ML20203M761
| ML20203M761 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 08/19/1986 |
| From: | Domer J TENNESSEE VALLEY AUTHORITY |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8609040268 | |
| Download: ML20203M761 (9) | |
Text
vC.T) r TENNESSEE VALLEY AUTHORITY CHATTANOOGA TENNESSEE 37401 gg gato @ 3 SN 1578 Lookout Place Nuo19s86 U.S. Nuclear Regulatory Commission Region II ATTN: Dr. J. Nelson Grace, Regional Administrator
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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 50-327/86-19 AND 50-328/86 RESPONSE TO VIOLATIONS Enclosed is our response to J. A. 01shinski's M&y 13, 1986 letter to S. A. White which transmitted IE Inspection Report Nos. 50-327/86-19 and 50-328/86-19 for our Sequoyah Nuclear Plant which cited TVA with two Severity Level IV Violations and one Severity Level V Violation. is our response to the subject violations and our commitments are listed in enclosure 2.
We do not recognize any other actions described herein or the subject inspection report as commitments.
An extension of the response date to August 19, 1986 was discussed.between G. Zech and R. Gridley on August 1, 1986.
If you have any questions, please get in touch with G. B. Kirk at 615/870-6549.
To the best of my knowledge, I declare the statements contained herein are complete and true.
Very truly yours, TENNESSEE VALLEY AUTHORITY
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J. A. Domer, Assistant Director Nuclear Safety and Licensing Enclosures cc (Enclosures):
Mr. James Taylor, Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Coinmission Washington, D.C. 20555 8609040268 860819 PDR ADOCK 05000327 G
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T'd Of An Equal Opportunity Employer
ENCLOSURE 1 RESPONSE - NRC-0IE INSPECTION REPORT NOS. 50-327/86-19 and 50-328/86-19 m
JOHN A OLSHINSKI'S LETTER TO S.
A'.
WHITE DATED MAY 13, 1986 Violation 50-327/86-19-06 and 50-328/86-19-06 10 CFR 50 Appendix B, Criterion V, requires that activities affecting quality be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and that these activities be accomplished in accordance with these instructions, procedures or drawings.
Contrary to the above, the licensee failed to accomplish activities affecting quality in accordance with established procedures for the examples discussed be' low.
a.
System Operating Instruction S01-82.3 contains a power availability checklist (82.3-J), utilized to confirm operability of electrical components for the 2A-A emergency diesel generator.
The power availability checklist specifies that 1 ampere fuses are to be installed for the emergency diesel generator'AC auxiliary lube oil pumps.
During a walkdown of the 2A-A emergency diesel generator, the inspector determined thac 10-ampere fuses were installed for the AC auxiliary tube oil pumps.
b.
AI-19, Part IV, Office of Nuclear Power Administrative Instruction -
Plant Modifications Af ter Licensing, and EP 4.06, Office of Engineering Instruction - Field Change Requests Initiated by NUC PR, require determination of FCR category based on an Unresolved Safety Question Determination (USQD) evaluation prior to-FCR approval.
Engineering Change Notice (ECN) 6023 was written to relocate the hydrogen analyzer panels to meet environmental qualifications requirements.
Field Change Request (FCR) 2468 was written by the site cognizant engineer to exchange a non-essential reagent air supply for the originally designed essential air supply.
The site cognizant engineer,'the Office of Engineering (OE) review l
engineer and the engineer who performed the OE independent check i
failed to comply with AI-19 and EP 4.06 in that the USQD was not reviewed prior to the erroneous determination that FCR 2468 met the requirements of the ECN 6032 USQD.
l c.
EP 3.10, Office of Engineering Instruction - Design Verification Methods and Performance of Design Verification,. requires review of design drawings by experienced design engineers and independent review of design changes.
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, Reviews conducted by the OE review and independent checker engineers were not conducted in accordance with EP 3.10 in that the OE review engineer and OE independent checker engineer did not review pertinent design drawings for modifications to the hydrogen analyzers.
In addition, the independent checker engineer did not perform an independent review but instead based his decision on a conversation with the OE review engineer.
d.
EP 3.10, Office of Engineering Instruction - Design Verification Methods and Performance of Design Verification, requires that measures be applied to assure the adequacy of design documents.
T..e procedure states that a minimum of one established, identifiable verification method will be used to assure design adequacy and the suitable documentation will be provided to show the method used, by whom, and when the verification was made.
EP 3.10 further requires the form of verification to be auditable.-
The OE review engineer and the OE independent checker engineer did not establish an auditable record to validate that the required review took place.
e.
Technical Specification (TS) 6.5.1.6 requires the PORC to be responsible for review of all proposed changes or modifications to unit systems of equipment that affect nuclear safety. Administrative Instruction AI-19, Part IV implements this requirement. AI-19 requires the PORC to review and verify USQD special requirements to ensure that the workplan implements them as necessary.
