ML20214J169

Rev 0 to TVA Employee Concerns Special Program Rept SWEC-SQN-01, Afws & Diesel Generator Procedures

ML20214J169
Person / Time
Site:	Sequoyah
Issue date:	11/13/1986
From:	Gass K, Knightly J, Stewart D TENNESSEE VALLEY AUTHORITY
To:
Shared Package
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References
SWEC-SQN-01, SWEC-SQN-01-R00, SWEC-SQN-1, SWEC-SQN-1-R, NUDOCS 8612010184
Download: ML20214J169 (10)

Text

I TVA EMPLOYEE CONCERNS REPORT NUMBER: SWEC-SQN-01

! SPECIAL PROGRAM

REPORT TYPE

Sequoyah Nuclear Plant Element REVISION NUMBER: 0 TITLE: AFWS and Diesel Generator Procedures k

f. REASON FOR REVISION: N/A j SWEC

SUMMARY

STATEMENT: The item in this report was identified by the Nuclear Regulatory Commission (NRC) and was included in the Stone & Webster Engineering Corporation (SWEC) systematic analysis. All items evaluated within this report j were verified to be adequately addressed and SWEC concerns A02 840917 005 -003

-004 were closed by NRC. Concerns A02 840917 005 -001, -002, -005 -006 are now ready for closure.

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TENNESSEE VALLEY AUTHORITY WATTS BAR NUCLEAR PLANT EMPLOYEE CONCERNS TASK GROUP OTHER SITES CEG Element

Title:

AFWS and Diesel Generator Procedures

SWEC Concerns: A02840917005-OO1, -002, --003, -004, --005, -006 Source Document: NRC Report 50-328/84-18 t

Report Number: SWEC-SQN--01 i

Evaluator:

/ O -lY-6 J. J. Knightly Date l

Reviewed By: Wh' h aa /s /g- %

K. R. Gass Date Approved By: 2 _ I N _m- /e/pg /gf~

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Report SWEC-SQN-01 NRC Report No. 50-328/84-18 I. Introduction Following'a June 30, 1984 failure of the turbine driven auxiliary

'feedwater pump to start on a loss of feedwater signal, the Nuclear Regulatory Commission (NRC) conducted an unannounced event followup

, inspection July 9-11, 1984 During this inspection, the NRC identified two violations (84-18-01 and 84-18-02), one unresolved item (84-18-03), and one inspector followup item (84-18-04) which were included in the Stone & Webster Engineering Corporation (SWEC) systematic analysis:

A. A02 840917 005-001, Operators failure to follow procedures (Violation 84-18-01, Part A1);

B. A02 840917 005-002, Lack of procedures for operators (Violation i 84-18-01, Part B);

C. A02 840917 005-003, Design bases not satisfied (Violation 84-18-02);-

D. A02 840917 005-004, Inconsistency between Auxiliary Feedwater I

System (AFWS) Technical Specifications (Unresolved Item 84-18-03); ,

E. A02 840917 005-005, Upgrade operator training on AFWS circuitry and Steam Supply Transfer (SST) logic (Inspector Followup Item 84-18-04); and l F. A02 840917 005-006, Failure to implement piesel Generator (DG)

I procedures (Violation 84-18-01, Part A2).

Information on the background, the corrective actions taken, the j verification methodology and analysis, the completion status, and any pertinent references for these items is included in this report.

II. Verification of SWEC Issues

! A. A02840917005-001, Operators Failure to Follow Procedures

! 1. Background - The NRC inspector determined (reference A) that j on June 30, 1984, two administrative instructions (AI-6 " Log

, Entries and Review" and AI-30 " Nuclear Plant Method of j Operation") applicable to the operation of the AFWS valves were not followed. This was reported as part Al of a Severity Level IV violation (84-18-01). Administrative Instruction l AI-30 was not followed in three areas: (1) the AFW valves were operated without use of a written procedure, (2) without

! the permission of the shift engineer; and (3) the system i alignment status change was not mentioned in the system i configuration log.

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2. Corrective Actions Taken - Sequoyah Nuclear Plant (SQN) stated (reference B) that all operators were required to read and initial a night order letter, dated June 30, 1984, describing the AFW event upon assuming their next shift assignment. A training letter describing the problems associated with the turbine driven AFW pumps was sent to the shift engineers, ,

assistant shift engineers, unit operators, assistant shift

. operators, and shif t technical advisors on July 10, 1984. In

addition, the operators involved with the violation were verbally di ciplined concerning their failure to communicato and follow written procedures.

, 3. Verification Methodology - The SWEC concern identified for

ECTG verification was stated as follows:

i

{ RIMS Number Issue RIMS Item A02 840917 005 Operators failed to RIMS-OO1 follow written and approved Administrative Instructions for the situation described.

ECTG reviewed the SQN Compliance Licensing files for internal and external correspondence related to this issue. This review of the pertinent documentation formed the basis for this verification activity.

4. Verification Analysis - The ECTG review of the pertinent documentation indicated that the NRC found the SQN response to i be acceptable (Reference C). Corrective actions were j implemented as described in II A.2 above.

