ML20236E736
| ML20236E736 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 10/23/1987 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8710290333 | |
| Download: ML20236E736 (6) | |
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I TENNESSEE VALLEY AUTggTg CHATTANOOGA. TENNESSEE 374o1 SN 157B Lookout Wgt 7.9 A 9: 51 08T 231987 U.S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D.C.
20555 Gentlemen:
In the Matter of
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Docket Nos. 50-327 Tennessee Valley Authority
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50-328 SEQUOYAH NUCLEAR NdiT (SQN) NRC INSPECTION REPORT NOS. 50-327/87-36 AND 50-328/87 REVISED RESPONSE TO NOTICE OF V1,LATION 50-327, -328/87-36-01
Reference:
TVA response to Notice of Violation 50-327, -328/87-36-01 dated August 11, 1987 On August 11, 1987 TVA submitted the response to the above subject violation.
As a result of subsequent discussions with the Resident Inspectors during their review of this response, we submit the enclosed revised response to this violation.
This revised response includes the results of additional reviews of technical specifications, functional testing requirements, and additional corrective actions to address these results. provides the revised response to the Notice of Violation. contains a list of commitments contained in enclosure 1.
We do not recognize any other items described herein as commitments.
If you have any questions, please telephone M. R. Harding at 615/870-6422.
To the best of my knowledge, I declare the statements contained herein are complete and true.
Very truly yours, TENNESSEE VALLEY AUTHORITY R. G idley,
' rector Nuclear Licensing and Re$ulatory Affairs Enclosures cc:
See page 2 8710290333 071023 PDR ADOCK 05000327 g/
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i An Equal Opportunity Employer
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-U.S. Nuclear' Regulatory. Commission'
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4 cc (Enclosures):'
L" Mr. G. G. Zech,' Assistant Director for Inspection Programs' l
Office of1Special Projects.
LU.S.' Nuclear Regulatory-Commission-
.101'Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Mr2 J. A. Zwolinski,-Assistant' Director for Projects Division' of TVA Projects
- Office of.Special Projects
. U.S. Nuclear Regulatory Commission'
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.4350 East-West Highway EWW 322 LBethesda,JMaryland. 20814 -
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Sequoyah Resident Inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road?
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Soddy Daisy Tennescoe 373'/9 1
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ENCLOSURE 1 REVISED RESPONSE TO NOTICE OF VIOLATION i
50-327, -328/87-36-01 1
Violation 50-327. -328/87-36-01 Technical' Specification 3.3.3.6 states that two independent chlorine detection j
systems (CDS), with their alarm / trip setpoints adjusted to actuate at a chlorine concentration of less than or equal to 5 ppm, shall be OPERABLE.
Surveillance Requirement 4.3.3.6 states that each chlorino detection system shall be demonstrated OPERABLE by performance of a CHANNEL FUNCTIONAL TEST at
'least once per 31 days and a CHANNEL CALIBRATION at least once per 18 months.
Contrary to the above, neither the CHANNEL CALIBRATION nor the CHANNEL FUNCTIONAL TEST have been adequately performed for the period of January 1, 1982.(since the preoperational test phase) to the prer,ent, in that the isolation of the control room (the CDS trip function) is not functionally tested using the chlorine detector signal as an initiation signal.
(Note:
one special test was performed at the request of the NRC in 1987.) Both channels of the CDS were considered to be inoperable at the time of the inspection,_and to have been inoperable for the period that these tests were not adequately performed.
This is a Severity Level IV violation (Supplement I).
1.
Admission or Denial _vf the Alleged Violation TVA' concurs the violation occurred as stated.
2.
Reason for the Viclation This violation resulted f rom an incorrect interpretation (informal) of the requirements associated with an instrument CHANNEL FUNCTIONAL TFJT i
(CFT). This interpretation required that the CFT verify a channel j
actuation via a change in state in the channel output relay.
- However, I
the actual change in state of the channel trip contacts was not required to be verif3ad.
For the cited example, the change in state of the channel output relay was verified by observation of an alarm that
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resulted from the closure of another pair of contacts on the same relay.
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3.
Corrective Steps That Have Been Taken and Results Achieved As a result of the generic nature of the deficiency, SQN personnel reviewed other technical specification (TS) requirements for CFT requirements. This review did not include the Solid State Protection System portions of the Reactor Protective System (RPS) or Engineered Safety Feature Actuation System (ESFAS) since the testing of these systems was known to include proper testing methodology to implement the
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CFT requirements, encompassing the entire instrument channel (s) as defined in the SQN Final Safety Analysis Report.
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. The results of this review indicated that for several instrument channels associated with Auxiliary Building Irolation (ABI), Containment Ventilation Isolation (CVI), Control hoom Isolation (CRI), loss of power (degraded voltage), Effluent Monitoring., and Auxiliary Feodwater (suction swap-over for turbine driven pump), the CFT surveillance procedures did not verify a change in state in the channel trip contacts.
The following table identifies these procedures that were found to be l
deficient and the associated TS CFT surveillance ~ requirement.
Procedure Number TS_CD'T Surveillance Requirement SI-240 Section 4.3.3.6 SI-82 Table 4.3-9, 5.a SI-82 Table 4.3-3, l.a SI-82 Table 4.3-3, 2.c SI-82, SI 82.2 Table 4.3-3, 2.s SI-82, SI 82.2 Table 4.3-3, 2.b.i.a SI-82, SI-82.2 Table 4.3-3, 2.b.i.b SI-82SI-82.2 Table 4.3-3, 2.b.ii.a SI-82, SI-82.2 Table 4.3-3, 2.b.ii.b SI-82, SI-82.2 Section 4.4.6.la, Table 4.3-3, 2.b.i.b SI-82, SI-82.2 Section 4.4.6.lb, Table 4.3-3, 2.b.ii.b SI-253 Table 4.3-2, 7.b.1 SI-298.1 (unit 1), 298.2 (unit 2)
Table 4.3-2, 6 5 SI-244, SI-288 Table 4.3-8. 3d Before the receipt of the Inspection Report and associated Notice of Violation, Surveillance Instruction (SI)-168, which fulfills the 18-month CHANNEL CALIBRATION (CC) requirements for the CDS, was revised to include a verification of the Control Room Emergency Ventilation System (CREVS) isolation from a CDS initiation.
This procedure has been successfully performed.
SI-240, SI-82, SI-82.2, and SI-253 have been revised to include a complete CFT.
SI-240, SI-82, and SI-82.2 have been successfully performed, i
SI-298.1 (unit 1) and SI-298.2 (unit 2) are not required to be performed in t.he current SQN operational mode.
Although SI-244 and SI-288 did not include specific verification of channel contacts, additional corrective maintenance performed in conjunction with the last surveillance demonstrated the channel contacts functioned properly.
1 SI-288 has been revised to include a proper CFT.
t A formal TS interpretation has been issued to ensure the requirements for a CFT are clearly established.
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Corrective Steps That Will Be Taken to Avoid Further Violations SI-244 will be revised to include a proper CFT before its next performance.
SI-253 will be performed before entry into mode 4.
SI-298.1 (unit 1) and SI-298.2 (unit 2) will be revised and performed before entry into operational mode 3.
SI-298.1 and SI-298.2 are not required to be performed in modes 5 or 4.
5.
Date When Full Compliance Will Be Achieved l
Full compliance relativo to this violation has been achieved for mode 5.
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,.,0 ENCLOSURE 2
-LIST OF COMMITHEiTS 1.
SI-244 will be revised to include a proper CFT before its next
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. performance.
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'SI-298.1 and SI-298.2 will be revised and performed before entry into j
operational mode 3.
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