ML20244D143
| ML20244D143 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 06/08/1989 |
| From: | Shell R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8906160119 | |
| Download: ML20244D143 (11) | |
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TENNESSEE VALLEY AUTHORITY 5N 157B Lookout Place JUN 081989 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 PLANT (SQN) UNITS 1 AND 2 - NRC INSPECTION REPORT NOS. 50-327, 328/89 RESPONSE TO NOTICE OF VIOLATION 50-327, 328/89-09-03 Enclosed is TVA's response to B. A. Wilson's letter to 0. 9. Kingsley, Jr...
dated May 9, 1989, that transmitted the subject Notice of Violation (NOV).
TVA has reviewed the NOV examples collectively and has concluded that no common element exists. TVA's response to the individual examples is provided in Enclosure 1.
Summary statements of commitments contained in this submittal are provided in Enclosure 2.
If you have any' questions concerning this submittal, please telephone M. A. Cooper at (615) 843-6651.
Very truly yours.
TENNESSEE VALLEY AUTHORITY 1
l Manager,NuclearLicensing and Regulatory Affairs
-Enclosures cc: See page 2
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f 8906160119 090608 I
I FDR ADOCK 05000327 Q
PDC An Equal Opportun!ty Employer
JUN 081989
' U.S. Nuclear Regulatory Commission cc (Enclosures):
Ms. S. C. Black, Assistant Director for Projects TVA Projects Division U.S. Nuc1 car Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Mr. B. A. Wilson, Assistant Director for Inspection Programs TVA Projects Division 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 l
Soddy Daisy, Tennessee 37379 1
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ENCLOSURE 1 I
I RESPONSE TO NRC INSPECTION REPORT NOS. 50-327/89-09 AND 50-328/89-09 B. A. WILSON'S LETTER TO 0.
D.' KINGSLEY, JR.,
1 DATED MAY.9, 1989 Violation 50-327. 328/89-09-03 (Example a)
" Technical Specification (TS) 6.8.1 requires that procedures recommended in.
Appendix A of Regulatory Guide 1.33, Revision 2, be established, implemented and maintained. This includes maintenance, operating, surveillance, and fuel handling procedures.
Th~ requirements of TS 6.8.1.are implemented in part by the following procedures:
a.
IMI-99, TT-601A, Revision 6, Response Time. Testing of Engineered Safety Features Actuation Slave Relays, provides instructions for testing certain Solid State Protection System components.
I Contrary to the requirements of T.S. 6.8.1, on March 25, 1989, procedure IMI-99, TT-601A, Revision 6, was inadequate in that prior.to allowing the'
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return of the solid state protection system to normal following response j
time testing, the procedure did not include provisions to reset l
permissives P-11 and P-12.
As a result-two separate inadvertent reactor I
trip signals were generated for Unit 2 while it was in cold shutdown for refueling."
Admission or Denial of the Alleged Violation (Example a)
TVA admits the violation example.
Reason for the Violation (Example a)
The immediate cause of this violation was the in' adequate revision of Instrument Maintenance Instruction (IMI) 99, RT-601A, " Response Time Testing Engineered Safety Features Actuation Slave Relays (K601, K602, K621)", which added the steps necessary to take the solid-state protection system (SSPS) input error inhibit switch from inhibit to normal, but not the proper steps to ensure that manual safety injection block functions were reinstated properly.
This event and subsequent corrective actions were discussed more fully in Licensee Event Report (LER) 328/89002.
Corrective Steps That Have Been Taken and Results Achieved (Example a)
As immediate corrective actions ~, procedure IMI-99 RT-601A was temporarily changed and the response time test was successfully completed.
In addition, the event was discussed with Instrument Maintenance personnel who perform response time testing to provide a lesson learned of how not considering the generic ramifications of the cause of the first event led to not acting promptly to preclude the second event.
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Corrective Steps That Will Be Taken'to Avoid Further Violations (Example a) 1.
IMI-99 RT-601A will be revised to include necessary steps to ensure that reactor trips and engineered safety features blocks are reinstated. This l
I action will be completed.by-July 7, 1989.
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Other response time tests including SSPS will be reviewed to ensure that a similar condition does not exist.
This action will be completed by July 7, 1989.
These corrective actions were previously committed to in LER 328/89002.
Date When Full Compliance Will Be Achieved (Example a)
Corrective actions will be completed by July 7, 1989.
