ML20237B185

Notice of Violation from Insp on 980606-0718.Violations Noted:On or Before 971103,conditions Adverse to Qualify Were Not Promptly Identified & Corrected,In That Licensee Failed to Correct &/Or Initiate Problem Evaluation Rept

ML20237B185
Person / Time
Site:	Sequoyah
Issue date:	08/04/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20237B172	List: IR 05000327/1998007 ML20237B170 ML20237B185
References
50-327-98-07, 50-327-98-7, 50-328-98-07, 50-328-98-7, NUDOCS 9808180090
Download: ML20237B185 (4)

Text

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NOTICE OF VIOLATION i

l Tennessee Valley Authority Docket Nos. 50-327 and 50-328 Sequoyah Nuclear Plant License Nos. DPR-77 and OPR-79

! During an NRC inspection conducted on June 6 through July 18, 1998.

violations of NRC requirements were identified. In accordance with the

" General Statement of Policy and Procedures for NRC Enforcement Actions."

NUREG-1600, the violations are listed below:

A. 10 CFR 50. Appendix B. Criterion XVI. Corrective Action, requires that

( measures shall be established to assure that conditions adverse to quality, such _as failures, malfunctions, deficiencies deviations.

defective material and equipment and nonconformances are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition. The identification of the significant condition adverse to quality, the cause of the condition, and the corrective action taken shall be documented and reported to appropriate levels of management.

Site Standard Practice SSP 3.4. Revision 22. Corrective Action, implements the Quality As'surance requirements for promptly identifying and correct hg conditions adverse to quality.

SSP 3.4. Section 3.0.A. requires personnel to "promptly report adverse conditions on a work request / work order and/or a problem evaluation report (PER)."

SSP 3.4. Appendix M. Engineering Evaluations for Operability Determination. Section 3.4. Technical Evaluation of TOES (Technical Operability Evaluations). Subsections B.2 and B.4.

requires the evaluator to " evaluate the specified function of the affected system, subsystem. or component. . .by describing the effects of the potential nonconformance/ degraded condition in relation to the components / system's capability of performing its specified function."

SSP 3.4. Subsection B.4.b, requires the evaluator to " evaluate and discuss the effects of the potential nonconformance at the lowest applicable level and continue the discussion up.through high levels until a conclusion can be reached concerning the effects of the potential nonconformance on system functionality."

i Contrary to the above, on or before November 3, 1997, conditions adverse to quality were not promptly identified and corrected, in that:

Enclosure 1 DR DOhO M PDR 7

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! NOV 2

1. The licensee failed to correct and or initiate a problem evaluation report on the deficient conditions exhibited by the pressurizer level instrument (2-LT-68-320). The deficient '

conditions included instrument hysteresis and pressure sensitivity l in excess of design documents and vendor specifications; abnormal l

popping noises from the instrument when pressurized: and failure to meet the acceptance criteria in the TS required calibration procedure.

2. The licensee failed to promptly correct the scaling errors in the calibration procedures (1.1% for 2-LT-68-335. 1.8% for 2-LT-68-339 and approximately 6.2% for 2-LT-68-320). As a result the instruments were not calibrated to the correct values for accurately measuring pressurizer level. This resulted in non-conservative pressurizer high level reactor trip setpoints for all three Unit 2 pressurizer level channels. (Actual level would be greater than the allowable TS limit of 92.7% before a trip could occur).

3. The licensee failed to adequately evaluate and discuss the effects of the potential nonconformances of pressurizer level instrument 2-LT-68-320 on the reactor protection system pressurizer high level reactor trip setpoint. In addition, the supporting engineering documentation / evaluation for the October 26 TOE.  ;

" Pressurizer Level Transmitter Loop Evaluation for 2-LT-68-320" l completed on February 5. 1998. incorrectly stated "Since the error i is a negative error, it affects only the decreasing setpoints and )

would not be applicable for the high level trip function." j This is a Severity Level IV Violation (Supplement I).

-l B. TS 4.3.1.1 required that "Each reactor trip system instrumentation channel and interlock shall be demonstrated OPERABLE by the performance of the CHANNEL CHECK. CHANNEL CALIBRATION and CHANNEL FUNCTIONAL TEST operations for the MODES and at the frequencies shown in Table 4.3-1."

Table 4.3-1. Reactor Trip System Instrumentation Surveillance i Requirements. Functional Unit 11. Pressurizer Water Level High.

L requires a channel calibration during each refueling (at least once per 18 months).

i CHANNEL CALIBRATION is defined by TS 1.4 as "the adjustment, as ,

necessary, of the channel output such that it responds with the  !

necessary range and accuracy to known values of the parameter which the channel monitors."

Contrary to the above, a CHANNEL CALIBRATION was not performed as required, in that.

NOV 3 l

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1. On October 24, 1997, the channel output of pressurizer level channel 2-LT-68-320 was not adjusted to the necessary range and accuracy to known values of the parameter which the channel monitors. During the performance of the calibration, per 2-SI-ICC-068-320.3. Channel Calibration of Pressurizer Level II Rack 9 Loop L-68-320, 2-LT-68-320 failed to meet the as-left L ceptance criteria of the procedure.

2. From 1988 to the present. the channel output of pressurizer level channel 2-LT-68-320 has not been adjusted to the necessary range and accuracy to known values of the parameter which the channel monitors. In 1988, the input pressure source calibration data contained in calibration

, procedure. 2-SI-ICC-068-320.3. Channel Calibration of Pressurizer Level II Rack 9 Loop L-68-320. 2-LT-68-320, was revised approximately 5.7% based on the difference in indication and not based on engineering scaling documents.

Subsequently. (1997). the licensee identified an instrument pressure shift but failed to verify the extent of the shift.

This condition resulted in not having an adequate analysis (unverified assumptions) of the setpoint margin for the pressurizer high level reactor trip. Therefore, it was concluded that the calibration was no longer based on the necessary range and accuracy to known pressurizer levels.

This is a Severity Level IV Violation (Supplement I).

Pursuant to the provisions of 10 CFR 2.201. Tennessee Valley Authority is hereby required to submit a written statement or explanation to the U.S.

Nuclear Regulatory Commission. ATTN: Document Control Desk. Washington, D.C.

20555 with a copy to the Regional Administrator Region II. and a copy to the NRC Resident Inspector at the Sequoyah facility, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation." and should include for each violation: (1) the reason for ne violation, or, if contested, the basis for disputing the violation. (2) the corrective steps that have been taken and the results achieved. (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or include previously docketed correspondence if the correspondence adequately addresses the required response. If an adequate reply is not received within the time specified in l this Notice, an order or Demand for Information may be issued as to why the license should be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.

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NOV 4 If you contest this enforcement action, you should also provide a copy of your response to the Director Office of Enforcement. United States Nuclear Regulatory Commission, Washington, DC 20555-0001.

Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted 'ovasion of personal privacy or provide the information required by 10 LFR 2.790(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

1 Dated at Atlanta. Georgia '

this 4thday of August 1998 l

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