ML20197A998

Revises Response to NRC Re Violation Noted in Insp Repts 50-327/85-46 & 50-328/85-46.Corrective Actions: Testing Contained in SI-256 & Acceptance Criteria for Target of Overcurrent Relay Changed to 0.1 & 0.2 Amperes

ML20197A998
Person / Time
Site:	Sequoyah
Issue date:	04/21/1986
From:	Gridley R TENNESSEE VALLEY AUTHORITY
To:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
NUDOCS 8605120436
Download: ML20197A998 (5)

Text

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4 g TENNESSEE VALLEY AUTHORITY SN 157B Lookout Place o,,

April 21, 1986 " ~ O7 I*!0 , 3 4 U.S. Nuclear Regulatory Conunission Region II ATTN: Dr. J. Nelson Grace, Regional Administrator 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 50-327/85-46 AND 50-328/85 REVISED RESPONSE TO VIOLATION Enclosed is our revised response to J. A. Olshinski's January 29, 1986, letter to S. A. White transmitting IE Inspection Report Nos. 50-327/85-46 and 50-328/85-46 for our Sequoyah Nuclear Plant which cited TVA with three Severity Level IV Violations. A recently issued technical specification change has altered the instruction numbers contained in my February 28, 1986 response. We have identified changes with a bar in the right margin.

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, TE ESSEE Vit. LEY AUTHORITY

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R.

. Gridle , Director Nuclear Saf y and Licensing l Enclosure cc: Mr. James Taylor, Director (Enclosure)

Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C. 20555 l

8605120436 860421 PDR ADOCK 05000327 G PDR An Equal Opportunity Employer / g J

RESPONSE - NRC-0IE INSPECTION REPORT NOS. 50-327/85-46 AND 50-328/85-46 JOHN A. OLSHINSKI'S LETTER TO STEVEN A. WilITE DATED JANUARY 29, 1986 Violation 50-327/85-46-04 and 50-328/85-46-04 Technical Specification (TS) 6.8.1 requires that adequata 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 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.

a. SI-256, Periodic Calibration of Overcurrent Relays and Distance Relays on 6.9 kV Reactor Coolant Pumps on 6.9 kV Unit Boards, contains the following inadequate acceptance criteria:

1. For primary overcurrent protective devices, the procedure esta-blishes a trip setpoint amperage tolerance value of 15%. TS Table 3.8-1 for both units requires a 12% tolerance.

2. For primary overcurrent protective devices, the procedure esta-blishes 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 IAC 66K relays requires proper operation between 0.1 and 2.0 amperes,

b. Procedure SOI 30.6,' Auxiliary 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 011-99, Reactor Protection System

• Calibration and Functional Testing, prescribed use of inadequate measuring and test equipment. The measuring and test equipment pre- -

scribed was only 2 to 2.5 times more accurate than the measured para-meter when the setpoint methodology used to determine reactor protec-tion setpoints assumed the equipment was ten times more accurate than the measured parameter.

This is a Severity Level IV Violation (Supplement I).

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

2. Reason for the Violation a.1. Division of Power System Operations (DPS0) personnel used their Field Test >bnual and relay setting sheets for developing the criteria in Surveillance Instruction (SI)-256 for the over-current protective device. The Field Test >bnual, Section K3 specifies a +5 percent tolerance on these type devices.

The example, as stated, is not completely correct in that the TS table 3.8-1 is different for units 1 and 2. Unit I references the critical pickup setpoint and does not specify a tolerance.

Unit 2 references the instantaneous setpoint and specifies the 12 percent tolerance, as stated, a.2. The DPS0 person who added the distance relay to the SI-256 procedure was in error by using the phase-to phase torque angle of 75 degrees, as the required value, instead of the 105 degrees three-phase torque angle that is the indication actually seen by the person performing the test.

