ML20198M787
| ML20198M787 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 10/21/1997 |
| From: | Bajestani M TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-327-97-08, 50-327-97-8, 50-328-97-08, 50-328-97-8, NUDOCS 9710290124 | |
| Download: ML20198M787 (6) | |
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Tennessee Valley Authority, Post Offce Box 2000, Soddy Dasy, Tennessee 37379-2000 Masoud Bajestad Site Vco Presdent Sequoyah Nuckw Plant October 21,'1997 U.S. Nuclear Regulatory-Commission 10 CFR 2.201 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 INTEGRATED INSPECTION REPORT NOS. 50-327/97-08 AND 50-328/97 REPLY TO NOTICE OF VIOLATION (NOV)
This letter provides TVA's reply to NOV 50-327/97-08-02 documented in the subject inspection report dated September 22, 1997.
The NOV identified one Severity Level IV Violation.
The violation is the failure to repair, replace, or analyze the data for a containment isolation valve prior to declaring the valve operable when it failed to exhibit the required change of obturator position.
The enclosure contains our response to the NOV.
There are no commitments contained in this submittal.
I would also like to convey to you my concern with the recent problems that have occurred in the ASME Section XI arena.
Several actions are underway to alleviate recurrence of these types of problems.
Software is being developed to improve our tracking and trending capabilities of ASME Section XI valve test results.
Our procedures-are undergoing a peer review to gain their insights into possible improvements.
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Additionally, training is being instituted to assist jhb Operations personnel in the performance of Section XI testing duties.
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- U.S.-Nuclear-Regulatory Commission:
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- Page!2 October 21, 1997;
?If.you-have-questions /regarding_this: response,-please contact
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me at - (423)~ 843-7001 -or Pedro Salas at'.(423). 843-7170.
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- Sincerely, V
- Masoud-
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Encio ures cc (Enclosures):
Mr.
R. W. Hernan, Project Manager
-NuclearcRegulatory Commission-One White _ Flint,= North-11555 Rockville~ Pike:
Rockvi lle,-- Maryland - 20852-27 3 9 -
NRC: Resident Inspector Sequoyah Nuclear' Plant
.2600.:Igou Ferry-Road Soddy-Daisy, Tennessee _ 37379-3624 Regional-Administrator;
=U.S.-Nuclear Regulatory Commission iRegion II-Atlanta-Federal' Center-61 For'syth _ Street, -- SW, -- Suite.23T8 5 ;.
Atlanta, Georgia 30303-3415 l
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ENCLOSURE 5
-TENNESSEE VALLEY AUTHORITY-SEQUOYAH NUCLEAR PLANT (SQN)
UNITS 1 AND 2 INSPECTION REPORT NUMBERS 50-327, 50-328/97-08 REPLY TO NOTICE OF VIOLATION (NOV)
I.
RESTATEMENT OF VIOLATION
" Technical Specification 4.0.5, Inservice Testing Program, requires that inservice testing of ASME Code Class 1, 2, and 3 pumps and valves shall be in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50.55a.
10 CFR 50.55a, Codes and Standardt, Section (f), Inservice Testing Requirements, paragraph 411 requires that-inservice testing conducted during the 120 month interval must comply with the requirements in the latest edition and addenda of the Code incorporated by 10 CFR 50.55a section-(b),
applicable within 12 months prior to the start of the 120 month interval.
10 CFR 50.55a, Section (b) references OMa-1988 Addenda to the OM-1987 Edition which is the applicable edition and addenda to the code.
ASME/ ANSI OMa-1988 Addenda to ASME/ ANSI OM-1987, Operation and Maintenance of Nuclear Power Plants, Part 10, Section 4.2.1.9, Corrective Action, Part (a) states, in part, 'If a y
valve fails to exhibit the required change of obturator position...the valve shall be immediately declared inoperable.'
Part (c) states, ' Valves declared inoperable may be repaired, replaced, or the data may be analyzed to determine the cause of the deviation and the valve shown to be operating acceptably.'
Contrary to the above, on July 14, 1997, containment isolation valve 1-FCV-31C-229 failed to exhibit the required change of obturator position (during three stroke attempts) and it was not repaired, replaced, nor was the data analyzed prior to declaring the valve operable.
This is a Severity Level IV Violation."
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TVA's REPLY. TO 'THE VIOLATION v
1.
Reason For'The Violation The cause of the violation was the failure of the main control room (MCR) staff to properly follow the procedure.
Procedural guidance was in place which directed that the valve be retested following correceive action.
However, corrective action consisting-of repair, replacement, or evaluation was not. performed before returning the valve to operable status.
During_the performance of ASME Section XI, stroke-time testing,_the valve failed to achieve the full-closed position on the first stroke.
Operators declared the valve' inoperable and entered the LCO.
The valve was stroked two additional times in accordance with the
-procedure.
The valve was stroked.a fourth time to investigate the operability of the postaccident monitocing status lights.
The valve _was not timed during the fourth stroke, but'it_ appeared to work properly.
The Operator stroked the valve three
-additional times (the fifth, sixth, and seventh strokes), and it operated properly within the required timeframe.
Operations declared the valve operable.and exited the LCO.
A contributing factor was that the Unit Supervisor was previously involved with a valve that failed to meet its stroke' time and was then declared operable after it
-was stroked successfully three times.
The' Operator was not aware that an evaluation had been performed by Engineering _and believed that the additional successful strokes were the basis for declaring the valve operable.
The operating crew did not understand the intent of the ASME Section XI valve stroke testing procedures.
Additionally, TVA has identified human factor
. improvements that could be made to ASME Section XI Testing procedures during the investigation.of this event.
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2.
Corrective Steps Taken And Results Achieved The Unit Supervisor for the oncoming shift called the Section XI Engineer to discuss the operation of the valve and discovered that the engineer considered the 1
valve inoperable.
The necessary actions were immediately performed to comply with Technical Specifications.
These actions were complete within four hours from the time the valve was initially i
declared inoperable as required by the LCO Action Statement.
3.
Corrective Steps That (Have Been Or) Will Be Taken To Prevent Recurrence The appropriate disciplinary action was taken for the personnel involved in this event.
i The procedure has been enhanced by revising the flowchart and adding steps to perform the two additional strokes to m&ke it consistent with the valve data sheet procedure.
As an additional enhancement, operations management issued a briefing sheet to Shift Managers (SMs) with the details of this event.
The SMs held discussions with licensed operators regarding lessons learned and the purpose, intent, and methodology for demonstrating the operability of valves in accordance with ASME Section XI.
A training session will be performed as part of License Operator Requalification Training.
This training will discuss lessons learned and the purpose, intent, and methodology for demonstrating the operability of pumps and valves in accordance with ASME Section XI.
The training will also discuss the root causes and errors made in this event.1 In order to improve their ease of use, Operations personnel will review the Section XI valve stroke test implementing procedures to develop recommendations for revision.
Engineering will review the recommendations and will revise the procedures to incorporate human factor enhancements realized from the Operations review.1 TVA does not consider this action a regulatory commitment. TVA's corrective action program will track completion of the action.
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- - e Additionally, TVA:will enhance the stroke-time Lprocedures_to give more detailed guidance 1to7 check for-proper operation of the postaccident monitoring status t
panel lights when applicable.
Enhancements will also ensure-detailed' guidance for. valves with stroke times outside-the acceptable range is included in stroke-time procedures.1
. 4.
.Date When Full Compliance Will Be Achieved
.With respect lto the cited violation,-TVA is in full compliance ~.
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1 TVA does not consider this action a regolatory commitment.
TVA' s corrective -action program will track cornpletion of the action.
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