessee hlk-y AVfhority, Post O%ce Box 2000. Soddy-Da sy, Tennessee 37379 2000 J
Robert A Fenech Vice Presdent, Seqqah Nuctear Plant December 23, 1992 U.S. Nuclear Regulatory Comrnission ATTN: Document Control Desk Washington, D.C. 20555 Gentiemen 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) - UNITS 1 AND 2 - REQUEST FOR WAIVER OF COMPLIANCE FOR TECHNICAL SPECIFICATION (TS) SURVEILLANCE REQUIREMENT (SR) 4.0.3 AND TS LIMITING CONDITION FOR OPERATION'(LCO) 3.7.4 This letter serves to document TVA's request for a waiver of compliance for Units 1 and 2 TS SR 4.0.3 and TS LCO 3.7.4 to support completion of inservice pressure testing of the essential raw cooling water (ERCW) system. This waiver was needed as a result of the failure to perform the total scope of prescure tests required by the American Society of Mechanical Engineers (ASME),Section XI, Table IWD-2500-1, on the ERCW system.
IVA is requec ting a waiver for an additional peiciod of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from TS SR 4.0.3 and 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> to TS:LCO 3.7.4-to allow completion of inservice system preasure tests on the ERCW system. This additional time is needed to prevent shutdown of both units in accordance-with TS 3.0.3 and TS 3.7.4.
This condition arose as a result of the discovery that not all the required inservice system pressure tests had been performed _during the second inspection' period of the first 10-year interval in accordance with ASME,Section XI, as required by_TS SR 4.0.5.
The purpose of an inservice system pressure test is to look for system leakage that is performed by a qualified inspector. Thus, while-the ERCW system is considered functional, compliance with TS SR 4.0.5 has not been maintained. As both trains of ERCW are affected, TS 3.0.3 is applicable; however, TS SR 4.0.3 allows delay of.up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to permit the completion of the. surveillance (i.e., pressure tests). -Efforts are-focusing on the completion of inspection of the B-train of the ERCW system. As the completion of the B-train inspections will not be completed within the timeframes allowed by TS SR 4.0.3, an additional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> was requested.
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i U.S. Nuclear Regulatory Comraission Page 2 December 23, 1992 Upon completion of these B-train inspections, the remaining inspections must be completed. As a result of the volume of work required and the s
timing for resolution of this issue, an additional 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> was also requested for both unit's TS LCO 3.7.4.
Thus, with this waiver, the B-train ERCW inspections for both units must be corpleted by 11:30 a.m.
Eastern standard time (EST) on December 24, 1992, and the A-tsain ERCW inspections for both units must be completed by 11:30 a.m. EST on December 29, 1992. This request has been reviewed and approved by the Plant Operations Review Committee. The detailed justification for the waiver of compliance is provided in the enclosure.
NTd approval of the 24-hour waiver of compliance to TS SR 4.0.3 and 96-L7ur waiver to TS LCO 3.7.4 was granted verbally by Luis Reyes, Action Regicnal Administrator, to TVA at 11:00 a.m. EST on December 23, 1992.
If you have any questions concerning this issue, please call J. D. Smith at (615) 843-6672.
Sincerely,
-- ON Robert A. Fenech 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 Mr. Michael H. Mobley, Director (w/o Enclosures)
Division of Radiological Health T.E.R.R.A. Building 150 9th Avenue, N Nashville, Tennessee 37243-1532 NRC Resident Inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road.,
t Soddy Daisy, Tennessee 37379-3624 L
Mr. B. A. Wilson, Project Chief l
U.S. Nuclear Regulatory Commission i-Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323-0199 i
s ENCLOSURE BAc.kgtnund
'American Society of Mechanical Engineers (ASME),Section XI, Table IWD-2500-1, requires a visual inspection (VT-2) as a part of an inservice pressure test of safety-related components within each of the three inspection periods during each 10-year inservice inspection interval.
The 10-year inspection interval ends September 15, 1994, and February 21, 1995, for Units 1 and-2, respectively.
