ML20205Q661

Notice of Violation from Insp on 880906-09.Violation Noted: Regulatory Requirements of 10CFR50.59 Not Properly Translated Into Instructions or Procedures in Rev 2 to PMP-0604.04

ML20205Q661
Person / Time
Site:	Sequoyah
Issue date:	11/01/1988
From:	Mccoy F NRC OFFICE OF SPECIAL PROJECTS
To:
Shared Package
ML20205Q642	List: ML20205Q638 ML20205Q661 ML20205Q680
References
50-327-88-43, 50-328-88-43, NUDOCS 8811090310
Download: ML20205Q661 (2)

Text

ENCLOSURE 1 NOTICE OF VIOLATION Tennessee Valley Authority Docket Nos. 50-327 and 50-328 Sequoyah 1 and 2 License Nos. OPR-77, and DPR-79 During the Nuclear Regulatory Comission (NRC) inspection conducted on September 6-9, 1988 a violation of NRC requirements was identified. The viola-tion involved failure to have adequate procedural controls in place and failure to follow procedures regarding 10 CFR 50.59 safety evaluations. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the violation is listed below:

10 CFR 50, Appendix B, Criterion V, implemented by TVA's Topical Quality Assurance Report TVA-TR75-1A, Rev. 10, requires that activities affecting l quality be described by documented instructions, procedures or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with those instructions, procedures or drawings.

10 CFR 50, Appendix B, 3 1terion III, implemented by TVA-TR75-1A, requires, in part, that measures shall be established to assure that applicable regulatory requirements are translated into specifications, 4

drawings, procedures, and instructions.

4 TVA-TR75-1A further commits to compliance with ANSI N45.2.11-1974, l

"Quality Assurance Requirements for the Design of Nuclear Power Plants".

ANSI N45.2.11, Section 3 "Design Input Requirements", requires that design input include regulatory requirements.

10 CFR 50.59 contains regulatory requirements concerning the determination that proposeo changes to licensed f acilities do not constitute unreviewed i safety questions.

q Contrary to the above, regulatory requirements of 10 CFR 50.59 were not l properly translated into instructions or procedures in that TVA Instruc- I l tion PMP-0604.04, Rev. 2, and subsidiary instructions implemented the l 10 CFR 50.59 criteria in a less conservative form and did not contain '

instructions to ensure that the assu ptions and limitations used as part 1 of the basis of the saf aty evaluation would remain valid. This resulted in USQ0 2EEE035 not being adequate and could have resulted in an unreviewed sdety question.

I This is a Severity Level :V violation (Supplerent I) and is applicable to l Units 1 and 2.

4 pursuant to the prnisions of 10 CFR 2.201, the Tennessee Valley Authority is t hereby required it sut-it a .-itten state ent or explanation to the Nucietr Regulatory Cc--ission ATIN: h:u ent Control Oesk, Washington, D.C. 20565, a

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8011090310 831102 PDR ADOCK 05000327 0 PDC

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Tennesiee Valley Authority 2 Docket Nos. 50-327 and 50-328 Sequoyah 1 and 2 License Nos. OPR-77, and OPR-79 with a copy to the Director, Office of Special Projects, and a copy to the NRC Resident Inspector, Sequoyah, within 30 days of the date of the letter trans-mitting this Notice. This reply should be clearly marked as a "Reply to a Notice of Violation" and should include (for each violation]: (1) admission or denial of the violation, (2) the reason for the violation if admitted, (3) the corrective steps which have been taken and the results achieved (4) the corrective steps which will be taken to avoid further violations, and (5) the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending the response time. If an adequate reply is not received within the time specified in this Notice, an order may be issued to show cause why the license should not be modified, suspended, or revoked or why such other action as may be proper should not be taken.

FOR THE NUCLEAR REGULATORY MMISSION Frank R. McCoy, Assistant Director for TVA Inspection Programs

-~ TVA Projects Division Office of Special Projects Dated at Atlanta, Georgia this/s/*dayofNovember1988

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