Although a review was conducted by PORC as required by TS 6.5.1.6, Al-19 was not implemented in that the PORC failed to perform an adequate review of USQD requirements for a design change to the hydrogen analyzers.
This is a Severity Level IV violation (Supplement I).
This violation applies to both units.
1.
Admission or Denial
/ the Alleged Violation TVA admits the violation occurred as stated.
2.
Reason for the Violation The root cause of the violation has been identified as a personnel
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error in that each case cited above involved personnel falling to follow procedures established to accomplish activities affecting quality.
Personnel performed actions which were perceived to be correct before initiat. ion and were not a result of intentional errors.
Additionally, the reagent air supply to the hydrogen analyzer was not included in the list of required loads for the design criteria for the essential air system which resulted in a misinterpretation by the DNE engineer.
3.
Corrective Steps Taken and Results Achieved When the assistant unit operator (AU0) determined that the fuse size for the emergency diesel generator AC auxiliary lube oil pump was incorrect in that it did not agree with the system operating instruction (SOI), work was stopped and the unit senior reactor operator (SRO) was consulted for resolution to the problem.
The SRO.
verified the correct fuse size to be 1 ampere by the as-constructed drawing which was consistent with the SOI.
Subsequently, the SR0 replaced the incorrect fuse with the fuse of the correct size.
Licensea Event Report 50-328/85012 was submitted on January 8, 1986 addressing the improper installation of reagen: air to the hydrogen analyzers.
The reagent air for Unit 2 A train hydrogen analyzer was modified to return its air supply source to the essential air system.
4.
Corrective Steps Taken to Avoid Further Violations Sequoyah Nuclear Plant (SON) has implemented a fuse verification program for IE systems to verify that the proper fuse is called for on the drawings, included in the procedures, and is installed in the field. This effort will be completed before startup of the respective units.
It has been common practice, as provided for in the applicaole project procedures, for field personnel to contact the cognizant Division of Nuclear Engineering (DNE) engineers, to discuss urgently needed changes and to obtain verbal approval to proceed.
This was eventually followed up with formal written documentation.
The process of informal verbal approval has been discontinued as of April 4, 1986.
Presently, field personnel requiring DNE approval of changes must prepare a written request for the changes using the.
appropriate format and transmit it to DNE for written approval. When appropriate DNE personnel are located onsite and expedited approval is needed, the originator discusses it with the cognizant DNE engineer in person and obtains his written approval. When
. appropriate DNE personnel are not located onsite and expedited approval is needed, the originator transmits the written request electronically and discusses it by telephone.
If the cognizant CNE engineer, after reviewing the change, approves it, he signs a copy of the FCR and transmits it electronically to the site for use.
This action was delineated.to DNE personnel in a memorandum from H: C. Drotleff, Director of Nuclear Engineering, dated April 4, 1986.
TVA has committed to identify modification criteria for all modifications after January 15, 1986 to establish a design basis foJ each plant modification.
This will result in a more detailed g
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This new requirement was a result of an assessinent of the design control program for SQN by Gilbert / Commonwealth in October 1985.
5.
Date When Full Compilance Will Be Achieved Full compliance will be achieved before the restart of each respective unit.
Violation 50-328/86-19-12 TS 3.6.4.1 Limiting'Condi tion for Operation (LCO) requires that two independent hydrogen monitors be operable in Modes 1 and 2.
The action statement states that with one hydrogen monitor inoperable the inoperable monitor must be restored to operable status within 3C days or the unit must be placed in at least HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. With two hydrogen anal'yzers inoperable, the requirements of TS 3.0.3 apply.
TS 3.0.3 requires that action be initiated to place the unit in a mode in which the Specification does not apply if the applicable LCO and action statement cannot be met.
Contrary to the above, Unit 2 was operated from approximately December 26, 1984, to August 21, 1985, in a mode that required both hydrogen analyzer trains (also referred to as hydrogen monitors) to bes operable in accordance with TS 3.6.4.1.
During this period, the A train hydrogen analyzer did not have a seismically qualified air supply and therefore was not operable.
In addition, there were three one week periods and one three day period during this time in which the B train hydrogen analyzer on Unit 2 was out of service and therefore TS 3.0.3 applied.
This is a Severity Level IV violation (Supplement I).
This violation applies to Unit 2 only.
TVA Response It appears that this violation is a result of 50-327, -328/86-19-06; however, the violation is written such that it is unclear as to what was violated.
Sequoyah requests NRC to further clarify this violation to ensure an adequate response is provided.
The following is a statement of the event and our policy in ensuring compliance with the technical specification is maintained.
Duri.1g the unit 2, cycle 2 refueling outage, a modification was performed on the hydrogen analyzer system in accordance with Engineering Change Notice (ECN) 6032 to move the test gas bottles and control outside the unit 2 Containment /Shleid Building annulus.
Part of the modification caused the A train hydrogen analyzer to have its reagent air supply changed from an essential air source to a nonessehtial air source.- The monitor was inoperable under this condition; however, the error in supplying the nonessential air source to the hydrogen analyzers was not, l
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. discovered until after the unit was shutdown on August 21, 1985.