5. Completion Status - Based on the SQN corrective actions, compliance with requirements, and NRC acceptance of the' corrective actions, no further action on this item is 4 required. The SWEC concern can be closed following NRC

! closure.

i j B. A02940917005-002, Lack of Procedures for Operators.

1. Background - The NRC reported (reference A), as the second i part of violation 84-18-01, that the licensee failed to provide written procedures to ensure that safety subsystems, such as portions of the AFWS, were properly ~ removed and restored to service during performance of abnormal valve alignments. The existing procedures were not applicable to a partial safety system removal and restoration where no tagging was involved. The NRC inspector stated that allowing

operators to routinely alter valves on safety systems or I subsystems, without adequate supervisory technical review and j independent verification or functional testing, provides a j distinct possibility that one or more safety systems could be

! left in a condition which would prevent them from performing their design function during an operational transient or an accident.

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2. Corrective Actions Taken - SQN stated (reference B) that a training letter describing the problems associated with the turbine driven auxiliary feeow ta- oumps was sont to the shift engineers, assistant shift engineers, unit operators, assistant unit coerators, and shift technical advisors on July 10, 1984. SQN also committed to reviewing and revising as needed operational procedures to add adequate instructions for the removal and restoration of safety systems and subsystems.

This item was completed and closed on November 6, 1985, by SQN CATS Number 85385.

3. Verification MetF doloqv - The SWEC concern identified for ECTG verification was stated as follows:

RIMS Number Issue RIMS Item A02 940917 005 The Licensee failed RIMS-OO2 to provide written procedures to ensure that safety subsystems are properly removed and restored to service with individual verification.

ECTG reviewed the SQN Compliance Licensing files for internal and external correspondence related to this issue. This review of the pertinent documentation formed the basis for this verification activity.

4. Verification Analysis - The ECTG review of the pertinent documentation indicated that the NRC found the SQN responses (reference B) to be acceptable. Corrective actions were implemented as described in II.B.2 above.

5. Completion Status - Based on the SQN corrective actions, compliance with requirements, and NRC acceptance of the l corrective action, no further action on this item is required. This SWEC concern can he closed following NRC closure.

C. A02840917005-003, Design Bases Not Satisfied, i

1. Background - The NRC inspector reported that SQN had failed to include the FSAR 10.4.7.2.3. design basis requirements into the AFWS specifications, drawings, procedures, and instructions. This NRC Severity Level IV Violation (84-18-02) was based on three AFWS operational examples: (1) a single failure of a valve during a steam supply transfer rendered the turbine driven AFW pump inoperative because of steam supply

circuitry design, (2) automatic start of all three AFW pumps J

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is inhibited on a loss of main feed pump trip below 80 percent power resulting from de-energization of one main feed pump i control circuit or single failure of the main feed pump

. turbine governor valve oil pressure switch, and (3) the AFW -

) initiating circuitry associated with the loss of main feed pump trip is not powered by emergency buses.

2. Corrective Actions Taken - SQN responded (reference B) that although the NRC analysis of the circuitry was correct, their determination of violation was incorrect. SQN stated that:

(1) a single failure will not cause the AFWS to not perform its design function or violate any' safety analysis assumptions, (2) the start mode initiated by the loss of main

feed pumps are anticipatory starts with no safety credit taken, and (3) the loss of the main feed pump is not a safety grade start, but is an anticipatory start and does not require i power from an emergency bus.

3. Verification Methodoloav - The SWEC concern identified for ECTG verification was stated as follow:

1 RIMS Number Issue RIMS Item A02 840917 005 The licensee failed RIMS-003 to establish adequate  ;

i. measures to assure that 1

the design basis requirements specified in FSAR were translated in

((

o specifications, drawings,

, procedures, and instructions.

l ECTG reviewed the SQN Compliance Licensing files for internal j and external correspondence related to this issue. This

review of the pertinent documentation formed the basis for

this verification activity.

4. Verification Analysis - The ECTG review found that after a

comprehensive review of the TVA denial of this violation, the

! NRC determined (reference C) that existing regulatory i requirements did not warrant enforcement action in this matter i

and that NRC had deleted this violation f rram the records. The SQN circuitry in question was determined to be acceptable.

5. Completion Status - Based on the SQN compliance with requirements and the NRC deletion of this violation from the records, no further action on this item is required. This item is closed.

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D. A02840917005-004, Inconsistency Between AFWS Technical Specifications

1. Background - The NRC inspector found (reference A) that the main feed pump circuitry had boon tagged out during maintenance activities for approximately 2-1/2 hours, thus causing in NRC's opinion the AFWS to be inoperable because the AFWS would not be able to start on loss of feed pump trip.

l Technical Specification LCO 3.3.2 allows loss of one control circuit for 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> in modes 1 and 2.

