ML20045H993
| ML20045H993 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 07/15/1993 |
| From: | Fenech R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9307220238 | |
| Download: ML20045H993 (5) | |
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Termessee valley Authority. Po',1 Office Boy 2000 Soddy-Daisy, Tennenee 373742000 Robert A. Fenech
%ce Premdent Sequoyah Nur. lear Pl ant July.15, 1993 U.S. Nucles. k..m'atory Commission
-ATTN:
Document vontrol Desk Washington, D.C. 20555 Gentlemen:
In the Matter of
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Docket Nos. 50-327-Tennessee Valley Authority
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50-328 SEQUOYAH NUCLEAR PLANT (SQN) - NRC INSPECTION REPORT NOS. 50-327, 328/93-300 - REPLY TO NOTICE OF VIOLATION (NOV) 50-327, 328/93-300-03 contains TVA's reply to Thomas A. Peebles' letter to Mark O. Medford dated June 15, 1993, which transmitted the subject NOV.
The violation involves a failure to maintain the emergency operating procedures technically correct and the step deviation document accurate-and complete. The list of commitments is contained in Enclosure 2.
If you have any questions concerning this sutmittal, please telephone-J. W. Proffitt at (615) 843-6651.
Sincerely,
..&bh Robert A. Fenech Enclosure cc: See page 2 200061 4
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'U.S. Nuclear Regulatory Commission.
Page 2 July'.15, 1993 cc (Enclosure): '
Mr. D. E. LaBarge, Project Manager U.S. Nuclear. Regulatory Commission One White ~ Flint, North l
. 11555 Rockville Pike-Rockville, Maryland 20852-2739 NRC Resident Inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road
.. Soddy-Daisy, Tennessee l37379-3624 Regional Administrator U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323-2711 F
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ENCLOSURE
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RESPONSE TO NRC INSPECTION REPORT NOS. 50-327/93-300 AND 50-328/93-300-i THOMAS A. PEEBLE'S LETTER TO MARK 0. MEDFORD 1
DATED JUNE 15, 1993 i
Violation 50-32L_328/93-300-03 "10 CFR 50, Appendix B, Criterion V requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Section IV of the Sequoyah Procedures Generation Package (Verification and Validation Program) article D.1 requires that the Emergency Operating Procedures be technically correct and that the step deviation document be accurate and complete.
" Contrary to the above, 1.
The Step Deviation Document (EPM-3) was not accurate _and complete in that section 3.2.3 did not agree with step 10.b of ES-3.2 (Post-Steam Generator Tube Rupture Cooldown by Ruptured S/G Depressurization).
EPM-3 stated that the Blowdown method was chosen as the preferred means to depressurize the ruptured steam generator in ES-3.2; however, the actual procedure used the condenser steam dump valves as the preferred method.
2.
The Step Deviation Docwnent was not technically correct in that' it stated that the intent of Westinghouse Owners Group guideline ES-0.0 was fully met by the Sequoyah Emergency Operating Procedures due to the transition steps within the instructions and inclusion of additional transitions on the foldout pages of applicable instructions; however, the transition from E-3 to E-1 could not be made within the framework of the Sequoyah Emergency Operating Procedures.
"This is a Severity Level IV violation (Supplement I)."
Reason _fn _ thel lolation The cause of the discrepancy contained in the EPM-3, " Step Deviation
-i Document," was the failure to perform the required verification during the development of Sections 1.0, 2.0, and 3.0 of the step deviation l
document.
During the emergency operating instruction 1(E01) upgrade project, the E01s, including Emergency Instruction ES-3.2, " Post SGTR Cooldown by Ruptured S/G Depressurization," were compared with the Westinghouse Owners Group (WOG) Emergency Response Guidelines, Revision 1A.
Procedure ES-3.2 was determined to be technically correct.
At this time, the step deviation document only included the justification for step-specific 'dif ferences that later became Section 4.0 of EPM-3.
i During the subsequent development of Procedure EPM-3 (Sections 1.0, 2.0, and 3.0), the individuals involved overlooked the verification requirement for these sections of the step deviation document since the justification for step-specific differences (Section 4.0 of EPM-3) had been previously verified.
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A contributing factor was inattention to detail and inadequate review by the individual developing the step deviation document.
The cause of the step deviation document not being correct by indicating that WOG Guideline ES-0.0, "Redlagnosis," was fully met was the failure to perform the required verification during the development of the step deviation document. Contributing factors were the inadequate review and inattention to detail by the procedure developers.
Correrliye Stapa_Ihat_llave Been Taken and the Results Achieved A direct work request has been submitted to the WOG Operations Subcommittee for a determination of the appropriateness of including the transition from E-3, " Steam Generator Tube Rupture," to E-1, " Loss of Reactor or Secondary Coolant." After completion of the review, procedures will be revised, if appropriate.
The_CoIIestive Stena_Ihat_Will be Iaken to Avoid Fur _ther Violation The verification of the step deviation documents against the E0Is will be performed to ensure that the step deviation documents agree with the' procedures.
EPM-3 will be revised to agree with Procedure ES-3.2.
The E01 program will be revised to include a requirement that verification be performed on the initial issue of all sections of a docunent that requires verification or validation of any section of that document.
Personnel performance issues are being addressed as part.of the SQN Restart Plan and the SQN Site Improvement Plan.
Date_}lhen Full Compli.ance Will be Achiere.d TVA will be in full compliance on December 23, 1993.
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ENCLOSURE 2 INSPECTION REPORT 50-327, 328/93-300 COMMITMENTS 1.
The verification of the step deviation document against the emergency operating instruction will be performed by December 23, 1993, to ensure that the step deviation documents agree with the procedures.
2.
The emergency operating instruction program will be revised before restart te include a requirement that verification is to be performed on the initial issue of all sections of a document that requires verification or validation of any section of that document.
3.
EPM-3, " Step Deviation Document," will be revised before restart to agree with Procedure ES-3.2.
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