ML20127F354

Confirms 921223 Telcon W/Licensees,Granting Regional Waiver of Compliance from Requirements of TS 4.0.3 & 3.7.4

ML20127F354
Person / Time
Site:	Sequoyah
Issue date:	12/24/1992
From:	Reyes L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Medford M TENNESSEE VALLEY AUTHORITY
References
NUDOCS 9301200215
Download: ML20127F354 (4)

Text

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4 Vu 7g Docket Nos. 50-327 and 50-328 License Nos. DPR-77, DPR-79 Tennessee Valley Authority ATTN: Dr. Mark 0. Medford, Vice President Nuclear Assurance, Licensing & Fuels 3B Lookout Place 1101 Market Street Chattanooga, Tennessee 37402-2801

SUBJECT:

TEMPORARY WAIVFR OF COMPLIANCE - SEQUOYAH UNITS 1 AND 2 This letter confirms the telephone convarsation between Mr. R. A. Fenech, Vice President, Sequoyah Nuclear Plant, and Mr. E. W. Merschoff of my staff on December 23, 1992, granting a Regional Waiver of Compliance for Sequoyah Units 1 and 2.

Our action was based on your written request letter dated December 23, 1992 (copy enclosed).

Technical Specifications (TS) 4.0.3, " Surveillance Requirements" requires in part that the failure to perform a Surveillance Requirement within the allowed surveillance interval shall constitute noncompliance with the OPERABILITY requirement for a Limiting Condition for Operation, lhe ACTION requirements may be 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 completion of the surveillance.

TS 3.7.4, " Essential Raw Cooling Water System" requires in part at least two independent essential raw cooling water (ERCW) loop; shall be operable.

On December 22, 1992, TVA identified that the ERCW system had not received the total scope pressure tests required by the ASME,Section XI, Table IWD-2500-1.

TVA immediately started to perform the required testing was unable to complete it in the required 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Thus TVA requested a Temporary Waiver of Compliance of TS 4.0.3 for an additional period of time not to exceed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from 11:30 a.m. on December 23, 1992 and a Temporary Waiver of Compliance of TS 3.7.4 for an additional period of time not to exceed 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> from 11:30 a.m. on December 25, 1992.

The purpose of this Waiver Request is to allow sufficient time to complete the total scope of pressure tests of the ERCW system and thereby satisfy the Surveillance Requirement without unnecessarily requiring the shutdown of both units.

Inspections conducted in the last 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> have identified no new problems.

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5 Tennessee Valley Authority 2

nr, 2 4 992 This Waiver request was reviewed by the Plant Operations Review Committee (PORC) and was approved by the Vice President Sequoyah Nuclear Plant, This request was discussed with the TVA and NRC staff by telephone on_

December 22 and 23, 1992. The NRC staff on December 22, consisted of E. W. Merschoff, F. J. Hebdon, G. C. Lainas, B. Wilson and J. Blake.

Concurring on the decision were H. Berkow and F. Hebdon, NRR, C. Julian, B. Wilson and E. Merschoff, Region 11.

Should you have any questions concerning this letter, please contact us.

Sincerely, (Original signed by L. Reyes)

Luis A. Reyes Deputy Regional Administrator

Enclosure:

Temporary Waiver of Compliance Request dated December 23, 1992 cc w/ encl:

(See page 3)

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i Tennessee Valley Authority 4

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5. D. Ebneter, Ril L. A. Reyes, Ril J. R. Johnson, Ril G. C. Lainas, NRR

f. J. Hebdon, NRR B. Bordenick, OGC H. S. Callahan, GRP/CA P. J. Kellogg, Ril J. L. Mathis, Ril D. E. Labarge, NRR NRC-Document Control Desk NRC Senior Resident inspector U.S. Nuclear Regulatory Commission 2600 Igou Ferry Soddy-Daisy, TN 37379 4

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Tennessee Valley Authority 3

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Mr. John B. Waters, Director.

