ML20134J848

Responds to NRC Re Violations Noted in Insp Repts 50-327/96-12 & 50-328/96-12.Corrective Actions:Operations Dept Performed Review of Procedures to Determine Which Procedures Ref Inoperable Radiation Recorder

ML20134J848
Person / Time
Site:	Sequoyah
Issue date:	02/03/1997
From:	Adney R TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9702120367
Download: ML20134J848 (5)

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Tennessee Valley Authority, Post Offee Box 2000, Soddy-Daisy, Tennessee 37379-2000 R.J. Adney  :

Sne Vce P uidan  !

&qwyah Nuceer Phnt [

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February 3,1997 l l

U.S. Nuclear Regulatory Commission Attention:

Document Control Desk 5 Washington, D.C. 20555 Gentlemen: ,

l In the Matter.of ) Docket Nos. 50-327 i Tennessee Valley Authority ) 50-328 l l

SEQUOYAH NUCLEAR PLANT (SON) UNITS 1 and 2 - REPLY TO NOTICE l OF VIOLATION (NOV) - NRC INSPECTION REPORT NOS. 50-32?,

328/96-12 ,

This letter responds to Harold O. Christensen's letter to Oliver D. Kingsley, Jr., dated January 2, 1997, that-transmitted the subject NOV. The NOV addresses one violation associated with the failure to adequately maintain emergency procedures.

The NRC letter transmitting the subject NOV expressed NRCs f concern relative to similarities between this violation ;"3 a previously issued violation that was contained in NRC f Inspection Report 50-327, 328/96-05. TVA has reviewed both igj' violations and has determined that although the violations p-both deal with abandoned equipment, the specific causes of the  !

violations are different. However, TVA is concerned in  :

general about how abandoned equipment is addressed. We l believe that as a result of the actions taken and that are to l be taken, to resolve the subject violation, understanding of  !

plant impact as a result of abandoning equipment will improve.

9702120367 970203  ?

PDR ADOCK 05000327; G PDR ,,

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! 'U.S. Nuclear Regulatory Commission

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[ February 3, 1997 j Enclosure 1 contains TVA's response to the NOV. Commitments 1 associated with the submittal'are contained in Enclosure 2.

j If you have any questions concerning this submittal, please i telephone R. H. Shell at ;423) 843-7170, l' Sincerely, 4

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f j R. J.-Adney

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i Enclosures 1

3 cc (Enclosures) :

Mr. R. W. Hernan, Project Manager l Nuclear Regulatory Commission I One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852-2739

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NRC Resident Inspector i l Sequoyah Nuclear Plant

'2600 Igou Ferry Road Soddy-Daisy, Tennessee 37379-3624 i Regional Administrator j U.S. Nuclear Regulatory Commission j- Region II

! 101 Marietta Street, NW, Suite 2900 i Atlanta, Georgia 30323-2711 J.

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ENCLOSURE 1 REPLY TO THE NOTICE OF VIOLATION i NRC REPORT NOS. 50-327, 328/96-12 HAROLD O. CHRISTENSEN'S LETTER TO OLIVER D. KINGSLEY, JR.

DATED JANUARY 2, 1997 DESCRIPTION OF VIOLATION 50-327, 328/96-12-01:

"Sequoyah Technical Specification 6.8.1 requires that procedures shall be established, implemented and maintained for activities l which include the recommended procedures of Appendix "A" to Regulatory Guide 1.33, Revision 2, February 1978.

" Regulatory Guide 1.33, Revision 2, Appendix "A", Section 6 includes Procedures for Combating Emergencies and other Significant Events, such as ... Loss of Coolant ... and Reactor Trip ...

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" Contrary to the above, the Procedures for Combating Reactor Trip 4

or Safety Injection (E-0, Revision 18) and Loss of Reactor or 4

Secondary Coolant (E-1, Revision 13) were not adequately I

I maintained in that both procedures required operator actions based on information obtained from radiation recorded RR-90-12, which was found to have been abandoned in place for a period exceeding two years. This deficiency was caused by failure of

! the licensee to adequately implement the design centrol process for abandoned plant equipment.

"This is a Severity Level IV violation (Supplement I)"

1 REASON FOR VIOLATION l

The cause of the violation was the failure to recognize the involvement of emergency operating procedures (EOPs) when the decision was made to stop maintaining the radiation recorder i 0-RR-90-12. In March 1993, a prob Am evaluation report (PER) was l initiated to address repetitive failures and obsolete parts on plant radiation monitors, including continuous air monitors (CAMS). As a result of that PER, a design change request was initiated to remove some CAMS, replace other CAMS, add three monitoring stations, and to replace the associated obsolete multi-point radiation recorder (0-RR-90-12). In March 1994, after the design change request was initiated and approved, maintenance of the equip 2 ant (including the :adiation recorder) was discontinued. Subsequent to the March 1993 PER, design documentation was issued, based on overall site priorities. to render some of the CAMS obsolete and to remove the recorder's alarm function. In January 1996, TVA determined that configuration control problems existed with the remaining CAMS t

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and associated recorder as a result of the equipment not being j- maintained and no approved design output documentation being issued for abandonment of the equipment. This condition was  ;

documented on a PER and a corrective action plan was developed to j issue a design change' notice for abandonment of the remaining equipment. In November 1996, during Maintenance Rule j evaluations, TVA discovered that the EOPs still addressed use of '

radiation recorder 0-RR-90-12.

CORRECTIVE STEPS TAKEN AND THE RESULTS ACHIEVED f The Operations department performed a review of procedures to  ;

dete mine which procedures reference the inoperable radiation  !

recorder. Four procedures were identified by the review, and j those procedures were revised to remove reference to recorder  ;

0-RR-90-12. The information that would have been provided by the  !

recorder is available through other means.  ;

Plant equipment that fell within the scope of the maintenance rule and is referenced in Revision 1B of the EOPs was reviewed.

Radiation recorder 0-RR-90-12 was the only component identified ,

as unavailable.

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CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS Operations personnel will review the EOPs by March 28, 1997, to  !

determine if other equipment referred to in the EOPs, but outside i the scope of the maintenance rule, is not being maintained functional. Any procedural changes required as a result of this review will be completed by April 25, 1997.

l To ensure equipment impacts are properly evaluated before  !

discontinuance of maintenance activities, appropriate process (es)  !

will be revised by March 28, 1997, to require the performance of l appropriate evaluations including recognition of EOP impact. l l

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED With respect to the violation, TVA will be in full compliance following additional procedural reviews and revision of the operator work around process in March 1997 and completion of any procedural changes in April 1997.

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• ENCLOSURE 2 l l

COMMITMENTS TO THE NOTICE OF VIOLATION J NRC 2EPORT NOS. 50-327, 328/96-12 HAROLD O. CHRISTENSEN'S LETTER TO OLIVER D. KINGSLEY, JR.

DATED JANUARY 2, 1997 ,

VIOLATION 50-327. 328/96-12-01:

1. Operations personnel will review the EOPs by March 28, 1997, ,

to determine if other equipment referred to in the EOPs, but  !

outside the scope of the maintenance rule, is not being i maintained functional. Any procedural changes required as a l result of this review will be completed by April 25, 1997. I

2. To ensure equipment impacts are properly evaluated before discontinuance of maintenance activities, appropriate process (es) will be revised by March 28, 1997, to require the performance of appropriate evaluations including recognition of EOP impact.

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