ML20236V820
| ML20236V820 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 07/27/1998 |
| From: | Bajestani M TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-327-98-06, 50-327-98-6, 50-328-98-06, 50-328-98-6, NUDOCS 9808040224 | |
| Download: ML20236V820 (13) | |
Text
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f Tennessee Valley Authority, Post Omce Box 2000, Soddy Daisy, Tennossoe 37379 2000 Masoud Bajestani Site Vice President Sequoyah Nuclear Plant July 27, 1998 U.
S.
Nuclear Regulatory Commission 10 CFR 2.201 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 PLANT (SQN) - NRC INSPECTION REPORT-50-327, 50-328/98 REPLY TO NOTICE OF VIOLATION (NOV)
This letter provides TVA's reply to the NOV.
The NOV contains three violations and is documented in the subject inspection report, which was dated June 26, 1998.
The first violation contains three examples of the failure to adequately implement American Society of Mechanical EngineersSection XI code testing requirements.
The second violation addresses the failure to perform an adequate safety analysis before implementing a plant design change of the oxygen and hydrogen waste gas monitors.
The third violation involves the failure to proper.i.y control personnel security access at a sally port on four different occasions. contains TVA's response to the NOV.
I contains the associated commitments to TVA's response.
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9808040224 980727 i
PDR ADOCK 05000327 l G
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9 U.S.
Nuclear Regulatory Commission l
Pa'ge 2*
July 27, 1998 If you have any questions regarding this response, please contact me at extension (423) 843-7001 or Pedro Salas at l
extension (423) 843-7170.
Sincerely, 1
d(
M. Baj ani Enci 9 re cc ( nclosure)
Mr.
R. W.
Hernan, Project Manager i
Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852-2739 1
NRC Resident Inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy-Daisy, Tennessee 37379-3624 Regional Administrator U.S.
Nuclear Regulatory Commission Region II Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 I
Atlanta, Georgia 30303-3415 l
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ENCLOSURE 1 TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT (SQN)
UNITS 1 AND 2 j
INSPECTION REPORT NUMBER 50-327, 50-328/98-06 REPLY TO NOTICE OF VIOLATION (NOV)
I.
RESTATEMENT OF VIOLATION A (50-327, 328/98-06-04) l I
" Technical Specification 4.0.5, Inservice Testing Program, requires that inservice testing of ACME Code Class 1, 2,
and 3 pumps and valves shall be in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50.55a.
10 CFR 50.55a, Section(b) references OMa-1998 Addenda to the OM-1987 Edition which is the applicable edition and addenda to the code.
ASME/ ANSI OMa-1988 Addenda t_o ASME/ ANSI OM-1987, Operation and Maintenance of Nuclear Power Plants, Part 10, l
Section 4.2.1.2, Exercising Requirements, Part (a) states, in part, ' Valves shall be tested to the positions required to fulfill its function (s).'
ASME/ ANSI OMa-1988 Addenda, Part 10 references OM-1987, Part 1 for relief valve requirements.
Part 1, Paragraphs 8.1.1.8, 8.1.2.8, and 8.1.3.7 require a minimum 10 minute hold time between valve openings.
Additionally Paragraph i
8.3.3(e) requires that the hold time be specified in a written procedure.
10 CFR 50.55a (a) (3) states that alternate tests to 1
inservice testing requirements may be used when authorized by the Director, Office of Nuclear Reactor Regulation (NRR).
l Contrary to the above, inservice testing of valves was not in accordance with Section XI of the ASME Boiler and l
Pressure Vessel Code and Applicable Addenda as required by l
10 CFR 50.55a in that:
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1.
As of March 22, 1998, the component cooling water system (CCS) outlet isolation valves to the residual heat removal (RHR) heat exchangers, FCV-70-153 and FCV-70-156, were not tested to both of the positions El-1 IE
required to fulfill their functions in that the CCS valves for both units were only tested in their open direction.
These valves have safety functions which would require them to be operated in both the open and close direction during accident conditions.
- 2. Procedure 0-SI-SXV-000-264.0, Testing Setpoints of i
Safety and Relief Valves (ASME Section IX Category C l
Valves), Revision 0, did not specify a minimum hold time l
of 10 minutes for testing Class 2 and 3 pressure relief valves.
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- 3. As of May 22, 1998, the licensee had continued to I
perform alternate tests related to relief request RP-03
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since September 20, 1996, and relief requests RV-05 and l
RV-06 since March 20, 1996, without authorization from the Director, NRR.
This is a Severity Level IV Violation (Supplement I)."
TVA's REPLY TO THE VIOLATION 1.
Reason For Violation A (50-327, 328/98-06-04)
A.
