ML20198S008

Responds to NRC Re Violations Noted in Insp Repts 50-327/86-20 & 50-328/86-20.Corrective Actions:Initial Testing of Manual Reactor Trip Function of Safety Injection Hand Switches Completed

ML20198S008
Person / Time
Site:	Sequoyah
Issue date:	05/23/1986
From:	Shell R TENNESSEE VALLEY AUTHORITY
To:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
NUDOCS 8606100284
Download: ML20198S008 (6)

Text

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.e hN TENNESSEE VALLEY AUTHORITY CH ATTA,NpOGA. TENNESSEE 374ol n* I

, .a4 .SN l57B Lookout Place

. . . .\ .3 May 23, 1986 U.S. Nuclear Regulatory Commission 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-0IE REGION II INSPECTION REPORT 50-327/86-20 AND 50-328/86 RESPONSE TO VIOLATIONS Enclosed is our response to J. A. Olshinski's April 23, 1986 letter to S. A. White which transmitted IE Inspection Report Nos. 50-327/86-20 and 50-328/86-20 for our Sequoyah Nuclear Plant which cited TVA with two Severity Level IV Violations and one Severity Level V violation. Enclosure 1 is our response to the subject violations.

2. We do not recognize any other actions Our comitments are listed in enclosure

' described herein or the subject inspection report as commitments.

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 I

R. H. Shell, Supervisor Licensing Project II Enclosures cc: Mr. James Taylor, Director (Enclosures)

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

t 8606100284 860523 PDR ADOCK 05000327 G PDR l

An Equal Opportunity Employer O p l

v ENCLOSURE 1 RESPONSE - NRC-OIE INSPECTION REPORT NOS. 50-327/86-20 AND 50-328/86-20 JOHN A. OLSHINSKI'S LETTER TO S. A. WHITE DATED APRIL 23, 1986 Violation 50-327/86-20-04 and 50-328/86-20-04 Technical Specification (TS) 6.8.1.c requires that written procedures be established and implemented for surveillance of safety related equipment.

Contrary to the above, a written procedure was not established for surveillance requirement of TS 4.3.1.1.1, Table 4.3-1, item 19, note (4),

which requires a manual engineered safety feature (ESP) functional input check of the reactor trip system every 18 months. This involved one missed relay on each of two multicontact switches. As such a functional check of these relays was not conducted.

This is a Severity Level IV violation (Supplement I). (Both units)

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

2. Reason for the Violation The event uccurred due to personnel error in that the testing requirements were overlooked during the preparation of the surveillance instructions.

3. Corrective Steps Taken and Results Achieved The initial testing of the manual reactor trip function of the safety injection hand switches was completed on April 30, 1986. This initial test identified additional testing which needed to be performed to verify proper overlap of cabling between the rod control cabinet and the main control room. This additional testing will be completed by June 30, 1986. Sequoyah Nuclear Plant (SQN) has reported this event to NRC in Licensee Event Report (LER) 1-86007.

4. Corrective Steps Taken to Avoid Further Violations The test requirements for the reactor trip function of the safety injection hand switches will 'be added to surveillance Instruction (SI)-26 to ensure compliance with the surveillance requirement (SR) for all future performances. This will be completed before the next scheduled performance date, October 1987, as identified in LER 1-86007.

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In'~addiEl~on~ thi~ plast inaWager has assigned a special subcommittee to evaluate all TS SRs. The subcommittee will identify each requirement E

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5. Date When Full Compilance Will Be Achieved The plant will be in full compliance on June 30, 1986, when the additional safety injection hand switch testing is completed. In addition, as stated in section 4, SI-26 will be revised before the next scheduled performance date in October 1987. The special TS subcommittee will complete their review by restart of either unit.

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b Violation 50-327/86-20-08 Technical Specification 4.6.1.1.a requires verifying the proper positioning of all containment isolation valves, with the exception of energized automatic isolation valves, while operating in mode 4 or above. This verification is required at least every 31 days and prior to heat up to mode 4 from mode 5 for each cold shutdown.

