ML20235M276

Responds to NRC 870508 Ltr Re Violations Noted in Insp Repts 50-327/85-01 & 50-328/85-01.Corrective Actions:Electrical Circuits & Equipment Required for Safe Shutdown Per 10CFR50 Identified & Physically Located on Series of App R Drawing

ML20235M276
Person / Time
Site:	Sequoyah
Issue date:	07/10/1987
From:	Gridley R TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NUDOCS 8707170132
Download: ML20235M276 (10)

Text

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e TENNESSEE VALLEY AUTHORITY CH ATTANOOG A. TENNESSEE 37401 SN 157B Lookout Place JUL 101987 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Gentlemen:

In the Matter of ) Docket Nos. 50-327 Tennessee Valley Authority -) 50-328 SEQUOYAH NUCLEAR PLANT (SQN) - NRC INSPECTION REPORT NOS. 50-327/85-01 AND 50-328/85-01 -- RESPONSE TO NOTICE OF VIOLATION Enclosed is our response to James G. Keppler's' June 8, 1987 letter to S. A. White which transmitted the subject Notice'of Violation.

Enclosure.1 provides our response to the Notice of Violation,.and our commitments are listed in enclosure 2. TVA does not recognize-any other items described herein as commitments.

If you have any other questions, please telephone M. R. Harding at (615) 870-6422.

To the best of my knowledge, I declare the statements contained herein i are complete and true. 1 I

Very truly yours,.

l TENNESSEE VALLEY AUTHORITY J o

' l R. G idley, Di ector Nuclear Safet and Licensing Enclosures cc: See page 2 i

8707170132 070710 PDR ADOCK 05000327 g PDR g 4

'9 b An Equal Opportunity Employer L j

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U.S. Nuclear Regulatory Commission JUL 10 087 l

cc (Enclosures):

Mr. G. G. Zech, Assistant Director for Inspection Programs Office of Special Projects i

U.S. Nuclear Regulatory Commission

! 101 Marietta Street, NW, Suite 2900 j Atlanta, Georgia 30323

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Mr. J. A. Zwolinski, Assistant Director for Projects Division of TVA Projects office of Special Projects ,

U.S. Nuclear Regulatory Commission i 4350 East West Highway EWW 322 Bethesda, Maryland 20814 i

Sequoyah Resident Inspector Sequoyah Nuclear Plant j 2600 Igou Ferry Road ,

i Soddy Daisy, Tennessee 37379 1 l

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ENCLOSURE 1 RESPONSE TO NRC INSPECTION REPORT NOS. 50-327/85-01 AND 50-328/85-01 JAMES G. KEPpLER'S LETTER TO S. A. WHITE

' DATED JUNE 8, 1987 Violation 50-328/85-01.Section I "Operatin6 License DPR-79, Section 2.C.(13)c for Unit 2 requires that TVA shall comply with Section III.G, III.J III.L and III.O of Appendix R of '

S 10 CFR Part 50, except where NRC has approved deviations. The NRC had not approved any deviations from these sections.

A. 10 CFR Part 50, Appendix R, Section III.G.1 requires that fire protection features shall be provided for structures, systems, and components -

important to safe shutdown. These features shall be capable of limiting fire damage so that one train of systems necessary to achieve and maintain '

hot shutdown from either the control room or emergency control station (s) is free of fire damage.

Sections III.G.2 and III.G.3 specify four alternatives that may be implemented outside of primary containment to ensure that one redundant _

train of equipment, cabling, and associated circuits necessary to achieve and maintain hot shutdown remains free of fire damage. The alternatives are:

Separation of redundant trains of equipment, cabling,. and associated circuits by a three-hour rated fire barrier.

Separation of redundant trains of equipment, cabling, and associated circuits by a horizontal distance of 20 feet with no intervening ..

combustibles and fire detection and automatic fire suppression systems installed in the area.

Enclosure of redundant trains of equipment, cabling, and associated circuits by a one-hour rated fire barrier with fire detection and automatic fire suppression systems installed in the area.

Installation of alternative or dedicated shutdown capability independent of the equipment, cabling, and associated circuits under consideration, and installation of fire detection and fixed fire suppression systems in the area under consideration.

Contrary to the above, as of August 10, 1984, fire protection features were not provided for certain redundant trains of equipment and/or cabling necessary to achieve and maintain hot shutdown from either the control room or emergency control stations such that one train would remain free of fire damage. The redundant trains of equipment and/or cabling were

-3 Violation 50-328/85-01.Section I (Continued) located in the same fire area outside the primary containment. None of the alternatives provided by Section III.G.2 and III.G.3 were implemented. Specifically:

1. Thirty-six examples within 19 plant areas existed in which both redundant trains were located in the same fire area and not provided the fire protection features of Section III.G.2 or III.G.3. These areas involved systems such as auxiliary '

feedwater, component cooling water, essential raw cooling water, chemical volume and control, pressurizer heater controls, steam generator inventory control, and on-site power i distribution.

