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| DEB 261989 7 | | DEB 261989 7 |
| l | | l U.S. Nuclear Regulatory Commission |
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| U.S. Nuclear Regulatory Commission | |
| . ATTN: Document Control Desk l Hashington, D.C.-- 20555 C | | . ATTN: Document Control Desk l Hashington, D.C.-- 20555 C |
| Gentlemen: | | Gentlemen: |
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| r cc (Enclosures): | | r cc (Enclosures): |
| Ms. S. C. Black, Assistant Director for Projects TVA Projects Division U.S. Nuclear Regulatory Commission > | | Ms. S. C. Black, Assistant Director for Projects TVA Projects Division U.S. Nuclear Regulatory Commission > |
| One White Flint, North r 11555 Rockville Pike Rockville, Maryland 20852 Mr. B. A. H11 son, Assistant Director for Inspection Programs TVA Projects Division U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 | | One White Flint, North r 11555 Rockville Pike Rockville, Maryland 20852 Mr. B. A. H11 son, Assistant Director for Inspection Programs TVA Projects Division U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 NRC Resident Inspector Sequoyah Nuclear Plant ' |
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| NRC Resident Inspector Sequoyah Nuclear Plant ' | |
| 2600 Igou Ferry Road Soddy Daisy, Tennessee 37379 l | | 2600 Igou Ferry Road Soddy Daisy, Tennessee 37379 l |
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| ENCLOSURE l' | | ENCLOSURE l' |
| ' RESPONSE TO NRC INSPECTION REPORT NOS, 50-327/89-25 AND 50-328/89-25 B. A. HILSON'S LETTER -T0 0. D. KINGSLEY, JR. , | | ' RESPONSE TO NRC INSPECTION REPORT NOS, 50-327/89-25 AND 50-328/89-25 B. A. HILSON'S LETTER -T0 0. D. KINGSLEY, JR. , |
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| Reason for the Violation At approximately 0630 EST on October 20, 1989, during performance of SI-51, l "Heekly Chemistry Requirements," the analyst in the Radiochemistry Laboratory obtained test results of 1,952 parts per million (ppm) boron for the Unit 2 refueling water storage tank (RHST). The RHST boron concentration required by Limiting Condition for Optration (LCO) 3.1.2.6 is between 2,000 and , | | Reason for the Violation At approximately 0630 EST on October 20, 1989, during performance of SI-51, l "Heekly Chemistry Requirements," the analyst in the Radiochemistry Laboratory obtained test results of 1,952 parts per million (ppm) boron for the Unit 2 refueling water storage tank (RHST). The RHST boron concentration required by Limiting Condition for Optration (LCO) 3.1.2.6 is between 2,000 and , |
| 2,100 ppm. In accordance with the requirements of both Sequoyah Standard Practice SQE22, "Sequoyah Nuclear Plant Chemistry Program," and Technical Instruction 37, " Radiochemical Laboratory Sampling and Log Sheets," a second sample was obtained at 0735 for analysis to verify the results of the first sample. At 0815, the results of the second sample showed 1,971 ppm boron. , | | 2,100 ppm. In accordance with the requirements of both Sequoyah Standard Practice SQE22, "Sequoyah Nuclear Plant Chemistry Program," and Technical Instruction 37, " Radiochemical Laboratory Sampling and Log Sheets," a second sample was obtained at 0735 for analysis to verify the results of the first sample. At 0815, the results of the second sample showed 1,971 ppm boron. , |
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| -AT 1748 ESTr on October 25, 1989,-2A-A diesel generator (D/G) was declared inoperable as the result of voltage regulator problems. Action Statement (a) of LC0 3.8.1.1,,which requires, in part, that the remaining alternating current sources be periodically demonstrated to be operable. SI-7.1, " Diesel Generator AC Electrical Power Source Operability Verification (Diesel Generator /Offsite Source)," is used to fulfill this requirement. At 0410, D duringla performance-of SI-7.1 for D/G 2B-B, an assistant unit operator (AV0) in the D/G building noticed that the " power on" indicator light on the D/G local-control panel wasLburned out. While attempting to change the burned out , | | -AT 1748 ESTr on October 25, 1989,-2A-A diesel generator (D/G) was declared inoperable as the result of voltage regulator problems. Action Statement (a) of LC0 3.8.1.1,,which requires, in part, that the remaining alternating current sources be periodically demonstrated to be operable. SI-7.1, " Diesel Generator AC Electrical Power Source Operability Verification (Diesel Generator /Offsite Source)," is used to fulfill this requirement. At 0410, D duringla performance-of SI-7.1 for D/G 2B-B, an assistant unit operator (AV0) in the D/G building noticed that the " power on" indicator light on the D/G local-control panel wasLburned out. While attempting to change the burned out , |
| light bulb, a short occurred, blowing a control. power fuse and causing a loss u of D/G 2B-8 control power. When the control power was lost, the operators in the main' control room lost control of the 2B-B D/G. The control room operator Jattempted to trip the D/G manually using the emergency trip button, but could - | | light bulb, a short occurred, blowing a control. power fuse and causing a loss u of D/G 2B-8 control power. When the control power was lost, the operators in the main' control room lost control of the 2B-B D/G. The control room operator Jattempted to trip the D/G manually using the emergency trip button, but could - |
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| not stop;the D/G. The AUO in the D/G building was contacted and directed to : | | not stop;the D/G. The AUO in the D/G building was contacted and directed to : |
| trip'the D/G, but also could.not stop the D/G. | | trip'the D/G, but also could.not stop the D/G. |
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| {p Enclosure 2 , | | {p Enclosure 2 , |
| List of Commitments | | List of Commitments |