The second period for each unit's first 10-year interval ended September 15, 1991, and February 21, 1992, for Units 1 and 2, respectively. During a-review of the Section XI program on December 22, 1992, to prepare for closure of the first 10-year interval, it was determined that pressure tests on various systems (e.g., auxiliary feedwater, containment spray, essential raw coo 1.ing water [ERCW), and spent fuel pit) had not been performed during the second period.
Technical Specification (TS) 4.0.5 requires, among other things, that surveillance requirements for inservice inspection and testing of ASME Code Class 1, 2, and 3 components be performed as required by 10 CFR 50.55a(g).
Upon identification of the above nonconformance, the appropriate limiting conditions for operation (LCOs) were entered. As l
both trains of containment spray for both units and both trains of the ERCW on Unit 2 were affected. TS 3.0.3 was entered. As allowed by TS Surveillance Requirement (SR) 4.0.3, the action requirements were delayed for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to permit the completion of the surveillance since the allowable outage time limits of the action requirements are less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. TVA immediately initiated efforts to perform the inservice system pressure terts to restore at least one train of each dual-train affected system to operable status. The scope of the work required to be completed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> consisted of one train (B-train) of containment spray for each unit and one train of the ERCW (B-train) for both units.
The volume of work required for one train of the ERCW could not be completed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
In addition, the volume of work required for completion of the A-train ERCW inspections for both units cannot be completed within the TS LCO required by TS 3.7.4.-
Thus,'because of this volume of work and the timing for the resolution of this issue, an additional 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> was requested for completion of the A-train inspections for both units.
Enfety Significance The ASME inservice pressure test consists of a walkdown to perform a VT-2 of a system to determine if there are any leaks in the system at normal operating pressure. The failure to perform the pressure test does not affect the function of the system or the adjacent areas. There are various other methods of detecting leaks.
These methods include various flow indicators, pressure indicators, radiation monitors, and other.
testing that'would show the existence of a substantial leak. Areas within the ERCW system that are known to be susceptible to leakage mechanisms (i.e., erosion / corrosion and microbiological 1y induced corrosion) are' maintained in plant programs using volumetric nondestructive examination and visual techniques. Additionally, there are frequent walkdowns performed by personnel in the plant ~from Operations, Technical Support,-and Radiological Control who would investigate the source of-any leakage found.
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' Operations personnel have specific rounds to be done each shif t and each day wherein all accessible areas of the plant are entered, with one objective being searching for developing problems (leaks).
Technical Support engineers perform periodic (usus11y weekly) walkdowns of specific systems to determine material condition. Radiological Control personnel investigate sources of contamination in the plant. The ERCW system is acknowledged to have occasional leaks, all of which have been discovered by the above methods.
TVA Request for Waiver of Compliance TVA requests a waiver of compliance for TS SR 4.0.3 with regard to the 24-hour limitation.
The VT-2 inspection of the ERCW B-train system is estimated to require an additional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
In addition, the volume of work required for the completion of the A-train ERCW inspections for both units cannot be completed within the TS LCO required by TS 3.7.4.
- Thus, because of this volume of work and the timing for the resolution of this issue, an additional 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> was requested for the completion of the A-train inspections for both units. No actual system functional concern exists. However, TS SR 4.0.5 requires the performance of the inservice.
system pressure tests. Thus, compliance with TS SR 4.0.3 would require reentry into TS 3.0.3, necessitating unit shutdown unless additional time is allowed. Similarly, without the relaxation of the TS 3.7.4 LCO for both unita, shutdown would again be required for either unit.-
The requested extension of time was determined to have no safety significance because no actual component functionality has been affected. Accordingly, the requested waiver cannot result in an increase in the prcbability or consequences of a previously evaluated accident, cannot create the possibility of a new accident, and cannot reduce the margin of safety. Therefore the action does not involve an unreviewed environmental question because it does not increase any adverse environmental impacts, change effluents or power levels, or result in unreviewed environmental matters.
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