Example 1 The reason we did not stroke time test the component cooling water system outlet isolation valves in both the open and closed directions was our interpretation of the testing requirements contained within Part 10 of the ASME/ ANSI OMa-1988 addenda to ASME/ ANSI OM-1987, Inservice Testing of l
Valves in Nuclear Power Plants.
We considered Paragraph 4.2.1.2, Exercising Requirements, that, in part, stated: " Valves shall be tested by full stroke to the position (s) required to fulfill its function (s)," as requiring l
the valves to be exercised by stroking them in i
both directions.
We considered Paragraph 4.2.1.4, Power-Operated Valve Stroke Testing, that, in part, stated: "The limiting value (s) of full-stroke time of each power-operated valve shall be specified by the Owner" was met when we specified a stroke time to be tested in one direction.
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This resulted in our stroking each valve in both directions, but timing the stroke in only the open direction.
B.
Example 2 The reason Procedure 0-SI-SXV-000-264.0, Testing Setpoints of Safety and Relief Valves (ASME
-Section XI Category C Valves), Revision 0, did not specify a minimum hold time of 10 minutes for testing Class 2 and 3 pressure relief valves was our interpretation of the clarification provided in Section 4.3.9 of NUREG-1482, Guidelines for i
Inservice Testing at Nuclear Power Plants.
Relief for the 10-minute hold time was granted in the first 10-year interval.
Specifically, Section 4.3.9 of NUREG-1482 states:
" Thermal equilibrium need not be verified for liquid service valves tested at ambient i
temperature using a test medium temperature."
Our application of this section of NUREG-1482 was incorrect.
C.
Example 3 The reason we continued to perform alternate tests related to Relief Request RP-03 since September 20, 1996,'and Relief Requests RV-05 and RV-06 since March 20, 1996, without authorization from NRC, was our interpretation of the clarification provided in Section 2.5 of NUREG-1482.
Specifically, Section 2.5, in part, states: "The licensee may implement the proposed alternative testing while NRC is reviewing the relief request if the request is for relief.from those requirements that have been determined to be clearly impractical."
For Relief Request RV-05, we did not adequately impleRent the code requirement since we identified Relief Request RV-05 as an alternate test but implemented the request prior to approval of NRC.
The code required NRC approval prior to implementation since the requirement had not been determined to be impractical.
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Also,.we did not adequately address in our submittals that Relief Requests RP-03 and RV-06 were being. submitted as impractical.
I Contributing to this condition was the time delay 1
between NRC's safety evaluation that was issued on March 20, 1996, and our response letter. issued December 22, 1997.
This delay resulted in-TVA continuing to implement the relief requests without providing the additional information requested by the NRC staff.
2.
Corrective Steps Taken.And Results Achieved A.
Example 1 The procedures associated with the stroke time testing of the component cooling water system (CCS) outlet isolation valves to the residual heat removal (RHR) heat exchangers, FCV-70-153 and FCV-70-156, have been revised to include verification of the stroke time in both the open and closed directions.
The procedures associated with the other power operated valves, included in our ASME Section XI testing program, have been revised to require stroke time testing in both directions if the component has a safety function in both directions.
Stroke time testing, in both directions, has been completed for the CCS outlet isolation valves to the RHR heat exchangers for both units (1-FCV l 153,156 and 2-FCV-70-153,156).
These valves were found to be acceptable.
Stroke time testing, in both directions, of other valves within the ASME Section XI testing program is being accomplished
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on the continuing basis as defined by the program.
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B.
Example 2 Procedure 0-SI-SXV-000-264.0 has been placed on administrative hold until a procedure revision is implemented to address the 10-minute hold time.
The administrative hold will ensure the procedure is not used to perform testing unte.1 the hold is released.
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A relief request was approved for the 10-minute hold in the first interval.
We will be submitting a revised relief request for the current interval.
C.
Example 3 The impracticality of implementing the code requirements for Relicf Requests RP-03 and RV-06 was discussed with R. Hernan and J.
Colaccino of NRC in a telephone conversation on June 25, 1998.
During this telephone conversation, it was determined that resubmittal of these two relief requests, to identify them as impractical, was not necessary.
The NRC staff agreed to address these two relief requests in the Inservice Test Program Safety Evaluation Report.
Discussions have been held with personnel involved with the Inservice Testing Program at SON to ensure their understanding of the differences between an alternate test and an impractical requirement.
These discussions also addressed the requirement to ensure tests are performed in accordance with the code requirements until such
-time as an alternate test method is formally approved by the staff.
Additionally, SON has implemented a computerized tracking system in order to ensure timely responses to NRC actions.
