ML20132H113
| ML20132H113 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 12/19/1996 |
| From: | Adney R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9612270141 | |
| Download: ML20132H113 (6) | |
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k Tennesses Valley Authority. Post Office Box 2000, Soddy-Daisy, Tennessee 37379-2000 R.J. Adney l
Site Vice President Sequoyah Nuclear Plant t
December 19,1996 i
U.S. Nuclear Regulatory Commission ATTN: Document Control Desk
. Washington, D.C. 20555 Gentlemen:
In'the Matter of
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Docket Nos. 50-327 Tennessee Valley Authority
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50-328 4
SEQUOYAH NUCLEAR PLANT (SQN) - NRC INSPECTION REPORT NOS. 50-327, j.-
328/96 REPLY TO NOTICE OF VIOLATIONS (NOVs) 50-327,328/96-11 J
Enclosed is TVA's reply to Mark S. Lesser's letter to Oliver D. Kingsley, Jr., dated l
Ncvember 19,1996, which transmitted the subject NOVs. The violations are associated with the failure to follow procedure during an excavation activity and an error in establishing design pressure for the diesel generator starting air system.
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The enclosure contains TVA's response to the NOV.
1 If you have questions regarding this response, please telephone R. H. Shell at (423) 843-7170.
Sincerely, R. J. 'Adney Enclosure cc: See page 2 1
32DI ' I 9612270141 961219 PDR ADOCK 05000327 G
PDR c'0003
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ENCLOSURE RESPONSE TO NRC ' NOTICE OF VIOLATION 50-327,328/96-11 l
INSPECTION REPORT NOS. 50-327,323/96-11 MARK S. LESSER'S LETTER TO OLIVER D. KINGSLEY, JR.
DATED NOVEMBER 19,1996 VIOLATION 50-327. 328/96-11-03
" Technical Specification 6.8.1 requires, in part, that procedures shall be established, implemented and maintained covering the activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978, " Quality Assurance Program Requirements (Operations)." Appendix A of Regulatory Guide 1.33, Section 9, includes procedures for maintenance activities that can affect the performance of safety related equipment, which includes performance of activities in accordance to documented instructions.
Site Standard Practice (SSP)-7.4, Work Permits, Revision 7, requires, in part, that Site Engineering shall be notified by the cognizant engineer prior to any excavations within 10 feet of Category 1 structures in order that an Excavation Permit can be evaluated and issued.
Excavation Permit No. 94-09292-00 required temporary missile protection if the excavation l
was within 6 feet from the edge of the Essential Raw Cooling Water system permanent missile l
protection.
i Contrary to the above, on October 4,1996, Site Engineering was not notified prior to excavation less than 6 feet from Essential Raw Cooling Water piping and temporary missile protection was not installed.
This is a Severity Level IV Violation (Supplement I)"
REASON FOR THE VIOLATION The root cause of the failure to provide temporary missile protection was determined to be failure to follow the work order. The fire protection piping excavation was necessary to support repair work on a fire hydrant. The underground fire protection piping is typical bell and spigot construction. The design depends on the soil with concrete thrust-blocks that in combination maintain the position of the pipe and therefore maintain the integrity of the fire protection piping and valves. The excavation permit contained a requirement to provide temporary missile shielding if the excavation was 6 feet or less from the edge of the permanent L
missile shielding for ERCW piping located nearby. The hole was excavated and during an
. attempt to free the hydrant, the isolation valve located immediately below the hydrant slipped off of the supply pipe which caused a large water spray in the area. The focus then shifted from repair of the hydrant to efforts to isolate the water. After the leak was isolated personnel
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determined that the work could not be completed within the shift The supervisor in the field decided to secure.the excavated area and install barricades and lights as required. Temporary shielding was not placed as required. The package review at the end of the shift by supervision failed to identify the requirement for temporary missile protection to be in place.
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CORRECTIVE ACTIONS THAT HAVE BEEN TAKEN AND RESULTS ACHIEVED t
Appropriate disciplinary actions have been taken with the responsible personnel.
A stand down meeting was conducted to communicate this event to the appropriate maintenance personnel and to stress the importance of understanding infrequently performed -
procedures referenced in work packages and the importance of following the work package or i
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procedure. In this case this was an infrequently performed procedure because fire hydrant repair work infrequently involves missile protection.
This event has been added to the block training for maintenance for industry events.
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CORRECTIVE ACTIONS THAT WILL BE TAKEN TO AVOID FUTURE VIOLATIONS i
Corrective actions to avoid future violations are complete as stated above.
i DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The completed corrective actions stated above bring TVA into full compliance with respect to I
i this example.
COMMITMENTS None.
