IR 05000327/1988024
| ML20235N448 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 07/22/1988 |
| From: | Partlow J NRC OFFICE OF SPECIAL PROJECTS |
| To: | White S TENNESSEE VALLEY AUTHORITY |
| Shared Package | |
| ML20235N439 | List: |
| References | |
| EA-88-086, EA-88-86, NUDOCS 8903010218 | |
| Download: ML20235N448 (7) | |
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Docket No9. 50-327, 50-328 License Nos. DPR-77, DPR-79 EA 88-86 Mr. S. A. White Senior Vice President, Nuclear Power Tannessee Valley Authority 6N 38A Lookout Place 1!91 Market Street Chattanooga, Tennessee 37402-2801 Gentlemen:
SUBJECT: NOTICE OF !!IOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY l
(NRC INSPECTION REPORT NOS. 50-P7/88-24 AND 50-328/88-24)
This refer:. to a special Nuclear Regulatory Comission (NRC) Appendix R insnection conducted at Sequoyah Unit 2 on March 14-18, 1988. During the inspection, a potentiai violation cf NRC requirements was identified by the licensee and reviewea by the NRC. At the conclusion of the inspection, the findings were discussed with those members of your staff identified in i
Inspection Report Nos. 50-327/88-24 and 60-328/88-24. The findings were also addressed by TVA in two letters from R. Gridley to the NRC dated April 19, 1988 and May 23, 1988 and in an Enforcement Conference held with members of your ctaff in Rockville, Maryland on May 10, 1988.
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After revfewing the information you provfded concerning the inspection findings, the staff has concluded that certain activities appeared to violate NRC i
requirements. The violation, which is described in the enclosed Notice of Violation and Proposed Imposition of Civil Penalty (Notice), involved failure to satisfy the fire peotection requirements set forth in your license which
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incorporates certain provisions of 20 CFR Part 50, Appendix R, involving the j
separation of redundant trains of equipment, cabling, and associated circuits necessary to achieve and maintain hot shutdown in the event of a fire.
Specifically, at the time of the inspection, TVA had not established by adequate analysis for all postulated fire scenarios that either an approved Appendix R protected reactor coolaat system letdown path was provided or that j
such a letdown path was not required.
In addition, TVA did not have an appropriate arMysis to show that adequate protection was provided for 1) some reactor coolant system high/ low pressure interfaces including the pressurir.er
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Power Operated Relief Valve and pressurizer block valve and excess letdown line reactor coolant system isolation boundary valves, 2) centrifugal charging
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pump train B, and 3) Yyp6 II spurious actuhtien for the Steam Generator Units I and 4 atmospheric dump valves.
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A., White Tennessee Va'iley Authority-2-Sequoyah Nuclear Plant One cause of the violation was that until the time of the inspection, TVA had not considered it necessary to provide a protected reactor coolant system letdown path. This was predicated on the assumption that reactor coolant l
shrinkago would allow the addition of sufficient makeup to provide adequate boron to reach and maintain cold shutdown.
Subsequent reverification of the
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shrinkage calculation by TVA at the time of the inspection caused the licensee to doubt the assumption that with peak xenon reactivity in conjunction with a rapid post trip recovery startup sequence, cold shutdown could be reached and maintained without providing reactor coolant system Ietdown.
The licensee indicated at the time of the inspection that it did have a calculation showing that with equilibrium xenon, the resultant cooldown and shrinkage would allow sufficient makeup to provide adequate boron to reach and
maintain cold shutdown. However, no administrative or other controls were in place at the time of the inspection to preclude startup during a peak xer.pn f
scenario and the equilibrium xenon calculations were not reviewed at the time of the inspection because peak xenon was considered the limiting scenario.
On May 23, 1988, TVA supplied additional information to support its contention that a calculational basis existed for operation of the Sequoyah Unit 2 reactor without a protected letdown path for all credible Appendix R fire scenarics.
