ML20137L937
| ML20137L937 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 08/28/1985 |
| From: | Mccloud D TENNESSEE VALLEY AUTHORITY |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8509130102 | |
| Download: ML20137L937 (9) | |
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TENNESSEE VALLEY AUTHORITY g
CHATTANOOGA, TENNESSEE 374ot 400 Chestnut Street Tower II rmo
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August 28, 1985 U.S. Nuclear Regulatory Commission Region II ATTN:
Dr. J. Nelson Grace, Regional Administratoc a
101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323
Dear Dr. Grace:
SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 - NRC-OIE REGION II INSPECTION REPORT 50-327/85-17 AND 50-328/85 RESPONSE TO VIOLATIONS Enclosed is our response to R. D. Walker's July 30, 1985 letter to H.
G.' Parris transmitting IE Inspection Report Nos. 50-327/85-17 and 50-328/85-17 for our Sequoyah Nuclear Plant which cited TVA with one Severity Level IV Violation and three Severity Level V Violations.
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, TENNESSEE VALLEY AUTHORITY D. E. McCloud Nuclear Engineer Enclosure cc:
Mr. James Taylor, Director (Enclosure)
Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C.
20555 8509130102 B50028 PDR ADOCK 05000327 G
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An Equal Opportunity Employer I
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f ENCLOSURE RESPONSE - NRC-0IE INSPECTION REPORT NOS.
50-327/85-17 AND 50-328/85-17 ROGER D. WALKER'S LETTER TO H. G. PARRIS DATED JULY 30, 1985 Violation 50-327/85-17-01 and 50-328/85-17-01 4
Technical Specification 6.8.1 requires that written procedures be established, covering safety related activities referenced in Appendix A of Regulatory Guide 1.33, Revisien 2, February 1978.
4 a.
DPSO-SHI-1DG, " Relay Functional Tests for Diesel Generator Protective Relays," and MI-10.1, " Diesel Generator Inspection,"
were established to Laplement Technical Specification surveillance requirements.
Contrary to the above, adequate procedures were not established in that DPSO-SMI-lDG did not specify Emergency Diesel Generator i
(EDG) local-remote switch position in the EDG cubical nor in the control room prior to the completion of paragraph 9.A(4)4.1 and did not require that controlled test equipment be used in the l
performance of step 9.A(3).
b.
SQM-24 " Torque and Limit Switch Settings for Motor-Operated 1
Valves," was established to comply with the above requirement for maintenance procedures on safety-related equipment.
Contrary to the above, SQM-24 did not incorporate the limit switch adjustment technique identified in MI-11.2, " Motor I
Operated Valve Adjustment Guidelines," which resulted in damage to two safety related valves and a reactor trip.
i c.
SI-484, " Periodic Calibration of Reactor Vessel Level Instrumentation System (RVLIS) and.OS wide Range Pressure Channels (P-403, P-406) (Refueling Outage)," was established to implement post-modification testing requirements.
Contrary to the above, SI-484 was not adequately established for configuration control in that the procedure did not include measures to assure that a sensing line common to RVLIS and i
Reactor Coolant System pressure transmitter PT-68-66 was isolated so as to preclude actuation of a pressure interlock for the Residual Heat Removal (RHR) isolation valves. This deficiency resulted in the unanticipated isolation of the RHR system due to a high pressure signal sensed by the transmitter during RVLIS fill, vent, and pressurization.
The above examples constitute a Severity Level IV Violation.
This violation applies to both units.
(Supplement I).
1.
Admission or Denial of the Alleaed Violation TVA admits the violation occurred as stated.
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2.
Reason for the Violation 1
The intent of step 9.A(4)4.1 in DPSO-SMI-1-DG, " Relay a.1.
Functional Tests for Diesel Generator Protective Relays," was to try to start the diesel generator from local start without resetting the 86GA relay. To perform the attempted start, the local / remote selector switch must be placed in local prior to depressing the local start button. Step 9.A(4)4.1 was not l
explicit in specifying the required position of the i
local / remote selector switch. The test engineer interpreted step 9.A(4)4.1 to mean perform the attempted start by-depressing th'a local start button.
a.2.
