ML20128G344

Forwards Supplemental Info to Responses to 850326 Questions Re TVA Rept Concerning Pressure Monitoring Instrumentation. Fact Finding Team Recommended Enforcement Action to Be Taken Based on Inadequacies in TVA Procedures

ML20128G344
Person / Time
Site:	Sequoyah
Issue date:	05/10/1985
From:	Palladino N NRC COMMISSION (OCM)
To:	Udall M HOUSE OF REP., INTERIOR & INSULAR AFFAIRS
Shared Package
ML20128G347	List: ML20128G344 ML20128G368
References
NUDOCS 8505300126
Download: ML20128G344 (6)

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WASHINGTON, D. C. 20555

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CHAIRMAN Y #

574r 713, 31f The Honorable Morris K. Udall, Chairman Subcommittee on Energy and the Environment Committee on Interior and Insular' Affairs United States House of Representatives Washington, D. C. 20515

Dear Mr. Chairman:

This is in response to questions addressed in your letter of

. March 26, 1985 regarding Tennessee Valley Authority report B 45 85 0305 309. The staff's interim responses were forwarded without Commission review to Subcommittee staff on March 29, 1985. For completeness, the enclosure to this letter includes the interim responses provided on March 29, 1985 as well as supplementary information obtained since that time.

The headquarters fact-finding team found a number of inadequacies in the applicable TVA procedures, in general, and in the handling of this particular issue. The fact-finding team has recommended that enforcement action be taken based on their findings. Enforcement actions are under consideration and we will inform you of final decisions in this regard.

We hope this information is responsive to your request.

Sincerely,

.!/ f'?;([s M 'u-Nunzio J. Palladino

Enclosure:

Supplemental Information to 3/29/85 Response cc: Rep. Manuel Lujan 8505300126 850510 PDR CDMMS NRCC CDRRESPONDENCE PDR

M Enclosure

. Supplemental Information to Responses to Congressman Udall's Questions Question No. 1: On what date did the NRC receive B45 '85 0305 3097 Answer provided to Subcommittee staff on 3/29/85:

, Region II received a copy of Revision 0 and Revision 1 of B45 '85 0305 309 on March 22, 1985. This was provided voluntarily by the licensee in response to a Region II telephone request. Region II requested this report in response to inquiries from the media which published non-tech'11 cal descriptions of Revision 0 to the nonconformance report.

Question No. 2: Was the condition described in B '85 0305 309 reportable pursuant to 10 CFR 50.72 or other NRC reporting require-

, ments?

Answer provided to Subcommittee staff on 3/29/85:

The conditions described in Revision 0 to NCR B45 '85 0305 309 would have been reportable pursuant to 10 CFR 50.72 if the conditions were valid. We currently understand that TVA on-site staff concluded that the NCR was not technically accurate and the containment pressure transmitters were operable; therefore, a determination was made that a report pursuant to 10 CFR 50.72 was not required.

The NRC is reviewing the adequacy of the licensee's process in making this de-termination. In addition, other reporting requirements responsibilities are being reviewed.

l 1

y Supplemental Information:

A headquarters fact finding team visited the TVA Sequoyah site and Knoxville engineering offices on March 26-29, 1985 to review the circumstances involving TVAs handling of the subject NCR. The conclusion of the team was that the licensee's systems and actions relative to the containment pressure transmitters were not consistent with the significance of the issue described in Revision 0 of the nonconformance report (NCR) and Failure Evaluation / Engineering Report (FE/ER). Although low level supervisory personnel believed the NCR to contain technical errors, the NCR depiction of the potential safety concerns with in-strument environmental qualification was not escalated to responsible managers, for resolution and appropriate disposition. This is supported by the facts that the Office of Engineering determined the existence of a potential safety problem on March 5, 1985; management resolution of the issue was not documented as com-plete until March 14, 1985 and Rev. I to the NCR was not issued until March 22, 1985. Inadequacies with the licensee process with respect to reportability of the issues raised in the NCR pursuant to 10 CFR 50.72 and 10 CFR 50.49 are still under review.