The submittals were reviewed and the staff has concluded that TVA has not established that a protected reactor coolant system letdown path was not required for all Appendix R scenarios.
The assumptions used fo-the calculations, the administrative controls in place at the time of the inspection, and the reliance on some systems which are not fire protected systems or are not normally used to facilitate safe shutdown of the plant, precludes the use of these calculations to justify the failure to provide a protected letdown path.
A second cause of the violation was TVA's failure to adequately address cable-to-cable spurious interactions. The NRC acknowledges that TVA had considered cable-to-cable spurious interactions in a 1984 TVA analysis and concluded that the likelihood of spurious interaction between the cables at issue was so low that further analysis was unnecessary. The NRC also acknowledges that this evaluation and the specific interactions reviewed during the inspection, with the exception of the interactions in the annulus area, had been identified by i
l TVA in 1984 and reviewed and accepted by the NRC, at least in part. However, in Generic Letter 86-10, the NRC clearly indicated that spurious actustions as a result of cable-to-cable interactions could not be dismissed as incredible and that such interactions must be addressed for high-low pressure interface situations. As TVA is aware, GL 86-10 was the culmination of extensive efforts between the staff and the industry to clarify the meaning of Appendix R and to ensure that it would be consistently interpreted in the future. After receiving the Generic Letter, TVA should have examined its Appendix R analyses for inconsistencies with the staff positions stated in the letter and performed any additional required analyses.
If TVA had any questions regarding the effects of the Generic Letter, they should have been addressed to the NRC.
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l Mr. S. A. White
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Tennessee Valley Authority-3-Sequoyah Nuclear Plant l
l Notwithstanding the above, the NRC has decided not to issue citations for the interactions specifically reviewed and approved by the NRC before GL 86-10.
However, with regard to the interaction in the annulus which could have prevented the establishment of a reactor coolant letdown path, this interaction would likely have been identified by TVA if it had correctly applied the guidance in the Generic Letter and considered the cable-to-cable interactions in the high-low pressure interface. Therefore, the staff believes q
a citation for this violation is appropriate.
Following identification of the interaction in the annulus and immediately I
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after the inspection, TVA installed additional fire suppression in the reactor containment annulus to provide an Appendix R protected reactor coolant system letdown path and to provide fire protection for the identified reactor coolant system high/ low pressure interfaces within the annulus. However, as described
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above, at the time of the inspection. TVA did not have available an adequate I
written fire hazards analysis for this area and could not demonstrate that systems important to safe shutdown of the reactor had been designed and maintained in such a condition that they would remain free of damage in the event of a fire.
To emphasize the importance of compliance with the NRC's fire protection requirements, I have been authorized, after consultation with the Director, Office of Enforcement and the Deputy Executive Director for Regional Operations, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty in the amount of Fif ty Thousand Dollars ($50,000) for the violation described in the enclosed Notice.
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In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2. Appendix C (1988) (Enforcement Policy),
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the violation described in the enclosed Notice,has been categorized in the
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aggregate at a Severity Level III.
The base value of a civil penalty for a Severity Level III violation is $50,000.
The escalation and mitigation factors in the Enforcement Policy were considered
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and no adjustment has been deemed appropriate.
l 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 discuss your proposed long-term corrective actions for the Interaction hos. 114 and 120 described in Inspection Report Nos. 50-327/88-24 and 50-328/88-24. After reviewing your response to this Notice, including your proposed corrective actions and the results of future inspections, the NRC will determine whether further NRC enforcement action is necessary to ensure compliance with NRC regulatory requirements.
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.Mr. S. A. White Tennessee Valley. Authority-4-Sequoyah Nuclear Plant In accordance with Section 2.790 of the NRC's " Rule's of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosure will be placed in the NRC Public Document Room.
The responses directed by this letter and the enclosed Notice are not subject to the clearance procedures of the Office of Management and Budget as required i
by the Paperwork Reduction Act cf 1980, Pub. L. No.86-511.