Violation 50-327, 328/89-09-03 (Example b) i "b.
SOI-30.7, Revision 19, Onsite Electrical Power Systems Board Room l
Heating, Ventilation and Cooling, and SOI-30.1, Revision 28, Control Building and Control Room Heating, Venting and Cooling, provides the conditions for operation, precautions and instructions for the tornado dampers associated with the control room emergency ventilation system.
Contrary to the provisions of T.S. 6.8.1., procedures 50I-30.7 and
$01-30.1 were inadequate in that precautions and instructions were not
-licluded to stipulate that closing the dampers renders the control room emergency ventilation system inoperable and-places the plant in Limiting Condition for Operation (LCO) 3.7.7 for one train inoperable and in
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LCO 3.0.3 when both trains are made inoperable. As a result of this inadequacy, the tornado dampers for both trains were closed at 8:30 a.m.
on March 20, 1989, placing the plant in LCO 3.0.3.
Plant operators did not realize that the control room emergency ventilation system was inoperable until 2:50 p.m. of the same day.
The operators immediately-opened the dampers and exited the LCO.">
j Admission or Denial of the Alleged Violatian (Example b)
TVA admits the violation example.
l Reason for the Violation (Example b)
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The cause of this event is attributed to an incomplete evaluation by a licensed operator of the effects of closing the tornado dampers. A
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l contributing factor was inadequate operator aids to warn the operators of the effects of closing the tornado dampers.
Both trains of-main control' room emergency ventilation were inadvertently rendered. inoperable when tornado l
dampers were closed,-resulting in an entry into LCO 3.0.3 for over six hours.
The dampers were closed to facilitate the replacement of smoke detectors 1
l without realizing-the potential consequences of this action. This event and
.l subsequent corrective actions were discussed more fully in LER 327/89008.
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- Corrective Steps That Have Been Taken and Results Achieved (Example b)
As immediate corrective actions, the tornado dampers were opened and LCO 3.0.3 was exited. Subsequently disciplinary action was taken, and the placard by containment / auxiliary vent board 1A1 was revised to' include.a warning about the effects of closing the tornado dampers.
In addition, System Operating Instruction (SOI) 30.1, " Control Building and Control Room Heating, Air Conditioning, and' Ventilation Systems," and 50I-30.7, "Onsite Electrical Power Systems Board Rooms Heating, Venting, Cooling," have been revised to include i warnings about the effects on the control room emergency ventilation' systems when tornado dampers are closed. A training letter has also been issued to licensed personnel, auxiliary unit operators, and shift technical advisors reviewing the circumstances and potential consequences of the event.
Corrective Steps That Will Be Taken to Avoid Further Violations (Example b)
Operators will review this event during requalification training by August 10, 1989. This corrective action was previously connitted to in LER 327/89008.
l Date When Full Compliance Will Be Achieved (Example b)
TVA is in full compliance.
Violation 50-327, 328/89-09-03 (Example c)
"c.
Sequoyah Engineering Procedure. SQEP 39, Revision 6, Review and Approval of Vendor Manuals / Revisions, implements control of vendor input and insures that vendor manuals reflect complete information for the applicable equipment.
Contrary to the requirements of T.S. 6.8.1, SQEP 39 was not followed in that the controlled vendor manual for Copes-Vulcan Valve, 2-FCV-74-2 did not contain the latest revision of the vendor's manual for the valve operator. A 1971 revision of the Limitorque Operator Manual was included as part of the controlled vendor manual and a 1983 revision was utilized for work planning.
This is a Severity Level IV violation (Supplement I)."
Admission or Denial of the Alleged Violation (Example c)
TVA admits the violation example.
Reason for the Violation (Example c)
The cause of this violation was failure to keep all subvendor information current and consistent. The vendor manual supplied by Westinghouse Electric Corporation for the Copes-Vulcan valve contained a 1971 Limitorque subvendor insert manual for the valve operator. The entire manual.was. issued to TVA by Westinghouse Electric Corporation. Additionally, Sequoyah had a generic
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1 Limitorque manual, a 1983 edition, which was utilized for the environmental qualification (EQ) maintenance requirements and incorporated into the EQ
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binder Qualification Maintenance Data Sheets (QMDS). The Westinghouse manual for the valve had been updated'by Westinghouse; however, the subvendor information contained in this manual had not been kept current. The generic
'Limitorque manual had been updated as part of the Sequoyah vendor manual update program. The subvendor insert manual was not updated when the generic manual was updated.