While performing step 9. A.3 of DPSO-SMI-1-DG, a test rig was used. The test ris cannot be calibrated, and it is not used to
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make any type of measurement.
The test rig is used to pass j
current through the 87 relay to actuate the 86GA relay.
Although several combinations of certified equipment could have been used, no one special calibrated relay testing kit existed to perform this function. One combination would have been to use the model C relay test set in conjunction with a variac and a loading transformer. Using this combination, the test engineer would connect the equipment together and vary current i
I through the 87 relay using the variac.
Since current is being varied, the test engineer could possibly raise the current level above the maximum current rating of the 87 relay, thus resulting in damage to the relay coil. The transformer in the test rig serves as an over-current protection device in that the maximum short circuit secondary current is 0.4 amperes.
Since the maximum current rating of the 87 relay is 10 amperes for a period of one minute /200 amperes for a period of one second, the relay could not possibly have been damaged by the test rig.
b.
Two instructions existed which addressed the setting of motor-operated valve limit switches. These instructions were Sequoyah Standard Practice SQM-24, Revision 0, " Torque and j
Limit Switch Settings for Motor-operated Valves," and Maintenance Instruction (MI)-11.2, Revision 14 " Motor-Operated Valve Adjustment Guidelines."
Workplan 11100 required the valve limit switches be set in accordance with Sequoyah Standard Practice SQM-24. The current revision of this procedure did not differentiate between
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fa'st-acting and normal-speed valves. It stated that motor-operated valves should have their limit switches set to.
stop the valve motor at 97 to 98 percent of the full open j
position. The four unit 2 feedwater isolation valve limits were adjusted in accordance with this instruction as specified l
in the workplan. The above limit set points of 97 to 98-percent were not adjusted far enough from the backseat to stop the valves from impacting their backseats due to inertia.
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MI-11.2 clearly identifies these four feedwater isolation valves as fast acting and specifies a different set point for the valves # 11mit switches. This procedure states that the limit switch is to be adjusted to 90 percent open, and then the valve will be electrically opened to determine the amount of inertia (travel) the valve has after the switch opens. The switch is then readjusted as necessary to allow the valve to open with motor operation and valve inertia between 99 and 100 percent.
c.
Sequoyah Surveillance Instruction (SI)-484, " Periodic Calibration of Reactor Vessel Level Instrumentation (RVLIS) and RCS Wide Range Pressure Channels (P-403, P-406)," and Special Maintenance Instruction (SMI)-0-68-26 did not include adequate configuration control to prevent actuation of one of the RHR suction valves during the partial refill of RVLIS upper plenum sense lines (trains A and B).
These procedures did not laclude steps to preclude this event by isolating the RCS pressure transmitter from RVLIS or by disabling the pressure signal to the RHR suction valve logic.
3.
Corrective Steps Which Have Been Taken and the Results Achieved a.1.
In revision 8 of DPSO-SMI-1-DG, step 9.A.(4)4.1 was revised to specify the position of the local / remote selector switch.
a.2.
Due to the concern over the test rig not being controlled by the maintenance and test eqelpment program, the TVA central laboratories have performed certification testing to qualify the test rig. Also DPSO-riI-1-DG has been revised to include a step for tecording test equipment data.
b.
All unit 2 feedwater isoi. tion valve open limit switches were reset in accordance with MI-11.2, Revision 14 and documented, Work was immediately halted on the RVLIS test and the system c.
depressurized. A plant operations review committee (PORC) approved temporary change was made to SMI-0-68-26 to add steps for preventing isolation of RHR srction before any more work was completed. After the temporary change was approved, the SMI was continued and completed successfully.
4.
Corrective Steps Which Will Be Taken to Avoid Further Violations a.1.
None.
9 a.2.
None.
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b.
SQM-24 was cancelled allowing only MI-11.2 to be utilized for adjusting torque and limit switches on motor-operated valves during modification or maintenance activities.
