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Ack Receipt of 891002 Response to Violations Noted in Insp Repts 50-327/89-19 & 50-328/89-19.NRC Disagrees That Licensee Could Not Comply W/Requirements of Tech Specs 3.0.1 & 3.3.1.1
	ML19332E397
Person / Time
Site:	Sequoyah
Issue date:	12/04/1989
From:	Liaw B; Office of Nuclear Reactor Regulation
To:	Kingsley O; Tennessee Valley Authority
References
	NUDOCS 8912070172
	Download: ML19332E397 (7)
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NUCLEAR CECULATCRY COMMISSION

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WAA888880700d, D. C. 30005

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December 4, 1989

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Docket Nos. 50-327

and 50-328

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Mr. Oliver D. Kingsley, Jr.

Senior Vice President Nuclear Power

Tennessee Valley Authority

6N 38A Lookout Place

1101 Market Street

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Chattanooga, Tennessee 37402-2801

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Dear Mr. Kingsley:

SUBJECT: NRC INSPECTION REPORT NOS. 50-327/89-19 AND E0-328/89-19

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By letter dated October 2,1989, you responded to our Notice of Violation which

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was issued on August 28, 1989,

facility.

concerning activities conducted at your Sequeyeh

We have evaluated your respo,nse to Violation A and found that it mee

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requirements of 10 CFR 2.201. We will examine im

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to correct Violation A during future inspections.plementation of your actions':

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After careful consideration of the bases for your denial of Violation 8, we

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'have concluded, for the reasons presented in the enclosure to this letter that

the violation occurred as stated in the Notice of Violation.

Therefore,In

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accordance with 10 CFR 2.201(a), please submit to this office within 30 days

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of the date of this letter a written statement describing steps which have been

taken to correct Violation B and the results achieved, corrective steps which

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will be taken to avoid further violations, and the date when full compliance

will be achieved.

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In reaching this conclusion regarding Violation B we are concerned about your

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entry into Limiting Condition for Operation (LCO),3.0.3.

It could be perceived

that such entry was made to allow Unit 1 to continue operating at 100 percent

power beyond the 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months of Action Statement 2.d of Specification 3.3.1.1 to

complete the thirCattempt to measure the quadrant power tilt ratio. . The staff

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would like to reiterate its view on voluntary entry into LC0 3.0.3.

As stated

in Generic Letter 8/-09. "... entry into LC0 3.0.3 is not intended to be used as

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an operational convenience ... Its intended purpose is to provide guidance on

the time limits for an ' orderly' shutdown when the individual LC0 or action

statements cannot be complied with."

Action 2.c of Specification 3.3.1.1 allows the operators to reduce the power

range neutron flux high trip to respond to an inoperable power range encore

detector.

We understand that the control room operators did not have a

procedure to perform this action. We would expect that procedures would be

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in place to allow the operators the full range of options permitted to meet the

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Mr. Oliver D. Kingsley, Jr.

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December 4,

1989

action statements in the Technical Specifications. The lack of procedures to

carry out Technical Specification actions can unnecessarily challenge the

operators. The staff would like to be informed of your actions with respect

to this issue.

The involvement of TVA management in the decisions for this event show an active

mana9erial role in the operations at Sequoyah,

The responses directed by this letter and its enclosure are not subject to the

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clearance arocedures of the Office of Management and Budget as required by the

Paperwork leduction Act of 1980, Pub. L. No. 96 511.

We appreciate your cooperation in this matter,

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Sincerely,

Original signed by

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D.D.Uaw

B. D. Liaw, Director

TVA Projects Division

Office of Nuclear Reactor Regulation

Enclosure:

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Evaluations and Conclusions

cc w/ enclosure:

See next page

Distribution

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DATE : g/g/89

0FFICIAL RECORD COPY

Document Name: TVA'S DENIAL

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.Mr. Oliver D. Kingsley, Jr.

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December 4, 1989

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cc w/ enclosures

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General Counsel

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Mr. Kenneth M. Jenison

Yennessee Valley Authority

Senior Resident Inspector

400 West Summiit Hill Drive

Sequoyah Nuclear Plant

ET 118 33H

U.S. Nuclear Regulatory Commission

hioxville, Tennessee 37902-

2600 IJou Ferry Road

Soddy )aisy Tennessee 37379

- Mr. F. L. Moreadith-

Vice President.-Nuclear Engineering

Mr. Michael H. Mobley, Director

Tennessee Valley Authority

Division of Radiological Health

400 West Simmit Hill Drive

T.E.R.R.A. Building 6th Floor

WT 12A 12A

150 9th Avenue North

Knoxville, Tennessee 37902

Nashville Tennessee 37219-5404

Dr. Mark 0. Medford

Dr. Henry Myers, Science Advisor

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Vice President and Nuclear

Committee on Interior

Technical Director

and Insular Affairs

Tennessee Valley Authority

U.S. House of Representatives

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6N 38A Lookout Place

Washington, D.C.