Based on the fact that the error was not known, entry into the action statement for LCO 3.6.4.1 or 3'.0.3 could not be made.
It is obvious that until an event occurs and is identified, compliance with an action statement cannot be made. Operations personnel evaluate occurrences at the plant for technical specification compliance, and this type of evaluation is a part of their training.
Additionally, Operations personnel cannot evaluate a condition they are not aware exists.
It should be noted that this inoperability was caused by errore in the design and installation process (Violation 50-327, 328/86-i>-06) and the technical specification sis are not intended or designed to detect this type of error.
When an event or problem is identified, Sequoyah Nuclear Plant (SQN)
Operations personnel will continue to perform an evaluation to determine if the event requires compliance with a LCO action statement.
This is consistent with the policy which has always been in place at SQN.
Violation 50-327/86-19-01 and 50-328/86-19-01 TS 6.8.1 requires that written procedures be established, implemented, and maintained covering safety-related activities referenced in Appendix A of Regulatory Guide 1.33, Rev. 2, February 1978.
System Operating Instructions (SOIs) 30.6, 65.1, 65.2 and 87.1 were established by the licensee to implerent the requirements for control of startup of safety-related equipment.
i Contrary to the above, procedures were not adequately established in that valves in the air supply to all air operated dampers in the auxiliary building gas treatment system and emergency gas treatment system were not included in the valve checklists for system operability in 501-30.6 and 501-65.1 and -65.2, respectively.
Isolation of these valves could result in loss of the capability to automatically open dampers required for system operability.
In addition, hydraulic lock release valves which must be.open to a throttled position to assure the closure of the UHI isolation valves on low UHI water accumulator level were not locked in position or verified to be in the correct position during system operability walkdowns conducted under S0I-87.1 This is a Severity Level V violation (Supplement I).
This violation applies to both units.
1.
Admission or Denial of the Alleged Violation TVA admits the portion of the violation concerning air _ operated valves in the Auxiliary Building Gas Treatment System (ABGTS) and Emergency Gas Treatmen.t System (EGTS) occurred as stated.
- However, TVA denies the portion of the violation concerning hydraulic lock release valves.'
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Reason for the Violation (Air Operated Valves)
The violation occurred due to the following reasons.
SQN Operations
. personnel had already begun taking action to correct the identified problem approximately two years ago.
During this two year period, two instructions were revised and others were in the process of revision.
The untimeliness of this corrective action resulted in an Unresolved Item (URI) being issued in October 1985 Additional corrective actions were then taken and six more instructions were revised before February 1986.
3.
Corrective Steps Taken and Results Achieved The need to ensure that an air supply to equipment is properly aligned had been identified in October 1985 by the SQN NRC Residents as a URI, and Operations personnel were in the process of revising the SOI's to add a note to the valve checklist which states:
For a pneumatically operated FCV to be ' aligned aad/or operable' it must have control air properly lined ur to its controller, air regulator, positioner and or,erator.
It must appear properly assembled and have no pnysical barriers or obstructions to its operation.
Two instructions had been revised before October 1985 (non-CSSC systems) and six were revised before February 18, 1936.
The revised instructions included those identified in this violation during the inspection period March 6 through April 5,1986.
There are approximately nine additional instructions requiring revision.
This will be completed before startup of unit 2.
4.
Corrective Steps Taken to Avoid Further Violations Completion of the revisions in section 3 above will prevent further violations in this area.
5.
Date When Full Compliance Hill Be Achieved Full compilance will be achieved before startup of unit 2.
6.
Reason for Denial (Hydraulic Lock Release Valves)
The hydraulic lock release valves on the UHI system are 'Jsed by Maintenance for adjustment of the UHI valve closing times on low accumulator level.
It is not considered appropriate to include these valves in an SOI checklist since the correct position of the throttle,
valve can only be set manually by instrument mechanics during an SI performance.
There are no requirements either in engineering drawings or vend'or procedures which state that the hydraulic lock
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g release valves should be locked.
These valves are located in a vital area controlled by a card reader system so that only authorized personnel may enter the rooms.
Periodically, the valves are verified to be in the correct position when the UHI isolation valve response time tests are performed.
Further, the valve position may require changing by maintenance personnel from SI to SI performance and-small changes in valve position may effect operability of the system.
For these reasons it is not appropriate to include in the SOI and to have operators check the valve position by any type of valve manipulation.
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ae ENCLOSURE 2 s.
COMMITMENTS i
1.
By startup of each respective unit, a fuse verification program for IE systems to verify that the proper fuse is called for on the drawings, included in procedures, and is installed in the field will be completed.
2.
By startup of either unit, modifications criteria will be identified for all modifications after January 15, 1986, to establish a design basis for each plant modification.
3.
By startup of unit 2, the remaining S0Is (nine) will be revised to include a note on the valve checklist.
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