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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217M4461999-10-20020 October 1999 Forwards Rev 8 to Sequoyah Nuclear Plant Physical Security/ Contingency Plan, IAW 10CFR50.54(p).Encl Withheld,Per 10CFR73.21 ML20217J4151999-10-15015 October 1999 Forwards Request for Addl Info Re Util 990624 Application for Amend of TSs That Would Revise TS for Weighing of Ice Condenser Ice Baskets 05000327/LER-1999-002, Forwards LER 99-002-00 Re Start of Units 1 & 2 EDGs as Result of Cable Being Damaged During Installation of Thermo- Lag for Kaowool Upgrade Project1999-10-15015 October 1999 Forwards LER 99-002-00 Re Start of Units 1 & 2 EDGs as Result of Cable Being Damaged During Installation of Thermo- Lag for Kaowool Upgrade Project ML20217G1141999-10-0707 October 1999 Responds to from P Salas,Providing Response to NRC Risk Determination Associated with 990630 Flooding Event at Sequoyah Facility.Meeting to Discuss Risk Determination Issues Scheduled for 991021 in Atlanta,Ga ML20217B2981999-10-0606 October 1999 Discusses Closeout of GL 92-01,rev 1,suppl 1, Reactor Vessel Integrity, for Sequoyah Nuclear Plant,Units 1 & 2. NRC Also Hereby Solicits Any Written Comments That TVA May Have on Current Rvid Data by 991101 ML20217B8431999-10-0505 October 1999 Requests NRC Review & Approval of ASME Code Relief Requests That Were Identified in Plant Second 10-yr ISI Interval for Both Units.Encl 3 Provides Util Procedure for Calculation of ASME Code Coverage for Section XI Nondestructive Exams IR 05000327/19990041999-10-0101 October 1999 Ack Receipt of Providing Comments on Insp Repts 50-327/99-04 & 50-328/99-04.NRC Considered Comments for Apparent Violation Involving 10CFR50.59 Issue ML20217C7101999-10-0101 October 1999 Forwards Response to NRC 990910 RAI Re Sequoyah Nuclear Plant,Units 1 & 2 URI 50-327/98-04-02 & 50-328/98-04-02 Re Ice Weight Representative Sample ML20212J5981999-10-0101 October 1999 Forwards SE Accepting Request for Relief from ASME Boiler & Pressure Vessel Code,Section Xi,Requirements for Certain Inservice Insp at Plnat,Unit 1 ML20212M1081999-09-29029 September 1999 Confirms Intent to Meet with Utils on 991025 in Atlanta,Ga to Discuss Pilot Plants,Shearon Harris & Sequoyah Any Observations & Lessons Learned & Recommendations Re Implementation of Pilot Program ML20217A9451999-09-27027 September 1999 Forwards Insp Repts 50-327/99-05 & 50-328/99-05 on 990718- 0828.One Violation Identified & Being Treated as Non-Cited Violation ML20216J9351999-09-27027 September 1999 Responds to NRC Re Violations Noted in Insp Repts 50-327/99-04 & 50-328/99-04.Corrective Actions:Risk Determination Evaluation Was Performed & Licensee Concluded That Event Is in Green Regulatory Response Band ML20212F0751999-09-23023 September 1999 Forwards SER Granting Util 981021 Request for Relief from ASME Code,Section XI Requirements from Certain Inservice Insp at Sequoyah Nuclear Power Plant,Units 1 & 2 Pursuant to 10CFR50.55a(a)(3)(ii) ML20212F4501999-09-23023 September 1999 Forwards Amends 246 & 237 to Licenses DPR-77 & DPR-79, Respectively & Ser.Amends Approve Request to Revise TSs to Allow Use of Fully Qualified & Tested Spare Inverter in Place of Any of Eight Required Inverters ML20212M1911999-09-21021 September 1999 Discusses Exercise of Enforcement Discretion Re Apparent Violation Noted in Insp Repts 50-327/99-04 & 50-328/99-04 Associated with Implementation of Procedural Changes Which Resulted in Three Containment Penetrations Being Left Open ML20211Q0311999-09-10010 September 1999 Requests Written Documentation from TVA to Provide Technical Assistance to Region II Re TS Compliance & Ice Condenser Maint Practices at Plant ML20216F5441999-09-0707 September 1999 Provides Results of Risk Evaluation of 990630,flooding Event at Sequoyah 1 & 2 Reactor Facilities.Event Was Documented in Insp Rept 50-327/99-04 & 50-328/99-04 & Transmitted in Ltr, ML20211N5681999-09-0101 September 1999 Submits Clarification of Two Issues Raised in Insp Repts 50-327/99-04 & 50-328/99-04,dtd 990813,which Was First Insp Rept Issued for Plant Under NRC Power Reactor Oversight Process Pilot Plant Study ML20211G5881999-08-27027 August 1999 Submits Summary of 990820 Management Meeting Re Plant Performance.List of Attendees & Matl Used in Presentation Enclosed ML20211F8891999-08-25025 August 1999 Forwards Sequoyah Nuclear Plant Unit 1 Cycle 9 Refueling Outage, Re Completed SG Activities,Per TSs 4.4.5.5.b & 4.4.5.5.c ML20211A1851999-08-16016 August 1999 Forwards Proprietary TR WCAP-15128 & non-proprietary Rept WCAP-15129 for NRC Review.Repts Are Provided in Advance of TS Change That Is Being Prepared to Support Cycle 10 Rfo. Proprietary TR Withheld,Per 10CFR2.790 ML20210V1471999-08-13013 August 1999 Forwards Insp Repts 50-327/99-04 & 50-328/99-04 on 990601- 0717.One Potentially Safety Significant Issue Identified.On 990630,inadequate Performance of Storm Drain Sys Caused Water from Heavy Rainfall to Backup & Flood Turbine Bldg ML20211A1921999-08-12012 August 1999 Requests Proprietary TR WCAP-15128, Depth-Based SG Tube Repair Criteria for Axial PWSCC at Dented TSP Intersections, Be Withheld from Public Disclosure Per 10CFR2.790 ML20210Q5011999-08-0505 August 1999 Informs That NRC Plans to Administer Gfes of Written Operator Licensing Exam on 991006 at Sequoyah Nuclear Plant. Sample Registration Ltr Encl ML20210L4291999-08-0202 August 1999 Forwards Sequoyah Nuclear Plant Unit 2 Cycle 9 12-Month SG Insp Rept & SG-99-07-009, Sequoyah Unit-2 Cycle 10 Voltage-Based Repair Criteria 90-Day Rept. Repts Submitted IAW TS 4.4.5.5.b & TS 4.4.5.5.c ML20210L1611999-07-30030 July 1999 Forwards Request for Relief RV-4 Re ASME Class 1,2 & 3 Prvs, Per First ten-year Inservice Test Time Interval.Review & Approval of RV-4 Is Requested to Support Unit 1 Cycle 10 Refueling Outage,Scheduled to Start 000213 ML20210G5301999-07-28028 July 1999 Forwards Sequoyah Nuclear Plant Unit 2 ISI Summary Rept That Contains Historical Record of Repairs,Replacement & ISI & Augmented Examinations That Were Performed on ASME Code Class 1 & 2 Components from 971104-990511 ML20211B9661999-07-26026 July 1999 Informs That Sequoyah Nuclear Plant Sewage Treatment Plant, NPDES 0026450 Outfall 112,is in Standby Status.Flow Has Been Diverted from Sys Since Jan 1998 ML20210B2521999-07-14014 July 1999 Confirms 990712 Telcon Between J Smith of Licensee Staff & M Shannon of NRC Re semi-annual Mgt Meeting Schedule for 990820 in Atlanta,Ga to Discuss Recent Sequoyah Nuclear Plant Performance ML20210J1091999-07-10010 July 1999 Submits Suggestions & Concerns Re Y2K & Nuclear Power Plants ML20196K0381999-06-30030 June 1999 Provides Written Confirmation of Completed Commitment for Final Implementation of Thermo-Lag 330-1 Fire Barrier Corrective Actions at Snp,Per GL 92-08 ML20209E4071999-06-30030 June 1999 Forwards Insp Repts 50-327/99-03 & 50-328/99-03 on 990328- 0531.Violations Being Treated as Noncited Violations ML20196J8261999-06-28028 June 1999 Forwards Safety Evaluation Authorizing Request for Relief from ASME Boiler & Pressure Vessel Code,Section XI Requirements for Certain Inservice Inspections at Sequoyah Nuclear Plant,Units 1 & 2 ML20196G7881999-06-22022 June 1999 Informs NRC of Changes That Util Incorporated Into TS Bases Sections & Trm.Encl Provides Revised TS Bases Pages & TRM Affected by Listed Revs ML20196G1801999-06-21021 June 1999 Requests Termination of SRO License SOP-20751-1,for Lf Hardin,Effective 990611.Subject Individual Resigned from Position at TVA ML20195G1821999-06-0808 June 1999 Requests NRC Review & Approval of ASME Code Relief for ISI Program.Encl 1 Provides Relief Request 1-ISI-14 That Includes Two Attachments.Encl 2 Provides Copy of Related ASME Code Page ML20195E9521999-06-0707 