ML20031E894

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Responds to NRC Re Violations Noted in IE Insp Repts 50-327/81-23 & 50-328/81-28.Corrective Actions:Revised Tracking Sys & Improved Organization Communication Re Adequate Followup Responses to Safety Issues
ML20031E894
Person / Time
Site: Sequoyah  Tennessee Valley Authority icon.png
Issue date: 09/28/1981
From: Mills L
TENNESSEE VALLEY AUTHORITY
To: James O'Reilly
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20031E886 List:
References
NUDOCS 8110160525
Download: ML20031E894 (3)


Text

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TENNESSEE VALLEY AUTHORITY CH ATTANOOG A, TEN NESSEE 37401 400 Chestnut Street Tower II ti September 28, 1981 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 REGION II INSPECTION REPORT 50-327/81-23, 50-328/81 RESPONSE TO VIOLATION AND DEVIATION The subject inspection report dated August 26, 1981 cited TVA with one Severity Level IV Violation and one deviation. Enclosure 1 contains our response to the violation. Our response to the deviation is contained in Enclosura 2.

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

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

Very truly yours, TENNESSEE VALLEY AUTHORITY

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]m, L.' M. Mills, Kanager Nuclear Regulation and Safety Enclosure oc:

Mr. Victor Stello, Director (Enclosure)

Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, DC 20555 i

8110160525 811007 DRADOCK05000g An Equal Opportunity Employer I

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DEIDSURE 1 SDDOOYAH NUCLEAR PIANT UNIT 1 RESPONSE 'IO VIOLATION Violation 327/81-23-02 10 CFR 50, Appendix B, '_riteric." XVI, requires tnat the licensee establish measures to assure that conditions adverse to quclity such as deficiencies are promptly identified and corrected. 'The accepted Quality Assurance Program Topical Report TVA-TR75-1, section 17.2.16, " Adverse Conditions and Correction Action," requires that adverse conditions be corrected in a manner consistent with their safety.

Contrary to the above, conditions adverse to quality were not promptly corracted. A deficiency concerning the potential for 6900-volt breakers to lockout without the knowledge of the control room operators was evaluated to be significant and require corrective action in August 1980 but was not corrected until June 1981.

This is a Severity Level IV Violation (Supplement I.D.3).

Admission or Denial of the Alleged Violation TVA admits the violation occurred as stated.

Reasons for the Violation if Admitted TVA did not properly identify the safety synificance of the deficiency and the urgency of the required corrective action because of (a) inadequate tracking systems within TVA organizations to properly ensure timely followup of potential safety concerns and (b) inadequate and not clearly defined lines-of-communications aaong applicable organizations within TVA concernire resolution of such issues.

Corrective Steps Which Have Been Taken and the Results Achieved TVA has taken masures to ensure adequate followup responses to safety or potential safety issues by (a) having revised existing tracking systems to include capability of tracking such concerns (Division of Nuclear Power Divison Procedure, DR4-N72-A39, " Reporting and Feedback of Operating FNperience Items," last revision July 28, 1981) and (b) having established improved lines of comunication among TVA organizations such that they will be made fully aware of the significance and needed resolution to all safety issue concerns. TVA recognizes the need for an overall improvement in the areas of tracking and interdivisional comunications and is working to resolve these deficiencies.

Corrective Steps Which Will Be Taken to Avoid Further Violations Corrective actions taken to date are deemed sufficient to minimize n.;urrence.

Date when Full Cm oliance Will Be Achieved All physical wark to accomplish full ccanpliance was completed June 26, 1981.

i ENCLOSURE 2 SEQUOYAH NU(1 EAR PLANT UNIT 2 RESPONSE ID DEVIATION Deviation 328/81-28-02 In a final report to the Nuclear Regulatory Commission dated August 25, 1980 regarding reportable deficiency NCR 27P, ' Safety Injection Pump Breaker Lockout,' the licensee stated that the work necessary to correct the deficiency would be corrected by November 3,1980.

Contrary to the above, on May 19, 1981 when the inspector inquired into the status of the work, no work had been performed.

Admission or Denial TVA admits the deviation occurred as stated.

P sons for Deviation This deviation occurred due to the lengthy review tine required for the Engineering Change Notice (ECN). Also, tLe Design Chenge ; equest (DCR) failed to be submitted in such a manner as to allow for the completion date of November 3,1980 to be supported.

Corrective Actions In February through May 1982, TVA reviewed responses associated with 10?FR50.55(e) items and identified all outstanding commitments made in the reports submittod on these items. The status of these commitments has been under evaluaticn and appropriate steps taken on items which are incomplete.

TVA documented the failure to meet thL commitment date by NCR SQN NEB 8128 on May 28, 1981. This item was reported to the NRC and the necessary corrective actions identified in the letter from L. M.

Mills to J. P. O'Reilly dated July 6, 1981. Additionally, revised final report on NCR 27P was submitted on June 9, 1981.

It provided our revised corrective ections and commitments.

Corrective Steos Taken to Avoid Further Noncomellance The TVA commitment tracking program is being re-ised to require tracking of commitments associated with 10CFR50.55(e) items. This program is outlined in revision 4 to EN DES-EP 2.07, which is anticipated to be issued by October 23, 1981. This procedure will prevent further deviations in this area.

Date of Full Comoliance TVA will be in full compliance with the issuance of EN DES-EP 2.07 on October 23, 1981.

Items identified as not being completen an schedule are being incorporated into the revised commitment tracking program.

TVA has been in full compliance in regard to the specific deviation since before plant heatup.

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