Since the insert was considered part of the Westinghouse-supplied product, no cross-referencing existed between the i
generic and insert manuals. An inconsistency resulted between the two manuals addressing the same type component.
The technical difference between the two manuals involved the choice of lubrication greases and the frequency for greasing. The 1983 manual specified:
icss frequent greasing (once every 18 months as oppoced to once every 6 months) but restricted the type of grease allowed for inside containment applications in order to maintain EQ of the valve; the.1971 subvendor manual insert allowed the use of several types of grease. Sequoyah's maintenance program requires review of each maintenance request to determine if the identified component is on the 10 CFR 50.49 list. Sequoyah's EQ program dictates use of the QMDS requirements for all 10 CFR 50.49 applications, superceding any other recommendations / requirements. Therefore, once the valve in question was identified as a 50.49 component, the process required the use of the QMDS vendor information, which had been obtained from the more current Limitorque manual.
Corrective Steps That Have Been Taken and Results Achieved (Example c)
I A Condition Adverse to Quality Report (SQN 890236) was written to initiate an investigation into both the specific situation and the generic / programmatic implications of this condition.
As a result of the initial review of this issue, TVA determined that the problem may be generic to subvendor insert information contained within all TVA vendor manuals. Discussions with Westinghouse confirmed that subvendors had not been contacted as part of current revisions (post initial issue) to the Westinghouse manuals and that subvendor inserts may not be current.
TVA's contract with Westinghouse addressing vendor manual updates had not explicitly stated that subvendor information be verified current.
l In accordance with TVA procedures established for the vendor manual update i
program, manuals provided by Westinghouse under the Nuclear Steam Supply System contract were validated as " system manuals".
Subvendor data in the manuals was considered to apply to a Westinghouse assembled and/or supplied l
" system" that Westinghouse, as the system assembler / supplier, would have to validate. As part of the manual validat*on process, TVA contracted with Westinghouse to identify the latest revision of manuals classified as Priority 1 manuals under the update program, the revision number of the manual, date, and vendor transmittal letter. This information was used to
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verify that TVA had the latest information provided by Westinghouse for each I
manual. Once this was verified, the manuals were irsued for use.
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At the time the Westinghouse revision data was received, TVA's contractor for the vendor manual update program noted that some of the subvendor bulletins in the Westinghouse " certified latest revision manuals" were earlier revisions of
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bulletins contained in " generic" manufacturer manuals for identical equipment. TVA reviewed this concern and instructed ATESI to maintain the Westinghouse manuals as-is (with the earlier subvendor bulletins), due to the proprietary nature of Westinghouse technical information.
This decision was based on the assumption that an adequate interface existed between Westinghouse and its subvendors to ensure that changes of substantive nature would be identified and incorporated into the Westinghouse manual revisions.
Regarding the potential generic applicability of this condition,-TVA reviewed records of contacts made with vendors other than Westinghouse. This review determined that for the vendors other than Westinghouse, either the vendor had assumed responsibility for the technical adequacy of the subvendor information, or that TVA had individually contacted the subvendors and updated the subvendor insert manuals. A sample of four vendors other than Westinghouse were contacted and no technical discrepancies were found. Thus the issue of technical adequacy of subvendor information has at this time been bounded to the Westinghouse supplied manuals.
In reevaluation of this issue, TVA determined that the safety significance of this condition--inconsistent and noncurrent subvendor information--was low.
The majority of vendor manual revisions are nontechnical in nature or do not
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impact functionality / operability of the device.
Regardless, for 50.49 i
equipment QMDS requirements procedurally and programmatically supercede any subvendor insert manual information where there is conflict in requirements.
For non-50.49 equipment, functionality is verified through functional / surveillance testing; notification of significant problems occurs through the industry and in-house experience review program, e.g., Part 21 INPO SER/SOERs and NRC notices and bulletins. Adequacy of reliability is l
assessed through the in-house maintenance tracking and trending programs.
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In the interim TVA removed the affected Westinghouse manual from circulation until all Westinghouse manuals could be reissued under_" Conditional Use" status. An information sticker was placed on Westinghouse manuals containing l
Limitorque inserts referring the user of the Westinghouse manuals to the Limitorque generic manual. These actions served to address any possible I
confusion / conflict that might arise pending determination of the scope of this l
condition and the plan for resolution.
