ML20004D336

Forwards Revised Response to NRC 810218 Ltr Re Violations Noted in IE Insp Rept 50-327/81-02.Corrective Actions:Std Practice SQA119 Unreviewed Safety Question Determination Issued 810319 & Issue Discussed in 810413 Meeting

ML20004D336
Person / Time
Site:	Sequoyah
Issue date:	04/17/1981
From:	Mills L TENNESSEE VALLEY AUTHORITY
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20004D334	List: ML20004D336 ML20004D340
References
NUDOCS 8106090225
Download: ML20004D336 (2)

Text

[ . - -

., , . ]s TENNESSEE VALLEY AUTHORITY CH ATTANOOG A. TENNESSEE 37401 400 Chestnut Street Tower II April,1.7,p 1981 t

i Mr. James P. O'Reilly, Director ,

f Office of Inspection and Enforcement U.S. Nuclear Regulatory Conunission ,

Region II - Suite 3100 I 101 Marietta Street [

Atlanta, Georgia 30303 ,

j

Dear Mr. O'Reilly:

s SEQUOYAH NUCLEAR PLANT UNIT 1 - NRC-0IE REGION II INSPECTION REPORT  !

I 50-327/81 REVISED RESPONSE TO VIOLATION The subject inspection report dated February 18, 1961 cited TVA with one  !

Severity Level V Violation. An initial response was subciitted on March 16, 1981. Enclosed is a revised response as requested by Inspector Fiedler. f If you have any questions, please get in touch with D. L. Lambert at ,

FTS 857-2581. ,

I To the best of c:y knowledge, I declare the statements contained herein are  ;

complete and true.

vary truly yours, TENNESSEE VALLEY AUTHORITY  ;

1

'l o b L. 3. Mills, !Ianager Nuclear Regulation and Safety 3 Enclosure cc: Mr. Victor Stello, Director (Enclosure) 4 Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission  ;

Washingtca, DC 20555 8106090 W l l

l ES EC9d: CDDOTTunity EmQlCV Ef

.. ~ .

'  ?

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

Centrary to the above, the PORC has not rendered determinatien3 in writing with regard to whether er not procedures er changes thereto considered under 6.5.1.6(a) constitutes an unreviewed safety question.

Ad=ission or Denial of the Alleged Violation TVA ad=its the violation.

Reason for the Violation TVA had =isinterpreted the require =ent. The minutes of PORC teetings state, "PORC reviewed and reco== ended approval. . . . " SQA21 contains the state =ent , "In its review of proposed changes to plant instructions, changes to equip =ent, changes to routine tests, and the review of proposed special tests, the co==ittee shall consider the following: .. 5.

Determination if an unreviewed safety question is involved. If so, a written summary shall be sub=itted to the Nuclear Safety Review Board and the Assistant Director' of Nuclear Power (Operations) for review." Sequoyah considered this cc=bination to be a deter =ination in writing with regard to whether or not procedures er changes thereto considered under 6.5.1.6(a) constitute an unreviewed safety question.

Corrective Steps Which Have Been Taken and the Results Achieved Standard Fractice SQA119, "Unreviewed Safety Questien Deter =ination," was issued en March 19, 1981. At a Plant Operatiens Review Cc==ittee meeting held en April 13, 1981, the require =ent for the PORC review responsibility was discussed. PORC =e=bers believed that all instructions and revisions af ter receipt of the operating license and before March 19, 1981, had been reviewed to determine if the plant could be operated safely and believed that their review =et the intent of 10 CFR 50.59.

Corrective Steps Which Will Be Taken to Avoid Further Violations Standard Practice SQA119 contains a form which will be reviewed by PORC and signed by the chair =an for all instructions and revisions.

Date When Full Compliance Will Be Achieved We are now is full co=pliance.

.