2. Two hundred forty-five associated circuits having & common power source with shutdown equipment which could prevent operation or cause malfunction of equipment necessary to achieve and maintain hot shutdown conditions were not properly electrically protected from the circuit of concern nor provided the fire protection features of Section III.G.2 or III.G.3.

l B. 10 CFR part 50, Appendix R.Section III.G.I.b, requires that systems necessary to achieve and maintain cold shutdown from the control room or emergency control station (s) can be repaired within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. .

Contrary to the above, as of August 10, 1984, the redundant trains of equipment and cabling necessary to achieve cold shutdown conditions were not capable of being repaired within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> as demonstrated by the absence of planning, procedures, and/or materials necessary to l implement fire damage repairs. Thirteen areas existed in which both _

redundant trains of cabling were located in the same fire area.

Collectively, these violations have been categorized as a Severity Level II problem (Supplement I).

1 l 1. Admissio or Denial of the Alleged Violation part A. TVA admits the violation.

part B. TVA admits the violation.

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2. Reason for the Violation t

A study of the requirements of Appendix R was done for units 1 and 2 and submitted to NRC on October 1, 1981. It was TVA's understanding at that time that SQN was in full compliance with 10 CFR 50, Appendix R, requirements. As more and more information became available through numerous workshops, generic letters, and notices, it became apparent that there was widespread confusion within the industry, of which TVA was no exception. Based on the numerous ,

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2. Reason for the Violation (Continued) f noncompliance found at the Watts Bar Nuclear plant in 1984, TVA performed a comprehensive reevaluation of SQN for Appendix R compliance. As a result of that reevaluation, interactions of j safety-related functions located within multiple plant areas and many Type I and Type III associated circuits of concern were identified. l planning and procedures were not implemented nor was material l

available to implement fire damage repairs because it was perceived {

that Appendix R criteria was satisfied and that redundant equipment

• l' would not be affected by fire damage in a single area.

3. Corrective Steps Taken and Results Achieved .

part A. All electrical circuits and equipment required for safe shutdown in accordance with 10 CFR 50, Appendix R, have been identified and physically located on a series of Appendix R drawings. These drawings were used to support a i comprehensive Appendix R reevaluation that determined locations where a fire could disable redundant safe shutdown functions. Operating procedures were developed, or deviation requests were submitted, and modifications are being implemented to resolve the subject interactions. The 480-volt shutdown board room opan head water spray system (item E) scheduled for completion by June 30, 1987, has yet .

l to be completed (reference: letter from J. A. Domer to J. Nelson Grace dated January 16, 1987). The postaccident monitoring source range instrumentation is scheduled for completion in accordance with TVA's commitments to Regulatory Guide 1.97.

l The potential Type I and Type III associated circuit problems identified in the 1984 Appendix R reevaluation have been resolved. Any additional Type I and Type III associated circuit issues identified will be resolved by the

, condition adverse to quality report (CAQR) process.

part B. TVA's 1984 reevaluation of SQN for Appendix R compliance identified many areas where redundant trains were located in the same fire area. As a result of this reevaluation, operating procedures were developed to provide alternate instructions to achieve and/or maintain cold shutdown as necessary. Casualty proce'dures were written, and material .

was procured to implement repairs to areas where a single i fire could damage both trains of equipment required for cold i shutdown.

4. Corrective Steps To Avoid Further Violations l

Design criteria has been issued or revised by the Division of Nuclear Engineering (DNE) to adequately define the requirements for l j

Appendix R. procedures have been issued with instructions for coordination and review for Appendix R requirements on all future plant changes.

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4. Corrective Steps To Avoid Further Violations (Continued)

If additional Appendix R noncompliance are identified, they will be documented and dispositiondd in accordance with the CAQR process.

Material dedicated to effect fire damage repairs is inventoried annually.

5. Date When Full Compliance Will Be Achieved The 480-volt shutdown board room open head water spray system *

(item E) will be completed before restart.

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Violation 50-328/85-01.Section II Operating License DPR-79, Section 2.C.(13)c for Unit 2 requires that TVA shall comply with Section III.G. III.J. and III.O of Appendix R of 10 CFR Part 50, except where NRC has approved deviations. The NRC has not approved deviations in the areas of Sections III.O and III.J, cited below.

A. 10 CFR Part 50, Appendix R, Section III.0, requires the reactor coolant pumps to be equipped with an oil collection system if the l containment is not inerted during normal operations. The system is

• required to be designed, engineered, and installed such that failure will not lead to fire during normal or design basis accident conditions and such that the system will withstand the Safe Shutdown e Earthquake. All leakage from potential pressurized and unpressurized _

leakage sites is to be collected and drained to a vented closed container that can hold the entire lube oil system inventory.

Contrary to the above, as of August 10, 1984, and with a containment not inerted during normal operations, the reactor coolant pump oil collection systems were not des'igned, engineered, or installed to withstand the Safe Shutdown Earthquake. In addition, the drainage tank was not designed to hold the entire reactor coolant pump lube oil system inventory.

