ML20151R340
| ML20151R340 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 04/20/1988 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8804270299 | |
| Download: ML20151R340 (11) | |
Text
'
4 TENNESSEE VALLEY AUTHORITY CHATTANOOGA. TENNESSEE 37401 SN 157B Lookout Place APR 201988 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C.
20555 Gentlemen:
In the Matter of
)
Docket Nos. 50-327 Tennessee Valley Authority
)
50-328 SEQUOYAH NUCLEAR PLANT (SQN) - NRC INSPECTION REPORT NOS. 50-327/87-73 AND 50-328/87 RESPONSE TO NOTICE OF VIOLATION Enclosed is TVA's response to K. P. Barr's letter to S. A. White dated March 9, 1988, that transmitted Notice of Violation 50-327, -328/87-73-05, and request for responses to items identified by cover letter. provides TVA's response to the Notice of Violation.
provides responses to items identified by the NRC cover letter.
contains a list of commitments contained in this submittal.
If you have any questions, please telephor:e M. R. Harding at (615) 870-6422.
Very truly yours, TENN S E LEY AUTHORITY R.
ridley, D rector Nuclear Lice sing and Regulatory Affairs En:losures cc:
See page 2 8804270299 080420 DR ADOCK 050 7
\\\\
An Ecual opportunity Employer
- U.S. Nuclear Regulatory Comission APR 201988 cc (Enclosures)
Mr. K. P. Barr, Acting Assistant Director for Inspection Programs TVA Projects Division U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Mr. G. G. Zech, Assistant Director for Projects TVA Projects Division U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Sequoyah Resident Inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy Daisy, Tennessee 37379 i
4
ENCLOSURE 1 Violation 50-327, -328/87-73-05 "10 CFR 50.59 states that the holder of a license authorizing operation of a utilization facility may make changes in the facility as described in the safety analysis report, without prior Commission approval, unless this proposed change involves a change in the Technical Specifications incorporated in the license or involves an unreviewed safety question.
The licensee should maintain records of changes in the facility which shall include a written safety evaluation which provides the bases for the determination that the change does not involve an unreviewed safety question.
Contrary to the above, as documented on condition adverse to quality report (CAQR SQP871738) Rev. O, the licensee either failed to perform or failed to adequately perform written safety evaluations for 15 modifications to the facility which involved compensatory actions for defeated safety functions.
Examples of this violation include the following:
Example #1: A flexible hose installed between the essential raw cooling water system and the emergency diesel generator coolers has not been qualified to withstand a seismic event. A compensatory measure has been initiated requiring visual inspection of the hose after each diesel generator start.
The licensee could not produce an unreviewed safety question determination for this issue.
Example #2: To avoid diesel generator overloading in the event of a loss of offsite power, fire pumps 2A-A and 2B-8 are to be placed in ' manual' to prevent their starting from a signal during a loss of coolant accident resulting from high containment temperatures.
Diesel generator loading analysis did not include loads associated with these two pumps.
The licensee could not produce an unreviewed safety question determination for this issue.
Example #3: The Department of Nuclear Engineering has determined that twenty-four additional plant doors must be opened during a tornado watch or warning due to incorrect models used during the original tornado analysis. A compensatory measure was implemented to require that these doors be opened.
The licensee could not produce an unreviewed safety question determination for this issue.
This is a Severity level IV Violation (Supplement I)."
Admission or Dental of the Alleged Violation TVA admits the violation.
Reason for the Violation j
Compensatory measures (cms) were incorporated into operations procedures to resolve problems that could not be corrected by physical changes alone or to provide an interim fix until planned modifications could be completed.
cms evolved as a result of activities such as condition adverse to quality / condition adverse to quality report (CAQ/CAQR) corrective actions, design calculations, Employee Concern. Reports, Engineering Change Notices (ECNS), and NRC inspections and commitments.
Procedural changes involving cms
. were evaluated for acceptability by responsible personnel on a case-by-case basis, but documentation of acceptability was not required by procedures.
10 CFR 50.59, "Changes, Tests and Experiments," was applied consistently during the ECN process; however, no standard practice existed for performing 10 CFR 50.59 Unreviewed Safety Question Determination (USQD) evaluations for CM procedure changes resulting from the other activities mentioned above.
Additionally, the USQDs for ECNs often addressed only the physical change itself. The USQD might mention or specify the procedural change, but there was no specific requirc:nent that the ECN USQO addresses the adequacy of the CM as a substitute for a defeated safety function or inadequate design. USQDs were performed by Operations for each revision made to a procedure.
These USQOs were often inadequate in that they did not address manpower requirements with respect to minimum staffing requirements of the technical specifications. -Therefore, in general, cms were either never formally evaluated and documented or were inadequately addressed.
This deficiency was primarily caused by the following factors:
1.
Procedural changes, which replaced physical modifications or were implemented as the result of defeated safety functions or inadequate design, were previously not formally defined as cms.
2.
