ML20197J665

Responds to NRC Re Violations Noted in Insp Repts 50-327/86-15 & 50-328/86-15.Corrective Actions:Method for Maintaining Formal Documentation of Reviews of Industry Advisors & NRC Issuances & Recommendations Established

ML20197J665
Person / Time
Site:	Sequoyah
Issue date:	05/08/1986
From:	Gridley R TENNESSEE VALLEY AUTHORITY
To:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
NUDOCS 8605200131
Download: ML20197J665 (4)

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May 8, 1986 U.S. Nuclear Regulatory Comission Region II ATTN: Dr. J. Nelson Grace, Regional Administrator 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323

Dear Dr. Grace:

SEQUOYA!i NUCLEAR PLANT UNITS 1 AND 2 - NRC-OIE REGION II INSPECTION REPORT 50-327/86-15 AND 50-328/86 RESPONSE TO VIOLATION Enclosed is our response to J. A. Olshinski's April 4, 1986 letter to S. A. White which transmitted IE Inspection Report Nos. 50-327/86-15 and 50-328/86-15 for our Sequoyah Nuclear Plant which cited TVA with one Severity Level V Violation.

If you have any questions, please get in touch with R. E. Alsup at FTS 858-2725.

To the best of my knowledge, I declare the statements contained herein are complete and true.

Very truly yours, TENNESSEE VALLEY AUTHORITY

. L. Gri ley, Director Nuclear Safet and Licensing Enclosure cc: Mr. James Taylor, Director (Enclosure)

Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C. 20555 8605200131 860508 PDR ADOCK 05000327 G PDR An Equal Opportunity Employer l

ENCLOSURE RESPONSE TO NRC INSPECTION REPORT NOS. 50-327/86-15 AND 50-328/86-15 LETTER FROM J. A. OLSHINSKI TO S. A. WHITE DATED APRIL 4, 1986 Violation 50-327/86-15-06 AND 50-328/86-15-06 Technical Specification 6.2.3 requires that the Independent Safety Engineering Group function to examine plant operating characteristics, NRC issuances, industry advisories, Licensee Event Report and other sources which may indicate areas for improving plant safety, and shall make detailed recommendations for revised procedures, equipment modifications, or other means of improving plant safety to the Assistant Director of Maintenance and Engineering of the Division of Nuclear Power.

Contrary to the above, the ISEG had no formal documentation that it examined industry advisories or NRC issuances and had not made detailed formal recommendations for revised procedures, equipment modifications or other means of improving plant safety based upon these examinations. In addition, the ISEG reported to the Site Director instead of an off-site Assistant Director as required.

This is a Severity Level V violation (Supplement I). This violation applies to both units. .

1. Admission or Denial of the Alleged Violation TVA agrees with the violation as stated.

2. Reason for Violation In March 1984, TVA initiated a major reorganization of its nuclear program, and as a part of that effort, changes were made in the duties and. responsibilities of the SQN Compliance Staff which fulfills the function as the SQN ISEG. The nuclear experience review program, formerly controlled at SQN by the SQN ISEG, was transferred to the onsite Regulatory Engineering Section. Before it was transferred, this program provided the formal documentation for review of industry advisories and

' NRC issuances for the SQN ISEG. Subsequent to this change, the SQN ISEG continued to receive experience review items; however, there was no

' formal documentation to indicate that reviews and recommendations were made.

The following are the general functions which have always been performed by the SQN ISEG:

i 1. Engineers review NRC-issued bulletins, notices, generic letters, and

! other regulatory material. This is normally accomplished by the j supervisor sending the above material to the engineers for review and initialing.

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2. Supervisor and engineers review plant operational characteristics and problems by:

a. Performing a detailed evaluation of all potential reportable occurrences (PROS) issued at the plant. This includes (1) review of surveillance instructions, maintenance instructions, technical instructions, system operating instructions, etc. ,

(2) discussions with plant maintenance and operations personnel on items identified in the PRO, and (3) evaluation of root causes and corrective actions.

b. Staying informed of day-to-day activities on a plant level by attendance of daily staff meetings and relaying this information to the ISEG engineers.

3. Engineers review operational events of other nuclear, plants by using INPO network items. These are sent out to the engineers for review and initialing. On some occasions, ISEG engineers contact these plants for further discussion of the issue.

4. Engineers perform evaluations of the content and need for Unreviewed Safety Question Determinations (50.59s) which require engineers to be familiar with the Final Safety Analysis Report (FSAR), technical specifications, various Westinghouse WCAPs, etc. Evaluation includes a determination of impact on plant nuclear safety.

5. Engineers review selected engineering change notices / design change requests for adequacy to meet commitments to NRC and non-NRC agencies (i.e., INPO).

6. Engineers review proposed changes to the technical specifications before PORC review.

7. Engineers write, review, and evaluate LERs to ensure correctness and completeness of a reportable event.

8. Perform selected trends of plant performance which could affect nuclear safety, (i.e., personnel errors, component failures, system losses, section trends, etc.).

! 9. Engineers investigate and prepare reports on special events or suspected problem areas. This includes looking at the background of

events, root causes and contributing causes, assessment of actior

taken, and making recommendations to plant management for additional corrective action both on an item-by-item basis and a generic basis.

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-10. Supervisor and engineers maintain open communications to all plant personnel, from the site director down to craf t personnel. This allows for a better opportunity to assess problem areas, get to the bottom of issues, ensure that items get the proper attention, and ease corrective action verification checks.

Reports are generated as deemed necessary by the ISEG section supervisor, and these are forwarded to the SQN site director. TVA considers that the i

SQN ISEG meets the intent of the requirements set forth in the technical specification and as required by NUREG-0737, item I.B.1.2. The failure to maintain formal documentation of certain ISEG achivities is not a breakdown of management control, and the SQN ISEG has provided management with useful information to identify potential problems.

A technical specification change was submitted in October 1984 which requested a change to TS 6.2.3 to indicate that the SQN ISEG would report to the site director. This was done to be consistent with TVA organizational changes made earlier in 1984.

3. Corrective Actions Taken and Results Achieved This violation has been discussed with the SQN ISEG engineers in an effort to stress the need to maintain formal documentation of certain ISEG functions. A method for maintaining formal documentation of reviews of industry advisories and NRC issuances and associated recomendations has been established.

4. Corrective Steps Taken to Avoid Further Violations Reorganization of TVA's corporate and site organization is being finalized which removes the ISEG function from the Compliance Staff and establishes a group that reports to the Manager of Nuclear Safety, a technical offsite corporate official. A proposed technical specification change reflecting this restructuring is presently being prepared for submittal to NRC. Until these proposed changes are approved and implemented, the SQN ISEG will maintain formal documentation of reviews of industry advisories and NRC issuances.

5. Date When Full Compliance Will Be Achieved Full compliance was achieved on May 2, 1986, when SQN ISEG established a method for formally documenting the reviews of industry advisories and NRC issuances received after May 2, 1986.

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