20515

Chattanooga, Tennessee 37402-2801

Tennessee Valley Authority

Manager, Nuclear Licensing

Rockville Office

and Regulatory Affairs

11921 Rockville Pike

Tennessee Valley Authority

Suite 402'

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SN 1575 Lookout Place

Rockville, Maryland 20852

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Chattanooga, Tennessee 37402-2801

Mr. Joseph Bynum.

Acting Site Director

Sequoyah Nuclear Plant

Tennessee Valley Authority

P. O. Box 2000

Soddy Daisy, Tennessee 37379

Mr. Mark J. Burzynski

Site Licensing Manager

Sequoyah Nuclear P.lant

P. O. Box 2000

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Soddy Daisy. Tennessee 37379

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County Judge

Hamilton County Courthouse

Chattanooga, Tennessee 37402

Regional Administrator, Region II

U.S. Nuclear Regulatory Commission

101 Marietta Street, N.W.

Atlanta, Georgia 30323

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ENCLOSURE

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EVALUATIONS AND CONCLUSIONS

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On August 28, 1989, a Notice of Violation (Notice) was issued for a violation

identified during a routine NRC inspection. TVA responded to the Notice on

October 2, 1989. TVA denies that Violation B is a violation. The NRC's

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evaluations and conclusions regarding the licensee's arguments are as follows:

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Restatament of Violation B

Technical Specification 3.0.1 states that upon failure to meet a Limiting

Condition for Operation, the associated Action requirements shall be met.

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Technical Specification 3.3.1 states that as a minimum, the reactor trip system

instrumentation channels and interlocks of Table 3.3-1 shall be operable with

response times as shown in Table 3.3-2.

Action Statement 2 of TS 3.3.1,

states that with the number of operable channels one less than the total number.

of channels, startup and power operation may proceed provided conditions 24

through 2.d are met.

Action 2.d states that the quadrant power tilt ratio (QPTR), as indicated by-

the remaining three detectors, shall be verified consistent with the normalized

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symmetric power distribution obtained by using the movable incore detectors in

the four pairs of symmetric thimble locations at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months when

thermal power is greater than 75 percent of rated thermal power.

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On July 22, 1989, the Unit I reactor trip system power range channel N43

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failed.

The licensee entered Action Statement 2.d.

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Contrary ~to the above, the licensee failed to reduce power to less than or

equal to 75 percent of rated thermal power to meet Action Statement 2.d when

an incore flux map to verify the QPTR could not be completed within the 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months

required by Action Statement 2.d.

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Sunnary of Licensee's Response

The 11consee dentes that its failure to reduce power to less than 75 percent of

rated thermal power constitutes a violation. The licensee believes a condition

existed that was not pmvfded for in the action statements of LCO 3.3.1.1 and

that entry into and compliance with LCO 3.0.3 were correct from both a

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regulatory compliance and reactor safety standpoint.

The licensee argues that

action statement 2.d does not require reduction to 75 percent power. The

licensee states that the violation implies that LC0 3.0.3 cannot be entered if

a licensee could have previously taku action including mwer reduction to

prevent it (i.e.. TVA should have reduced power before tw expiration of the

2.d action statement to less than 75 percent so that action statement 2.d would

no longer be applicable).

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The licenses dese< net eensider that imediate reduction in power was the

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conservettve er~ reget:wd action to take upon expiration of the initial-12-hour

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action statement nor that unnecessarily introducing a plant transient as a

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result of potential loss of monitoring would have been conservative in

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consideration of all factors.

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The licensee believes that the decisions made in this situation were

technically sound with foremost consideration to safe and prudent plant

operation. The licensee additionally believes operations were conducted

conservatively and in full compliance with associated technical specifications.

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The licensee requests that the subject violation be withdrawn.

NRC Evaluation

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The licensee has denied violation 327,328/89-19-07 on the basis that Limiting

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Condition for Operation (LC0) 3.0.3 was appro

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statement 2d of Technical Specification (TS) priately entered when action

3.3.1.1 was not met within the

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specified time allowance. Upon failurs of a power range monitor, action

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statement 2d requires that the Quadrant Power Tilt Ratio (QPTR) be verified to-

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be consistent with an incore detector power distribution at least once ever

hours when themel power is greater than 75 percent of rated themel power.y 12.

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With 56 minutes remining in the action statement time limit, the licensee had

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not successfully completed a flux map and the Assistant Shift Operations

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Supervisor was notified that an additional flux map would be required.

Instead

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of innediately initiating a reduction to 75 percent power, a decision was made

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by the Operations Superintendent to invoke the provisions of TS 3.0.3

applicable when LCO action statements are not met.

