ML20004D340

Responds to NRC 810218 Ltr Re Violations Noted in IE Insp Rept 50-327/81-02.Corrective Actions:Std Practice Drafted to Further Define Performance of Unreviewed Safety Question Determination

ML20004D340
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)
Shared Package
ML20004D334	List: ML20004D336 ML20004D340
References
NUDOCS 8106090236
Download: ML20004D340 (2)

Text

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~INNEs3EZ VALLEY A UTHCRIT

CH ATT ANCCG A TC',N U S C:; 3 7 G ,

(gg 400 Chestnut Street Tower I.' f

. 1 March 16, 1981 .

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

Office of Inspection and Enforcement -

U.S. Nuclear Regulatory Commission -

Region II - Suite 3100 101 Marietta Street Atlanta, Georgia 30303

Dear Mr. O'Reilly:

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j SEQUOYAH NUCLEAR PLANT UNIT 1 - NRC-ole REGION II INSFECTION REPORT l

50-327/81 RESPONSE TO VIOLATION t i-i The subject inspection report dated February 18, 1981, cited TVA with one Severity Level V Violation. Enclosed is our response. l i i If you.have any questions, please get in touch with D. L. Lambert at i i FTS 857-2581. t I

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

Very truly yours, (

TENNESSEE VALLEY AUTHORITY  ;

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L. M. Mills, nager j Nuclear Regulation and Safety ,

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Enclosure i j cc

Ftr. Victor Stello, Director (Enclosure) i Office of Inspection and Enforcement  !

U.S. Nuclear Regulatory Commission {

Washington, DC 20555  !

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8106090 N s.

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

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 =ectings state, "PORC reviewed and recom-mended approval...." SOA21 contains the statement, "In its review of proposed changes to plant instructicns, changes to equipment, changes to routine tests, and the review of propoaed special tests, the committee shall consider the following: .. 5. Determination if an unreviewed 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 (Operatiens) for review." Sequoyah considers this combination to be a deterninaticn in writing with regard to whether or not procedures or changes thereto considered under 6.5.1.6(a) constitutes an unreviewed safety questien.

Reason for the Violation Not applicable Corrective Steps Which Have Been Taken and the Results Achieved Not applicable Corrective Steos Which Will Be Taken to Avoid Further Violations To avoid future interpretation problems, Sequoyah immediately began adding the following statement to the PORC minutes. "PORC reviewed the items listed below and determined that each item 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 de termina tion .

Date When Full Ccmpliance Will Be Achieved j Sequoyah is now in full compliance with the NRC's interpretation of the l requirement.

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