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Permanent revisions to SI-484 and SMI-0-68-26 have been initiated and are in approval cycic to include steps for preventing isolation of RHR suctiota during testing of the RVLIS system. These instructions will not be used again until the permanent revisions receive final approval. The permanent j
revisions will receive final approval and be available for work by November 1, 1985.
5.
Date When Full Compliance Will Be Achieved
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a.1.
Full compliance was achieved on June 13, 1985, for paragraph 9.A(4)4.1.
i a.2.
Full compliance was achieved on June 3, 1985, for step 9.A.3.
b.
Full compliance was achieved on June 6, 1985.
c.
The plant will be in full compliance by November 1, 1985.
Violation 50-327/85-17-02 j
Technical Specification 6.11 requires that procedures for personnel radiation protection.shall be prepared consistent with the requirements of j
10 CFR 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure. These requirements are implemented by procedure RCI-1, " Radiological Hygiene Program," which requires each employee to adhere to Health Physics procedures and 4
protective measures. One protective measure, Radiation Work Permit (RWP) 1-85-105, required a canvas hood be worn in addition to other protective clothing while conducting activities in the Unit 1 containment radiation area.
l Contrary to the above, RWP 1-85-105 requirements were not implemented in that an individual was observed conducting activities in the Unit 1
_ containment without the prescEibed canvas hood.
4 This is a Severity Level V violation. This violation applies to Unit 1 only. (Supplement IV).
4 1.
Admission or Denial of the Allemed Violation TVA admits the violation occurred as stated.
2.
Reason for the Violation The Quality Control (QC) inspector in question was dressed out in accordance with the requirements of RWP 1-85-105 while performing QC 1'
inspections on upper and lower limit switches in accumulator room number four. Upon completion of the inspections and While exiting the elevated work area, the inspector's hood fell off while moving through i
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an unusually tight area. As he was climbing down to the floor of the accumulator room, the NRC resident questioned him about dress-out i
requirements with respect to wearing a hood. The inspector stated
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that he had dropped it, and it was on the floor below.
Since the hood may have been contaminated, he could not put it back on; and since he t
did not continue working without the hood, but was in fact leaving the area, his actions were not in violation of practices taught during Health Physics dress-out training.
3.
Corrective Steps Which Have Been Taken and the Results Achieved In order to ensure continued compliance with Radiation Control Instruction (RCI)-1, he has been reinstructed in the proper procedures to be followed in the event that protective clothing is lost or damaged during work.
4.
Corrective Steps Which Will Be Taken to Avoid Further Violations None.
5.
Date When Full Compliance Will Be Achieved Full compliance was achieved on May 18, 1985.
Violation 50-327/85-17-03 and 50-328/85-17-03 Technical Specification 6.8.1 states that written procedures shall be established, implemented and maintained covering the procedures referenced in Appendix A of Regulatory Guide 1.33, Revision 2. February 1978.
Procedure MI-10.1 was established to implement requirements for Emergency Diesel Generator surveillance testing.
MI-10.1 paragraph 5.3.1.2.2.5 requires technicians to set up test equipment prior to diesel engine start and paragraph 5.3.1.2.4 requires the technician to verify receipt of the
" Engine Running" annunciation at 850 rpm engine speed.
Contrary to the above, as of May 21, 1985, MI-10.1 was not implemented in that technicians did not set up their test equipment prior to engine start and the technician arroneously recorded 850 rpm as the annunciation speed when the annunciation actually energized at about 875 rpm.
This is a severity Level V violation. This violation applies to both units. (Supplement I).
1.
Admission or Denial of the A11 exed Violation
. I TVA admits the violation occurred as stated.
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Reason for the Violation a.l.
The note in MI-10.1, preceeding step 5.3.1.2.2.5, stated the following:
"DPSO to set up their test equipment prior to this start." The purpose of the note was to notify DPSO of the intention to start the diesel generator so that DPSO could coordinate DPSO-SMI-1-DG, " Relay Functional Tests for Diesel Generator Protective Relays," with MI-lO.1, " Diesel Generator Inspection." DPSO-SMI-1-DG does not require any work to be dono until after the diesel generator is running. Therefore, DPS0 setting up their test equipment is not a prerequisite for starting the diesel generator. Before preforming step 5.3.1.2.2.5 of MI-10.1, on May 21, 1985, the technicians notified DPSO of their intention.to start the diesel generator, thus fulfilling the purpose of the note.
a.2.