June 1999 Requests Relief from Specific Requirements of ASME Section Xi,Subsection IWE of 1992 Edition,1992 Addenda.Util Has Determined That Proposed Alternatives Would Provide Acceptable Level of Quality & Safety ML20195E9311999-05-28028 May 1999 Informs of Planned Insp Activities for Licensee to Have Opportunity to Prepare for Insps & Provide NRC with Feedback on Any Planned Insps Which May Conflict with Plant Activities ML20195B3631999-05-21021 May 1999 Requests Termination of SRO License for Tj Van Huis,Per 10CFR50.74(a).TJ Van Huis Retired from Util,Effective 990514 ML20207A5721999-05-20020 May 1999 Forwards Correction to Previously Issued Amend 163 to License DPR-79 Re SR 4.1.1.1.1.d Inadvertently Omitted from Pp 3/4 1-1 of Unit 2 TS ML20206Q8791999-05-13013 May 1999 Forwards L36 9990415 802, COLR for Sequoyah Nuclear Plant Unit 2,Cycle 10, IAW Plant TS 6.9.1.14.c 05000327/LER-1999-001, Forwards LER 99-001-00 Re Condition That Resulted in Granting of Enforcement Discretion,Per Failure of Centrifugal Charging Pump.Condition Being Reported IAW 10CFR50.73(a)(2)(i)(B) & (a)(2)(iv)1999-05-11011 May 1999 Forwards LER 99-001-00 Re Condition That Resulted in Granting of Enforcement Discretion,Per Failure of Centrifugal Charging Pump.Condition Being Reported IAW 10CFR50.73(a)(2)(i)(B) & (a)(2)(iv) ML20206M9341999-05-10010 May 1999 Forwards Rept of SG Tube Plugging During Unit 2 Cycle 9 Refueling Outage,As Required by TS 4.4.5.5.a.ISI of Unit 2 SG Tubes Was Completed on 990503 ML20206K6271999-05-0606 May 1999 Requests Termination of SRO License for MR Taggart,License SOP-21336 Due to Resignation on 990430 ML20206J2061999-05-0404 May 1999 Requests Relief from Specified ISI Requirements in Section XI of ASME B&PV Code.Tva Requests Approval to Use Wire Type Penetrameters in Lieu of Plaque Type Penetrameters for Performing Radiographic Insps.Specific Relief Request,Encl ML20209J0391999-04-27027 April 1999 Forwards Annual Radioactive Effluent Release Rept, Radiological Impact Assessment Rept & Rev 41 to ODCM, for Period of Jan-Dec 1998 ML20206C6541999-04-23023 April 1999 Forwards Response to NRC 990127 RAI Re GL 96-05 for Sequoyah Nuclear Plant,Units 1 & 2 ML20206C0841999-04-23023 April 1999 Forwards Insp Repts 50-327/99-02 & 50-328/99-02 on 990214-0327.No Violations Noted ML20206B9591999-04-20020 April 1999 Responds to 990417 Request That NRC Exercise Discretion Not to Enforce Compliance with Actions Required in Unit 1 TS 3.1.2.2,3.1.2.4 & 3.5.2 & Documents 990417 Telephone Conversation When NRC Orally Issued NOED ML20205S5891999-04-17017 April 1999 Documents Request for Discretionary Enforcement for Unit 1 TS LCOs 3.1.2.2,3.1.2.4 & 3.5.2 to Support Completion of Repairs & Testing for 1B-B Centrifugal Charging Pump (CCP) 1999-09-07
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML20217M4461999-10-20020 October 1999 Forwards Rev 8 to Sequoyah Nuclear Plant Physical Security/ Contingency Plan, IAW 10CFR50.54(p).Encl Withheld,Per 10CFR73.21 05000327/LER-1999-002, Forwards LER 99-002-00 Re Start of Units 1 & 2 EDGs as Result of Cable Being Damaged During Installation of Thermo- Lag for Kaowool Upgrade Project1999-10-15015 October 1999 Forwards LER 99-002-00 Re Start of Units 1 & 2 EDGs as Result of Cable Being Damaged During Installation of Thermo- Lag for Kaowool Upgrade Project ML20217B8431999-10-0505 October 1999 Requests NRC Review & Approval of ASME Code Relief Requests That Were Identified in Plant Second 10-yr ISI Interval for Both Units.Encl 3 Provides Util Procedure for Calculation of ASME Code Coverage for Section XI Nondestructive Exams ML20217C7101999-10-0101 October 1999 Forwards Response to NRC 990910 RAI Re Sequoyah Nuclear Plant,Units 1 & 2 URI 50-327/98-04-02 & 50-328/98-04-02 Re Ice Weight Representative Sample ML20216J9351999-09-27027 September 1999 Responds to NRC Re Violations Noted in Insp Repts 50-327/99-04 & 50-328/99-04.Corrective Actions:Risk Determination Evaluation Was Performed & Licensee Concluded That Event Is in Green Regulatory Response Band ML20211N5681999-09-0101 September 1999 Submits Clarification of Two Issues Raised in Insp Repts 50-327/99-04 & 50-328/99-04,dtd 990813,which Was First Insp Rept Issued for Plant Under NRC Power Reactor Oversight Process Pilot Plant Study ML20211F8891999-08-25025 August 1999 Forwards Sequoyah Nuclear Plant Unit 1 Cycle 9 Refueling Outage, Re Completed SG Activities,Per TSs 4.4.5.5.b & 4.4.5.5.c ML20211A1851999-08-16016 August 1999 Forwards Proprietary TR WCAP-15128 & non-proprietary Rept WCAP-15129 for NRC Review.Repts Are Provided in Advance of TS Change That Is Being Prepared to Support Cycle 10 Rfo. Proprietary TR Withheld,Per 10CFR2.790 ML20211A1921999-08-12012 August 1999 Requests Proprietary TR WCAP-15128, Depth-Based SG Tube Repair Criteria for Axial PWSCC at Dented TSP Intersections, Be Withheld from Public Disclosure Per 10CFR2.790 ML20210L4291999-08-0202 August 1999 Forwards Sequoyah Nuclear Plant Unit 2 Cycle 9 12-Month SG Insp Rept & SG-99-07-009, Sequoyah Unit-2 Cycle 10 Voltage-Based Repair Criteria 90-Day Rept. Repts Submitted IAW TS 4.4.5.5.b & TS 4.4.5.5.c ML20210L1611999-07-30030 July 1999 Forwards Request for Relief RV-4 Re ASME Class 1,2 & 3 Prvs, Per First ten-year Inservice Test Time Interval.Review & Approval of RV-4 Is Requested to Support Unit 1 Cycle 10 Refueling Outage,Scheduled to Start 000213 ML20210G5301999-07-28028 July 1999 Forwards Sequoyah Nuclear Plant Unit 2 ISI Summary Rept That Contains Historical Record of Repairs,Replacement & ISI & Augmented Examinations That Were Performed on ASME Code Class 1 & 2 Components from 971104-990511 ML20210J1091999-07-10010 July 1999 Submits Suggestions & Concerns Re Y2K & Nuclear Power Plants ML20196K0381999-06-30030 June 1999 Provides Written Confirmation of Completed Commitment for Final Implementation of Thermo-Lag 330-1 Fire Barrier Corrective Actions at Snp,Per GL 92-08 ML20196G7881999-06-22022 June 1999 Informs NRC of Changes That Util Incorporated Into TS Bases Sections & Trm.Encl Provides Revised TS Bases Pages & TRM Affected by Listed Revs ML20196G1801999-06-21021 June 1999 Requests Termination of SRO License SOP-20751-1,for Lf Hardin,Effective 990611.Subject Individual Resigned from Position at TVA ML20195G1821999-06-0808 June 1999 Requests NRC Review & Approval of ASME Code Relief for ISI Program.Encl 1 Provides Relief Request 1-ISI-14 That Includes Two Attachments.Encl 2 Provides Copy of Related ASME Code Page ML20195E9521999-06-0707 June 1999 Requests Relief from Specific Requirements of ASME Section Xi,Subsection IWE of 1992 Edition,1992 Addenda.Util Has Determined That Proposed Alternatives Would Provide Acceptable Level of Quality & Safety ML20195B3631999-05-21021 May 1999 Requests Termination of SRO License for Tj Van Huis,Per 10CFR50.74(a).TJ Van Huis