Technical Specification LCO 3.7.1.2 requires the AFW to be operable in Modes 1, 2, and 3 and states that immediate corrective action is to be initiated to restore one AFWS pump to operable status if three AFWS pumps are inoperable. The NRC view was that the paragraph 3.3.2 allowed, in effect, all pumps to be inoperable while paragraph 3.7.1.2 required at least one pump to be operable. This apparent contradiction was reported as Unresolved Item 84-18-03,

2. Corrective Actions Taken. In the TVA response to a similar AFWS item, NRC violation 84-18-02 (A02 840917 005-003 above),

SQN established that controls for the two AFWS pumps were independent and that failure of pump controls would affect i only a single pump leaving one operational per FSAR 15.2.8.2 i requirements. Based on their acceptance of this SQN response, NRC closed the Unresolved Item 84-18-03 on July 10, 1986 (reference C).

3. Verification Methodoloav. The SWEC concern identified for i ECTG verification was stated as follow:

RIMS Number Issue RIMS Item A02 840917 005 Inconsistency Between RIMS-004 AFWS Technical Specifications.

l.

ECTG reviewed the SQN Compliance Licensing files for internal and external correspondence related to this issue. This review of the pertinent documentation formed the basis for this verification activity.

4. Verification Analysis. The ECTG review of the pertinent documentation verified that the NRC found the SQN response to l

be acceptable and that NRC closed the Unresolucd Item on July 10, 1986, in reference C.

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5. Completion Status. Based on the SQN compliance with l

i requirements, and NRC administrative closure of the item, no further action on this item is required. This item is closed.

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t

E. A02840917005-005, Upgrade Operation Training on AFWS Circuitry and SST Logic

1. Backgrp_und - The NRC inspector noted (reference A) that following the AFWS eveht of June 30, 1984, in which the AFWS failed to start on a loss of feedwater, the AFWS remained in a partially inoperable condition for several hours because of the operator's lack of understanding on the AFWS initiating circuitry and the SST logic. This need for operator training on the logic of the AFWS was reported as Inspector Follow-up

[

Item 84-18-04.

2. Corrective Actions Taken - SQN stated (reference B) that a i training letter describing the problems associated with the I turbine-driven AFW pumps, including the circuitry, was sent.to the shift engineers, assistant shift engineers, unit operators, assistant shift operators, and shift technical advisors on July 10, 1984.

3. Verification Methodology - The SWEC concern identified for

. ECTG verification was stated as follow:

RIMS Number Issue RIMS Item A02 840917 005 Event reflected a need RIMS-OO5 to upgrade operator training on the AFWS initiating circuitry and ,

the SST logic.

ECTG reviewed the SQN Compliance Licensing files for internal and external correspondence related to this issue. This review of the pertinent documentation formed the basis for this verification activity.

4. Verification Analysis - The ECTG review of the pertinent documentation indicated that SQN ccmpleted corrective action as described in II.E.2 above.

5. Completion Status - Based on the SQN corrective action and compliance with requirements, no further action on this item is required. This item can be closed following NRC closure.

F. 402840917005-006, Failure to Implement DG Procedures.

1. Background - The NRC inspector determined (reference A) that on July 5, 1984 a surveillance instruction (SI-7),

" Surveillance of the Diesel Generator Emergency Safety Features (ESF)" was not followed. This was reported as part A2 of a Severity Level IV Violation (84-18-01). The steps described in SI-7 were performed out of sequence which resulted in an inadvertent startup of all four diesel 1

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generators rather than just the one being tested. The inspector also noted that this was another example of a failure to follow a written, approved procedure on communications (AI-30) which required the recipient of verbal directions to repeat the directions back before performing them.

2. Corrective Actions Taken - SQN stated (reference B) that the operators involved with the violation were verbally disciplined as to their failure to communicate and follow written procedures. In addition, Surveillance Instruction SI-258.2, " Inspection of Molded Case and Lower Voltage Circuit Breaker," was revised to emphasize the need to maintain power on breaker 213, Emergency Start Relay, which prevents the start of all 4 diesel generators and allows the start of one for testing.

3. Verification Methodoloav - The SWEC concern identified for ECTG verification was stated as follow:

RIMS Number Issue RIMS Item A02 840917 005 Inadvertent start of all RIMS-006 4 Diesel Generators:

Another example of failure to implement procedures as required.

ECTG eviewed the SQN Compliance Licensing files for internal and external correspondence related to this issue. This

review of the pertinent documentation formed the basis for this verification activity.

t

4. Verification Analysis - The ECTG review of the pertinent documentation indicated that the NRC found the SQN response to l

be acceptable (reference C). Corrective actions as described l in II.F.2 above were accomplished according to SQN corrective l action tracking system (CATS) number 84161. Surveillance

! instruction SI-258.2 was verified to include the specified l

changes.

5. Completion Status - Based on the SQN corrective actions, compliance with requirements, and NRC acceptance of the l corrective action, no further action on this item is required. This item can be closed following NRC closure, t

III. References t

l A. NRC Report No. 50-328/84-18, dated September 11, 1984, from R. C. Lewis to H. G. Parris l

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B. TVA Memorandum "Sequoyah Nuclear Plant-NRC-OIE Region II Inspection Report No. 50-328/84-18," dated October 25, 1984, from T. G. Campbell to L. M. Mills C. NRC Memorandum, "NRC Inspection Report No. 50-328/84-10," dated July 10, 1986, from G. G. Zech to S. A. White I

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