ML20217R295
| ML20217R295 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 08/27/1997 |
| From: | Bajestani M TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-327-97-06, 50-327-97-6, 50-328-97-06, 50-328-97-6, NUDOCS 9709050011 | |
| Download: ML20217R295 (8) | |
Text
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TennesN>e Valley Authority. Post offce Box 2000. Sockfy Daisy Temtssoo 37379 2000 Masoud Dajestani Sne Vee ProwMt Sorwyah Nacks Ptard August 27, 1997 i
U.S. Nuclear Regulatory Commission 10 CFR 2.201 ATTN:
Document Control Desk
(
Washington, D.C. 20555 Gent 1emen1 l
In the Matter of
)
Docket Nos.
50-327 Tennessee Valley Authority
)
50-328 i
SEQUOYAH NUCLEAR PIANT (SQN)
NRC INTEGRATED INSPECTION REPORT NOS. 50-327/97-06 AND 50-328/97-06'- REPLY TO NOTICE OF VIOLATION (NOV)
This letter provides TVA's reply to the NOV documented in the subject inspection report that is dated July 20, 1997.
The NOV Identified two Severity Level IV Violations.
The violations are characterized as:
t failure to implement prompt corrective actions for three e
safety injection system relief valves that failed to open
'within the acceptable range / tolerance, and failure to identify and promptly correct an adverse
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condition resulting in the Auxiliary Building Railroad Bay not being at a slight negative pressure and railroad track i
seals not being installed.
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The enclosure contains our response to the NOV.
There are no commitments contained in this submittal.
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i 9709050011 970827' lll]li )lll-l l
.PDR ADOCK 05000327
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c' U.S. Nuclear Regulatory Commirsion Page 2 August 27, 1997 i
In addition to the corrective steps that we are taking in response to the violations, we are taking other actions that address NRC stated concerns.
rirst, we are taking steps to improve the m'aterial condition of-the plant.
A Material Condition Improvement Program has been developed, and the program will identify the significant operator challenges and evaluate aggregate effect.
Also, we i
will perform a system-by-system-review of outstanding work orders.
The overall number of outstanding work orders will i
be reduced by application of additional dedicated resources.
1 Second, we believe that the corrective action program implementation is showing signs of improvement.
This improvement stems from management's efforts to train site personnel in root cause analysis, encourage problem identification at increasingly lower levels, and shift implementation ownership to line management.
The Management' i
Review Committee (MRC) which is composed of key site-line management is ensuring' continued program improvement.
The MRC is closely monitoring problem evaluation report analysis
- i and corrective action development and implementation.
Increased line management ownership of program implementation, through the MRC, will ensure continued improvement.
We believe your recent inspections had an opportunity to observe MRC's increased involvement.
~
Finally, we have also observed minor implementation deficiencies of the ASME Section XI program since the program began implementation of the second 10-year interval in I
December 1995.
In response, we are performing an independent review of ASME Section XI implementation at SON.
The evaluation will identify any required actions to improve
. program implementation.
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U.S. Nuclear Regulatory Commission Page 3 August 27, 1997 i
I If you have questions regarding this response, please contact me at (423) 843-7001 or Pedro ' alas at (423) 643-7170.
Sincerely, t
Masoud jestani Enclosures cc (Enclosures):
1 Mr. R. W. Hernan, Project Manager Nuclear Regulatory Commission r
One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852-2739 NRC Resident Inspector Sequoyah Nuclear Plant l
2600 Igou Ferry Road Soddy-Daisy, Tennessee 37379-3624 i
Regional Administrator U.S. Nuclear Regulatory Commission Region II Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta, Georgia 30303-3415
ENCLOSURE TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT (SQN)
UNITS 1 AND 2 INSPECTION REPORT NUMBERS 50-327/97-06 AND 50-328/97-06 REPLY TO NOTICE OF VIOLATION (NOV)
I.
RESTATEMENT OF VIOLATION A A.
"10 CFR 50, Appendix B, Criterion XVI, Corrective Action, requires that measures shall be established to assure that conditions adverse to quality are promptly identified and corrected.
Contrary to the above, on November 2, 1996, the licensee failed to implement prompt corrective actions to resolve a condition adverse to quality in that following a Safety Injection System overpressure event, where three safety injection system relief valves failed to open within the acceptance range / tolerance, two safety injection system relief valves were not reset and/or an analysis was not performed to ensure compliance with the ANSI /ASME OM-1 code requirements prior to continued operation.
A formal analysis was not completed until June 20, 1997 This is a Severity Level IV Violation (Supplement I)."
TVA's REPLY TO THE VIOLATION A 1.
Reason For The Violation The cause of the violation was an incorrect implementation of documentation requirements.
The ASME 1994 OM-1 Code, Section 1.1.3(e), states that the owner shall establish and document acceptance criteria based upon the system and valve design or technical specifications.
Based on interpretation of these requirements, the procedural acceptance range was established at plus or minus 6 percent of the valve's setpoint.
On November 2, 1996, Operations personnel identified an elevated pressure condition on the safety injection system.
During troubleshooting, one of the three safety injection system relief valves was removed from the system and tested.
Testing found the valve
. ~. - - -
+
1 l
within the procedural acceptance criteria of plus or minus-6 percent of the valve's setpoint.
No additional l
evaluation was performed, and no immediate action was taken.