Discussions were promptly initiated with Westinghouse to verify the process by whica the original (Revision 0) manuals were issued and subsequent revisions vere issued specifically related to subvendor insert manuals. Westinghouse confirmed to TVA that initial issuances were verified accurate and current at the time of issuance, including the subvendor information. Additionally, Westinghouse stated that subsequent updating of the Westinghouse manuals would not require recontact of the subvendors to determine if more current information was available. Westinghouse based this process on their experience that technical adequacy is seldom affected by subvendor manual updates and they rely oa their subvendor interface relationship to ensure they
were notified of any significant changes that could affect the ability of a component to perform its intended function. Westinghouse evaluates subvendor performance in this area through audits of subvendor Part 21 and Appendix B programs. Westinghouse has concluded that this process of updating Westinghouse manuals adeouately ensures that the manuals, including the subvendor inserts, remain technically adequate, if not totally current'.
Because the subject Limitorque bulletin is contained in a manual published by Copes-Vulcan, Westinghouse ordinarily would rely on Copes-Vulcan as the source of information related to the manual. Although Copes-Vulcan did not submit the Limitorque bulletin to Westinghouse as an update to the original manual, Westinghouse was aware of the content of the Limitorque bulletin through direct contacts with Limitorque.
Westinghouse evaluated the more current Limitorque bulletin (SMBI-82C) against the bulletin contained in the Copes-Vulcan manual (SMBI-170) and concluded the SMBI-82C bulletin contained no new information that would affect the operability of the equipment or the. technical adequacy of the information in the existing manual. The technical differences between the two balletins involve an additional selection of lubricants for general applications and a limitation on the types of lubricants that can be used for inside containment applications. The restriction on the types of grease that can be used inside containment was imposed by Limitorque to meet the requirements of IEEE 323-1974, which required type testing of the lubricants.
The lubricants called out in the never Limitorque bulletin were the only lubricants that had been tested. Since the valves in question were purchased to the requirements of IEEE 323-1971, which does not require lubricant testing, the data in the 3
older Limitorque bulletin (SMBI-170) remained technically adequate.
For this reason, Westinghouse did not update the subject manual when the revised information originally became available.
However, TVA subsequently upgraded the subject actuators to the IEEE 323-1974 requirements as a part of the EQ program. This upgrade required lubricants for the valve actuators to conform to the requirements specified in the newer Limitorque (SMBI-82C) manual.
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Corrective Steps That Will Be Taken to Avoid Further Violations (Example c)
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TVA is compiling a list of all Westinghouse subvendor manual inserts for which there is also a generic manual maintained under the Sequoyah vendor manual j
program. To eliminate any potential for present or future conflict, the subvendor insert pages will be removed from the manuals and replaced with a i
reference to the generic Limitorque manual. Westinghouse has concurred with this methodology. This action will be completed by September 1, 1989.
I Additionally TVA is establishing a sampling plan to verify the adequacy of both the Westinghouse and non-Westinghouse vendor programs for enr. ring the j
technical adequacy of subvendor information and to evaluate veo/ar performance j
in implementing those programs. This evaluation will be comp'.eted by i
September 1, 1989.
Upon completion of the sample evaluation, any additional l
corrective action resulting from the sample will be developed and implemented. TVA will submit additional corrective action if necessary to NRC within 30 days after the sample evaluation is completed.
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TVA has collectively evaluated the subject violation example and the vendor manual issue addressed by URI 88-50-07, to determine whether they involve or indicate a programmatic weakness in the vendor manual control and validation program. The above-noted UR1 involving Grinnell valves resulted from a mistake in the updating process with applicability lists where the valve size overlap was not recognized; as a result, conflicting manuals for the same 3
uniquely identified component existed. This mistake ic considered an isolated personnel error and is unrelated to the cause of the subject violation example.
While the causes of the two issues are different and unrelated, a common attribute was identified from our review, indicating that a programmatic weakness may exist affecting implementation of the Sequoyah program. This common element was the lack of a clearly prescribed process for addressing discrepancies, such as conflicting or confusing information or circumstances where the plant staff desires to deviate from the vendor recommendations.