Retired from Util,Effective 990514 ML20206Q8791999-05-13013 May 1999 Forwards L36 9990415 802, COLR for Sequoyah Nuclear Plant Unit 2,Cycle 10, IAW Plant TS 6.9.1.14.c 05000327/LER-1999-001, Forwards LER 99-001-00 Re Condition That Resulted in Granting of Enforcement Discretion,Per Failure of Centrifugal Charging Pump.Condition Being Reported IAW 10CFR50.73(a)(2)(i)(B) & (a)(2)(iv)1999-05-11011 May 1999 Forwards LER 99-001-00 Re Condition That Resulted in Granting of Enforcement Discretion,Per Failure of Centrifugal Charging Pump.Condition Being Reported IAW 10CFR50.73(a)(2)(i)(B) & (a)(2)(iv) ML20206M9341999-05-10010 May 1999 Forwards Rept of SG Tube Plugging During Unit 2 Cycle 9 Refueling Outage,As Required by TS 4.4.5.5.a.ISI of Unit 2 SG Tubes Was Completed on 990503 ML20206K6271999-05-0606 May 1999 Requests Termination of SRO License for MR Taggart,License SOP-21336 Due to Resignation on 990430 ML20206J2061999-05-0404 May 1999 Requests Relief from Specified ISI Requirements in Section XI of ASME B&PV Code.Tva Requests Approval to Use Wire Type Penetrameters in Lieu of Plaque Type Penetrameters for Performing Radiographic Insps.Specific Relief Request,Encl ML20209J0391999-04-27027 April 1999 Forwards Annual Radioactive Effluent Release Rept, Radiological Impact Assessment Rept & Rev 41 to ODCM, for Period of Jan-Dec 1998 ML20206C6541999-04-23023 April 1999 Forwards Response to NRC 990127 RAI Re GL 96-05 for Sequoyah Nuclear Plant,Units 1 & 2 ML20205S5891999-04-17017 April 1999 Documents Request for Discretionary Enforcement for Unit 1 TS LCOs 3.1.2.2,3.1.2.4 & 3.5.2 to Support Completion of Repairs & Testing for 1B-B Centrifugal Charging Pump (CCP) ML20205B1091999-03-19019 March 1999 Submits Response to NRC Questions Concerning Lead Test Assembly Matl History,Per Request ML20204H0161999-03-19019 March 1999 Resubmits Util 990302 Response to Violations Noted in Insp Repts 50-327/98-11 & 50-328/98-11.Corrective Actions:Lessons Learned from Event Have Been Provided to Operating Crews ML20204E8251999-03-0505 March 1999 Forwards Sequoyah Nuclear Plant,Four Yr Simulator Test Rept for Period Ending 990321, in Accordance with Requirements of 10CFR55.45 ML20207E6851999-03-0202 March 1999 Responds to NRC Re Violations Noted in Insp Repts 50-327/98-11 & 50-328/98-11.Corrective Actions:Lessons Learned from Event Have Been Provided to Operating Crews ML20207J1171999-01-29029 January 1999 Forwards Copy of Final Exercise Rept for Full Participation Ingestion Pathway Exercise of Offsite Radiological Emergency Response Plans site-specific to Sequoyah NPP ML20202A7141999-01-20020 January 1999 Provides Request for Relief for Delaying Repair on Section of ASME Code Class 3 Piping within Essential Raw Cooling Water Sys ML20198S7141998-12-29029 December 1998 Forwards Cycle 10 Voltage-Based Repair Criteria 90-Day Rept, Per GL 95-05.Rept Is Submitted IAW License Condition 2.C.(9)(d) 05000327/LER-1998-004, Forwards LER 98-004-00,providing Details Concerning Inability to Complete Surveillance within Required Time Interval1998-12-21021 December 1998 Forwards LER 98-004-00,providing Details Concerning Inability to Complete Surveillance within Required Time Interval ML20198D5471998-12-14014 December 1998 Requests That License OP-20313-2 for Je Wright,Be Terminated IAW 10CFR50.74(a).Individual Retiring ML20197J5541998-12-10010 December 1998 Forwards Unit 1 Cycle 9 90-Day ISI Summary Rept IAW IWA-6220 & IWA-6230 of ASME Code,Section Xi.Request for Relief Will Be Submitted to NRC Timeframe to Support Second 10-year Insp Interval,Per 10CFR50.55a 05000327/LER-1998-003, Forwards LER 98-003-00 Re Automatic Reactor Trip with FW Isolation & Auxiliary FW Start as Result of Failure of Vital Inverter & Second Inverter Failure.Event Is Being Reported IAW 10CFR50.73(a)(2)(iv)1998-12-0909 December 1998 Forwards LER 98-003-00 Re Automatic Reactor Trip with FW Isolation & Auxiliary FW Start as Result of Failure of Vital Inverter & Second Inverter Failure.Event Is Being Reported IAW 10CFR50.73(a)(2)(iv) ML20196F9841998-11-25025 November 1998 Provides Changes to Calculated Peak Fuel Cladding Temp, Resulting from Recent Changes to Plant ECCS Evaluation Model ML20195H7891998-11-17017 November 1998 Requests NRC Review & Approval of Five ASME Code Relief Requests Identified in Snp Second ten-year ISI Interval for Units 1 & 2 ML20195E4991998-11-12012 November 1998 Forwards Rev 7 to Physical Security/Contingency Plan.Rev Adds Requirement That Security Personnel Will Assess Search Equipment Alarms & Add Definition of Major Maint.Rev Withheld (Ref 10CFR2.790(d)(1)) 05000328/LER-1998-002, Forwards LER 98-002-00 Re Automatic Turbine & Reactor Trip, Resulting from Failure of Sudden Pressure Relay on 'B' Phase Main Transformer1998-11-10010 November 1998 Forwards LER 98-002-00 Re Automatic Turbine & Reactor Trip, Resulting from Failure of Sudden Pressure Relay on 'B' Phase Main Transformer ML20195G5701998-11-10010 November 1998 Documents Util Basis for 981110 Telcon Request for Discretionary Enforcement for Plant TS 3.8.2.1,Action B,For 120-VAC Vital Instrument Power Board 1-IV.Licensee Determined That Inverter Failed Due to Component Failure ML20155J4031998-11-0505 November 1998 Provides Clarification of Topical Rept Associated with Insertion of Limited Number of Lead Test Assemblies Beginning with Unit 2 Operating Cycle 10 Core ML20154R9581998-10-21021 October 1998 Requests Approval of Encl Request for Relief ISI-3 from ASME Code Requirements Re Integrally Welded Attachments of Supports & Restraints for AFW Piping ML20155B1481998-10-21021 October 1998 Informs That as Result of Discussion of Issues Re Recent Events in Ice Condenser Industry,Ice Condenser Mini-Group (Icmg),Decided to Focus Efforts on Review & Potential Rev of Ice condenser-related TS in Order to Clarify Issues ML20154K1581998-10-13013 October 1998 Forwards Rept Re SG Tube Plugging Which Occurred During Unit 1 Cycle 9 Refueling Outage,Per TS 4.4.5.5.a.ISI of Unit 1 SG Was Completed on 980930 ML20154H6191998-10-0808 October 1998 Forwards Rev 0 to Sequoyah Nuclear Plant Unit 1 Cycle 10 COLR, IAW TS 6.9.1.14.c 05000328/LER-1998-001, Forwards LER 98-001-00 Providing Details Re Automatic Turbine & Reactor Trip Due to Failure of Sudden Pressure Relay on 'B' Phase Main Transformer1998-09-28028 September 1998 Forwards LER 98-001-00 Providing Details Re Automatic Turbine & Reactor Trip Due to Failure of Sudden Pressure Relay on 'B' Phase Main Transformer ML20151W4901998-09-0303 September 1998 Responds to NRC Re Violations Noted in Insp Repts 50-327/98-07 & 50-328/98-07.Corrective Actions:Revised Per SQ971279PER to Address Hardware Issues of Hysteresis, Pressure Shift & Abnormal Popping Noise 1999-09-27
[Table view] Category:UTILITY TO NRC
