ML20135G521

Responds to NRC Re Violations Noted in Insp Repts 50-327/85-24 & 50-328/85-24.Corrective Actions:Std Practice SQM2 to Be Revised,Steam Leakage Source to Be Repaired & Surveillance Instruction to Be Prepared

ML20135G521
Person / Time
Site:	Sequoyah
Issue date:	09/06/1985
From:	Domer J TENNESSEE VALLEY AUTHORITY
To:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
NUDOCS 8509190343
Download: ML20135G521 (4)

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1 TENNESSEE VALLEY AUTHORiTyg CH ATTANOOGA. TENNESSEE 374ot 400 Chestnut Street Tower II h, September 6, 1985 8 U.S. Nuclear Regulatory Comission Region II ATTN: Dr. J. Nelson Crace Regional Administrator 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323

Dear Dr. Grace:

SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 - NRC-0IE REGION II INSPECTION REPORT 50-327/85-24 AND 50-328/85 RESPONSE TO VIOLATIONS Enclosed is our response to R. D. Walker's August 7, 1985 letter to H. G. Parris transmitting IE Inspection Report Nos. 50-327/85-24 and 50-328/85-24 for our Sequoyah Nuclear Plant which cited TVA with two Severity Level IV Violations. The concerns associated with the Maintenance Management System are being addressed as part of an overall review of the Sequoyah maintenance program.

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 statements contained herein are complete and true.

Very truly yours, TENNESSEI VALLEY AUTHORITY J. A. Domer, Chief Nuclear Licensing Branch Enclosure ec: Mr. James Taylor, Director (Enclosure)

Office of Inspection and Enforcement U.S. Nuclear Regulatory Comission Washington, D.C. 20555 8509190343 e50906 PDR ADOCK 05000327 l Q PDR l

An Equal Opportunity Employer

ENCLOSURE RESPONSE TO R. G. WALKER'S LETTER TO H. G. PARRIS DATED AUGUST 7, 1985 OIE INSPECTION REPORT NOS.

50-327/85-24, -328/85-24 Violation 50-328/85-24-02 10 CFR 50 Appendix B, Criterion V, states, in part, that instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.

Technical Specification 6.8.la states that written procedures shall be established, implemented and maintained covering the activities of applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2 February 1978.

Regulatory Guide 1.33 Revision 2, Appendix A, ststes that maintenance that can affect the performance of safety-related equipment should be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances.

Contrary to the above, the licensee failed to conduct an appropriate post maintenance flow rate test on the Emergency Gas Treatment System (EGTS) after completing an ECTS damper repair on June 18, 1985, due to a lack of adequate criteria to determine the need for a post maintenance test.

This is a Severity Level IV violation (Supplement 1).

1. Admission or Denial of the Alleged Violation TVA admits the violation occurred as stated.

2. Reason for the Violation The violation occurred due to inadequate procedures / training in that the individuals planning the work did not recognize the need for post-maintenance flow testing following damper adjustment.

3. Corrective Steps Which Will Be Taken and the Results Achieved A satisfactory flow rate test was performed in accordance with Surveillance Instruction-142 July 19, 1985.

4. Corrective Steps Which Have Been Taken to Avoid Further Violations Standard Practice SQM2, " Maintenance Management System," will be revised to includo direction for when a postmaintenance test (PMT) is required for maintenance activities and descriptions of what should be required in the PMT. Personnel who plan maintenance requests will be instructed in proper PMT requirements.

5. Date When Full Compliance Will Be Achieved The plant will be in full compliance by January 1, 1986.

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e Violation 50-328/85-24-03 Technical Specification 3.6.5.3 states that, the ice condenser inlet doors, intermediate deck doors, and top deck doors shall be closed and operable for modes 4 through 1. Additionally, with one or more ice condenser doors

-inoperable, power operations may continue for up to 14 days provided the ice bed temperature is monitored once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and the maximum ice bed temperature is maintained less than or equal to 270F.