This tracking system is presently being monitored and maintained by the Site Licensing organization at SQN.
3.
Corrective Steps That [Have Been Or] Will Be Taken To Prevent Recurrence Additionally, to ensure adequate implementation of the ASME Section XI program, we are going to perform an independent review.
We expect to perform it in August 1998.
We will use personnel from outside of TVA, that are experienced in the Section XI program, to ensure that proper industry experience is factored in.
Following completion of the review, we will determine the need for additional program improvements.2 2
TVA does not consider these corrective actions a regulatory commitment.
TVA's corrective action program will track completion of these actions El-5 a
A.
Example 1 No additional corrective actions are required to prevent recurrence.
B.
Example 2 A review to identify any additional procedures requiring revision to address the 10-minute hold time has been completed.
The revision of the appropriate procedures, including Procedure 0-SI-SXV-000-264.0,- will be completed by August 31, 1998.
An administrative hold for procedures other than 0-SI-SXV-000-264.0 is not required since they are only implemented during outages and the next scheduled outage begins September 9, 1998.
C.
Example 3 The procedures related to the testing of the components associated with Relief Request RV-05 will be revised, to require testing in accordance with the requirements of Part 10 of the ASME/ ANSI OMa-1988 addenda to ASME/ ANSI OM-1987, if approval of the relief request is not received before
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testing is required.
The next required testing is scheduled for August 6, 1998, but must be completed by August 28, 1998.
4.
Date When Full Compliance Will Be Achieved With respect to Example No. 1 of the violation, we are in full compliance.
With respect to Example No.
2, compliance will be achieved on August 31, 1998, on completion of the procedure revisions to incorporate the 10-minute hold time.
With respect to Example No. 3 of the violation, compliance will be achieved on completion of the procedure revision, in accordance with code J
requirements, before the next required test performance or when NRC approval of Relief Request RV-05 is received.
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~ II.
RESTATEMENT OF VIOLATION B (50-327, 328/98-06-03)
"10 CFR 50.59 (a) (1) allows the holder of a license to make changes to the facility and procedures as described in the Updated Final Safety Analysis Report (UFSAR) without prior Commission approval unless the proposed change involves a change to the Technical Specifications or an unreviewed safety question (USQ).
10 CFR 50.59 ' (b) (1) required that the licensee shall maintain records of changes to the facility and that these records include a written safety evaluation which provides
'the bases for the determination that the change does not involve an unreviewed safety question.
The Sequoyah Updated Final Safety Analysis Report (UFSAR),
Amendment 13, Section 11.3, Gaseous Waste System, states that the online gas analyzer determines the quantity of oxygen and hydrogen in the volume control tank, pressurizer relief tank, holdup tanks, gas decay tanks, and spent resin storage tank by monitoring the waste gas header, or by selecting the individual sample point.
Contrary to the above, on October 6, 1997, the licensee made changes to the facility as described in the UFSAR without an adequate written safety evaluation when the waste gas analyzer system was modified to remove the online capability to monitor the oxygen and hydrogen concentrations in the volume control tanks, waste holdup tanks, pressurizer relief tanks, and spent resin storage. tanks and was replaced by grab sample only capability.
This is a Severity Level IV Violation (Supplement I)."
TVA's REPLY TO THE VIOLATION 1.
Reason For Violation B (50-327, 328/98-06-03)
The cause of the violation is personnel error as a result of inadequate research and incomplete documentation.
The safety evaluation performer and reviewer did not provide sufficient justification in the safety evaluation relative to removal of the automatic sequencing capability of the waste gas analyzer.
As a result, the safety evaluation did not l
adequately address the FSAR and sampling requirements.
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2.
Corrective Steps Taken And Results Achieved A review was completed of the safety evaluations performed by the individuals, within the last two years, involved with the waste gas analyzer modification.
No other problems were identified.
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The safety evaluation for the waste gas analyzer I
modification was revised to clarify the discussion of gas sampling, waste gas analyzer operation, and to define sampling requirements for the following auxiliary tanks: volume control tanks, pressurizer relief tanks, holdup tanks, and the spent resin tank.
This corrected the deficiency with the safety evaluation.
L The Chemistry Sampling Requirements procedure was i
revised to include the requirement for quarterly sampling and analysis for hydrogen and oxygen concentration in auxiliary tanks.
Quarterly sampling for hydrogen and oxygen concentrations in auxiliary tanks was completed for the March through June 1998 time frame.
Hydrogen and oxygen gas concentrations were found to be acceptable.
Overall, TVA management sensitivity to ensuring that-personnel issue quality safety evaluations has increased.