MONTHYEARML20059K6661990-09-17017 September 1990 Forwards Evaluation That Provides Details of Plug Cracks & Justification for Continued Operation Until 1993 ML20059H4031990-09-10010 September 1990 Discusses Plant Design Baseline & Verification Program Deficiency D.4.3-3 Noted in Insp Repts 50-327/86-27 & 50-328/86-27.Evaluation Concluded That pre-restart Walkdown Data,Loops 1 & 2 Yielded Adequate Design Input ML20059E1851990-08-31031 August 1990 Responds to NRC Re Violations Noted in Insp Repts 50-327/90-22 & 50-328/90-22.Corrective Actions:Extensive Mgt Focus Being Applied to Improve Overtime Use Controls ML20059E2881990-08-31031 August 1990 Forwards Addl Info Re Alternate Testing of Reactor Vessel Head & Internals Lifting Rigs,Per NUREG-0612.Based on Listed Hardships,Util Did Not Choose 150% Load Test Option ML20059H1831990-08-31031 August 1990 Forwards Nonproprietary PFE-F26NP & Proprietary PFE-F26, Sequoyah Nuclear Plan Unit 1,Cycle 5 Restart Physics Test Summary, Re Testing Following Vantage 5H Fuel Assembly installation.PFE-F26 Withheld (Ref 10CFR2.790(b)(4)) ML18033B5031990-08-31031 August 1990 Forwards Financial Info Required to Assure Retrospective Premiums,Per 10CFR140 & 771209 Ltr ML20028G8341990-08-28028 August 1990 Forwards Calculation SCG1S361, Foundation Investigation of ERCW Pumping Station Foundation Cells. ML20063Q2471990-08-20020 August 1990 Submits Implementation Schedule for Cable Tray Support Program.Util Proposes Deferral of Portion of Remaining Activities Until After Current Unit 2 Cycle 4 Refueling Outage,Per 900817 Meeting.Tva Presentation Matl Encl ML20056B5181990-08-20020 August 1990 Responds to NRC Re Order Imposing Civil Monetary Penalty & Violations Noted in Insp Repts 50-327/90-01 & 50-328/90-01.Corrective Actions:Organizational Capabilities Reviewed.Payment of Civil Penalty Wired to NRC ML20063Q2461990-08-17017 August 1990 Forwards Cable Test Program Resolution Plan to Resolve Issues Re Pullbys,Jamming & Vertical Supported Cable & TVA- Identified Cable Damage.Tva Commits to Take Actions Prior to Startup to Verify Integrity of safety-related Cables ML20059A5121990-08-15015 August 1990 Provides Clarification of Implementation of Replacement Items Project at Plant for Previously Procured Warehouse Inventory.Util Committed to 100% Dedication of Commercial Grade,Qa,Level Ii,Previous Procurement Warehouse Spare ML20058M2321990-08-0707 August 1990 Forwards Rept of 900709 Fishkill,Per Requirements in App B, Environ Tech Spec,Subsections 4.1.1 & 5.4.2.Sudden Water Temp Increase Killed Approximately 150 Fish in Plant Diffuser Pond ML20058N2361990-08-0707 August 1990 Confirms That Requalification Program Evaluation Ref Matl Delivered to Rd Mcwhorter on 900801.Ref Matl Needed to Support NRC Preparation for Administering Licensed Operator Requalification Exams in Sept 1990 ML20058M4471990-07-27027 July 1990 Responds to Unresolved Items Which Remain Open from Insp Repts 50-327/90-18 & 50-328/90-18.TVA in Agreement W/Nrc on Scope of Work Required to Address Concerns W/Exception of Design Basis Accident & Zero Period Accelaration Effects ML20058M0111990-07-27027 July 1990 Forwards Addl Info Re Plant Condition Adverse to Quality Rept Concerning Operability Determination.Probability of Cable Damage During Installation Low.No Programmatic Cable Installation Problems Exist ML20055J3531990-07-27027 July 1990 Forwards Revised Commitment to Resolve EOP Step Deviation Document Review Comments ML20055J0771990-07-26026 July 1990 Requests Termination of Senior Reactor Operator License SOP-20830 for Jh Sullivan Due to Resignation from Util ML20055G6611990-07-17017 July 1990 Forwards Justification for Continued Operation for safety- Related Cables Installed at Plant,Per 900717 Telcon.No Operability Concern Exists at Plant & No Programmatic Problems Have Been Identified.Summary of Commitments Encl ML20058L7001990-07-16016 July 1990 Forwards Response to SALP Repts 50-327/90-09 & 50-328/90-09 for 890204 - 900305,including Corrective Actions & Improvements Being Implemented ML20055F6151990-07-13013 July 1990 Provides Addl Bases for Util 900320 Proposal to Discontinue Review to Identify Maint Direct Charge molded-case Circuit Breakers Procured Between Aug 1983 & Dec 1984,per NRC Bulletin 88-010.No Significant Assurance Would Be Expected ML20044B2211990-07-12012 July 1990 Forwards Addl Info Clarifying Certain Conclusions & Recommendation in SER Re First 10-yr Interval Inservice Insp Program ML20055D2531990-07-0202 July 1990 Provides Status of Q-list Development at Plant & Revises Completion Date for Effort.Implementation of Q-list Would Cause Unnecessary & Costly Delays in Replanning Maint,Mod, outage-related Activities & Associated Procedure Revs ML20043H9061990-06-21021 June 1990 Responds to Generic Ltr 90-04, Request for Info on Status of Licensee Implementaion of Generic Safety Issues Resolved W/Imposition or Requirements or Corrective Actions. No Commitments Contained in Submittal ML20043H2281990-06-18018 June 1990 Informs of Issue Recently Identified During Startup of Facility from Cycle 4 Refueling Outage & How Issue Addressed to Support Continued Escalation to 100% Power,Per 900613 & 14 Telcons ML20043G4901990-06-14014 June 1990 Forwards Tabs for Apps a & B to Be Inserted Into Util Consolidated Nuclear Power Radiological Emergency Plan ML20043F9261990-06-13013 June 1990 Responds to NRC Bulletin 89-002, Stress Corrosion Cracking of High-Hardness Type 410 Stainless Steel Internal Preloaded Bolting in Anchor/Darling Model S3502 Swing Check Valves or Valves of Similar Design. ML20043F9301990-06-13013 June 1990 Responds to NRC 900516 Ltr Re Violations Noted in Insp Repts 50-327/90-17 & 50-328/90-17.Corrective Action:Test Director & Supervisor Involved Given Appropriate Level of Disciplinary Action ML20043H0361990-06-11011 June 1990 Forwards Supplemental Info Re Unresolved Item 88-12-04 Addressing Concern W/Double Differentiation Technique Used to Generate Containment Design Basis Accident Spectra,Per 900412 Request ML20043D9921990-06-0505 June 1990 Responds to NRC 900507 Ltr Re Violations Noted in Insp Repts 50-327/90-14 & 50-328/90-14.Corrective Actions:Util Reviewed Issue & Determined That Trains a & B Demonstrated Operable in Jan & Apr,Respectively of 1989 ML20043C2821990-05-29029 May 1990 Requests Relief from ASME Section XI Re Hydrostatic Pressure Test Requirements Involving RCS & Small Section of Connected ECCS Piping for Plant.Replacement & Testing of Check Valve 1-VLV-63-551 Presently Scheduled for Completion on 900530 ML20043C0581990-05-29029 May 1990 Forwards Response to NRC 900426 Ltr Re Violations Noted in Insp Repts 50-327/90-15 & 50-328/90-15.Response Withheld (Ref 10CFR73.21) ML20043B3051990-05-22022 May 1990 Forwards Detailed Scenario for 900711 Radiological Emergency Plan Exercise.W/O Encl ML20043B1201990-05-18018 May 1990 Forwards, Diesel Generator Voltage Response