Technical Specification 4.6.5.3.2 states, in part, that each intermediate deck door shall be verified closed and free of frost accumulation by visual i

inspection at least once per 7 days.

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Contrary to the above, on June 10, 1985, ice buildup was observed on the intermediate door and ice bed test --1ure was recorded once per eight hour shift vice the required once per fo hours due to a lack of adequate post maintenance criteria.

This is a Severity Level IV violation (Supplement 1).

1. Admission or Denial of the Alledged Violation I TVA admits a violation occurred.

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2. Reason for the Violation The alleged violation states that the ice bed temperature must be recorded once per four hours if ice is observed on the intermediate deck doors.

This does not accurately reflect Technical Specification'3.6.5.3 which allows the flexibility, in lieu of recording the ice bed temperature, to i ". . otherwise, restore the doors to their closed positions or OPERABLE status (as applicable) within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> . "

. . . Upon discovery of the ice buildup on June 10, 1985, the ice was removed, and a surveillance instruction was_ performed which documents that the intermediate deck doors were free of ice and restored to operable status later that same day.

l This is within the 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> allowed by Technical Specification 3.6.5.3.

i l As indicated by the NRC inspection report, additional icing was ob erved on June 16, 1985. The inspection report stated that this ice buildup was caused by inleakage of humid air through torn insulating tape on the

overhead upper ice condenser doors. TVA has evaluated this condition and determined that the torn insulating tape does not constitute a significant contribution to the buildup of ice. Unit 2 has experienced a history of ice condenser inleakage, primarily through the existing vent blankets,

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which in conjunction with the high humidity, has resulted in additional i ice accumulation. To address this problem, maintenance personnel

established a routine of periodically entering the ice condenser and I

removing the ice buildup. This was.in addition to performance of the weekly surveillance instruction required to meet Technical Specification surveillance Requirement 4.6.5.3.2.a. The periodic maintenance routine was considered to be acceptable because the ice removal activity was the same as that performed for any ice-buildup discovered during the j weekly surveillance. Upon discovery on June 16, 1985, the ice was removed j within the 48. hours allowed by technical specifications.

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.~ o Contrary to the statement of the violation, TVA complied with all action requirements for both events on June 10 and June 16, 1985. During discussion of these findings with the NRC resident inspector at Sequoyah and the cognizant NRC Region II inspector, it was ascertained that the principal NRC concern resulted from performance of ice removal activities without formal procedures needed for work on safety-related equipment.

After reevaluation of the periodic ice removal routine, TVA agrees that the potential for problems may exist due to the fact that this practice is not controlled by formal procedures.

3. Corrective Steps Which Will Be Taken and the Results Achieved With respect to the two incidents of ice buildup found on June 10 and June 16, 1985, the only corrective step needed was the removal of the ice. This was completed, and the intermediate deck doors returned to operable status within the 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> prescribed by technical specifications.

The cause of the increased containment humidity has been determined to be steam leakage through the steam generator manway. This problem is expected to be corrected during the current outage.

4. Corrective Steps Which Have Been Taken to Avoid Further Violations To address the potential problems associated with periodic ice removal, TVA is preparing a Sequoyah Nuclear Plant surveillance instruction to provide specific instructions. These instructions will require that when ice or frost is discovered on the intermediate deck doors, Surveillance Requirement 4.6.5.3.2.b will be performed for those doors.

This will determine the effect of the ice or frost accumulation on door operability. If the force required to lift the subject door exceeds the values specified by 4.6.5.3.2.b the door will be deemed inoperable, and Technical Specification actions of 3.6.5.3 will be met. If the iced door passes the pull test, the door will be considered operable, and ice will be removed as work schedules allow. After ice removal, the test will also be conducted to verify that the door has been returned to an operable condition.

5. Date When Full Compliance Will Be Achieved Full compliance was achieved on June 10 and June 16, 1985, for each respective incident of ice buildup.

The surveillance instruction for periodic ice removal will be implemented before entry into mode 4 following the current outage. A finm date for restart has not been established at this time.

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