ML20249A920
| ML20249A920 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 06/15/1998 |
| From: | Bajestani M TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-327-98-04, 50-327-98-4, 50-328-98-04, 50-328-98-4, NUDOCS 9806190125 | |
| Download: ML20249A920 (6) | |
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l Tennessee Valley Authority, Post Office Box 2000. Soddy Daisy, Tennessee 37379-2000 Masoud Bajestani Site Vice Prosdent Sequoyah Nuclear Plant I
June 15, 1998 U.
S.
Nuclear Regulatory Commission 10 CFR 2.201 ATTN:' Document Control Desk Washington, D. C.
20555 Gentleman:
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) 50-327/98-04-01 This letter provides TVA's reply to the subject NOV dated
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May 15, 1998.
The NOV addresses the failure to perform the t
appropriate technical specification surveillance requirement
/1 when the emergency diesel generator fuel oil transfer pump I
automatic start circuitry was disabled. contains TVA's response to the NOV.
contains the associated commitment to TVA's response.
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1 If you-have any. questions regarding this response, please
,[k contact me at extension (423) 843-7001 or Pedro Salas at
. extension (423).843-7170.
1 Sincerely,:-
Masoud-
'estani Enclost s
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l-c O.S., Nuclear Regulatory Commission-
- 1 Pa ge, 2 June 15, 1998 cc
(' Enclosures) :
Mr. R. W. Hernan, Project. Manager Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852-2739 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 Atlanta, Georgia-30303-3415 j
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. ENCLOSURE 1
-1 TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT (SQN)
UNITS 1 AND 2 INSPECTION REPORT NUMBER 50-327, 50-328/98-04 REPLY TO NOTICE OF VIOLATION (NOV) 50-327/98-04-01 RESTATEMENT OF VIOLATION
" Technical Specification (T.S.) 3.8.1.1.b requires as a minimum, the following A.C.
electrical power sources shall be operable:
Four separate and independent diesel generator.
sets each with a separate fuel storage system containing a minimum volume of 62,000 gallons of fuel and a separate fuel oil transfer pump.
The Updated Final Safety Analysis Report, Section 8.3.1.1, Description - Diesel Fuel Oil System, states ' Transfer of fuel between the seven day supply tanks and the engine day tanks is accomplished automatically by a pair of pumps controlled by float operated switches which sense fuel level in the engine day tanks.'
The T.S.
definition for Operability, Section 1.19, states 'A system, subsystem, train, or component or device shall be Operable or have Operability when it is capable of performing its specified functions and when all attendant... auxiliary equipment that are required for the system, subsystem, train, component or device to perform its functions are also capable of performing their related support function.'
T.S.
3.8.1.1 action
'b' requires that with a diesel
-generator inoperable, demonstrate the operability of the remaining A.C.
sources by performing Surveillance Requirement 4.8.1.1.1.a within one hour and at least once
.per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter.
Contrary to.the above, on March 24, 1998, the licensee l
failed to perform Surveillance Requirement'4.8.1.1.1.a, within'one hour and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter,
~i when the 1A-A diesel generator automatic start circuitry of the fuel oil transfer system was disabled for a period of 1approximately 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> and 20 minutes, thus rendering the L
transfer. pumps inoperable.
The transfer pumps could no i
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longer perform their intended function of automatically l
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filling the emergency diesel day tanks, which resulted in an inoperable 1A-A diesel generator.
This is a Severity Level IN Violation (Supplement I)."
TVA's REPLY TO THE VIOLATION 1.
Reason For The Violation The reason we did not enter the technical specification (TS) action was our interpretation that disablement of-the automatic ' unction did not affect emergency diesel generator (EDG) operability.
As described in the inspection report's, " Exit Meeting Summary," we did not believe that manual operation of the EDG fuel oil transfer pumps, rather than. automatic, affected the ability of the EDG to perform its intended safety function.
This opinion was based the following:
An automatic start of the 1A-A EDG fuel oil transfer pumps is not specifically required by TS limiting condition for operation (LCO) 3.8.1.1.
final Safety Analysis Report, Section 8.3.1.1, which e
describes the automatic operation of the fuel oil transfer pumps,-was viewed as a design capability, not as a TS operability ~ item.
- The alarm response procedure, for abnormal day tank fuel oil level,-takes' credit for fuel transfer pump manual operation.
TS Surveillance Requirement 4.8.1.1.2.a.3 does not require testing the automatic operation of the fuel oil transfer system.
As a result, a modification of the day tank fuel oil
-limit switch set points was planned and worked outside of the'EDG outage time.
To implement the modification,
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fuses _were removed for the EDG day tank fuel oil' level switches..This disabled the automatic start for both of the fuel oil transfer pumps on the EDG.
A TS LCO was not entered.
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, Corrective Steps Taken And Results Achieved We have reviewed the condition and now understand the NRC position that disabling the automatic-start function on low oil level, for both fuel oil transfer pumps concurrently, impacts EDG operability.
Appropriate Operations personnel have been informed of this condition.
3.
Corrective Steps That Have Been Taken To Prevent Recurrence We are developing administrative controls to ensure minimal impact to the EDG for intentional disablement of the automatic function of the fuel oil transfer pump.
The controls will allow disablement of the automatic start function for only one pump at a time.
Since each pump is fully redundant, the administrative controls will ensure that the EDG remains operable.
If the automatic start function for both pumps are disabled, the EDG will be considered inoperable.
The controls will be implemented by August 28, 1998.
4.
Date When Full Compliance Will Be Achieved With respect to the violation cited, SON will be in full compliance on August 28, 1998, when administrative controls are implemented.
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o-ENCLOSURE 2 L
s TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT (SQN)
. UNITS 1 AND 2 INSPECTION REPORT NUMBER 50-327, 50-328/98-04 REPLY TO NOTICE OF VIOLATION (NOV) 50-327/98-04-01 COMMITMENT Administrative controls will be developed and implemented by August 28, 1998,-to ensure minimal impact to the EDG for intentional disablement of the automatic function of the fuel oil transfer pump.
The controls will allow disablement of the automatic start function for only one pump at a time.
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