ML19332F754

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Notice of Violation from Insp on 891006-1108.Violation Noted:Licensee Drew 2 Samples from Unit 2 Refueling Water Storage Tank & Determined Boron Concentration to Be Below 2000 Ppm W/O Informing Operating Supervisor of Fact
ML19332F754
Person / Time
Site: Sequoyah  Tennessee Valley Authority icon.png
Issue date: 12/07/1989
From: Wilson B
Office of Nuclear Reactor Regulation
To:
Shared Package
ML19332F753 List:
References
50-327-89-25, 50-328-89-25, NUDOCS 8912180216
Download: ML19332F754 (2)


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4 ENCLOSURE 1 NOTICE OF VIOLATION Tennessee Valley Authority Docket Nos. 50-327, 50-328 Sequoyah License Nos. OPR-77, DPR-79 During the Nuclear Regulatory Commission -(NRC) inspection conducted October 6 through November 8,

1989, three violations of NRC requirements were identified.

In accordance with thc " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2 Appendix C (1989), the violations are listed below:

A.

Technical Specification 6.8.1 states that, written procedures shall be established, implemented and maintained covering surveillance and test activities of safety-related equipment.

Section 4.9 and the associated flow chart of Instruction Change Form (ICF) 89-0758 to procedure SI-137.2, Reactor Coolant System Water Inventory, requires that, if the unidentified leakage calculation results in a negative value, then the calculations will be reperformed using a minimum of one bour of additional data.

Contrary to the above, on October 18, 1989, the reactor operators completed the performance of S1-137.2 at 7:26 a.m., when the calculated unidentified leak rate was negative, without taking the additional data as required by section 4.9 of ICF 89-0758.

This is a Severity Level IV violation (Supplement I).

B.

Technical Specification 6.8.1 states that, written procedures shall be established, implemented and maintained covering surveillance and test activities of safety-related equipment.

TI-37, Radiochemical Laboratory Sampling and Logsheets, action IV requires that corrective actions as specified by the Technical Specifications should be performed if the RWST concentration is greater than 2100 or less than 2000 ppm boron.

Additionally, TI-37 requires tha', the actions of SI-51, Weekly Chemistry Requirements, be followed af ter a resample confirms a condition that does not meet acceptance criteria.

SI-51 requires the performer to notify the shift operating supervisor (505) if the data does not satisfy the acceptance criteria.

Contrary to the above, on October 20, 1989 by 8:15 a.m., the licensee had drawn 2 samples from the Unit 2 RWST and determined the boron l

concentration to be below 2000 ppm and did not inform the SOS of this fact.

l This is a Severity Level IV violation (Supplement I).

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i Tennessee Valley Authority 2

Docket Nos. 50-327, 50-328 Sequoyah License Nos. DRP-77, DPR-79 C.

Technical Specification 6.8.1.e states that written procedures shall be established, implemented and maintained covering site Radiological Emergency Plan (REP) implementation.

The Sequoyah Radiological Emergency Plan implementing procedure (EPIP)-1 Emergency Plan Classification Logic, implements these requirements, and requires that the Radiological Emergency Plan (REP) be activated when any one of the conditions listed therein is detected.

The Shif t Operating Supervisor (SOS) is responsible for declaring the emergency and providing the initial activation.

The logic of EPIP-1 states that both unit related emergency diesel generators (EDGs) inoperable simultaneously by unscheduled outage or failure as determined by the shif t engineer is a Notification of Unusual Event.

Contrary to the above, at 4:10 a.m. on October 26, 1989 the 2B-B EDG became inoperable while the 2A-A EDG was also inoperable, and the SOS did not declare an NOUE nor provide for initial activation of the REP until 6:15 a.m., over two hours after the condition was discovered.

This is a Severity Level IV violation (Supplement VIII).

Pursuant to the provisions of 10 CFR 2.201, Tennessee Valley Authority is hereby required to submit a written statement or explanation to the Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, DC 20555, with a copy to the Associate Director for Special Projects, Office of Nuclear Reactor Regulation, and a copy to the NRC Resident Inspector, within 30 days of the date of the letter transmitting this Notice.

This reply should be clearly r

marked as a " Reply to a Notice of Violation" and should include (for each violation]:

(1) admission or denial of the violation, (2) the reason for the violation if admitted, (3) the corrective steps which have been taken and the results achieved. (4) the corrective steps which will be taken to avoid further violations, and (5) the date when full compliance will be achieved.

Where good cause is shown, consideration will be given to extending the response time.

If an adequate reply is not received within the time specified in this Notice, an order may be issued to show cause why the license should not be modified, suspended, or revoked or why such other action as may be proper should not be taken.

FOR THE NUCLEAR REGULATORY COMMISSION fLC.

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Bruce A. Wilson, Assistant Director for Inspection Programs TVA Projects Division Office of Nuclear Reactor Regulation Dated at Atlanta, Georgia this 7A day of November 1989

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