ML20212R380
| ML20212R380 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 01/23/1987 |
| From: | Domer J TENNESSEE VALLEY AUTHORITY |
| To: | Grace J NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8702020621 | |
| Download: ML20212R380 (6) | |
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s TENNESSEE VALLEY AUTHORITY CHATTANOOGA. TENNESSEE 37401 SN 157B Lookout Place FKN 23 S87 U.S. Nuclear Regulatory Comission Attn: Document Control Desk Cffice of Nuclear Reactor Regulation Washington, D.C.
20555 Attention:
Dr. J. Nelson Grace In the Matter of the
)
Docket Nos. 50-327 Tennessee Valley Authority
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50-328 SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 - NRC-OIE REGION II INSPECTION REPORT NOS.
50-327/86-59 AND 50-328/86 RESPONSE TO VIOLATION ITEM 327, 328/86-59-01 Enclosed is our response to Gary G. Zech's December 19, 1986 letter to S. A. White which transmitted NRC Inspection Report Nos. 50-327/86-59-01 and 50-328/86-59-01 for Sequoyah Nuclear Plant and the subject Notice of Violation. Enclosure 1 provides our response to the violation. Enclosure 2 lists the commitments identified in enclosure 1.
We do not recognize any other actions described herein or the nubject inspection report as comitments.
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 vJ. A. Domer, Assistant Director Nuclear Safety and L.lcensing Enclosures cc: See page 2 l
1 8702020621 870123 PDR ADOCK 05000327 O
PDR gyl An Equal Opportunity Employer g
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. U.S. Nuclear Regulatory Commission WEW 23 E87 Enclosures cc (Enclosures):
Mr. J. J. Holonich Sequoyah Project Manager U.S. Nuclear Regulatory Commission 7920 I?orfolk Avenue Bethesda, Marylend 20814 Mr. G. G. Zech, Director TVA Projects U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Sequoyah Resident Inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy Daisy, Tennessee 37379
ENCLOSURE 1 RESPONSE - NRC-OIE INSPECTION REPORT NOS. 50-327/86-59 AND 50-328/86-59 GARY G. ZECH'S LETTER TO S. A. WHITE DATED DECEMBER 19, 1986 Violation 50-327/86-59-01 and 50-328/86-59-01 During the Nuclear Regulatory Commission (NRC) inspection conducted on October 20, 1986, a violation of NRC requirements was identified. The violation involved failure to perform stroke testing of Category "A" and "B" Class 1, 2, and 3 valves at the required frequency.
In accordance with the
" General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1986), the violetion is listed below:
Sequoyah Technical Specification 4.0.5. requires inservice testing of ASME Code Class 1, 2, 3 valves in accordance with Section XI of the ASME Boiler and Pressure Vessel Code.
Paragraph IWV-3411 of the 1977 Edition of Section XI, applicable to Unit 2, and paragraph IWV-3410 of the 1974 Edition of Section XI, applicable to Unit 1, require stroke testing of Category "A" and "B" valves every three months. The Technical Specification defines the three months as 92 days and allows a 25%
extension of the surveillance interval.
Contrary to the above, at various times during 1984 and 1985, a number of Category "A" and "B" valves were not stroke tested within the 92 days, plus 25% extension, surveillance interval.
The following are examples:
Dates Where Test Valve No.
Frequency Violated Requirements 1-FVC-62-92 2/29/84 - 7/25/84 1-FVC-70-206 4/23/85 - 12/17/85 2-FVC-62-90 6/28/84 - 11/26/84 2-FVC-67-352 6/28/85 - 2/3/86 2-FVC-67-348 6/27/84 - 11/26/84 This is a Severity Level IV violation (Supplement I).
r
. 1.
Admission or Denial of the Violation TVA admits the violation occurred as stated.
(It should be noted that valve 1-FVC-62-92 identified in the notice of violation should have been identified as 1-FCV-62-91 and valve 1-FVC-70-206 should have been identified as 0-FCV-70-206.)
2.
Reason for the Violation The violation occurred because of an inadequate procedure resulting from an oversight in the program regarding tracking and scheduling of the surveillance performance. The scheduling was solely based on the starting of the surveillance instruction (SI) test packages, not on the testing of individual valves; i.e.,
the package would be initiated at the required frequency. As such, the period for package performance could permit individual valves to be tested at intervals greater than once every 92 days, plus the 25-percent extension, especially since the order of testing would not be necessarily duplicated and the SI package involved contains several hundred valves.
Additionally, it was not recognized early in the extended ongoing outage by the surveillance performing section personnel that a limited number of the Section XI valves were required to le maintained in frequency during Mode 5.
As a result of these two conditions, certain valves were not stroke tested at the required f requency as identified in the subject inspection report and corresponding notice of violation.
3.
Corrective Steps Taken and Results Achieved All identified valves were verified to currently be within required frequency.
As a result of the test frequency lapses during Mode 5 and TVA investigation initiated at the time of the subject NRC inspection, Potential Reportable Occurrences (PRO) 1-85-369 and 1-86-318 were written on December 13, 1985 and November 7, 1986, respectively. Additionally, Licensee Event Report (LER)86-051 was filed on December 5, 1986 in accordance with 10 CFR 50.73 and a revision, LER 86-051-01, was filed on January 13, 1987.
Revisions to the associated sis have been initiated and are currently in the review and approval process.
As interim measures, before approval and issuance of the revised instructions, a night order was issued indicating the Section XI valves which are required to be stroke time tested during Mode 5 and additional administrative controls were implemented to clarify both the testing and frequency requirements.
. 4.
Corrective Steps to Be Taken to Avoid Further Violations The associated SI-166 series stroke time test procedures are being revised to place the valves required to be maintained in frequency in Mode 5 in separate procedures with instructions to keep the test frequency current in all modes.
The procedurec are also being revised to require the entire surveillance test package to be completed within 23 days (25 percent of the 92-day test interval) of the package scheduled performance. Valves not tested within the 23 days will be declared inoperable until tested or verified to be within allowable test frequency.
The revised procedures are currently in the review process but will be approved and issued before restart.
5.
Date When Full Compliance Will Be Achieved For the valves indicated, the plant was in full compliance on February 3, 1986.
I
ENCLOSURE 2 LIST OF COMMITMENTS 1.
Surveillance Instruction (SI)-166 series procedures which perform stroke time testing for Category A and B valves will be revised to place valves which require frequency to be maintained in Mode 5 into separate procedures. The associated procedures will also be revised to require each entire surveillance package to be completed within 23 days of the scheduled performance date. These revisions will be approved and issued before restart.
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