ML20004B608

Responds to NRC 810520 Ltr Re Potential Environ Qualification Deficiencies for Facility.Internal Procedures Adequately Address Potential Deficiencies.Continued Safe Operation Is Adequately Ensured

ML20004B608
Person / Time
Site:	Sequoyah
Issue date:	05/26/1981
From:	Mills L TENNESSEE VALLEY AUTHORITY
To:	Harold Denton Office of Nuclear Reactor Regulation
References
NUDOCS 8105290164
Download: ML20004B608 (2)

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l e TENNESSEE VALLEY AUTHORITY CH AT T A NOOG A. TEf 4 N ESS L C 37 401 4 'to' 400 Chestnut Street Tower II e IT 4 g[1 yJ j\

J Hay 26, 1981 g

( N 2.S 1981m .$

Mr. Harold L. Denton, Director s Office of Nuclear Remotor Regulation U.S. Nuclear Rsi;;ilatory Commission 9 ,

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ID@(S Washington, DC 20555

Dear Mr. Denton:

In the Matter of the Application of ) Docket Nos. 50-327 Tennessee Valley Authority ) 50-328 This in in response to R. L. Tedesco'a letter to H. G. Parris dated May 20, 1981, concerning potential environmental qualification deficiencies for Sequoyab Guolear Plant identified as a m ault of the NRC staff's preliminary review of our submittals over the past months. The letter-required that TVA provido a uritten statement supporting the safe operation of Sequoyah that takes into account the NRC staff's preliminary list of deficiencies indicated in Appendix B of the enclosure to the lotter.

It appears that Appendix B is based on your review of my October 31, 1980, and February 5,1981, submittals since it addresses the equipment listed in Table 11 of those submittels (Suzciary of Equipment Qualification Status).

Our October 31, 1980, and February 5, 1981, responses serve as a m ference document. They contain the conditions for qualification and avference all documentation of equipment status and qualification. This win be main-tained current, auditable, and available for review. The classifloation and qualificaticn of Class IE electrical equipment is a dynasio process which of necessity requirs;.: mvision to the original submittal. Revision 1 to our original response to NUREG-0588 and the Qualification Program Plan, prepared under contract by Wyle Laboratories, were transmitted with my February 5,1981, submittal. This revision is ir41oative of the I evolutimary process.

We continue to fcous our attention on equipment qualifloation and its impact on the safe operation of Sequoyah. We believe that our internal l

procedures for addressing equipment qualification, coupled with the tasks being performed under contract by organizations such as Wyle Laboratories, adequately address the potential equipment deficiencies indicated in Appendix B. Several Licensee Event Reports (LER's) have been submitted on equipment identified as being unqualified under the mquirements of NUREG-0588. LER's will be submitted on any equipment so identified in the future.

Based on the above, we believe Sequoyah is in conformance with General Design Criteria 4 of 10 CFR 50 Appendix A, and continued safe operation of Sequoyah mit 1 is adequately ensured.

s 8105290 M p e c--mo emo.

l

== o r Mr. Harold H. Denten, Director thy 26,1981 For the record, we would like to point cut one minor discrepancy In* the notaticn of correctivo action for the components listed in Appendix A of the enclosure to the letter- The 10 Cutice-Hammer handsvitches listed ere noted as heing recoved from service by disconnecting and eliminating their function from the control circuit. This cotion has been taken only for, hundowitchos 1-H3-72-403 and 1-H3-72-41B. The rer.aining elEht hand: witches were evaluated by TVA and, from a safety significance standpoint, were determined to be not required for operaticn in the pctentially harsh accident environments in which they are located.

TVA has made and will continue to make every reaocnable of ort to eceply with the requirements of NUREG-0588. However, several concisions over which TVA has no control cay preclude full implementation of these requironents by June 30, 1982. Theco conditions are the delay of publication cf the HRC Safety Evaluation Report, originally dua to be ccepleted by February 1, 1931, and the inability of equipment vendors to provide equipment qualified to the pertinent qualifination standards in sufficient quantities to neet de=and. Additionally, due to the nuolear Iolustry's cocpotitive demand for qualified equipment, the lead time between cotually purchasing the equipment and delivery of the equipacnt for installation is expected to ta significant.

Very truly yours, l

TENNESSEE VALLEY AUTUORITY L. H. Hills, Dianager 1

Nuclear Regulation end Safety M en oe g before me subscrit thia ,f* ddayof///gt. - 1981 utar tNsilo utY YLMS6 - '

hy Comission Expires M, , L l

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