The denial letter states

that'this. decision was made because initiating a plant transient by reducing

power was not considered the most prudent course of action.

The flux map was

completed approximately 17 hours1.967593e-4 days 0.00472 hours 2.810847e-5 weeks 6.4685e-6 months after the failure of the power range monitor.

The licensee's denial of the violation does not address the requirement of

TS 3.0.1 to meet action statement requirements when an LC0 is not met.

The-

denial letter states that the violation implies that LC0 3.0.3 cannot be

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entered if a licensee could have previously taken action. including power

reduction, to prevent it. This is not the purpose of the vio!ation.

LCO 3.0.3 may be entered at any time if the purpose is to initiate an orderly

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shutdown of the un~1t. as discussed below.

The bases of the Sequoyah Technical Specifications, as well as the NRC

posities. contained in Generic Letter 87-09 and Part 9900 of the NRC Inspection

Manual, provide technical guidance pertaining to the use of LC0 3.0.3.

The

technical. specification bases for Section 3.0.3 state that "3.0.3 delineates

the action to be taken for circumstances not directly provided for in the

action statements and whose occurrence would violate the intent of the

specification." Generic Letter 87-09 and the Inspection Manual state that

" entry into LCO 3.0.3 is not intended to be used as an operational convenience

- which pemits redundant. safety systems to be out of service for a limited

period of time.

Its intended purpose is to provide guidance on the time limits

for an ' orderly' shutdown when the individual LC0 or action statements cannot

be complied with." The above guidance makes it clear that LCO 3.0.3 does not

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relieve the licenseerfrom meeting those requirements of an LCO action

statement which can be met. The incore probes used to obtain the flux map and

verify that the QPTR is within limits essentially act as a redundant core

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monitoring system for the power range excore detectors.

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The denial letter states that the licensee considered reducing power within 12

hours to comply with the action statement requirements, but chose instead to

enter TS 3.0.3.

Paragraph 9.c of inspection report 327,328/89-19 stated that

the shift supervisor intended to reduce power to 75 percent prior to the end of

the LC0 3.0.3 action time requirement rather than shut down to mode 3 as required

by the LCO 3.0.3 action statement. The licensee states in the response that_

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this plan was justified by the provisions of TS 3.0.2, since the LC0

requirements of TS 3.3.1.1 could then be met.

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In effect, the licensee used the requirements of TS 3.0.3 to extend the TS 3.3.1.1 action requirweents until either an acceptable flux map was performed

(allowing exit of LC0 3.0.3 via LCO 3.0.2, which occurred in this case) or the

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remaining LCO 3.0.3 action time had run sufficientl

power to 75 percent would allow exiting LCO 3.0.3 (y low that reduction ino j

via LC0 3.0.2) prior tea W ,

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having to be in mode 3.

The fact that the licensee planned to reduce poser 103

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75 percent prior to the expiration of TS 3.0.3 is evidence that the TS 3.3.1.1-

requirements were clear to the licensee and that the requirements could else.

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have been met-by such a power reduction before LCO 3.0.3 was entered.

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The Basis of TS 3/4.2.4 states that the quadrant power tilt ratio limit assures

that the radial power distribution satisfies the design values used in the

power capability analysis.

The clear intent of TS 3.3.1.1 and surveillance

requirement 4.2.4.2 is to limit to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months the period of operation above 75

percent power with an unmonitored quadrant.

However, the licensee operated at

approximately 100 percent power for 17 hours1.967593e-4 days 0.00472 hours 2.810847e-5 weeks 6.4685e-6 months after the power range instrument

'siled (five hours after the expiration of TS 3.3.1.1) without adequate

monitoring of the quadrant with the failed power range monitor. Although the

licensee's response stated that TVA considered a reduction in power not to be

the conservative or required action, the NRC staff believes that the reasonable

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and conservative approach would have been to reduce power to 75 percent to

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meet the action requirements of TS 3.3.1.1, as required by TS 3.0.1, rather

than continuing operation at 100 percent power with an unmonitored quadrant.

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The dental letter states that out-of-limit conditions did not exist and uses

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this assumption as additional justification for not initiating a power

reduction within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , and for not reducing power upon entry into TS 3.0.3.

As the quadrant associated with the failed power range detector was unmonitored

for 17 hours1.967593e-4 days 0.00472 hours 2.810847e-5 weeks 6.4685e-6 months , it is unclear how the lack of out-of-limit conditions on other

parameters assured that a quadrant power tilt did not exist in the unmonitored

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quadrant.

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.The staff does not agree that the licensee could not comply with the

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requirements of TS 3.0.1 and 3.3.1.1; does not agree that the licensee's

decision to not reduce power was either conservative or prudent; and does not

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agree that the licensee used LC0 3.0.3 as intended by the technical

specifications to provide for an orderly shutdown. Therefore the violation

stands.as wr1tten.

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ML19332E397

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