ML20010F301
| ML20010F301 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 08/10/1981 |
| From: | Mills L TENNESSEE VALLEY AUTHORITY |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20010F300 | List: |
| References | |
| NUDOCS 8109100020 | |
| Download: ML20010F301 (4) | |
Text
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' TENNESSEE VALLEY AUTHORITY l CH ATTANOOG A, TENNESSEE 37401 4
400 Chestnut Street Tower II -
August 10, 1:)81,,, g. g 3., q,
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:
SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 - NRC-0IE RE0 ION II INSPECTION REPORT '
50-327/81-22, 50-328/81 RESPONSE TO VIOLATIONS
- rhe subject inspection report dated June 9,1981 cited TVA with two Severity Level IV Violations in accordan,e with 10 CFR 2.201.
Enclosed is our response as discussed with Inspector P. Burnett on August 4 and August 7,.981.
If you-have any questions, please get in touch with D. L. Lambert at FTS 857-2581.
To the best of my knowledge, I declare the statements contained herein are complete and true.
Very truly yours,.
TENNESSE3 VALLEY AUTHORITY s - '0Y)8 L. M. Mills, Manager Nuclear Regulation and Safety Enclosure cc:
Mr. Victor Stello, Director (Enclosure)
Office of Inapection and Er.Nrcement U.S. Nuclear Regulatory Commission Washington, DC 20555 i
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ENCLOSURE SEQUOYAH NUCLEA'R PLANT UNIT 1 RESPONSE TO VIOLATIONS
. Violation 50-327/81-22-01 10 CFR 50, Appendix B, criterion V, and Section 17.2.5 of the accept d QA program-require that procedures and instructions prescribing operational e
activities that affect safety-related functions provide applicable quantitati and qualitative acceptance criteria.
Quality Assurance Manual requires that acceptance criteria shall be i ve these criteria as a basis for acceptance or rej6ctionthe surve n
e compared with Contrary to the above, instructions prescribing operational acti iti qualitative acceptance criteria in that surveillance ins v
es that include quantitative and qualitative acceptance criteria not pressurizer level channel LI-68-339A was inoperable on April 2 Consequently, inoperable condition was identified by an NRC inspectornot p
, 1981, but was
..., until the This is a Severity Level IV Violation (Supplement I.F)
Admission or Denial of the Alleged Violation TVA admits the violation occurred as stated.
Reasons for the Violation if Admitted When SI-2 was prepared, the need for acceptance criteria f overlocked and therefore was not included in the instruction or channel checks was this specific incident, it should be noted that the pressuri With respect to signal from pressurizer level is from a high level trip.68 zer level channel LI-rotection employees were aware of the offset.
Shift operating intended safety function and was therefore never actually inThe channel wou operable.
_ Corrective Steps Which Have Been Taken and Results Achieved The pressurizer level channel LI-68-339A was declared inoperabl associated bistable tripped on April 2, 1981.
e and the A change to SI-2 was put into effect on April 6,1981 to establi h acceptance criteria for the pressurizer level instrument channel check s
s.
The problems with the pressurizer channel were further investi discovered that a tubing error had prevented proper operation gated. It was pot ~ which had resulted in incorrect level indications.
of the condensate corrected on May 13-14, 1981.
The tubing error was 4
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.' orrective Steps Which' Will Be Taken-to Avoid Further Violations C
b Plans have been established to initiate a review of all SI's which contain' channel comparisons and/or checks. Through this review, TVA will evaluate the
- SI's for the need for acceptance criteria; and as determined appropriate, the acceptance criteria will be incorporated.
Date When Full' Compliance Will Be Achieve'd TVA has been in full compliance since April 6,1981 when the modifications to SI-2 were put into effect. Additionally, the above-mentioned review (and incorporation of acceptance -critaria, if necessary) of all. SI's which cc,tain channe,1 comparisons and/or checks will be completed by September 15, 1981.
1
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Violation 50-327/81-22-02
.10 CFR 50, Appendix B, Criterion V requires that activi 'ea affecting quality shall be accomplished in accordance with instructions. ~ection 17.2 3 of the accepted QA program requires that instructions shall be implemented to assure that modifications meet quality assurance standard at least equal to those of the original installation. The safety evaluation for workplan 9117 which recalibrated pressurizer level channel LT-68-339 included special requirement 2 whi.ch required that the level indication of channel 68-339 to be compared once per shift to the other two level channels (335 and 320) to confirm that the relationship was unchanged.
Contrary to the above, the safety evaluat t'n was inadequate in that it assumed without confirmation that adequate, quantified surveillance instructions existed when in fact they did not.
This is a Severity Level IV Violation (Supplement I.F).
Admission or Denial of the Alleged Violation TVA admits the violation occurred as stated.
Reasons for the Violation if Admitted The unreviewed safety question determination (USQD),
i.e.,
safety evaination, correctly stated the special condition to be observed in connection with this temporary change. The violation occurred as stated, however, in that the Plant Operations Review Committee (PORC) in their review of workplan 9117 assumed that SI-2 was adequate to assure full implementation of special requirements of the USQD when in fact it was not.
SI-2 had previously been reviewed and approved by PORC.
It had been succ6ssfully used for this same activity in the past. PORC did not assure when SI-2 was first approved that it contained adequate acceptance criteria. On this particular occasion, PORC believed that the special condition would be adequately implemented since an approved instruction was to be used.
Corrective Steps Which Have Been Taken and Results Achieved The pressurizer level channel LI-68-339A was declared inoperable and the associated bistable tripped on April 2, 1981. A change to SI-2 was put into effect on April 6,1981, to establish acceptance criteria for the pressurizer level instrument channel checks.
Corrective Steps Which Will Be Tcken To Avoid Further Violations This occurrence will be discussed with PORC members by August 31, 1981. Members will be reminded of the importance of fully assuring that work instructions implement USQD requirements.
Plant instruction AI-19 will be revised by September 15, 1981 to require PORC to assure that USQD special requirements are delineated in the workplan.
Date When Full Compliance Will Be Achieved
. We will be in full complian'e by September 15, 1981.