Improvement Rept. Combined Effect of Resetting Exciter Current Transformers to Achieve flat-compounding & Installing Electronic Load Sequence Timers Produced Acceptable Voltage ML20043A6101990-05-15015 May 1990 Forwards Rev 16 to Security Personnel Training & Qualification Plan.Rev Withheld (Ref 10CFR2.790) ML20043A2391990-05-15015 May 1990 Forwards Revised Tech Spec Pages to Support Tech Spec Change 89-27 Re Steam Generator Water Level Adverse Trip Setpoints for Reactor Trip Sys Instrumentation & Esfas. Encl Reflects Ref Leg Heatup Environ Allowance ML20043A0581990-05-11011 May 1990 Forwards Cycle 5 Redesign Peaking Factor Limit Rept for Facility.Unit Redesigned During Refueling Outage Due to Removal & Replacement of Several Fuel Assemblies Found to Contain Leaking Fuel Rods ML20043A0571990-05-10010 May 1990 Forwards List of Commitments to Support NRC Review of Eagle 21 Reactor Protection Sys Function Upgrade,Per 900510 Telcon ML20042G9771990-05-0909 May 1990 Responds to NRC 900412 Ltr Re Violations Noted in Insp Repts 50-327/90-01 & 50-328/90-01 & Proposed Imposition of Civil Penalty.Corrective Actions:Rhr Pump 1B-B Handswitch in pull- to-lock Position to Ensure One Train of ECCS Operable ML20042G4651990-05-0909 May 1990 Provides Addl Info Re Plant Steam Generator Low Water Level Trip Time Delay & Function of P-8 Reactor Trip Interlock,Per 900430 Telcon.Trip Time Delay Does Not Utilize P-8 Interlock in Any Manner ML20042G4541990-05-0909 May 1990 Provides Notification of Steam Generator Tube Plugging During Unit 1 Cycle 4 Refueling Outage,Per Tech Specs 4.4.5.5.a.Rept of Results of Inservice Insp to Be Submitted by 910427.Summary of Tubes Plugged in Unit 1 Encl ML20042G0441990-05-0808 May 1990 Forwards Nonproprietary WCAP-11896 & WCAP-8587,Suppl 1 & Proprietary WCAP-8687,Suppls 2-E69A & 2-E69B & WCAP-11733 Re Westinghouse Eagle 21 Process Protection Sys Components Equipment Qualification Test Rept.Proprietary Rept Withheld ML20042G1431990-05-0808 May 1990 Forwards WCAP-12588, Sequoyah Eagle 21 Process Protection Sys Replacement Hardware Verification & Validation Final Rept. Info Submitted in Support of Tech Spec Change 89-27 Dtd 900124 ML20042G1001990-05-0808 May 1990 Forwards Proprietary WCAP 12504 & Nonproprietary WCAP 12548, Summary Rept Process Protection Sys Eagle 21 Upgrade,Rtd Bypass Elimination,New Steam Line Break Sys,Medical Signal Selector .... Proprietary Rept Withheld (Ref 10CFR2.790) ML20042G1701990-05-0808 May 1990 Provides Addl Info Re Eagle 21 Upgrade to Plant Reactor Protection Sys,Per 900418-20 Audit Meeting.Partial Trip Output Board Design & Operation Proven by Noise,Fault,Surge & Radio Frequency Interference Testing Noted in WCAP-11733 ML20042G1231990-05-0707 May 1990 Forwards Detailed Discussion of Util Program & Methodology Used at Plant to Satisfy Intent of Reg Guide 1.97,Rev 2 Re Licensing Position on post-accident Monitoring ML20042F7741990-05-0404 May 1990 Informs of Completion of Eagle 21 Verification & Validation Activities Re Plant Process Protection Sys Upgrade.No Significant Disturbances Noted from NRC Completion Date of 900420 ML20042F1691990-05-0303 May 1990 Responds to NRC Bulletin 88-009, Thimble Tube Thinning in Westinghouse Electric Corporation Reactors. Wear Acceptance Criteria Established & Appropriate Corrective Actions Noted. Criteria & Corresponding Disposition Listed ML20042G1381990-04-26026 April 1990 Forwards Westinghouse 900426 Ltr to Util Providing Supplemental Info to Address Questions Raised by NRC Re Eagle-21 Process Protection Channels Required for Mode 5 Operation at Facilities ML20042E9641990-04-26026 April 1990 Forwards Rev 24 to Physical Security/Contingency Plan.Rev Withheld (Ref 10CFR73.21) ML20012E6181990-03-28028 March 1990 Discusses Reevaluation of Cable Pullby Issue at Plant in Light of Damage Discovered at Watts Bar Nuclear Plant. Previous Conclusions Drawn Re Integrity of Class 1E Cable Sys Continue to Be Valid.Details of Reevaluation Encl 1990-09-17
[Table view] |
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s TENNESSEE VALLEY- AUTHORITY
- 4J > l*I CHATTANOOGA. TENNESSEE 37401-6N.38A Lookout Place
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DEB 261989 7
l U.S. Nuclear Regulatory Commission
. ATTN: Document Control Desk l Hashington, D.C.-- 20555 C
Gentlemen:
In the Matter of- ) Docket Nos. 50-327 Tennessee Valley' Authority ) 50-328 SEQUOYAH NUCLEAR PLANT-(SQN) - NRC INSPECTION REPORT NOS. 50-327; 328/89 s REPLY T0 NOTICE Of VIOLATION Enclosed is~TVA's response to B. A. Wilson's letter to 0. D. Kingsley, Jr., ,
dated December 7,1989, which transmitted the subject notice of violation. :
. Enclosure 1 provides TVA's response to the notice of violation. A summary ,
statement of the commitments contained in this submittal are provided in Enclosure-2.- 4
'If you have any questions concerning-this submittal, please telephone A. M. A. Cooper at (615) 843-6651.
Very truly yours, TENNESSEE VALLEY AUTHORITY- r h,
Mark 0. Medford, Vice President Nuclear Technology and Licensing L- Enclosures cc: See-page 2 l
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An Equal Opportunity Employer
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. _t).S.tNuclear Regulatory Commission- DEC 261989 .
r cc (Enclosures):
Ms. S. C. Black, Assistant Director for Projects TVA Projects Division U.S. Nuclear Regulatory Commission >
One White Flint, North r 11555 Rockville Pike Rockville, Maryland 20852 Mr. B. A. H11 son, Assistant Director for Inspection Programs TVA Projects Division U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 NRC Resident Inspector Sequoyah Nuclear Plant '
2600 Igou Ferry Road Soddy Daisy, Tennessee 37379 l
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ENCLOSURE l'
' RESPONSE TO NRC INSPECTION REPORT NOS, 50-327/89-25 AND 50-328/89-25 B. A. HILSON'S LETTER -T0 0. D. KINGSLEY, JR. ,
DATED DECEMBER 7,.1989
.,- Violation. 50-327, 328/89-25-01 "A. Technical Specification 6.8.1 states that, written procedures shall be established, implemented and maintained covering surveillance and test activities of safety-related equipment. I Section 4.9 and the associated flow chart of Instruction Change Form (ICF) 89-0758 to procedure SI-137.2, Reactor Coolant System Water a Inventory, requires that, If the unidentified leakage calculation results in a negative value, then the calculations will be reperformed using a minimum of one hour of additional data, j
Contrary to the above, on October 18, 1989, the reactor operators I completed the performance of SI-137.2 at 7:26 a.m., when the calculated l unidentified ' leak rate was negative, without taking the additional data j as required by section 4.9 of ICF 89-0758, 3 This'is a Severity Level IV violation (Supplement I)."
Admission or Denial of the Alleged Violation TVA admits the violation.