Contrary to the above, in Unit 1, 20 vent, drain and test Containment Isolation valves were not verified to be in the proper position when SI-14, Verification of Containment Integrity - Unit 1, was performed on May 20, 1985 prior to heat up to mode 4 and while in mode 4 on May 17, 1985; June 3, 6, 19 and 27, 1985; and July 25, 1985. This involved Containment Isolation Valves62-707, 70-735,70-737, 70-678B, 70-691B, 70-702B,C,E & F,70-703, 70-760,70-762, 70-763, 72-546, 72-554, 72-543, 72-545, 78-226A, 78-228A and 87-523.

This is a Severity Level IV violation (Supplement I). (Unit 1 only)

1. Admission or Denial of Alleged Violation TVA admits the violation occurred as stated. However, the following valves should not be included in the violation for the reasons stated:

a.70-703 (This is a relief valve).

b. 72-546 and 72-554 (Locked closed valves and checked by SI-186),

c.78-226 and 78-228A (Lochd closed valves and checked by SI-14).

2. Reason for Violation The violation occurred due to TVA interpreting TS 4.6.1.1.a differently than NRC.

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3. Corrective Steps Taken and Results Achieved A complete review including a physical walkdown of containment penetrations and associated piping is being perforned by the Operations Section. Upon completion of the review, SI-14 will be revised as necessary.

4. Corrective Steps Taken to Avoid Further Violations i

The actions identified in section 3 above should prevent further violations.

5. Date When Full Compliance Will Be Achieve'd The review of containment penetrations and revision to SI-14 will be completed before startup.

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1 Violation 50-327/86-20-10 and 50-328/86-20-10 4 Technical Specification 6.5.1.2 requites that the Plant Operations Review Committee (PORC) be composed of the Chairman, and six other members. TS 6.5.1.3 states that no more than two alternates shall participate as voting members in PORC activities at one time. TS 6.5.1.5 states that the minimum quorum of the PORC necessary for the performance of the PORC responsibility and authority ... shall consist of the chairman or his designated alternate and four members including alternates.

Contrary to the above, the Sequoyah procedure implementing the above requirements, SQA21, provided for a PORC composition of the Chairman and eight members. The two " extra members," beyond the TS required composition, could legally function as alternates, but were recognized by the licensee as members. The two " extra members" resulted in the quorum requirements being violated with respect to PORC members present during Meetings 3351, 3364, 3367, 3378, 3381, 3389 in May 1985. The persons serving as the " extra members" do meet ANSI N18.1 qualifications.

This is a Severity Level V violation (Supplement I). (Both units)

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

2. Reason for Violation The violation occurred as a result of changes in the plant organization.

A TS change was submitted in October 1984 to add the new plant organization chart and to establish the new supervisory positions as PORC members. The new members meet ANSI N18.1-1971 qualifications as noted in the notice of violation. The SQN Standard Practice SQA21 was revised to add the new PORC members as specified in the TS amendment request and to agree with the new organizational structure. This resulted in SQA21 being in conflict with the current requirements of TS 6.5.1.2 and 6.5.1.5.

3. Corrective Steps Taken and Results Achieved SQN SQA21 was revised to remove the new positions and to return the composition of PORC to the requirements as stated in TS 6.5.1.2. A quorum of qualified individuals was present at all meetings, and no further action is needed.

4. Corrective Steps Taken to Avoid Further Violations SQA21 will not be revised to change the PORC composition until the TS change is approved by NRC.

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5. Date.When Full Compliance Will Be Achieved The plant was in full compliance on March 14, 1986, when SQA21 was revised to agree with the TS.

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ao s Et! CLOSURE 2 C0!!MITMENTS

1. By June 30, 1986 sie will test the manual reactor trip function of the safety injection hand switches to verify proper overlap of cabling between the rod control cabinet and the main control room.

2. By October 1987 SI-26 vill be revised to include the additional testing of the reactor trip system as discussed in enclosure 1. NOTE: This commitment was established in the OQN LER 1-86007.

3. By restart the Technical Specification Requirement Subcommittee will identify each surveillance.requirewent. and verify that plant procedures properly ensure that the int.ent of each requhement is met.

4. By restart SI-14 will' be revised based on a complete review, including a physics 1 walkdown,' of containment penetrations and associated piping.

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