No tracking method was established for cms.
3.
No instruction had been established to require USQOs to address the acceptability of a CM to replace a safety function or correct an inadequate design or to address manpower and staffing requirements.
Corrective Steps That Have Been Taken A task force was developed to review' potential cms. The task force identified 148 potential cms.
An initial review determined 39 potential cms were duplicates. Review of the remaining 109 potential cms yielded the following results:
77 potential cms did not meet the definition of a CM.
24 potential cms met the specific definition of a CM.
Scven potential cms were classified as indeterminate because of insufficient information available during performance of the evaluation.
The corrective action was completed for one CM and the CM was cancelled during the review.
Review of the 24 potential cms that met the specific definition of a CM resulted in the following:
Seven cms had adequate USQOs existing.
13 cms did not have a USQD written.
Four cms had inadequate USQDs written.
A
, The 17 CHs with inadequate USQOs or no written USQDs were documented on CAQR No. SQN 871738.
The resolution of the CAQR was to write USQDs for the 13 cms with no written USQO and revise the four CMr with inadequate USQOs.
Further review of the seven indeterminate cms resulted in the following:
Three were determined not to be cms.
Four were determined to be cms and USQOs were written.
In addition, Administrative Instruction 49, "Control and Tracking of Compensatory Measures," was issued.
This instruction accomplishes the following actions:
1.
Establishes a single point of contact to control implementation of CHs.
2.
Establishes uniform definitions to be used in identifying and evaluating cms.
3.
Defines the responsibilities of. individuals assigned the task of evaluating potential cms.
4.
Establishes minimum requirements associated with USQDs/ screening reviews for cms.
5.
Outlines actions to track activities for eliminating cms.
6.
Specifically requires review for impact of CHs on the Operations (or other affected) crew in regard to minimum plant staffing requirements.
The issuance of this instruction establishes a program for control and tracking of potential compensatory measures.
Corrective Steps That Will Be Taken to Avoid Further Violations There is no further corrective action required.
Date When Full Compliance Will Be Achieved TVA is in full compilance.
i 6
ENCLOSURE 2 In K. P. Barr's letter to S. A. White dated March 9, 1988, you identified two issues that should be addressed in the response. These issues are as follows:
... (1) Schedules to complete actions necessary to correct the defeated safety functions and to eliminate the compensatory measures; and (2) a determination of the need for an additional assistant shift engineer to be added to each shift prior to two unit operation."
Response 1 Corrective Source ID Description Action Status Main Control Room Investigate logic After unit 2 CAQR SQP 870217 (MCR) standby air-circuitry problems restart conditioning start in the system CAQR Put assistant Valve operators CAQR closed SQP 870031 unit operator at rewired and 3/18/88; diesel generator functionally tested CM cancelled (D/G) building to in-accordance with ECNs 3/20/88 open essential raw ~
X0117 and X0118; cooling water (ERCW) all work and tests valves completed satisfactorily Memo Operators not DNE calculation CM cancelled J
B45 860226 218 use containment ieanalyzed and revised 3/13/88 sump level to bring transmitter indications for accuracy to within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> after loss limits ~
I of coolant accident (LOCA)
Problem Only essential Procedure changes Complete Identification space heaters needed by 6/6/98 Report energized SQNEEB 8683 CAQR Ultimate heat sink ECNs L7334 and Complete SQP 871696 temperature L7335 to be issued; by 5/5/88 fieldwork complete by 5/5/88 SCR Manually isolate (1) Revise Abnormal AOI-8, SQNEEB 86136 certain tornado Operating Instruction Rev 12, dampers (A01) 8 to ensure
?pproved manual isolation of 5/20/87 tornado dampers if required (2) Investigate to After unit 2 determine permanent restart corrective action
, Corrective Source ID Description Action Status CAQR Block open tornado DNE to reinalyze Complete SQF 870022 doors Auxillary Building by 4/30/88 structures for design basis tornado and revise calculation accordingly CAQR 480-V shutdown (1) Reconfigure existing Complete SQF 870181 board ground circuitry to provide during next detector inspection high resistance ground unit 1 once each shift and MCR alarm refueling outage (2) Revise Surveillance Approved Instruction (SI) 2 to 1/18/88 provide check once each (Revision 49) shift CAQR Lower compartment ' Environmentally Unit 2 SQT 870349 cooler use non-LOCA qualify coolers nonrestart items 11/30/88; unit 1 items 8/1/88 CAQR Xenon discrepancy Revise Technical TI-22, Rev 22, SQP 870083 in shutdown Instruction (TI) 22 to revised 5/9/87 calculation incorporate vendor recommendations CAQR Hanual start unit 2 Initiate ECNs L7155 Complete by:
