ML20057A414

Notice of Violation from Insp on 930711-0807.Violation Noted:Licensee Implemented Design Change Outside Established Design Control Measures & Sys & Components Found Incorrectly Translated Into Listed Category 1 Drawing

ML20057A414
Person / Time
Site:	Sequoyah
Issue date:	09/03/1993
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20057A412	List: ML20057A411 ML20057A414 ML20057A416 ML20057A420
References
50-327-93-33, 50-328-93-33, NUDOCS 9309140170
Download: ML20057A414 (3)

Text

e .

ENCLOSURE 1 NOTICE OF VIOLATION Tennessee Valley Authority Docket Nos. 50-327 and 50-328 Sequoyah, Units 1 and 2 License Nos. DPR-77 and DPR-79 During an NRC inspection conducted July 11 through August 7,1993, violations of HRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Apoendix C, the violations are listed below:

A. 10 CFR Part 50, Appendix B, Criterion III, Design Control, requires in part, that design changes, including field changes, shall be subject to design control measures commensurate with those applied to the original design.

Site Standard Practice, SSP-6.1, Conduct of Maintenance, requires that deviations from design configuration be accomplished in accordance with AI-19 (Part VI) Modifications: Permanent Design Change Control Program, or SSP-12.4, Temporary Alterations Control Form.

Contrary to the above, the licensee implemented a design change outside the established design control measures. Specifically, on January 25, 1992, modification of the heat trace circuitry on the Unit 1 emergency boration flowpath was performed by a work request.

This is a Severity Level IV violation (Supplement 1).

B. 10 CFR Part 50, Appendix B, Criterion III, Design Control, requires in part, that measures shall be established to assure that applicable regulatory requirements and the design basis, as defined Section 50.2 and as specified in the license application, for those structures, s: stems, and components to which this appendix applies are correctly translated inte specifications, drawings, procedures, and instructions.

Contrary to the above, systems and components were found to be incorrectly translated into the following Category 1 drawing:

Drawing 47W848-2, Compressed Air System Flow Diagram, contained drawing transition flags that mislabeled compressed air system headers A and B.

This drawing error resulted in the inadvertent isolation of both control air headers in the auxiliary building on July 13,1993, while establishing a clearance for work involving a moisture element. The isolation resulted in an Engineered Safety Features actua'cion in that containment isolation valves associated with the ice condenser and radiation monitor systems closed.

This is a Severity Level IV violation (Supplement 1).

r; 9309140170 930903 '

PDR ADDCK 05000327 O PDR U

4 -

\

Tennessee Valley Authority 2 Docket Nos. 50-327 and 50-328 Sequoyah, Units 1 and 2 License Nos. DPR-77 and DPR-79 '

C. Technical Specification 6.8.1 requires, in part, that written procedures l be established, implemented and maintained for applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Quality Assurance Program Requirements, Revision 2, February 1978. This includes i procedures required for the safe operation and refueling of nuclear power plants. Implicit in these requirements is that the applicable i procedures be adequate.

1. Site Standard Practice SSP-12.2, SYSTEM AND EQUIPMENT STATUS -

CONTROL, Revision 4, implements the requirements of Technical Specification 6.8.1 in that it establishes configuration control for systems and components important to safety.

Contrary to the above, SSP-12.2 was inadequate, in that, a temporary pressurization system for the reactor cavity pneumatic ,

seal was not being controlled via the requirements of SSP-12.2.

The temporary seal was utilized to support safety-related core alterations during the Unit 1 Cycle 6 (April - August 1993)  ;

refueling outage without adequate configuration controls on the  !

reactor cavity seal air supply components.

This is a Severity Level IV violation (Supplement 1).

i

2. Site Standard Practice SSP-8.2, SURVEILLANCE TEST PROGRAM, Revision 1, implements the requirements of the licensee's surveillance program.

Section 3.5.3 of SSP-8.2 describes the process for reviewing )

completed surveillance instructions packages. Item 3.5.3.H l requires that Technical Specification related packages be returned to the surveillance inst; ..: tion Scheduling Group within 10 calendar days following completion of the surveillance. j Contrary to the above, in July 1993, the NRC identified that the licensee failed to meet the required 10 calendar day review time for eight surveillance instruction packages.

This is a Severity Level IV violation (Supplement 1).

D. Technical Specification Surveillance requirement 4.9.1.2 states that the boron concentration of the reactor coolant system and the refueling canal shall be determined by chemical analysis at least once per 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The purpose of this requirement is to maintain and verify a uniform boron concentration in the water having direct access to the ,

reactor vessel. I

' l

\

l Tennessee Valley Authority 3 Docket Nos. 50-327 and 50-328 Sequoyah, Units 1 and 2 License Nos. DPR-77 and DPR-79 Contrary to the above, on July 17, 1993, with Unit 1 in Mode 6 and the  :

refueling cavity flooded, the licensee failed to perform the required TS surveillance to measure boron concentration in the Unit I refueling canal. l This is a Severity Level IV violation (Supplement 1).

Pursuant to the provisions of 10 CFR 2.201, Tennessee Valley Authority is j hereby required to submit a written statement or explanation to the U.S. -

Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C.  !

20555 with a copy to the Regional Administrator, Region II, and a copy to the NRC Resident Inspector, Sequoyah, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each  :

violation: (1) the reason for the violation, or, if contested, the basis for '

disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further  :

violations, and (4) the date when full compliance will be achieved. If an

• adequate reply is not received within the time specified in this Notice, an order or demand for information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper  ;

should not be taken. Where good cause is shown, consideration will be given to extending the response time.

Dated at Atlanta, Georgia this 3rd day of September 1993 1

i i

i E

l

,