Mr. M. J. Burzynski, Manager Tennessee Valley Authority Nuclear Licensing and ET 12A Regulatory Affairs 400 West Summit Hill Drive Tennessee Valley Authority Knoxville, TN 37902 58 Lookout Place Chattanooga, Tennessee 37402-2801 TVA Representative Tennessee Valley Authority Rockville Office Mr. Michael H. Mobley, Director 11921 Rockville Pike Division of Radiological Health Suite 402 T.E.R.R. A. Building 6th Floor Rockville, MD 20852 150 9th Avenue North Nashville, TN 37219-5404 General Counsel Tennessee Valley Authority County. Judge ET llH Hamilton County Courthouse 400 West Summit Hill Drive Chattanooga, TN 37402 Knoxville, TN 37902 bec w/ encl:

(See page 4)

Mr. J. R. Bynum, Vice President Nuclear Operations Tennessee Valley Authority 3B Lookout Place 101 Market Street Chattanooga, TN 37402-2801

- Ms. Marci Cooper, Site Licensing Manager Sequoyah Nuclear Plant Tennessee Valley Authority P. O. Box 2000 Soddy-Daisy, TN 37379 Mr. Jack Wilson, Vice President Sequoyah Nuclear Plant-Tennessee Valley Authority P. O. Box 2000 Soddy-Daisy, TN 37379 L

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ENCLOSURE 1

Tennessee Vuey Aomy Post Cthce 6ca MO. Sc: ray.owsr Temesset J7379 2000 Robert A. Fenecs vee e,eemem. seummte= Pont December 23. 1992 U.S. Nuclear Regulatory Commission ATTN Document Control Desk Washington, D.C. 20555 Gentlement In the Matter of

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Docket Nos. 50-327 Tennessee Valley Authorf.ty

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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 Unite 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 pressure tests required by the American Society of Mechanical Engineers (ASME),Section XI, Table IWD-2500-1,'on the ERCW system.

WA is requesting a waiver for an additionel period 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 pressure testa on the ERCW system. This additional time is needed i

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 innervice system pressure tests had been performed durin6 the second inspection period of the first 10-year interval in accordance with ASME,Section XI. as required by TS SR h.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 terts).

Efforts are

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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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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 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 unita must be completed by 11:30 a.m.

Eastern standard time (EST) on December 24, 1992, and the A-train 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.

NRC approval of the 24-hour waiver of compliance to TS SR 4.0.3 and 96-hour waiver to TS LCO 3.7.4 was Eranted verbally by Luis Reyes, Action Regional A6ninistrator, - 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,

" - G4 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 I

NRC Resident Inspector Sequoyah Nuclear Plant i

2600 Igou Ferry Road' Soddy Daisy, Tennessee 37379-3624 Mr. B. A. Wilson, Project Chief U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323-0199 CR'd E N E S & LS @

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11.S. Nuclear Regulatory Commission Page 3 December 23, 1992 MAC:JDS PMB Enclosure cc (Enclosure)

M. J. Buraynski, LP 5B-C J. R. Bynwn, LP 3B-C E. S. Christenbury ET 11H-K W. R. Coboan, Jr., LP 3B-C M. A. Cooper, OPS 40-SQN L. M. Cuoco LP SB-C R. W. Iluoton, Rockville Licensing Office B. T. 14ndrey, MR 20-0 T. J. McGrath, LP 3B-C M. O. Medford, LP 3B-C D.

F.. Hunn, Jr., LP 3B-C 8enior Vice President, LP 33-C J. N. Ward, OPS 4H-SQN RIMS, fir 2F-C PL316201/785 k

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ENCLOSURE DAcitraunti American Society of Hechanical 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 perioda during each 10-year inservice inspection interval.

The 10-year inspection interval enda 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, f or l' nits 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 cooling 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 survoillance requirements for innervice 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 both trains of containment spray for both unita 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 />.

'IVA immediately initiated efforts to perform the inservice system pressure testa 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 f or 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 f or both unita.

Safety Sinnificanct 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 kncwn to be susceptible to leakage mechanisms (i.e., erosion / corrosion and microbiologically induced corrosion) are maintained in plant programs using volumetric nondestructive examination and visual techniques. Additionally, there are _ f requent walkdowns performed by personnel in the plant f rom Operations, Technical Support, and Radiological Control who would investigate the source of any leaka6e found.

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