ML20154L206
| ML20154L206 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 02/28/1986 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8603110420 | |
| Download: ML20154L206 (8) | |
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TENNESSEE VALLEY AUTHORITY CH ATTANOOGA. TENNESSEE 37401 LP SN 1578 Lookout Placo February 28, 1986 kn
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U.S. Nuclear Hegulatory Conunission Region Il
- 3 sn ATTN Dr. J. Nelson Grace, Heslonal Administrator 101 Marletta Strunt, NW, Sulto 2900 o
Atlunta, Cuorgia 30323 Dear Dr. Grace!
cp co SEQUOYAli NUCLEAR PLANT UNIT 3 1 AND 2 - NHC 01E HEG10N 11 INSPECTION Whl'OkT
$0-327/85-46 AND $0-328/85 HE3PONGE TO V10LATIONG Knclosed is our responso to J. A. Olshinski's January 29, 1986 letter to S. A. Whito transmitting IE Inspection Heport Nos. ' 0-321/85-46 and 50-328/85-46 for our ucquoyah Nuclear Plant which cited TVA with three Goveelty Level IV Violations. Enclosurv 1 la our rosponse to the subject violations and enclosure 2 la a listing of TVA cotanttments.
If you have any questions, g$leanagot in touch with H. E. Alsup at FT3 858-2/25.
To the best of my knowledge, I declare the statement.s contained heroin are complete and*Lrue.
Very truly yours, TENNEuSEF VALLEY AUTHOH1TY l
H. Weldley HanJr,er of 1.lepusin6 Enclosures cc Mr. James T.sylor, Dlrector (knelosurea) ofIleo of Inspectlon and Enforco u nt U.G. Nuclear Hegulatory Commission Washin6 ton, D.C.
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RESPONSE - NRC-0!E INSPECTION REPORT NOS. 50-327/85-46 AND 50-328/85-46 JOHN A. OLSHINSK!'S LETTER TO STEVEN A. WHITE l
OATED JANUARY 29. 1986 i
l Violation 50-327/85-46-04 and 50-328/85-46-04 Technical Specification (TS) 6.8.1 requires that adequate written procedures be established and maintained covering safety-related activities stated in Appendix A of Regulatory Guide 1.33, Revision 2, which include the use of i
l surveillance procedures and system operating Instructions.
Contrary to the above, in the instances cited below, the licensee inade-quately established or maintained surveillance instructions and system operating instructions.51-256, Periodic Calibration of Overcurrent Relays and Distance Relays on a.
6.9 kV Reactor Coolant Pumps on 6.9 kV Unit Boards, contains the following inhfeguate acceptance criteria:
1.
For primary overcurrent protective devices, the procedure establishes a trip setpoint amperage tolerance value of tS%.
TS Table 3.8-1 for both units requires a g2% tolerance.
2.
For primary overcurrent protective devices, the procedure establishes a 75 degree impedance angle of maximum torque.
The proper value is 105 degrees.
3.
For primary overcurrent protective devices.. the procedure requires distance relay targets to operate between 1.0 and 2.0 amperes with DC voltage applied.
The vendor manual for these type !AC 66K relays requires proper operation between 0.1 and 2.0 amperes, b.
Procedure 50! 30.6, Auxillary Building Gas Treatment System, listed use of fuses with incorrect amperage ratings and prescribed positioning of a block switch which has been previously disconnected from the circuit, c.
Instrument maintenance procedure IMI-99. Reactor Protection System Calibration and Functional Testing, prescribed use of inadequate measuring and test equipment.
The measuring and test equipment prescribed was only 2 to 2.5 times more accurate than the measured parameter when the setpoint methodology used to determine reactor protection setpoints assumed the equipment was ten times more accurate than the measured parameter.
This is a Sever'ty Level IV Violation (Supplement !).
o l 1.
Admission or Dental of Alleged Violation TVA admits that the violation occurred.
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Reason for the Violation a.l. Olvision of Power System Operations (DP50) personnel used l
their Field Test Manual and relay setting sheets for l
developing the criteria in Surveillance Instruction (51)-256 i
for the over-current protective device.
The Field Test l
Manual, Section K3 specifies a 25 percent tolerance on these type devices.
i The example, as stated, is not completely correct in that the TS table 3.8-1 is different for units I and 2.
Unit I references the critical pickup setpoint and does not specify a tolerance. Unit 2 references the Instantaneous setpoint and
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specifies the 32 percent tolerance, as stated, i
a.2 The OP50 person who added the distance relay to the 51-256 procedure was in error by using the phase-to-phase torque angle of 75 degrees, as the required value, instead of the 105 l
degrees three-phase torque angle that is the indication actually seen by the person performing the test.
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The example, as stated, is not completely correct in that the I
torque angle is associated with the distance relay and not the i
primary overcurrent protective device.
4.3. The operating current for the target of the overcurrent relay being misstated is apparently a typographical problem since no reason for the error can be found.
The example, as stated, is not completely correct in that the current requirement stated for the relay target is for the overcurrent relay and not the distance relay, i
b.
