ML20207J671
| ML20207J671 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 07/15/1986 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8607290217 | |
| Download: ML20207J671 (13) | |
Text
7 e
TENNESSEE VALLEY AUTHORITY CH ATTANOOGA, TENNESSEE 374o1 SN 157B Lookout Place
.; C :2 a7: 7/
JUL 151986 U.S. Nuclear Regulatory Commission Region II ATTN:
Dr. J. Nelson Grace, Regional Administrator 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323
Dear Dr. Grace:
SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 - NRC-OIE REGION II INSPECTION REPORT 50-327/86-28 AND 50-328/86 RESPONSE TO VIOLATION AND DEVIATION Enclosed is our response to S. P. Weise's June 13, 1986 letter to S. A. White which transmitted Notice of 73.olation Nos. 50-327/86-28-01 and 50-328/86-28-01 and Notice of Deviation Nos. 50-327/86-28-17 and 50-328/86-28-17 for our Sequoyah Nuclear Plant. is our response to the subject violation and deviation.
Our commitments are listed in enclosure 2.
We do not recognize any other actions described herein or the subject inspection report as commitments.
If you have any questions, please get in touch with G.
B. Kirk at (615) 870-6549.
To.the best of my knowledge, I declare the statements contained herein are complete and true.
Very truly yours.
TENNESSEC VALLEY AUTHORITY R. Gridley, Director Nuclear Safety and Licensing Enclosures cc (Enclosures):
Mr. James Taylor, Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Mr. S. P. Weise, Chief Reactor Projects Branch 1 Division of Reactor Projects U.S. Nuclear Regulatory Commission Region II - Suite 2900 101 Marietta Street, NW Atlanta, Georgia 30323 8607290217 860715 PDR ADOCK 05000327 G
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An Equal Opportunity Employer
ENCLOSURE 1 RESPONSE - NRC-0IE INSPECTION REPORT NOS. 50-327/86-28 AND 50-328/86-28 STEVEN P. WEISE'S LETTER TO S. A. WHITE DATED JUNE 13, 1986 l
Violation 50-327/86-28-01 and 50-328/86-28-01 Technical Specification (TS) 6.15, Major Changes to Radioactive Waste Treatment Systems (Liquid, Gaseous and Solid), requires that licensee initiated major changes to the radioactive waste systems be reported to the Commission in the Semi-Annual Radioactive Effluent Release Report (or Final Safety Analysis Report) for the period in which the evaluation was reviewed by the Plant Operations Review Committee (PORC). TS 6.15 states, in parts d, e, f, g and h that the discussion of each change shall include:
d.
an evaluation of the change which shows the predicted releases of radioactive materials in liquid and gaseous effluents and/or quantity of solid waste that differ from those previously predicted in the license application and amendments thereto; e.
an evaluation of the change which shows the expected maximum exposures to individuals in the restricted area and to the general population that differ from those previously estimated in the license application and amendments thereto; f.
a comparison of the predicted releases of radioactive materials, in liquid and gaseous effluents and in solid waste, to the actual releases for the period prior to when the changes are to be made; g.
an estimate of the exposure to plant operating personnel as a result of the change; and h.
documentation of the fact that the change was reviewed and found acceptable by the PORC.
TS 6.15 further states that the modification shall become effective upon review and acceptance by the PORC.
Contrary to the above, the licensee did not submit information on a major radwaste system change made in 1982 until the submittal of a Final Safety Analysis Report Revision dated April 11, 1985. The licensee also failed to perform the evaluations to meet the requirements of TS 6.15, parts d, e, f, i
1 J
g and h and failed to provide a discussion of these parts to the Commission.
In addition, the modifications were implemented without review and acceptance by the PORC.
This is a Severity Level V violation (Supplement I).
This violation applies to both units.
1.
Admission or Denial of Alleged Violation TVA admits the violation occurred as stated.
J
4
.. 2.
Reason for the Violation The violation occurred due to interpretation of the words " major change." Since the CDWE was designed to process secondary side spent regenerant solutions and is capable of concentrating floor and tritiated drain wastes from the liquid radwaste systems, plant personnel did not consider its use as des:ribed in the referenced inspection report to be a " major change".
3.
Corrective Steps Taken and Results' Achieved The Division of Nuclear Engineering (DNE) will prepare an evaluation which addresses the requirements of TS 6.15 items d through g by December 31, 1986. Within two weeks of the plant staff's acceptance of this evaluation, it will be PORC reviewed to satisfy the requirements of item h.
This information will be submitted to the Commission in the next Semi-Annual Radioactive Effluent Release Report (RERR) following PORC approval of the evaluation.
4.