The technician requested the operator to increase the engine speed from 550 rpm to 850 rpm to make the annunciation check.
The operator used the hydraulic governor control switch to raise the speed.
This switch, when placed in the raise (speed) position, drives a motor that drives a shaft down on a lever that pushes a piston against hydraulic fluid that eventually results in a governor actuator output rotation that is connected to the engine fuel rack to increase fuel flow and therefore engine speed. An increase in speed trails the actuation of the hydraulic governor control switch. For this reason, the operator has to momentarily place the switch in the raise position and then return it to its neutral position while waiting for the engine speed to respond and reach a constant speed. To prevent over speed or exceeding 850 rpm, the operator performs this exercise several times before getting the engine speed close to 850 rpm.
If 845 rpm was reached, and the operator actuated the raise switch and kept it in the raise position a little too long (3 to 5 seconds), 860 or 870 rpm could easily result. The operator cannot see the speed indication annunciation lights being checked and usually continues his rhythm of switch actuation until the technician notifies him (notification is by hand signal or some other means, because hearing is impossible with the engines running) that the speed indicating lights have actuated. Often, the operator will not be able to stop his rhythm of switch actuation until he has raised the speed one time past the point where the technician first noticed the speed indicating lights actuate.
The intent of MI-10.1 is to verify that the speed indicating lights actuate when the speed switch operates approximately at a calibrated setpoint. The calibration procedure, Instrue.ent Maintenance Instruction (IMI)-82, for the speed switches verifies their accuracy.
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Corrective Steps Which Hava Been Taken and the Results Achieved a.1.
MI-10.1 has been revised to change the note to clarify its purpose,
a.2.
A.
Temporary changes 85-0633 and 85-0828 were written to provide a more detailed instruction for communications between the technicians and the operator while raising the engine speed to 850 rpm.
B.
On recent performances of MI-10.1, step 5.3.1.2.4 engineering support was provided for the technician to implement the necessary communications with the operator outside of the running engine chamber for raising the engine speed very slowly to 850 rpm.
C.
The aforementioned temporary changes reworded the specified 850 rpm to allow for approximately 850 rpm. The wording, "approximately 850 rpm," was already included on the data sheet at the time the violation occurred.
4.
Corrective Steps Which Will Be Taken to Avoid Further Violations a.1.
- Nono, a.2.
Presently, comments from the technicians are being reviewed for use in future revisions to clarify other difficult areas of MI-10.1.
5.
Date When Full Compliance Will Be Achieved a.1.
Full compliance was achieved on August 13, 1985, a.2.
Full compliance was achieved on June 6, 1985.
Violation 50-327/85-17-04 and 50-328/85-17-04 Technical Specification 6.8.1 requires that written procedures be implemented covering activities referenced in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Contrary to the above, Workplan No. 11188, which was established to install the battery racks and battery cells for vital battery V, was not implemented in that installation of the intercell spacers for vital battery V was not completed in accordance with the vendor. drawings for installation of the battery' racks as required by the workplan.
This is a Severity Level V violation. This violation applies to both units. (Supplement I).
1.
Admission or Denial of the Alleged Violation TVA admits that the violation occurred as stated.
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Reason for the Violation The vendor drawings were used for both the battery and the battery rack installation. The detail showing the spacer was on the battery rack installation drawing but not on the battery installation drawing. The battery rack was installed before the batteries were installed. The battery rack installation drawing was not referred to when the batteries were installed; therefore, the battery spacer detail was overlooked.
3.
Corrective Steps Which Have Been Taken and the Results Achieved Spacers were installed as specified on the vendor batter'y rack installation drawing.
4.
Corrective Steps Which Will Be Taken to Avoid Further Violations None.
5.
Date When Full Compliance Will Be Achieved Full compliance was achieved on May 13, 1985.
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