The procedure inadeauacles in System Operating Instruction (50!)-30.6 were caused by changes made by a Field Change Request (FCR) 3055 on an esisting work package.
The changes affected the equipment in 50!-30.6, but the FCR was not 1
reviewed by Operations Section for potential Impact.
This has been identified as a programmatic problem.
c.
The Sequoyah plant personnel who developed the instrument maintenance surveillance program were neither Involved with the original review nor approval of the Westinghouse setpoint methodology (HSM).
The Instrument setpoints used were from i
the Hostinghouse protection setpoint and limitations document, i
and the test equipment specified in the procedures was field-type test equipment with the best tolerances available.
When the methodology was later transnitted to the site, the f
plant personnel were unfamillar with the analytical l
methodology involved and did not reallte it was a licensing document.
Because of this, no actions were taken to Incorporate it into the plant procedures.
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Corrective Steps Taken and Results Achievg l
a.l.51-256 has been canceled, and two new instructions written for units I and 2 (S!-256.1 and 51-256.2) are presently in tne
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review cycle.
The tolerance for the overcurrent instantaneous trip point has been changed from t5 percent to 12 percent.
which is consistent with our technical specifications.
The revision will be Plant Operations Review Committee (PCRC) l reviewed before the next required performance date of April 8, l
1986. Additionally, the TVA design engineers have performed calculations for the containment electrical penetration and 1
verifled that the previous use of a t5 percent tolerance has not challenged the penetrations integrity, these actions l
ensure that future performances will be made with the tolerance consistent with technical specifications, and no equipment that was previously calibrated using the 15 percent l
tolerance had a detrimental effect on plant safety-related equipment.
I a.2. The relay setting sheet for the distance relay has been vertfled to be correct.
The relay was only callbrated one time with the improper torque angle referenced in the S!-256 package.
The OP50 technicians performing the test used the values from the relay setting sheet; therefore, a proper callbration was performed.
The distance relay is not a l
technical specification required function; therefore, the OPSO supervisor presently is considering either removing it from 51-256.1 and SI-256,2 completely or correcting the ma:Imum torque angle specified to 105 degrees.
The OPSO supervisor i
will ensure one of the two corrective actions is complete before the nest performance of the S!$ on April 8, 1986.
The review has verlfled that the distance relay torque angle l
was properly set even thougn improperly stated in SI-256.
l Since the relay setting sheet for the dittance relay is correct, either of the two corrective actions discussed will i
' ensure future relay settings are performed correctly.
l a.3. The acceptance Criteria for the target of the overcurrent relay in new procedures51-256.1 and S!-256.2 is being changed j
from 1.0 and 2.0 amperes to.I and.2 amperes, this criteria l
l 15 consistent with a tap setting of.2.
This will be completed before the nent perfcrmance on April 8, 1986.
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b.
50!-30.6 was revised to correct the deficiencies.
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l revision was PORC reviewed on January 28. 1986.
This ensures proper doc'smentation of the items modified under FCR 3055.
c.
Sequoyah has contracted with Westinghouse to perform a new f
Sotpoint analysis using the measurement and test equipment (M&TE) tolerances actually used in the plant, the Initial calculations have Indicated that the as-used H&TE tolerance was acceptable and would provide adequate safety margins.
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work will be formall:ed before the unit restart.
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4 Corrective Steps Taken to Avold_ Fur _ther Violations a.l. Sequoyah's OP50 is performing a review of their SI program to ensure that all technical specifications covered are properly stated.
This review will be complete by December 31. 1986.
a.2. Sequoyah's OP50 will conduct formal training of its personnel a.3. In the requirements for acceptance criteria to be properly l
stated and complied with in surveillance instructions.
Additionally, a section Instruf tion letter ($!U 15 to be l
written to ensure long-term compliance.
The training will be complete and the SIL in place before June 30, 1986.
b.
The failure to implement changes in procedures due to changes made by FCR has been identifled as a programmatic problem.
i Changes have been made to the administrative procedure covering modifications to ensure that when FCRs are written on existing packages, they are reviewed for effects on plant j
Instructions, c.
The formal Westinghouse recalculation will be Complete, and any equipment" that could possibly require recalibration will i
be recalibrated prior to the restart of either unit.
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Instrument Maintenance Section supervisor will ensure that any procedures that could be affected by the recalculations will be revised before the nest performance, the Sequoyah Instrumentation engineering staff will be famillarized with l
the new setpoint methodology by June 30, 1986.
t Date When Full Compilance_ Hill Be Achieved A.
Full compilence will be achieved by April 8, 1986, when procedure changes are complete, b.
Full compliance was achieved on January 28, 1986.
c.
Full compilance will be achieved before either unit restart.
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Violation 50-327/85-46-05 and 50-328/85-46-05 TS 6.8.1 requires that written procedures be implemented covering safety-related activities stated in Appendia A of Regulatory Guide 1.33. Revision 2. which includes the use of surveillance and administrative procedures. Surveillance Instruction (SI) 256 Periodic 3
Calibration of Overcurrent Relays and Olstance Relays on 6.9 kV Reactor Coolant Pumps on 6.9 kV Unit Boards was established to controi testing of the primary and secondary overcurrent containment penetration protection devices required by TS 3/4.8.3. Administrative Instruction (AI) 4, Plant Instructions - Document Control, was established to provide controls for procedure changes, as required by TS 6.8.3.