Corrective Steps Taken to Avoid Future Violations To prevent future violations of this nature, DNE's Design Control Process procedures will include steps / precautions to ensure that the requirements of TS 6.15 are met for any future " major changes" to the Radwaste Systems.
5.
Date When Full Compliance Will Be Achieved The besign Control Process procedures will be issued / revised by October 1, 1986, and the Commission will be notified of completion of the evaluation of requirements of items d through h of TS 6.15 in the next Semi-Annual RERR following completion of item h (PORC approval o.f evaluation).
Deviation 50-327/86-28-17 and 50-328/86-28-17 Facility Operating License (FOL) No. DPR-77, Section 2.C(23)E. and FOL No.
DPR-79, Section 2.C(16)f. require the installation of reactor coolant system and reactor vessel head high point vents that are remotely operable from the control room. The licensee utilizes the pressurizer power operated relief valves (PORVs) as the reactor coolant system high point vents.
In a letter dated July 16, 1982, the licensee committed to provide guidelines for reactor operator use on the release of noncondensibles from the reactor coolant system in accordance with an Emergency Operating Instruction provided as an attachment to the letter. The attachment described the use of the PORVs for this function in the event of the failure of the Reactor Vessel Head Vent System (RVHVS).
I
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.. In a letter dated February 15, 1984, the licensee committed to implement these procedures at the time that the upgraded emergency operating instructions were implemented. By order dated June 15, 1984, the Nuclear Regulatory Commission required implementation of the upgraded emergency operating procedures by August 1985 for both units.
Contrary to the above, the licensee failed to meet the commitment in the July 16, 1982, and February 15, 1984 letters in that the upgraded Sequoyah Emergency Instructions do not include procedures for use of the pressurizer PORVs as reactor coolant system high point vents.
Sequoyah Response In accordance with NUREG 0737 commitments for upgrading emergency procedures, in August 1935 Sequoyah issued new emergency procedures for the release of noncondensibles from the Reactor Coolant System (RCS). These procedures are based on the Westinghouse Owners Group (WOG) generic guidelines revision 1 dated September 1983. The WOG guidelines utilize the RVHVS but do not utilize the pressurizer PORV as described in the above notice of deviation.
It is TVA's intention to continue to utilize these WOG guidelines and a letter clarifying the configuration of the RVHVS and how it will be utilized will be submitted to NRC by September 1, 1986, to revise the commitments made in the July 16, 1982 submittal.
I
ENCLOSURE 2 COMMITMENTS 1.
By December 31, 1986, DNE will prepare an evaluation which addresses the requirements of TS 6.15 items d through g.
2.
Within two weeks of the plant staff's acceptance of this evaluation, it
- will be PORC reviewed and approved to satisfy the requirements of item h.
3.
In the next Semi-Annual RERR following completion of item h (PORC approval of evaluation) the information relative to this evaluation of
- TS 6.15 will be submitted to the Commission.
4.
By October 1, 1986, the Design Control Process procedures will be issued / revised to insure that the requirements of TS 6.15 are met for any future " major changes" to the radwaste systems.
5.
By September 1, 1986, TVA will make a submittal clarifying the configuration of Sequoyah RVHVS and how it will be utilized. This will revise the commitments made in the July 16, 1982 submittal.
9
ENCLOSURE 1 RESPONSE - NRC-0IE INSPECTION REPORT NOS. 50-327/86-28 AND 50-328/86-28 STEVEN P. WEISE'S LETTER TO S. A. WHITE DATED JUNE 13, 1986 Violation 50-327/86-28-01 and 50-328/86-28-01 Technical Specification (TS) 6.15, Major Changes to Radioactive Waste Treatment Systems (Liquid, Gaseous and Solid), requires that licensee initiated major changes to the radie ctive waste systems be reported to the Commission in the Semi-Annual Radioactive Effluent Release Report (or Final Safety Analysis Report) for the period in which the evaluation was reviewed by the Plant Operations Review Committee (PORC).
TS 6.15 states, in parts d, e, f, g and h that the discussion of each change shall include:
d.
an evaluation of the change which shows the predicted releases of radioactive materials in liquid and gaseous effluents and/or quantity of solid waste that differ from those previously predicted in the license application and amendments thereto; e.
an evaluation of the change'which shows the expected maximum exposures to individuals in the restricted area and to the general population that differ from those previously estimated in the license application and amendments thereto; f.
a comparison of the predicted releases of radioactive materials, in liquid and gaseous effluents and in solid waste, to the actual releases for the period prior to when the changes are to be made; g.
an estimate of the exposure to plant operating personnel as a result of the change; and h.
documentation of the fact that the change was reviewed and found acceptable by the PORC.
TS 6.15 further states that the modification shall become effective upon review and acceptance by the PORC.