Subsequent to issuance of the initial safety evaluation for the waste gas analyzer modification, a procedure change was issued to require safety evaluations to be reviewed by the plant operations review committee (PORC).
This review has resulted in an improvement in the quality of safety evaluations and is ensuring consistency and quality of safety evaluations.
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Corrective Steps That (Have Been Or] Will Be Taken To Prevent Recurrence No additional actions are required.
4.
Date When Full Compliance Will Be Achieved With respect to the violation, we are in full l
compliance.
III. RESTATEMENT OF VIOLATION C (50-327, 328/98-06-05)
"The Tennessee Valley Authority Sequoyah Nuclear Plants Units 1 and 2 Facility Operating Licenses, Section 2.E El-8
l states that the licensee shall fully implement and maintain
'in effect all provisions of the Commission approved physical security, guard training and qualification, and safeguards contingency plans including amendments.
The Sequoyah Nuclear. Plant Physical Security / Contingency Plan Revision 4 dated September 10, 1996, Paragraph 5.2.4, states, ' Verification of each individual will be with the hand geometry system which provides a nontransferable means of identifying individuals, coupled with the badgecard reader.
Both the badgecard and hand geontetry shall be necessary for normal access to the protected area (PA).
Hand geometry shall provide assurance that only authorized personnel are allowed access to the PA.'
Physical Security Instruction - 32, Revision 16, Appendix N, Post 12, and 13 - Vehicle Search / Access Control, Paragraph
- 3. 6, states, ' Ensure individuals with PA badges utilize the hand geometry readers.'
Contrary to the above, on May 8, October 22, December 11, 1997, and March 27, 1998, an individual did not utilize the badge and hand-geometry system prior to entering the PA at the vehicle sally port.
The four individuals were licensee employees who were authorized unescorted access.
This is a Severity Level IV violation (Supplement III). "
TVA's REPLY TO THE VIOLATION 1.
Reason For Violation C (50-327, 328/98-06-05)
The cause of the violation is inadequate corrective action for previously identified safeguard event reports.
The four events, identified by the violation, occurred over an 11-month period.
Each of the four events were documented in safeguard event reports (SERs).
Corrective actions were taken at the time of each occurrence for each of the SERs.
An assessment based on the number of events or similar causal factors was not performed for the SERs to determine if any negative trends existed.
As a result, no trending information was available to determine if additional corrective actions were needed to address common problems.
2.
Corrective Steps Taken And Results Achieved An analysis was performed of the four events referenced in the violation.
The analysis identified a deficiency l
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in trending evaluation including the need for written
' guidance on trending methodology.
Additionally, the analysis provided process improvements for access at the sally port.
Written trending program guidance has been developed.
This written guidance includes: review of safeguard events (SGEs) by security supervision, assessment of the SGE for determination of negative trends, and escalation of SGEs to upper management.
The SGEs issued during the last two years were reviewed to identify any other potential trends.
No other trends were identified.
A change to the policy for vehicle access has been made to allow only one vehicle to enter or exit the sally port at one time.
Also, the applicable procedure has been revised to ensure that the officer performing the
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pat down is responsible for ensuring that the driver properly uses the hand geometry readers.
3.
Corrective Steps That [Have Been Or] Will Be Taken To Prevent Recurrence No additional actions are necessary relative to the cause of the violation.
The following additional corrective actions
- will be taken to improve sally port access control, a) Issuing a site bulletin to plant personnel reinforcing driver responsibility for proper use of the hand geometry reader at the sally port.
b) Developing and implementing a design change to the sally port protected area gate to interlock with the hand geometry reader.
4.
Date When Full Compliance Will Be Achieved With respect to the violation, TVA is in full compliance i
i TVA does not consider these corrective actions a regulatory commitment.
TVA's corrective action program will track completion of these actions El-10
ENCLOSURE 2 TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT (SQN)
UNITS 1 AND 2 INSPECTION REPORT NUMBER 50-327, 50-328/98-06 LIST OF COMMITMENTS Violation A (50-327, 328/98-06-04)
- 1. A review to identify any additional procedures requiring revision to address the 10-minute hold time has been completed.
The revision of these procedures will be completed by August.31, 1998.
- 2. The procedures related to the testing of the components associated with Relief Request RV-05 will be revised, to require testing in accordance with the requirements of Part 10 of the ASME/ ANSI OMa-1988 addenda to ASME/ ANSI OM-1987, if approval of the relief request is not received before testing is required.
The next required testing is scheduled for August 6, 1998, but must be completed by August 28, 1998.
Violation B (50-327, 328/98-06-03)
None.
Violation C (50-327, 328/98-06-05)
None.
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