ML19343C548

Forwards Response to Violation Noted in IE Insp Rept 50-327/81-02 on 810218.Corrective Action:Util Has Clarified Requirements for Determination That Item Does Not Constitute Unreviewed Safety Question

ML19343C548
Person / Time
Site:	Sequoyah
Issue date:	03/16/1981
From:	Mills L TENNESSEE VALLEY AUTHORITY
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
NUDOCS 8103240466
Download: ML19343C548 (2)

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U.S. Nuclear Regulat Commission fo j (g Regicx1 II - Suite 3100 h'aV <p 101 Marietta Street \ A,' y$ .6' Atlanta, Georgia 30303

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Dear Mr. O'Reilly:

SEQUOYAH NUCLEAR PLANT UNIT 1 - NRC-0IE REGION II INSPECTION REPORT 50-327/81 RESPONSE TO VIOLATION The sub, ject inspection report dated February 18, 1981, cited TVA with one 3everity Level V Violation. Enclosed is our response.

If you have any questions, please get in touch with D. L. Lambert at FTS 857-2581.

To the best of ny knowledge, I declare the statements contained herein are complete and true.

Very truly yours, TENNESSEE VALLEY AUTHORITY

. L. M. Mills, Manager

' Nuclear Regulation and Safety Enclosure , ,' f cc: Mr. Victor Stello, Director (Enclosure)If Office of Inspection and Enforcement U.S. Nuclear Regulatory Commiission Washington, DC 20555 3o6

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ENCLOSURE SEQUOYAH NUCLEAR PLANT RESPONSE TO VIOLATION Violation 50-327/81-02-1 Technical Specification 6.5.1.7(b) requires that the PORC shall render determinations in writing with regard to whether or not each item considered under 6.5.1.6(a) through (e) constitutes an unreviewed safety question.

Contrary to the above, the PORC has not rendered determinations in writing with regard to whether or not procedures or changes thereto considered under 6.5.1.6(a) constitutes an unreviewed safety question.

Admission or Denial of the Alleged Violation TVA believes the violation is based on misinterpretation of the require-ments. The minutes of PORC meetings state, "PORC reviewed and recom-mended approval. . . . " SQA21 contains the statement, "In its review of proposed changes to plant instructions, changes to equipment, changes to routine tests, and the review of proposed special tests, the committee shall consider the following: .. 5. Determination if an unreview2d safety

- question is involved. If so, a written summary shall be submitted to the Nuclear Safety Review Board and the Assistant Director of Nuclear Power (Operations) for review." Sequoyah considers this combination to be a determination in writing with regard to whether or not procedures or changes thereto considered under 6.5.1.6(a) constitutes an unreviewed safety question.

Ryason for the Violation Not applicable ,

Corrective Steps Which Have Been Taken and the Results Achieved Not-applicable Corrective Steps Which Will Be Taken to Avoid Further Violations

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To avoid future interpretation proble=s, Sequoyah immediately began adding the follcwing statement to the PORC minutes. "PORC reviewed the items listed below and determined that' each i'tes does not constitute an unreviewed safety. question." . In addition, a Standard Practice has been

, draf ted. to further . define the performance of an unreviewed safety question determination.

Date When Full Compliance Will Be Achieved

- Sequoyah is now in full compliance with the NRC's interpretation of the l requirement.'