Contrary to the above, the licensee did not submit information on a major radwaste system change made ir. 1982 until the submittal of a Final Safety Analysis Report Revision dated April 11, 1985. The licensee also failed to perform the evaluations to meet the requirements of TS 6.15, parts d, e, f, g and h and failed to provide a discussion of these parts to the Commission.
In addition, the modifications were implemented without review and acceptance by the PORC.
This is a Severity Level V violation (Supplement I).
This violation applies to both units.
1.
Admission or Denial of Aller,ed Violation TVA admits the violation occurred as stated.
1
' 2.
Reason for the Violation The violation occurred due to interpretation of the words " major change." Since the CDWE was designed to process secondary side spent regenerant solutions and is capable of concentrating floor and I
tritiated drain wastes from the liquid radwaste systems, plant
_ personnel did not consider its use as described in the referenced inspection report to be a " major change".
_3.
Corrective Steps Ta en and Results Achieved The Division of Nuclear Engineering (DNE) will prepare an evaluation
~'
which addresses the requirements of TS 6.15 items d through g by December 31, 1986. Within two weeks of the plant staff's acceptance of this evaluation, it will be PORC reviewed to satisfy the requirements l
of item h.
This information will be submitted to the Commission in the next Semi-Annual Radioactive Effluent Release Report (RERR) following PORC approval of the evaluation.
4.
Corrective Steps Taken to Avoid Future Violations To prevent future violations of this nature, DNE's Design Control Process procedures will include steps / precautions to ensure that the requirements of TS 6.15 are met for any future " major changes" to the Radwaste Systems.
5.
Date When Full Compliance Will Be Achieved The Design Control Process procedures will be issued / revised by October 1, 1986, and the Commission will be notified of completion of the evaluation of requirements of items d through h of TS 6.15 in the next Semi-Annual RERR following completion of item h (PORC approval of evaluation).
beriation 50-327/86-28-17 and 50-328/86-2C-17 Facility Operating License (FOL) No. DPR-77, Section 2.C(23)E. and FOL No.
DPR-79, Section 2.C(16)f. require the installation of reactor coolant system and. reactor vessel head high point vents that are remotely operable from the control room. The licensee utilizes the pressurizer power operated relief valves (PORVs) as the reactor coolant system high point vents.
In a letter dated July 16, 1982, the licensee committed to provide guidelines for reactor operator use on the release of noncondensibles from the reactor coolant system in accordance with an Emergency Operating Instruction provided as an attachment to.the letter. The attachment described the use of the PORVs for this function in the event of the failure of the Reactor Vessel Head Vent System (RVHVS).
I l
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l
. In a letter dated February 15, 1984, the licensee committed to implement these procedures at the time that the upgraded emergency operating instructions were implemented. By order dated June 15, 1984, the Nuclear Regulatory Commission required implementation of the upgraded emergency operating procedures by August 1985 for both units.
Contrary to the above, the licensee failed to meet the commitment in the July 16, 1982, and February 15, 1984 letters in that the upgraded Sequoyah Emergency Instructions do not include procedures for use of the pressurizer PORVs as reactor coolant system high point vents.
Sequoyah Response In accordance with NUREG 0737 commitments for upgrading emergency procedures, in August 1985 Sequoyah issued new emergency procedures for the release of noncondensibles from the Reactor Coolant System (RCS). These procedures are based on the Westinghouse Owners Group (WOG) generic guidelines revision 1 dated September 1983. The WOG guidelines utilize the RVHVS but do not utilize the pressurizer PORV as described in the above notice of deviation.
It is TVA's intention to continue to utilize these WOG guidelines and a letter clarifying the configuration of the RVHVS and how it will be utilized will be submitted to NRC by September 1, 1986, to revise the commitments made in the July 16, 1982 submittal.
I l
t
ENCLOSURE 2 COMMITMENTS 1.
By December 31, 1986, DNE will prepare an evaluation which addresses the requirements of TS 6.15 items d through g.
- 2.. Within two weeks of the plant staff's acceptance of this evaluation, it will be PORC reviewed and approved to satisfy the requirements of item h, 3.
In the next Semi-Annual RERR following completion of item h (PORC approval of evaluation) the information relative to this evaluation of TS 6.15 will be submitted to the Commission.
4.
By October 1, 1986, the Design Control Process procedures will be issued / revised to insure that the requirements of TS 6.15 are met for any future " major changes" to the radwaste systems.
5.
By September 1, 1986, TVA will make a submittal clarifying the configuration of Sequoyah RVHVS and how it will be utilized. This will revise the commitments made in the July 16, 1982 submittal.
