ML20205P014

Notice of Violation from Insp on 860306-0415

ML20205P014
Person / Time
Site:	Sequoyah
Issue date:	05/13/1986
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20205P007	List: ML20205P003 ML20205P014 ML20205P021
References
50-327-86-19, 50-328-86-19, NUDOCS 8605210071
Download: ML20205P014 (3)

Text

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a ENCLOSURE 1 NOTICE OF VIOLATION Tennessee Valley Authority Docket Nos. 50-327 and 50-328 Sequoyah Units 1 and 2 License Nos. DPR-77 and DPR-79 The following violations were identified during an inspection conducted on March 6 - April 5, 1986. The Severity Level was assigned in accordance with the NRC Enforcement Policy (10CFR Part 2 Appendix C).

1. 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 below,

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 avail-ability 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 that 10-ampere fuses were installed for the AC auxiliary lube oil pumps.

b. AI-19, Part IV, Office of Nuclear Power Administrative Instruction -

Plant Modifications After 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 require-ments. 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 (0E) review engineer and the engineer who performed the OE independent check 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.

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Tennessee Valley Authority 2 Docket Nos. 50-327 and 50-328 Sequoyah Units 1 and 2 License Nos. DPR-77 and DPR-79

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.

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 indepen-dent 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 Verifict ion, requires that measures be applied to assure the adequacy of desi;n documents. The procedure states that a minimum of one established, identifiable verification method will be used to assure design adequacy and that 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 or 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, AI-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.

2. TS 3.6.4.1 Limiting Condition 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 30 days or the unit must be placed in at least H0T 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 analyzers 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 Specifica-tion does not apply if the applicable LC0 and action statement can not be met.

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Tennessee Valley Authority 3 Docket Nos. 50-327 and 50-328 Sequoyah Units 1 and 2 License Nos. OPR-77 and DPR-79 l

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 be operable in accordance with TS 3.6.4.1. During this period, the A train hydrogen analyzer did not i 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.

3. 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 (S01s) 30.6, 65.1, 65.2 and 87.1 were established by the licensee to implement the requirements for control of startup of safety-related equip-ment.

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 S01-30.6 and S01-65.1 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 Udl water accumulator level were not locked in position or verified to be in the correct position during system operability walkdowns conducted under S01-87.1.

This is a Severity Level V violation (Supplement I). This violation applies to both units.

Pursuant to 10 CFR 2.201, you are required to submit to this office within 30 days of the date of this Notice, a written statement or explanation in reply, including : (1) admission or denial of the alleged violations; (2) the reasons for the violations if admitted; (3) the corrective steps which have been taken and the results achieved; (4) corrective steps which will be taken to avoid further violations; and, (5) the date when full compliance will be achieved.

Security or safeguards information should be submitted as an enclosure to facilitate withholding it from public disclosure as required by 10 CFR 2.790 (d) or 10 CFR 73.21.

Date: MAY 131986

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