B. Technical Specification, Section 6.8.1.f, requires that written ,

procedures be established, implemented, and maintained for the fire protection program. TVA's approved fire protection program, as discussed in an October 23, 1979 responne to the NRC's Auxiliary Systems Branch, indicates in Table 1.3 which circuits are to be protected by a 1/2-hour fire rated barrier.

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Contrary to the above, as of January 14-18, 1985, TVA had not implemented its procedures for the approved fire protection program in that the 1/2-hour fire barriers required by Table 1.3 for conduits 2PM101I, 2PH21141I, and 2PM2084I in the auxiliary building were found to be partially missing or damaged and, therefore, did not meet the required fire rating.

C. 10 CFR Part 50, Appendix R Section III.J. , requires emergency lighting units with at least an 8-hour battery power supply to be provided in all areas needed for operation of safe shutdown equipment and in access and egress routes thereto.

Contrary to the above, as of January 14-18, 1985, the existing emergency lighting units had battery power supplies rated at 3-3/4-hours and lighting units were provided for only 76 of approximately 150 areas needed for operation of safe shutdown equipment and in access and egress routes thereta.

Collectively, these violations have been categorized as a Severity Level IV problem (Supplement I).

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1. Admission or Denini of the Alleged Violation Part A: TVA admits the violation.

Part B: TVA admits the violation.

Part C: TVA admits the violation.

2. Reason for the Violation Part A: The subject violation occurred because TVA misinterpreted the requirements of section III.0 of Appendix R to 10 CFR Part 50.

4 Part B: The omission of a periodic inspection of the Kaowool-wrapped conduits was caused by an oversight. Thenmal-wrapped conduits are not in fire barriers and, therefore, do not fall under the surveillance requirements of technical specification 3.7.12 or other fire protection surveillance requirements. It was believed that this wrap was a civil feature, and the need for a periodic inspection was not realized. Clarification was received during the subject NRC inspection when the wrap on three conduits was found damaged. It was then determined that there was a need to inspect this material as a part of the overall fire protection program.

Part C: The 3.75-hour light packs, transferred from another TVA facility, required changeout of the 25-watt bulbs to 10-watt bulbs to meet the 8-hour specification. Because the light bulb wattage was not identified on the bulbs, some incorrect bulbs remained installed. The location and number of emergency lights were based on the October 1, 1981 Appendix R study. Additional _

information and clarification of Appendix R requirements between 1981 and 1984 resulted in TVA reevaluating SQN for Appendix R compliance. As a result of that reevaluation, additional areas were identified that required emergency lighting.

3. Correcti e Steps Taken and Results Achieved Part A: TVA has filed the necessary deviation requests justifying the cited deviations to section III.O of Appendix R to 10 CFR Part 50 (reference: letter from J. A. Domer to E. Adensam dated December 18, 1984). These, deviations have already been approved by NRC (reference: letter from B. J. Youngblood to S. A. White dated May 29, 1986).

Part B: The surveillance instruction (SI) for inspection of penetration fire barriers, SI-233, was immediately revised; and an inspection was performed on all conduits bearing a Kaowool wrap. Work requests were generated and repairs were made to the damaged areas expeditiously.

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In addition to the above actions, a preventive maintenance (PM) .

program, PM 1864-302, has been initiated to inspect on a I six-month basis the Kaowool-wrapped conduits most susceptible to l mechanical damage.  !

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3. Corrective Steps Taken and Results Achieved (Continued)

Part C: The emergency lighting system was modified and tested in 'T l

accordance with the requirements of Appendix R, section III.J. l In Inspection and Enforcement (IE) Report No. 86-40, dated August 12, 1986, NRC stated that they inspected the current e emergency lighting system. No violations or deviations were identified. *

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4. Corrective Steps Taken To Avoid Further Violations Part A: NRC has approved a deviation request to accept the reactor coolant pump oil collection system as is. No further TVA action ,

is required. l Part B: SQN has implemented the above controls and requested DNE to I evaluate the continued use of Kaowool versus a more durable type I of material or the possibility of protecting the Kaowool in the .'

areas most subject to damage with a sheetmetal-type barrier. In addition, a memorandum was sent to all plant sections for dissemination to employees describing what actions are to be taken if Kaowool wrap is discovered damaged.

Part C: Design criteria, SQN engineering procedures, and a surveillance. j program have been implemented to ensure that Appendix R emergency j lighting requirements are maintained. )

5. Date When Full Compliance Was Achieved Part A: Full compliance was achieved on May 29, 1986, when NRC accepted TVA's exemption request pertaining to this subject (letter from B. J. Youngblood to S. A. White dated May 29, 1986).

Part B: Full compliance was achieved on August 8, 1985, when the revised #

SI was completed.

Part C: Full compliance was achieved on June 23, 1986, when the emergency lighting system was declared operational.

Enclosura 2 List of Commitments .{

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1. Complete the modification for item E (open head water spray system in the 480-volt shutdown board room) before restart (formerly committed to i completion by June 30, 1987).

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