Reason for'the Violation f
A spetlal performance of Surveillance Instruction (SI) 137.2, " Reactor Coolant j System Water Inventory," was conducted on Unit 2 from 0351 to 0726-Eastern i standard-timeL(EST) on October 18, 1989, because of an increased radiation j reading.in the lower containment. The unidentifled leakage calculated after i obtaining two hours of data was -0.06 gallon per minute (gal / min), which was l within the acceptance criteria for unidentified leakage (less than 1.0 gal / min i but greater than -0.10 gal / min). Two hours is the minimum duration of data l collection for performing the SI. Completion of the SI was expedited because l it.was being performed to determine whether the increased lower containment j radiation reading was the result of reactor coolant system leakage. However, p the SI contained a stipulation that negatively valued unidentified leakage I (within the acceptance criteria) could be accepted only after continuing data !
collection for a minimum of one additional hour. Thus, the SI was completed l prematurely after two hours of data collection when it should have continued l l, for at least one additional hour, g it The reason for the violction was inadequate attention te detail by the personnel performing the SI in that the additional hour of data collection l
stipulated in the procedure was not performed. A contributing cause for the violation may have been that the procedure being used to perform this surveillance was not clear. At the time this violation occurred, four ICFs had accrued in SI-137.2, which resulted in a patchwork procedure that no l
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r longer provided clear, step-by-step instructions to the performer of the surveillance. An ICF is an administrative vehicle for making urgently needed changes _to site procedures. An ICF is generally processed with handwritten changes on the affected pages, which are incorporated into the procedure by-page substitution.
Corrective Steps That Have Been Taken and Results Achieved The Operations Superintendent has-administered the appropriate level of disciplinary action to the shift personnel responsible for the failure to properly perform SI-137.2 or to properly document that the results of the test were not valid to use for.-surveillance requirement compliance. ;
r i' Corrective' Steps That Will Be Taken to Avoid Further Violations SI-137.2 is-being revised as part of an SI enhancement effort to incorporate [
the ICFs into a more clearly understandable text. The revision has been ;
drafted and is in the review and comment cycle. This revision is expected to 'l be completed by January 26, 1990. 1 L- Date When Full Compliance Will Be Achieved
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TVA is in full compilance. Corrective steps will be completed by ;
January 26, 1990.
1 Violation 50-327. 328/89-25-02 l
"B. Technical Specification 6.8.1 states that, written procedures shall be "
established, implemented and maintained covering surveillance and test activities of safety-related equipment. <
TI-37, Radiochemical Laboratory Sampling and Logsheets, action IV '
requires that corrective actions as specified by the Technical Specifications should be performed if the RHST concentration is greater than 2100 or less than 2000 ppm boron. Additionally, TI-37 requires that the actions of SI-51, Weekly Chemistry Requirements, be followed after a resample confirms a condition that does not meet acceptance criteria.
SI-51 requires the performer to notify the shift operating supervisor (505) if the data does not satisfy the acceptance criteria.
Contrary to the above, on October 20, 1989 by 8:15 a.m., the licensee had drawn 2 samples from the Unit 2 RHST and determined the boron 1 concentration to be below 2000 ppm and did not inform the SOS of this fact.
This is a Severity Level IV violation (Supplement I)."
Admission or Denial of the All ged Vio.lation TVA admits the violation. )
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Reason for the Violation At approximately 0630 EST on October 20, 1989, during performance of SI-51, l "Heekly Chemistry Requirements," the analyst in the Radiochemistry Laboratory obtained test results of 1,952 parts per million (ppm) boron for the Unit 2 refueling water storage tank (RHST). The RHST boron concentration required by Limiting Condition for Optration (LCO) 3.1.2.6 is between 2,000 and ,
2,100 ppm. In accordance with the requirements of both Sequoyah Standard Practice SQE22, "Sequoyah Nuclear Plant Chemistry Program," and Technical Instruction 37, " Radiochemical Laboratory Sampling and Log Sheets," a second sample was obtained at 0735 for analysis to verify the results of the first sample. At 0815, the results of the second sample showed 1,971 ppm boron. ,
i At approximately 0816, the Secondary Chemistry Manager arrived and was briefed on the RHST test results. This manager reviewed the analytical results, along i with the standardization results, and questioned the validity of the analysis. Changes had been made to the chemistry analytical procedure three ,
days prior to this event that had changed the standards used to bracket the j expected sample boron concentration. Prior to the change, 1,000 ppm and l 3,000 ppm standards were specified while after the change 100 ppm and ;
3,000 ppm standards were specified. Suspecting that there was an analytical l problem rather than an actual RHST boron concentration problem, the Secondary {
Chemistry Manager asked the analyst to run a 1,000 ppm standard as a check, ,
and also asked the Chemistry shift supervisor to call the SOS to brief him on j the situation and to tell him that Chemistry was looking into it and.would get -
back to him as soon as possible. The SOS was telephoned at 0819 and told of the problem with the RHST boron concentration and that the analysis would be reverified. The Chemistry shift supervisor did not make it clear that the results were based on two samples. As a result, the SOS did not enter the LCO. At approximately 0845, the 1,000 ppm standard showed an analysis result of 956 ppm, which is below the 1-percent control limit. The standard being below the 1-percent control limit volded the previous analysis results and confirmed that the problem was analytical as had been suspected. At 0850, the ,
SOS was informed about the boron standardization problem. The SOS confirmed !
that the RHST level had not changed since the last weekly boron concentration surveillance. (At least a 3-percent level change would be required to dilute (
the tank to the lower boron concentration.) l Having confirmed an analytical problem, troubleshooting efforts were initiated to isolate and correct the source of the problem. Following a full recalibration of both boron titrators in the laboratory using new potential H(ydrogen-lon) activity (pH) buffers and restandardized sodium hydroxide l titrant, both the 1,000 ppm and 3,000 ppm standards were within specification. At 1025, the first RHST sample was reanalyzed and determined to contain 2025 and 2048 ppm boron with the two titrators in the laboratory.
At 1029, Operations was notified of the first sample reanalysis results. At 1050, the second RHST sample was reanalyzed and determined to contain 2,038 ppm boron. At 1100, the first sample was delivered to the laboratory at the Power Training Center (PTC) for independent analysis. At 1300, the PIC laboratory reported two test results of 2036 and 2037 ppm on thc fitst sample, confirming the results obtained at the SQN laboratory at 1025. In addition, a third sample was obtained from the Unit 2 RHST at 1235 for confirmatory
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p _4 L analysis. At 1305, this sample was determined to contain 2043 ppm boron. At 1310, the Chemistry shif t supervisor notified the SOS of the independent PTC results and of the test results for the confirmatory third sample.
F The reason for the violation was a failure by the Chemistry shift supervisor to make clear in the 0819 report to the SOS that the analytical results were based on two separate samples. Had this been made clear, LCO 3.5.5 would have been entered. The cause.of the unacceptable boron concentration results was '
that the range of standards used to bracket the expected sample boron concentration was too wide (100-3,000 ppm versus 1,000-3,000 ppm) and the 100 ppm standard had too wide'an acceptance criterion. The changes to the chemistry analytical procedure had been made without adequate validation.
Corrective Steps That Have Been Taken and Results Achieved The appropriate Chemistry personnel have been counselled as to the importance of complete and timely notification of the SOS with information needed to make plant operational decisions. The individual responsible for changing the range of standards used to bracket the expected boron concentration and those persons responsible for reviewing the procedure change have been given the appropriate level of disciplinary action.
In addition, as immediate corrective action, a night order was issued giving explicit instructions to ensure that any boron standardization would more closely bracket the boron concentration being analyzed.
Corrective Step' That Hill Be Taken to Avoid further Violation Sequoyah Standard Practice SQE22 will be revised by January 31, 1990, to clarify that the SOS should be notified af ter the results of the first sample, even though there may be open issues relative to sample or analysis quality.
These issues.will be provided to the SOS so that he has that information for an LCO call. A night order is already in effect stating this prior to the procedure revision.
Date When Full Compliance Hill Be Q.hieved TVA is in full compilance.
Violation 50-327, 328/89-25-04 "C. Technical Specification 6.8.1.e states that written procedures shall be established, implemented and maintained covering site Radiological Emergency Plan (REP) implementation.
The Sequoyah Radiological Emergency Plan implementing procedure (EPIP)-1, Emergency Plan Classification Logic, implements these requirements, and requires that the Radiological Emergency Plan (REP) be activated when any one of the conditions listed therein is detected. The Shift Operating Supervisor (< SOS) is responsible for declaring the emergency and providing the initial activation. The logic of EPIP-l states that both unit-related emergency diesel generators (EDGs) inoperable simultaneously by unscheduled outage or failure as determined by the shift engineer is a Notification of Unusual Event.