A Code Inquiry response on relief valve set point acceptance criteria was received in March 1997 l
The response supported a plus or minus 3 percent i
acceptance criteria for expansion of relief valve testing and did not support the 6 percent criteria that was originally thought to be allowed.
This resulted in the procedural acceptance criteria being incorrect.
i j
2.
Corrective Steps Taken And Results Achieved 9
on December 5, 1996, a follow-on engineering structural analysis concluded that fatigue damage from pressure i
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cycling, to the elevated as-found pressure, is negligible.
This analysis provided acceptable documentation for the as-found condition of the relief valve.
i The procedure that provides test guidance for Classes 2 and 3 relief valves was revised.
This changed the l
acceptance criteria to plus or minus 3 percent for i
valves without Engineering documentation supporting the
[
use of another value.
A review of other maintenance l
procedures for non-code relief valves was performed, and no other procedure was identified that allows a relief valve setting greater than 3 percent of the setpoint.
3.
Corrective Steps-That Will Be Taken To Prevent l
Recurrence i
l No additional action is required.
l 4.
Date When Full Compliance Will Be Achieved l
.With respect to the cited violation, TVA is in full compliance.
I II.
RESTATEMENT OF VIOLATION B B.
"10 CFR 50, Appendix B, Criterion XVI, Corrective-Action, requires that measures shall be established to assure that conditions adverse to quality are promptly identified and corrected.
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The Updated Final Safety Analysis Report, Section 9.4.2.1, Design Basis for the Auxiliary Building states that areas of the building which are subject to radioactive contamination are maintained at a slight negative pressure to limit out leakage.
Detailed Design Criteria No. SON-DC-V-1.1.7, Auxiliary Building Railroad Access Door and Associated Equipment, dated July 29, 1971, Section 4.1.2, Seals, requires that removable rubber blocks shall be provided for sealing at each of the railroad rails where they pass through the embedded door sill.
Contrary to the above, a condition adverse to quality was not promptly identified and corrected in that on June 27, 1997, a slight negative pressure in the Auxiliary Building did not exist and removable rubber blocks were not installed at each of the railroad rails where they pass through the embedded door sill.
This is a Severity Level IV Violation (Supplement I)."
TVA$s REPLY TO THE VIOLATION B 1.
Reason For The Violation The cause of the violation is failure to follow procedure as a result of personnel error.
Failure to follow procedural guidance for development of the vent boundary impairment permit resulted in the improper classification of the removed rubber blocks as a door breach, and therefore, the breach was not tracked as a measured opening in the Auxiliary Building Secondary Containment Boundary Enclosure (ABSCE) boundary.
The breach was handled as a normal door breach; that is, as a door that can be closed and thereby closing the breach.
However, this door is unique in that, with the rail seals removed, the door can be closed and still have a breach to the outside environment through the rail space.
Failure to follow procedural guidance for development of Post-Maintenance Testing (PMT) following repair of a general ventilation damper resulted in the slight positive pressure in the Auxiliary Building Railroad J
=.
Day.
The work document required damper position verification as a PMT, This requirement incorrectly assumed that the damper's painted handle mark was the correct location for positioning the damper.
This resulted in too much air flow to the Auxiliary Bui] ding railroad bay.
A contributing cause to the ventilation flow balance problem is a lack of a periodic testing or observation methodology for station general ventilation.
Whereas periodic testing is performed to ensure that ABSCE boundary and negative pressure requirements can be established, no periodic testing or observations of the general ventilation system flow rates and pressures are performed to ensure the requirements of the FSAR are maintained.
It should be noted that previous testing of the ABSCE boundary has been successfully performed with the rubber rail blocks removed.
This testing ensured the integrity of the ABSCE boundary under accident conditions.
The post-accident ABSCE ventilation system is independent of the normal ventilation system and was not impacted by this condition.
2.
Corrective Steps Taken And Results Achieved Upon identification of the condition, the actions listed below were taken:
A work document was initiated and worked to grout the railroad track openings between the embedded door sill and the railroad tracks.
A Design Change Notice is being issued to eliminate the rubber blocks.
This eliminated the potential for a breach to the outside environment in this area.
Other breach permits were reviewed to determine if other breaches existed that were not measured ABSCE breaches.
None were found.
Open work documents associated with doors and ventilation dampers were reviewed to determine other impact to the.ABSCE boundary.
No other open work documents were found that corld adversely affect the performance of the ABSCE. _ _. __
9 The areas adjacent to the cask loading area (Auxiliary Building Railroad Bay) were tested for negative air pressure.
The waste packaging and post-accident sampling areas were also found to be at a slight positive pressure.
Air flow rates of Auxiliary Building general ventilation system were taken and the system was balanced.
The areas in question were retested and found to be at a negative pressure with respect to the outside and in compliance with the FSAR.
3.
Corrective Steps That Will Be Taken To Prevent Recurrence f
The appropriate procedure (s) will be enhanced to increase awareness that the seals on ABSCE boundary doors are included as a measured breach.*
A methodology will be developed to ensure that normal ventilation systems meet the design and regulatory g
intent as discussed in the FSAR.*
Lessons learned relative to the condition will be provided to the appropriate personnel.1 4.
Date When Full Compliance Will Be Achieved With respect to the cited violation, TVA is in full compliance.
TVA does not consider this action a regulatory committnent.
TVA's corrective action program U111 track completion of the action 5-
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