SQT 870649 fire pumps and L7154 to trip unit 1: 9/1/88 and lock out fire unit 2: 6/1/88 I
pumps on SI CAQR Containment DNE to incorporate Complete by:
SQP 8711S2 integrity -
circuit protection 10/1/88 electrical penetrations P
, Corrective Source ID Description Action Status CAQR Manual operations (1) Operations to Complete SQP 871263 oi' ERCH screens revise procedures for 1/18/88 and strainers manual operation (2) Modifications to Complete work ECNs 7291 and 7292, 11/12/87 electrical circuit rework (3) DNE to prepare Complete by design documents to 1/31/89 procure or modify ERCH flow indicator in D/G building (4) Systems Engineering Complete generate design change by 7/31/88 request to inject
' sodium hypochlorite downstream of the strainers (5) DNE to do mission Complete dose calculation when placing screens and strainers in continuous bsikwash following LOCA (6) DNE (Mechanical Complete Engineering Branch) to 2/15/88 evaluate strainer flow Delta P CAQR Visual inspection (1) DNE calculation Complete SQP 871477 of D/G flex hoses No. CEB-CQS-340, 3/1/88 revision 0, "Flexible Me' cal Hose Evaluation" with metal flex hose (2) Letter from Complete Impell to TVA dated 3/1/88 j
10/14/87, "TVA Contract TV-73037A IDI Consulting Task Preliminary Flex Hose Evaluation" 1
'~
.i Corrective Source ID Description Action Status (3) Memorandum from Complete l
F J. B. Hosme, to 3/9/88 L. M. Nobles dated 10/16/87, "Sequoyah
' Nuclear Plant (SQN) -
Flexonics Flex Hoses" (4) Procure qualified Next refueling flex hose and install outage, unit I Do not use alternate Partial field-ECN remains ECN L6712 feeder breaker for complete workplan open until turbine-driven 12147 finished appropriate auxiliary feedwater drawings are pump revised.
4 A detailed status of all-items identified as "after u'.lt 2 restart" will be submitted by June 6, 1980.
A detailed status including corrective actions necessary to eliminate cms will be submitted June 6, 1988, on the following cms:
(cms identified by source 4
document identification number)
SQNMEB8677, SQNNEB8617, S53 851206 915, EC203.01, EC243.00, EC17301, NRC observation No. 6.22, NC085-0086-020, Operations printout No. 27, A27 830919 018, ECNL6073, IDI D-2.09, and IDI D2.2-7.
j Response 2 The determination for the need of an additiona' assistant shift engineer to be added + sach shift before two-unit oneration is still being evaluated and will be completed before unit 1 mode 4.
f l
1 e
i
+='
A
- g
ENCLOSURE 3 1.
A supplemental responic will be submitted by June 6, 1988, to define corrective action and provide final completion dates for cms identified below.
a.
CAQR SQP 870217, MCR standby air-conditioning start--Investigate logic circuitry problems in the system, b.
SCR SQNEEB 86136, manually isolate certain tornado dampers--Invettigate to determine permanent corrective action.
c.
ECN L6712, do not use alterr. ate feeder breaker for turbine-driven AFH pump--ECN remains open until appropriate drawings are revised.
2.
The following cms along with respective corrective actions will be completed on the identified dates.
a.
PIR SQNEEB 3683, procedure changes needed--complete by June 6, 1988.
b.
CAQR SQP 871696, ECNs L7334 and L7335 to be issued and fieldwork to be performed--complete by May 5, 1988.
c.
CAQR SQF 870022, DNE to reanalyze Auxiliary Building structures for design basis tornado and revise calculation accordingly--complete by April 30, 1988.
d.
CAQR SQr 870181, reconfigure existing circuitry to provide high-rasistance ground and MCR alarm--complete during next unit I refueling outage, e.
CAQR SQT 870349, environmentally qualify lower compartment coolers--complete unit 2 by November 30, 1988, and unit 1 by August 1, 1988.
f.
CAQR SQT 870649, initiate ECNs L7155 and L7154 to trip and lock out fire pumps on SI--complete unit 1 by September 1, 1988, and unit 2 by June 1, 1988.
g.
CAQR SQP 871182, DNE to incorporate circuit protection--complete by October 1, 1988.
h.
CAQR SQP 871263, DNE to prepare design documents to procure or modify ERCH FI in D/G Building--complete by January 31, 1989; generate DCR to inject sodium hypochlorite downstream of the strainers--complete by July 31, 1988.
1.
CAQR SQP 871477, DNE to procure qualified flex hose and install--next unit I refueling outage.
e 4-
- )
, 3.
A detailed status including corrective actions necessary to eliminate cms will be submitted June 6, 1988, on the following cms:
(cms identified by source document identification number)
SQNMEB8677, SQNNEB8617, S53 851206 915, EC203.01, EC243.00, EC17301, NRC observation No. 6.22, NC085-0086-020, Operations printout No. 27, A27 830919 018, ECNL6073, IDI D-2.09, and IDI D2.2-7.
4.
Determination of the need for an additional assistant shift engineer will be conipleted before unit 1 mode 4 and a supplemental response will be submitted.
4 1
l l
e i
-. _..