Contrary to the above, these procedures were not implemented in that:
l a.
Initial and independent verification signoffs for conformance to i
51-256 Relay fest Record Sheet acceptance criterla were made when l
the recorded value was outside the procedure acceptance criteria.
l In addition, supervisory review of the surveillance package did not i
Identify these deficiencies, b.
Proper procedure change control requirements of A!-4 were not implemented for pen and ink changes made in the units of measure for Relay fest Record parameters of 51-256.
Supervisory review of the surveillance package did not identify these deficiencies.
This is a Severity Level IV Violation (Supplement I).
1.
Admission or 0 ental of Allejed Violation I
l TVA admits the violation occurred as stated.
2.
Reason for the Violation a.
OP50 technicians verify the target by requirements in the Field fest Manual or tne relay setting sheet.
From these documents, the technicians performing the test and the supervisor verified that the.2 amperes recorded were correct.
The incorrect acceptance criteria stated in SI-2$6 was not considered to affect the quality of the perfortrance; therefore, the package was approved.
The Quality Assurance (QA) reviewer was not famillar with the format of S!-256.
Additionally, a lack of attention to detall when making the review wa% also a factor, b.
OPSO technlcians were using routine relay test records and OP50 practices.
The violation was due to a lack of understanding of the requirements of Al-4 on changes to QA documents, l
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Corrective Steps Taken and Results Achie ed a.
The DPS0 supervisor has been made aware of the requirements of acceptance criteria In SI packages.
This should ensure he l
does not approve any SI p,nckages where the acceptance Criterla l
is not met.
b.
The CPSO technicians have been informed by their supervisor of the requirement for changing QA records.
Additionally, the routine relay test records are being revised to incorporate the required mechanism to select the proper tested function.
l Thi$ provides procedural control for the techniclans to l
perform the required tests within the QA guidelines of AI-4 l
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Corrective Steps Taken to Avold Further Violations i
a.
A OP50 SIL will be written with a checklist to be used when
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revising existing instructions or writing new ones. One item on the checklist will be to verify acceptance criteria is correct as stated.
Additionally, training of all Sequoyah OPSO personnel will be completed on proper use of acceptance criteria.
Both items will be complete by June 30, 1986.
QA will perform tratritng on the content and format l
requirements for S!s.
All QA personnel responsible for l
performing reviews of SI data packages will receive the l
training.
Training will De complete by March 10, 1986.
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b.
The Sequoyah OP50 Section will perform a formal training f
program on the requirements of A!-4 which will be complete by 1
June 30, 1986 Additionally, changing the routine relay test records will ensure no long-range QA problems entst in this i
- area, this should preclude any future violations.
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0.ite_Hhen Full Ocyp,llance Hil_1 Be Achieved a.
Full compliance was achieved on February 24, 1986.
b.
Full ccmpliance was achieved on February 24, 1986.
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ENCLO3URE 2 TVA commits to the following actions:
I 1.
By April 8, 1986 Implement SI-256.1 and 31-256.2 to a.
change tolerance on IAC66 instantaneous culpoint f rom t flV' I
l percent to i 2 percent.
b.
romove distance relay from procudure or correct the maxiruum torque angin to 10's degrees.
change targut acceptance criteria to.1 and.2 amperes ior ovwrcurrent
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protection.
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By June 30, 1986 conduct trainint, of Power System Operations (PEG) personnel
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on properly stating and cornplying with acceptance criteria in surveillance
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inotructions, and prepare a section instruction Intter for future guidance.
3.
By restart of units 1 and 2 recalibrate equipm*nt as required by results of, formal Westinghause (y) recalculatlunn of cutpoints using setual plant instrutnent accu acino.
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i Before nnxt performance, reviso procedures offucted by the above y l
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recalculations.
5.
By June 30, 1986, conduct training for the Instrument Maintenenen Engincoring staff on new setpoint methodology.
I 6.
By June 30, 1986, prepare a P30 auction instruction letter with a check 11at for pr*paration of procedures. This will includo guidanen on acceptance, criteria.
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By March 10, 1986, conduct training on content and format requirements of surveillance instivettoria (SI) for QA put monnel respotisible f or rov 1ww of 31 l
data packigns.
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By June 30, 1986, conduct training for puo ovetion on the requirements of f
1 Administrative Instruction A!-4, " Plant Instructions - Document control."
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By April 8, 1986, reviso P30 routine relay inst records in accordance with AI-4 I
10.
Before rustart of units 1 or 2, nubmit inf ormal Cortpliancu Staf f evaluations i
of measurnment und test equirrwnt accuraclet for PUNfl review.
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- 11. By Dwcanber 31, 1906, P30 will review their 31 program to unsurn that the i
technical specification requirernenta ern propurly stated.
12.
by Junn 1, 198fi, provkdo a supple.montal responso with the results of TVA's investigation into altertiato fnethods of fulfillitig the responisth111tles of
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