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w 2 Contrary to the above, at 4:10.a,m. on October 26, 1989 the 28-8 EDG became. inoperable while the 2A-A EDG was also inoperable, and the SOS did not declare'an NOUE nor provide for initial activation of the REP until 6:15 a.m.', Lover two hours after the condition was discovered.
This..is a Severity Level IV violation (Supplement VIII)."
Admission'or Denial of the Alleged Violation
-TVA admits- the: violation.
Reason-for the Violation-
-AT 1748 ESTr on October 25, 1989,-2A-A diesel generator (D/G) was declared inoperable as the result of voltage regulator problems. Action Statement (a) of LC0 3.8.1.1,,which requires, in part, that the remaining alternating current sources be periodically demonstrated to be operable. SI-7.1, " Diesel Generator AC Electrical Power Source Operability Verification (Diesel Generator /Offsite Source)," is used to fulfill this requirement. At 0410, D duringla performance-of SI-7.1 for D/G 2B-B, an assistant unit operator (AV0) in the D/G building noticed that the " power on" indicator light on the D/G local-control panel wasLburned out. While attempting to change the burned out ,
light bulb, a short occurred, blowing a control. power fuse and causing a loss u of D/G 2B-8 control power. When the control power was lost, the operators in the main' control room lost control of the 2B-B D/G. The control room operator Jattempted to trip the D/G manually using the emergency trip button, but could -
not stop;the D/G. The AUO in the D/G building was contacted and directed to :
trip'the D/G, but also could.not stop the D/G.
The_ SOS was contacted about the problem. It was determined that Action Statement (d) of LCO 3.8.1.1 and LCO 3.0.5 applied, which require that at least one of the two D/Gs (2A-A or j 28-B)Jbe returned to operable status within two hours or both units be in hot a standby within the next six hours. These LCOs were entered as of 0410. The '
SOS sent an assistant shift operations supervisor (ASOS) to the D/G building to Investigate. The ASOS found the blown control power fuse. When the fuse was replaced, normal control of the D/G was regained. At 0522, SI-7.1 was ];
completed on 2B-B D/G with:all acceptance criteria passed and the D/G was
- returned to operable status. Action Statement (d) of LCOs 3.8.1.1 and 3.0.5 were exited at that time. It was not until after the 2B-B D/G was operable )
again that the SOS, during his review of the activities, realized that Emergency Plan Implementing Instruction (EPIP) 1, " Emergency Plan j Classification Logic," defined a condition.with both unit-related D/Gs being inoperable at the same time as the result of unscheduled maintenance or a failure. At 0615, the SOS declared and exited a notification of unusual event
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(NOUE) and made the appropriate notifications.
The reason for the violation was that the SOS failed to realize that an NOUE q should have been declared. The SOS did not immediately consider the REP because he was in a technical specification action statement and incorrectly assumed that the action statement was the only controlling document.
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1 Two contributing reasons for the violation have also been identified. First, a review of_ EPIP-1 found that the unusual event classification process relied-solely on memory. For most other conditions, the emergency operating instructions (E0!s) and abnormal operating instructions.(A01s) branch the operator'into the appropriate EPIP event for proper classification. The loss of both D/Gs on the same unit is not covered by an A01 or an E01, and consequently, there is no directed entry into the EPIP classification process. The second contributing reason for the violation was an omission in training. The 50Ss are tralned and evaluated on the simulator to make timely event classification calls on events related to the REP. However, not all unusual event classifications concerning normal technical-specification events have been routinely covered during simulator evaluations. Training exercises have included EPIP classifications on E0I and A01 scenarios, but generally have not included normal operational events that are covered by operation within technical specification requirements.
Corrective Steps That Have Been Taken and Results Achieved The Operations Superintendent has discussed this event and the need for timely EPIP classification with all SOSs. The SOS who failed to make the timely -
classification has been disciplined for failure to declare an NOUE in a timely manner. In addition, each individual incident that would cause an entry into an NOUE is being reviewed and, if possible, included in the appropriate section of a plant instruction to enhance identification of EPIP entry criteria. - Actions have also been initiated to include normal operational events of this nature in operator requalification training to evaluate performance on unusual event recognition.
In an effort to make EPIP-1 more user-friendly and, therefore, more effective, a revision has been completed and will be implemented during January 1990 that includes a new format reflecting Nuclear Management and Resources Council recommendations. Use of the new EPIP-1 format has been reviewed with operators during requalification training. In addition, site emergency preparedness personnel have begun conducting tabletop drills with the duty 505 on event classification using the new EPIP-1 format. This continuing training .
is being conducted approximately weekly on the mid-shift to familiarize operators with the r,ew format and to reinforce awareness of the REP.
Corrective Steps That Will Be Taken to Avold Further Violations No further corrective actions are needed.
DA e Hhen Full Compliance Hill Be Achieved TVA is in full compliance.
Additional Requested Response The cover letter transmitting this violation stated the violation is similar to Violation 50-327, 328/88-33-01 cited by letter on November 5, 1988, and requested TVA give particular attention to the identification of the root cause of the problem and the corrective action to prevent recurrence. TVA was also requested in paragraph f of Inspection Report 89-25 to discuss the
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corrective actions taken for Violation 88-33-01 and four emergency preparedness-related inspector follow-up items (IFIs) as part of the response n to Violation 89-25-04. The corrective actions described in the response to Violation 89-25-04 and information provided in TVA's response to Violation 89-21-01 dated-November 6, 1989, encompass the corrective actions for the:four IFis. Violation 88-33-01 is discussed below.
Violation.88-33-01 involved a delay of approximately one hour by the SOS in initiating'the REP following receipt of a seismic alarm. The SOS did not initiate the REP immediately because the seismic alarm was believed-to be spurious. Although the alarm was subsequently confirmed to have been spurious, initiation of the REP should not have been delayed. The corrective action for Violation 88-33-01 was a revision to EPIP-1 to direct the SOS to follow his' indications and, unless a suspected spurious or otherwise false alarm can be substantiated in a minimum timeframe (based on the potential
, severity of the event), to proceed with actions as required by EPIP-1 until such time as the alarm is verified to be false.
i Although Violation 88-33-01 and Violation 89-25-04 both involved untimely initiation of an-NOVE, they are unrelated in terms of common root cause or appropriate. corrective actions. In Violation 88-33-01 the SOS delayed L initiation of the REP because he believed (correctly) that a seismic alarm was spurious. The corrective action was a clarification of the latitude given to
.the SOS to investigate suspected spurious indications before initiating the REP. In Violation 89-25-04 the SOS simply did not at first recognize the D/G event required initiation of the REP. The corrective actions are a major enhancement to EPIP-1 format to simplify its use; expanded operator training on event recognition during annual requalification; continuing on-shift exercises with the 50Ss on event classification; and the inclusion of incidents that would cause an NOUE entry into appropriate plant instructions to enhance their recognition. These corrective actions are believed to be appropriate and responsive.to the issues and to be adequate to prevent recurrence of the violation. These actions are also believed to be responsive to the concerns expressed in NRC Information Notice 89-72, " Failure of Licensed Senior Operators to Classify Emergency Events Properly," issued October 24, 1989, 1
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{p Enclosure 2 ,
List of Commitments
- 1. .SI-137.2 is being revised as part of an SI enhancement effort to incorporate the ICfs into a more clearly understandable text. This ;
revision is expected to be completed by January 26, 1990.
' 2 .- Sequoyah Standard Practice SQE-22 will be revised by January 31, 1990, to clarify.that the_ SOS should be notified.after'the results of the first
< sample even though there may be open issues relative to sample or analysis quality. These issues will be provided to the SOS so that he has that information for an LC0 call. A night' order is already in effect stating this prior to the procedure revision.
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