IR 05000327/1985001

Discusses Safety Insp Repts 50-327/85-01 & 50-328/85-01 on 850114-18 & Forwards Notice of Violation.Notice Issued W/O Civil Penalty Due to Lack of Clarity Re Fire Protection Requirements & Significant Time Lapse Since Insp

ML20215F401
Person / Time
Site:	Sequoyah
Issue date:	06/08/1987
From:	James Keppler NRC OFFICE OF SPECIAL PROJECTS
To:	White S TENNESSEE VALLEY AUTHORITY
Shared Package
ML20215F404	List: IR 05000327/1985001 ML20215F401 ML20215F440
References
EA-85-048, EA-85-48, NUDOCS 8706220369
Preceding documents:	ML20237G570 (19 August 1987)
Download: ML20215F401 (6)

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[ uq'o UNITED STATES 8' 7go NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555

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4 JUN 0 8 1987 Docket No. 50-328

. License No. DPR-79 EA 85-48 Tennessee Valley Authority

ATTN: Mr. S. A.. White Manager of Nuclear Power 6N 38A Lookout Place 1101 Market Street <

Chattanooga, TN 37402-2801 l SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORT NOS. 50-327/85-01 AND50-328/85-01)

Gentlemen:

As a result of deficiencies identified by the NRC during a July 16-20, 1984 i Appendix R inspection at Tennessee Valley Authority's'(TVA) Watts Bar facility, a Confirmation of Action Letter concerning t.he implementation of 10 CFR Part 50, ,

Appendix R, Sections III.G, III.J, III.L and III.0 was issued to the Sequoyah ,

NuclearPlant(SNP)byRegionIIonAugust 10, 1984. TVA's_re-evaluation at i SNP was completed on December 21, 1984. A special safety inspection was l conducted on January 14-18, 1985 at SNP Units l'and 2 to evaluate the adequacy -

of TVA's performance with respect to fire protection at SNP. As a result of the inspection, numerous violations of NRC requirements were identified, some ,

of which you had identified previously. The report which documents'this i

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inspection was sent to you with a letter dated March 29, 1985. An Enforcement Conference to discuss the violations was held in the NRC Region II Office on February 28, 1985. The enforcement action c,n .this matter. was then held in abeyance while the Commission resolved a number of. issues pertaining to c

Those~ actions have now been I Appendix R implementation and enforcemen resolved and we a're proceeding to issue this enforcement actio Violation I.A.1 described in the enclosed Notice of Violation'(Notice) involves 36 examples in 19 different plant areas in which both trains of redundant hot shutdown systems could have been rendered inoperable in the event of a fir Thus, the plant's ability to achieve and maintain hot shutdown was not assure ;-

Violation I.A.2 involves 245 circuits that had a common power source with other shutdown equipment and which were not properly electrically protected from the circuit of concern. These circuits could have prevented operation or caused malfunction of equipment necessary to achieve and maintain hot-shutdown conditions in the event of a fire. Violation I.B involves 13 examples in which both redundant trains of cabling for systems'necessary.to achieve and maintain cold shutdown were located in the same fire area and therefore could have been rendered inoperable had there been a fir .;

The number of examples of noncompliance that were identified. in;1984 are of- '

concern to the NRC because they are' indicative of weaknesses in TVA's original review, design, construction and modifications made to implement the requirements of 10'CFR Part 50, Appendix R for.Sequoyah Unit 2. We recognize that since this 8706220369 870608 PDR ADOCK 05000328-G PDR- ,