Sincerely, James G. Partlow, Director Office of Special Projects Enclosure:
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Notice of Violation and Proposed Imposition of Civil Penalty cc: see next page
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Mr. S. A. White Tennessee Valley Authority-5-Sequoyah Nuclear Plant In accordance with Section 2.790 of the NRC's " Rule's of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosure will be placed in the NRC Public Document Room.
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The responses directed by this letter and the enclosed Notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, Pub. L. No. 86 511.
Sincerely, l
Jamer G. Partlow, Director Office of Special Projects
Enclosure:
Notice of Violation and Proposed Imposition of Civil Penalty cc:
see next page l
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OFFICIAL RECORD COPY
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Mr. S. A. White Tennessee Valley Authority-6-Sequoyah Nuclear Plant i
cc:
General Counsel Regional Ao'ministrator, Region II Tennessee Valley Authority U.S. Nuclear Regulatory Commission i
I 400 West Summit Hill Drive 101 Marietta Street, N.W.
Ell B33 Atlanta, Georgia 30323
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Knoxville, Tennessee 37902 i
Resident Inspector /Sequoyah NP Mr. R. L. Gridley c/o U.S. Ncelear Regulatory Commission Tennessee Valley Authority 2600 Igou Ferry Road
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SN 1578 Lookout Place Soddy Daisy, Tennessee 37379 i
Chattanooga, Tennessee 37402-2801
Mr. Richard King Mr. H. L. Abercrombie c/o U.S. GA0 Tennessee Valley Authority 1111 North Shore Drive Sequoyah Nuclear Plant Suite 225, Box 194 P.O. Box 2000 Knoxville, Tennessee 37919 i
Soddy Daisy, Tennessee 37379 l
Tennessee Department of Health i
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Mr. M. R. Harding and Environment Tennessee Valley Authority ATTN: Director, Bureau of Environment Sequoyah Nuclear Plant T.E.R.R. A. Building,1st Floor P.O. Box 2000 150 9th Avenue North Soddy Daisy, Tennessee 37379 Nashville, Tennessee 37219-5404 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, 6th Floor W10 885 150 9th Avenue. North Knoxville Tennessee 37902 Nashville, Tennessee 37219-E404
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County Judge Dr. Henry Myers, Science Advisor Hamilton County Courthouse Committee on Interior Chattanooga, Tennessee 37407 and Insular Affairs
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U.S. House of Representatives State of Tennessee Washington, D.C.
20515 Director, Division of Radiological Health J. A. Kirkebo, Director.
Tennessee Department of Public Health Nuclear Engineering Cordall Hull Building, C-212 W12 A12 Nashville, Tennessee 37219 400 West Summit Hill Drive Knoxville, Tennessee 37902
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Mr. S..A. White Tennessee Valley Authority-7-Sequoyah Nuclear Plant
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SUBJECT: NOTICf 0F VIOLATION AND' PROPOSED IMPOSITION OF CIVIL PENALTY (NRC ;4SPECTION REPORT NJS. 50-327/88-24AND50-328/88-24)
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DISTRIBUTION: (w/taclosure)
05P R/F TVA TP R/F JPartlow JAxelrad SRichardson j
JNGrace, RII BDLiaw SBlack
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RHermann RPierson EMarinos JBradburne, CA
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JTaylor, ED0 JLieberman, EO LChandler, 0GC MSims JDonohew SConnelly 01A TMurley, NRR RGrimes, NRR FMiraglia, NRR TMartin, DEDR0 DHolody, RI GJenkins, RII
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JGrobe, RIII HScott, RIV AJohnson, RV DRS Technical Assistant, RII BHayes, 01 FIngram, GPA/PA EJordan, AE0D JBBrady, OSP/RII WSlittle,OSP/RII OGC SECY ACRS (10)
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