ML20072V211
| ML20072V211 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 09/12/1994 |
| From: | Zeringue O TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9409190258 | |
| Download: ML20072V211 (5) | |
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$ ne see Valley Authority. Post Once Box 2000. Soody-Daisy. Tennessee 37379 Sept ember 12, 1994 U.S. Nuclear Regulatory Commission ATTN Document Control Desk Washington, D.C.
20555 Gentlemen:
In the Matter of
)
Docket Nos. 50-327 Tennessee Valley Authority
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50-328 SEQUOYAH NUCLEAR PLANT (SQN) - INSPECTION REPORT NOS. 50-327, 328/94 REPLY TO NOTICE OF VIOLATION (NOV) 50-327, 328/94-17-02
~
Enclosure l contains TVA's response to William E. Cline's letter to i
Oliver D. Kingsley, Jr. dated August 11, 1994, which transmitted the subject NOV.
The NOV involves inadequate corrective action (a violation of 10 CFR 50, Appendix B, Criteria XVI) to prevent recurrence of an l
adverse condition. The adverse condition involved reactor coolant water overflowing the Unit 2 postaccident sampling system collector drain tank.
Commitments are listed in Enclosure 2.
If you have any questions concerning this submittal, please telephone C. H. Whittemore at (615) 843-7210.
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Sincere
'.y O.
J.'Zeringue Acting Site Vice President OPS 4A-SQN Enclosures cc:
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9409190258 940912 PDR ADOCK 05000327 I
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l U.S. Nuclear Regulatory Commission Page 2 September 12, 1994 1
1 cc (Enclosures):
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Mr. D.
E.
LaBarge, Project Manager U.S.
Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852-2739 NRC Resident Inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy-Daisy, Tennessee 37379-3624 i
Regional Administrator U.S.
Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323-2711 1
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r ENCLOSURE 1 RESPONSE TO NRC INSPECTION REPORT' b
NOS. 50-327, 328/94-17 WILLIAM E.' CLINE'S. LETTER TO OLIVER D. KINGSLEY, JR.
DATED AUGUST 11, 1994 Violation 50-327. 328/94-17-02
" Technical Specification;(TS) 6.8.4.e for.both units required the licensee to establish, implement, and maintain.a program which would j
i ensure the. capability to obtain and analyze samples of reactor coolant, l
radioactive' iodines and particulates in plant gaseous effluents, and containment atmosphere under accident conditions. The program was required to include training of personnel, procedures for sampling and
.J analysis, and provisions for maintenance of sampling and analytical j
equipment.
"10 CFR.50,' Appendix B, Quality Assurance Criteria for Nuclear' Power Plants and Fuel Reprocessing Plants, Criterion _XVI,' Corrective Actions,.
requires that measures shall be established to assure conditions adverse to quality, such as, failures, malfunctions, deficiencies,. deviations,.
defective material and equipment, and non-conformances are.promptly l
identified and corrected.
In.the case of significant conditions adverse l
l to quality, the measures shall' assure that the cause of the condition is determined knd corrective action to preclude repetition. The i
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identification of the significant conditions adverse to quality, the l-cause of the condition, and the corrective action taken shall be documented and reported to the appropriate levels of management.
" Contrary to the above, on or about September 10, 1992, and July 5,
- 1994, reactor coolant overflowed the Unit 2' Post Accident Sample' Collector Drain Tank and spilled into a ventilation duct. Also, on or about October 8, 1993, reactor coolant overflowed the Unit 2 Post Accident sample System sample _ sink and spilled onto the floor of the Post Accident Sampling Facility. These events were documented by the licensee in l
Problem Evaluation Reports. As evidenced-by the repitition (sic) of this 1
l problem, licensee corrective actions have not been effective in I
precluding recurrence.
"This is a Severity Level.IV violation (Supplement IV)."
I Reason for the Violation The reason for the violation is management's failure to ensure that adequate compensatory measures had been established and would be maintained until the appropriate permanent corrective action could be implemented to correct and prevent recur'ence of an adverse condition.
r The adverse condition was reactor coolant system (RCS) water leaking.
through postaccidant sampling system (PASS) containment isolation valve (CIV) seats and overfilling the PASS collector drain tank.
The tank was vented to a ventilation duct and as the tank filled up, RCS water I
4 subsequently overflowed into the duct.
The reason for this condition was that the CIVs were. installed in an application for which they were not well suited. The appropriate corrective action at that time'was determined to'be either replace the valves or cap the lines; however, because of resources, the modification was postponed.
In the interim, a
compensatory measures were recommended, i.e., periodically cycling the valves to clear the seats and monitoring' tank levels.
The subject isolation valves had experienced leakage through the seats, and in previous instances, the PASS collector drain tank had overflowed as a result. The cycling of the valves reduced.the leakage and therefore reduced the chances for the drain tank to overfill. 'However,'the cycling
- of the valves was discontinued because it exposed the plant to.a possible
- TS containment' integrity action statement (3.6.1.1) requiring the plant to l
be shut down within six hours should the valves not re-seat.
The monitoring of tank levels was discontir.ned because.of a lack of formalization of compensatory actions. Management failed to provide additional interim actions to prevent the overfilling of the subject tank 1
once the cycling of the CIVs was discontinued.
Corrective Steps That Have Been Taken and the Results Achieved.
Daily checks of the PASS collector drain tank have been established and will be maintained with directions to drain the tank, if required. A l
study has-been initiated to determine the appropriate long-term corrective action.
Corrective' Steps That Will be Taken to Avoid Future Violations This event has been reviewed by management with specific emphasis on lessons learned, i.e.,
the importance of evaluating and making a conscious decision as to whether additional compensatory measures are needed when an activity is discontinued.
Date When Full Compliance Will be Achieved With respect to the incident cited, TVA is in full compliance with 10 CFR 50, Appendix B, Criteria XVI with the implementation of the corrective action stated.
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ENCLOSURE 2 COMMITMENTS INSPECTION REPORT 94-17 This event will be reviewed by management with specific emphasis on lessons learned, i.e.,
the importance of evaluating and making a conscious decision as to whether compensatory measures are needed whenever an activity is discontinued. This will be accomplished by October 7, 1994.
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