Further review indicated that improvement was needed in the definition of Nuclear Engineering's role and responsibility in the utilization of the updated vendor manuals by the plant staff and in the interface mechanisms 6
between the plant and Nuclear Engineering organizations.
As a result of this finding, TVA has initiated revisions to AI-23. " Vendor Manual Control," and SQEP-39, " Review and Approval of Vendor Manuals I
Revisions," to clearly define organizational responsibilities, to establish the appropriate mechanisms for the plant staff to provide. feedback and obtain Nuclear Engineering support for vendor manual utilization, and to define how deviations from vendor recommendations should be addressed or dispositioned.
TVA's Nuclear Engineering organization will retain program ownership and accordingly overall responsibility for translation and updating of vendor recommendations and requirements, for achieving and maintaining manual quality, and specifying program utilization requirements as necessary to achieve appropriate program implementation and provide support to the plant staff. Criteria will be developed for determining when deviations from vendor recommendations require Nuclear Engineering concurrence. Revisions to these procedures to enhance program definition and implementation will be 1
completed by August 18, 1989.
In addition to the above-described evaluation of the vendor manual program, TVA has evaluated whether adequate feedback exists between the plant and Nuclear Engineering organizations in specific relation to the acceptability of deliverables, such that assurance is provided that these deliverables are correct, usable, and maintain the design basis of the plant. The results of this evaluation indicate that interfaces and feedback mechanisms between these organizations are generally good, although occasional examples of improper program implementation or less than adequate communication have been identified. The following examples are cited as evidence of active feedback between the plant and Nuclear Engineering organizations to ensure the j
l acceptability of deliverables. Design change packages are deliverables j
provided to the plant staff often in response to plant identified needs through the design change request process. The present program includes a constructibility walkdown of the design package and rignoff by the installer i
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prior to issue by engineering. This walkdown is a mechanism to ensure the i
" deliverable" is correct and usable, and has resulted in improved output quality. Design changes that require additions or changes to the 10 CFR 50.49 i
EQ program are procedurally controlled such that proper documentation of qualifications has been established before equipment can be installed and declared operable.
Upon completion of f,ield changes, field verification forms 3
are also procedurally required to be returned to Nuclear Engineering by the plant group performing the mod!fications on 10 CFR 50.49 equipment. Also, for 10 CFR 50.49 scope equipment, the QMDS are deliverables utilized by Nuclect Engineering to specify to the plant special maintenance activities j
(supplemental to existing maintenance) required to maintain equipment environmental qualification. These requirements are tracked and scheduled for implementation along with other routine maintenance by the plant. Plant procedures require Nuclear Engineering concurrence for deviation from QMDS requirements.
TVA management recognized the needed transition of the Nuclear. Engineering organization at Sequoyah from providing primarily a design / construction function during the extended shutdown, to providing primarily a plant support function in advance of and subsequent to the restart of the Sequoyah units.
Specific actions have been taken to enhance implementation of that function, such as Nuclear Engineering participation in plan-of-the-day Meetings, dedication of 24-hour-a-day support for key plant issues, and addition of a Nuclear Engineering representative to the Plant Operations Review Committee.
TVA remains keenly aware of the importance of timely and quality engineering support of plant operations, and will continue to monitor existing interfaces to ensure adequate feedback exists to verify the quality of plant support.
Date When Full Compliance Will Be Achieved (Example c)
Conflicting information between Westinghouse subvendor manuals and generic vendor manuals will be eliminated by September 1, 1989.
Full compliance will be verified after the sample evaluation of subvendor manuals is completed, the results evaluated, and corrective actions developed and implemented if required. The sample evaluation will be completed and any necessary corrective actions will be identified by September 1, 1989.
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ENCLOSURE 2 List of Commitments 1.
The subvendor insert pages will be removed from the manuals and replaced' with a reference to the generic manual. This action will be completed by September 1,'1989.
2.
TVA is establishing a sampling plan to verify the adequacy of both the Westinghouse and non-Westinghouse vendor programs for ensuring the technical adequacy of subvendor information and to evaluate the performance in implementing those programs. At the completion of the sample evaluation, any additional. corrective action resulting from the sample will be implemented. This evaluation will be completed by September 1, 1989.
3.
TVA will submit additional corrective action if necessary to NRC within 30 days after the sample evaluation is completed.
4.
Revisions to AI-23 and SQEP-39 to enhance program definition and implementation will be completed by August 18, 1989.
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