Question No. 3: Does TVA possess an analysis which demonstrates that the conclusions described in B45 '85 0305 309 are invalid?

If so, when was that analysis prepared? When was it given to the NRC? When was it given to the TVA Chief Nuclear Engineer? What was the TVA Chief Nuclear Engineer's response to it?

'4 Answer provided to Subcommittee staff on 3/29/85:

Revision 1 to NCR B45 '85 0305 309 contained changes to Revision 0 of that document and added a justification for interim operation. The TVA Chief Nuclear Engineer concurred by signature with Revision 1 of this document on March 22, 1985. Both.of these documents were provided to the NRC on March 22, 1985, as stated above. Although we do not currently have answers to the other parts of this question, this matter including examination of the utilities actions between receipt of Revision 0 and March 22, 1985 is presently under review by the NRC.

Supplemental Information:

Revision 0 of NCR B45 '85 0305 309 is a straight forward and conservatively based document with respect to qualification of the accuracy of the contain-ment pressure transmitters during the post accident phase. Revision 0 con-cludes that the Sequoyah containment pressure transmitters should be replaced with instruments whose qualification has been specifically verified. However, Revision 0 relied on instrument accuracy data that was questionable in its rel-evance to the installed Sequoyah pressure transmitters in their actual location.

Revision 1 of NCR B45 '85 0305 309 was prepared by TVA to correct technical errors in Revision 0 and to add a Justification for Continued Operation (JLO),

in accordance with the requirements of 10 CFR 50.49(i). Revision 1 is a less conservatively based document that contains contradictions. Revision 1 does not

o ..

's clearly invalidate the technical assessments and conclusions made in Revision 0, but reduces the overall safety impact assessment from Rev. O. The JC0 contains the essential elements for justifying interim operation, but there are inadequa-cies and technical items not properly addressed.

Question No. 4: Did the Sequoyah Operating License require that the Sequoyah plants be shutdown following discovery of a condition such as that described in B45 '85 0305 3097 Answer Provided to Subcommittee staff 3/29/85:

The Sequoyah Nuclear Unit Technical Specifications (Appendix A to the Ooerating License) require that the pressure transmitters in question be operable and that if they are not operable, the unit must start to shutdown in 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> and be in hot shutdown in the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

As discussed above, the operability determination for these pressure transmitters differed between Revision 0 and Revision 1 of B45 '85 0305 309. The timing and adequacy of the licensee's operability determination are currently under review by the headquarters fact finding team.

-Supplemental Information:

As discussed in the response to Question 2 and Question 3,.the headquarters fact finding team found inadequacies in the licensee's process for dealing with the safety concerns raised in Revision 0 and Revision 1 of the NCR.

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.1 By letter dated April 8,1985, TVA stated their position concerning both the qualification (pursuant to 10 CFR 50.49) and operability of the pressure trans-mitters in question. In their letter, TVA stated that the transmitters were qualified for interim use in accordance with 10 CFR 50.49 and operable at the time Revision 0 and Revision 1 were approved by the Chief Nuclear Engineer, Nuclear Engineering Branch. TVA replaced transmitters PD-30-44 and -45 with ones fully qualified in accordance with 10 CFR 50.49 on March 31 - April 1, 1985.

TVA's stated reason for replacing the transmitters was to eliminate any question concerning their environmental qualification.

i The staff found that TVA did not have a written, formal document justifying ac-ceptable interim operation (i.e., operability) during the period of March 5 to March 22, 1985. However, the JC0 contained in Revision 1 did not rely on any equipment, operating or procedural changes that would have made the JC0 invalid between March 5 to March 22, 1985. Thus, while there was no documented basis for acceptable interim operation, the JCO, in retrospect, did provide a valid basis for establishing operability in this time period.

L.

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