The example, as stated, is not completely correct in that the torque angle is associated with the distance relay and not the primary overcurrent protective device.

a.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,

b. The procedure inadequacies in System Operating Instruction (SOI)-30.6 were caused by changes made by a Field Change Request (FCR) 3055 on an existing work package. The changes affected the equipment in 501-30.6, but the FCR was not reviewed by Operations Section for potential impact. This has been identified as a programmatic problem.

c. The Sequoyah plant personnel who developed the instrument main- ,

tenance surveillance program were neither involved with the original review nor approval of the Westinghouse setpoint method-ology (WSSI). The instrument setpoints used were from the Westinghouse protection sdepoint and limitations document, and the test equipment specified in the procedures was field-type test equipment with the best tolerances available. When the methodology was later transmitted to the site, the plant personnel were unfamiliar with the analytical methodology involved and did not realize it was a licensing document. Because of this, no actions were taken to incorporate it into the plant procedures.

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3. Corrective Steps Taken and Results Achieved

^a.1- Technical specification changes, Revision 46 and Revision 34 for units 1 and 2 respectively, reference SI-256 to fulfill surveillance requirement 4.8.3.1.a.l.a; therefore, SI-256.1 and SI-256.2 will not be used. The testing for both units will be contained in SI-256. Additionally, the instantaneous setpoint of i2 percent, referenced in the violation, has been removed from the technical specifications. Engineering Design has verified that the 15 percent originally used in SI-256 is consistent with respect to the electrical calculations and the manufacturers' specifications; therefore, 5 percent will be used. The changes to SI-256 were completed and reviewed by the Plant Operations Review Committee by April 8, 1986.

a.2 The relay setting sheet for the distance relay has been verified to be correct. The relay was only calibrated one time with the improper torque angle referenced in the SI-256 package. The DPSO technicians performing the test used the values from the relay setting sheet; therefore, a proper calibration was performed. The distance relay is not a technical specification required function or a required design feature for the penetration protection. The DPSO supervisor ensured the distance relay was removed from SI-256 before the next performance of the sis (by April 8, 1986).

The review has verified that the distance relay torque angle was properly set even though improperly stated in SI-256. Since the relay setting sheet for the distance relay is correct even though the relay is removed from SI-256, this will ensure future relay settings are performed correctly.

a.3 The acceptance criteria for the target of the overcurrent relay in

{ SI-256 has been changed from 1.0 and 2.0 amperes to .1 and .2 j

amperes. This criteria is consistent with a tap setting of .2.

This was completed by April 8,1986 7

b. SOI-30.6 was revised to correct the deficiences. The revision was

PORC reviewed on-January 28, 1986. This ensures proper documentation of the items modified under FCR 3055.

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c. Sequoyah has contracted with Westinghouse to perfonn a new setpoint analysis using the measurement and test equipment (M&TE) tolerances I

actually used in the plant. The initial calculations have indicated that the as-used M&TE tolerance was acceptable and would provide adequate safety margins. All work will be formalized prior

( to unit restart.

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4. Corrective Steps Taken to Avoid Further Violations a.1 Sequoyah's DPSO is performing a review of their SI program to ensure that all technical specifications covered are properly stated. This review was completed by December 31, 1986, a.2 Sequoyah's DpSO will conduct formal training of its personnel in a.3 the requirements for acceptance criteria to be properly stated and complied with in surveillance instructions. Additionally, a section instruction letter (SIL) is to be written to ensure long-term compliance. The training will be completed and the SIL in place prior to June 30, 1986.

b. The failure to implement changes in procedures due to changes made by FCR has been identified as a programmatic problem. Changes have been made to the administrative proceduro covering modifications to ensure that when FCRs are written on existing packages, they are reviewed for effects on plant instructions.

c.

The formal Westinghouse recalculation will be complete, and any equipment that could possibly require recalibration will be recalibrated prior to restart of either unit. The Instrument Maintenance Section supervisor will ensure that any procedures that could be affected by the reccalculations will be revised prior to the next performance. The Sequoyah instrumentation engineering staff will be familiarized with the new setpoint methodology by June 30, 1986.

5. Date When Full Compliance Will Be Achieved

a. Full compliance was achieved by April 8, 1986, when procedure changes were completed,

b. Full compliance was achieved on January 28, 1986.

c. Full compliance will be achieved prior to either unit restart.

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