VIOLATION 50-327. 328/96-11-04 i
" Technical Specification 4.0.5 requires that inservice inspection of ASME Code Class 1,2 and 3 components and inservice testing of ASME Code class 1,2 and 3 pumps and valves shall be performed in accordance wiib Section XI of the ASME Boiler and Pressure Vessel Code and i
applicable Addenda as required by 10 CFR 50, Section 50.55a(g), except where specific written relief has been granted by the Co.mmission pursuant to 10 CFR 50, Section j
50.55a(g)(6)(i).
4 FSAR Table 3.2.1-2 identifies ASME Section VIII as the design criteria for auxiliary air system receivers.
The 1986 Edition of the ASME Pressure vessel Code,Section VIII, Subsection UG-125 (c),
I states that all pressure vessels shall be protected by a pressure-relieving device that shall prevent pressure from rising more than 10% above the maximum allowable working pressure (operating condition) of the system.
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Contrary to the above, on September 16,1996,Section XI inservice testing procedures for the emergency diesel generator starting air receiver pressure relievmg devices were inadequate m L
that setpoints were set in the range of 340-360 psig which was more than 10% above the
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maximum allowable working pressure of 300 psig.
j This is a Severity Level IV Violation (Supplement 1)."
REASON FOR THE VIOLATION TVA agrees that a violation of Section VIII of the ASME Pressure Vessel Code has occurred.'
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l However, TVA does not agree that this is a violation of Section XI of the ASME Pressure j
Vessel Code, nor a violation of Technical Specification 4.0.5. These requirements are incorrectly referenced as the subject relief valves are not a part of Section XI. Also note that 2
the reference to FSAR Table 3.2.1-2 is incorrect in that auxiliary air receivers are not part of i
i the diesel generator starting air system.
The problem with the design pressure is believed to have occurred during the initial design of the system. The Original Equipment Manufacturer (OEM) drawings submitted to TVA during i
a the initial design indicated a system working pressure of 300 psig. It appears that this was I-incorrectly assumed to be the design pressure; The vendor equipment was supplied at a design
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pressure of 350 psig and a working pressure of 300 psig which is consistent with the j-iequirements of Section III and Section VIII of the ASME code. The vendor supplied relief valves were supplied at a specified pressure of 350 psig. The misunderstanding in nomenclature appears to have resulted in the system design pressure being incorrectly i
specified as 300 psig versus 350 psig.
f In 1988 during a system adequacy review this design discrepancy was identified and a calculation was generated that verified the piping was qualified for a design pressure of 350 L
psig. However, this calculation did not address components and did not revise the drawing to reflect the higher design pressure.
CORRECTIVE ACTIONS THAT HAVE BEEN TAKEN AND RESULTS ACHIEVED An operability evaluation of the piping and components was performed to support continued operation and concluded that the diesel generator starting air system is operable.
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' CORRECTIVE ACTIONS THAT WILL BE TAKEN TO AVOID FUTURE VIOLATIONS Since 1988, controls for the design of pressurized piping systems have been strengthened.
Piping system design is performed to established design standards and is subjected to a series ofintegrated design reviews which ensure the proper specification of design pressures and overpressurization protection setpoints
' A review of safety-related systems will be performed to ensure that relief valve set pressures are consistent with the code of record for the associated system design pressures. Problems identified through this review will be documented and corrected using the corrective action process. This review will be complete on or before January 15,1997.
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i A design pressure and temperature calculation for the diesel generator startmg air system will be prepared to compare the design pressure and temperature of the individual components to j
the system design pressure and temperature for adequacy. The calculation will establish the l
system relief valve set pressure. This calculation will be complete on or before February 14, j
1997.
i A' design change notice (DCN) will be issued to correct drawings to agree with the conclusions l
of the calculation. This DCN will be issued on or before February 14,1997.
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i DATE WHEN FULL COMPLIANCE WILL BE ACHIEVEQ -
l Full compliance will be achieved upon completion of the corrective actions stated above and will be complete on or before February 14,1997 l
COMMITMENTS I
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A review of safety-related systems will be performed to ensure that relief valve set pressures are consistent with the code of record for the associated system design.
pressures. Problems identified through this review will be documented and corrected i
using the~ corrective action process. This review will be complete on or before January-15,1997.
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A design pressure and temperature calculation for the diesel generator starting air system will be prepared to compare the design pressure and temperature of the individual components to the system design pressure and temperature for adequacy. The calculation will establish the system relief valve set pressure. This calculation will be complete on or -
l before February 14,1997.
- 3). A DCN will be issued to correct drawings to agree with the conclusions of the calculation. This DCN will be issued on or before February 14,1997.
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U.S. Nuclear Regulatory Commission Page 2 December 19,1996 l
cc (Enclosure):
l Mr. R. W. Hernan, Project Manager Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852-2739 NRC Resident Inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road
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Soddy-Daisy, Tennessee 37379-2000 J
Regional Administrator U.S. Nuclear Regulatory Commission Region II l
.101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323-2711 l
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