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Tennessee Valley Authority -2-inspection you have taken actions to correct the deficiencies. We expect that SNP 2 will either be in compliance with Appendix R or have approved compensatory measures in place prior to restart. However, in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1987), Violations I.A and I.B described in the enclosed Notice have been categorized in the aggregate as a Severity Level II problem because the numerous violations identified in hot shutdown and cold shutdown systems lead us to conclude that a fire in these areas would have damaged equipment to the extent that safe shutdown would not have been achieved and maintained in the event of a fir A civil penalty is normally proposed for a Severity Level II violation or problem absent mitigating circumstances. However, after consultation with the Commission and the Deputy Executive Director for Regional Operations, I have been authorized to issue the enclosed Notice without a civil penalty. Because of the apparent lack of clarity which existed regarding the fire protection requirements, the significant time that has elapsed since the inspection associated with these violations, and after considering the unique circumstances at TVA involving the extensive efforts to identify and correct problems including some of the cited violations, I have concluded that issuance of a civil penalty at this time is unnecessar Violation II.A in the enclosed Notice involves design deficiencies associated with the reactor coolant pump oil collection systems; Violation II.B involves deficiencies associated with cable fire barrier assemblies; and Violation I involves deficiencies associated with the emergency lighting units. Collectively, these violations have been characterized as a Severity Level IV proble You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response.. In your response, you should document the specific actions taken and any additional actions you plan to prevent recurrence. You may reference previous submittals regarding this matter in your response to this lette In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosure will be placed in the NRC's Public Document Roo The responses directed by this letter and its enclosure are not subject to the clearance procedures of the Office of Management and Budget issued under the Paperwork Reduction Act of 1980, PL 96-51

Sincerely, g a b /yd ~ 0a- - l VJamesG.Keppfek, Director !

Office of Special Projects o

Enclosure: See next Page

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Tennessee' Valley' Authority -3-Enclosure:

Notice of Violation Ucc w/ encl:

H. L.:Abercrombie, Site Director

- Sequoyah Nuclear Plant-J. A. Kirkebo, Acting Director Nuclear Engineerin R. L. Gridley, Director Nuclear Safety and Licensing i M. R. Harding, Site Licensing Manage l I

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HWong, DE JGoldberg, 0GC TMurley, NRR i Enforcement Coordinators l RI, RII, RIII, RIV, RV EJordan, AE0D  ;

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Docket File (50-327 and 50-328)

NRC PDR Local PDR JAxelrad  ;

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GZech SEbgeter JAxelrad J ler JGoldberg l 6/F/87 66/87 6/ 7 /87 6/ &/87 6/ /87

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Mr. S. A. White Tennessee Valley Authority Sequoyah Nuclear Plant I

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General Counsel Regional Administrator, Region II Tennessee Valley Authority U.S. Nuclear Regulatory Commission 1 400 West Summit Hill Drive 101 Marietta Street, '

Eli B33 Atlanta, Georgia 30323 Knoxville, Tennessee 37902 Resident Inspector /Sequoyah NP !

Mr. R. L. Gridley c/o U.S. Nuclear Regulatory Commission l Tennessee Valley Authority 2600 Igou Ferry Road i 5N 157B Lookout Place Soddy Daisy, Tennessee 37379 j f

Chattanooga, Tennessee 37402-2801 Mr. Richard King Mr. H. L. Abercrombie c/o U.S. GA0 Tennessee Valley Authority 1111 North Shore Drive j Sequoyah Nuclear Plant Suite 225, Box 194 '

P.O. Box 2000 Knoxville, Tennessee 37919 Soddy Daisy, Tennessee 37379 Tennessee Department of Mr. M. R. Harding Public Health Tennessee Valley Authority ATTN: Director, Bureau of Sequoyah Nuclear Plant Environmental Health Services P.O. Box 2000 Cordell Hull Building Soddy Daisy Tennessee 37379 Nashville, Tennessee 37219 Mr. D. L. Williams Mr. Michael H. Mobley, Director Tennessee Valley Authority Division of Radiological Health 400 West Summit Hill Drive T.E.R.R.A. Building W10 B85 150 9th Avenue North Knoxville, Tennessee 37902 Nashville, Tennessee 37203 County Judge Hamilton County Courthouse Chattanooga, Tennessee 37402