G
ENCLOSURE 1 RESPONSE - NRC-0IE INSPECTION REPORT NOS. 50-327/86-28 AND 50-328/86-28 STEVEN P. WEISE'S LETTER TO S. A. WHITE DATED JUNE 13, 1986 Violation 50-377/86-28-01 and 50-328/86-28-01 Technical Specification (TS) 6.15, Major Changes to Radioactive Waste Treatment Systems (Liquid, Gaseous and Solid), requires that licensee initiated major changes to the radioactive waste systems be reported to the Commission in the Semi-Annual Radioactive Effluent Release Report (or Final Safety Analysis Report) for the period in which the evaluation was reviewed by the Plant Operations Review Committee (PORC). TS 6.15 states, in parts d, e, f, g and h that the discussion of each change shall include:
d.
an evaluation of the change which shows the predicted releases of radioactive materials in liquid and gaseous effluents and/or quantity of solid waste that differ from those previously predicted in the license application and amendments thereto; an evaluation of the change'which shows the expected maximum exposures e.
to individuals in the restricted area and to the general population that differ from those previously estimated in the license application and amendments thereto; f.
a comparison of the predicted releases of radioactive materials, in liquid and gaseous effluents and in solid waste, to the actual releases for the period prior to when the changes are to be made; g.
an estimate of the exposure to plant operating personnel as a result of the change; and h.
dccumentation of the fact that the change was reviewed and found acceptable by the PORC.
TS 6.15 further states that the modification shall become effective upon review and acceptance by the PORC.
Contrary to the above, the licensee did not submit information on a major radwaste system change made in 1982 until the submittal of a Final Safety Analysis Report Revision dated April ll, 1985.
The licensee also failed to perform the evaluations to meet the requirements of TS 6.15, parts d, e, f, g and h and failed to provide a discussion of these parts to the Commission.
In addition, the modifications were implemented without review
(
and acceptance by the PORC.
This is a Severity Level V violation (Supplement I).
This violation applies to both units.
1.
Admission or Denial of Alleged Violation TVA admits the violation occurred as stated.
. 2.
Reason for the Violation The violation occurred due to interpretation of the words " major change." Since the CDWE was designed to process secondary side spent regenerant solutions and is capable of concentrating floor and tritiated drain wastes from the liquid radwasto systems, plant
, personnel did not consider its use as described in the referenced inspection report to be a " major change".
3.
ICorrective Steps Taken and Results Achieved The Division of Nuclear Engineering (DNE) will prepare an evaluation which addresses the requirements of TS 6.15 items d through g by December 31, 1986. Within two weeks of the plant staff's acceptance of this evaluation, it will be PORC reviewed to satisfy the requirements of item h.
This information will be submitted to the Commission in the next Semi-Annual Radioactive Effluent Release Report (RERR) following PORC approval of the evaluation.
4.
Corrective Steps Taken to Avoid Future Violations To prevent future violations of this nature, DNE's Design Control Process procedures will include steps / precautions to ensure thst the requirements of TS 6.15 are met for any future " major changes" to the Radwaste Systems.
5.
Date When Full Compliance Will Be Achieved The Design Control Process procedures will be issued / revised by October 1, 1986, and the Commission will be notified of completion of the evaluation of requirements of items d through h of TS 6.15 in the next Semi-Annual RERR following completion of item h (PORC approval of evaluation).
Deviation 50-327/86-28-17 and 50-328/86-28-17 Facility Operating Liccuse (FOL) No. DPR-77, Section 2.C(23)E. and FOL No.
DPR-79, Section 2.C(16)f. require the installation of reactor coolant system and reactor vessel head high point vents that are remotely operable from the control room. The licensee utilizes the pressurizer power operated relief valves (PORVs) as the reactor coolant system high point vents.
In a letter dated July 16, 1982, the licensee committed to provide guidelines for reactor operator use on the release of noncondensibles from the reactor coolant system in accordance with an Emergency Operating Instruction provided as an attachment to the letter. The attachment described the use of the PORVs for this function in the event of the failure of the Reactor Vessel Head Vent System (RVHVS).
a
I
. In a letter dated February 15, 1984, the licensee committed to implement these procedures at the time that the upgraded emergency operating instructions were implemented. By order dated June 15, 1984, the Nuclear Regulatory Commission required implementation of the upgraded emergency operating procedures by August 1985 for both units.
Contrary to the above, the licensee failed to meet the commitment in the July 16, 1982, and February 15, 1984 letters in that the upgraded Sequoyah Emergency Instructions do not include procedures for use of the pressurizer PORVs as reactor coolant system high point vents.
Sequoyah Response In accordance with NUREG 0737 commitments for upgrading emergency procedures, in August 1985 Sequoyah issued new emergency procedures for the release of noncondensibles from the Reactor Coolant System (RCS). These procedures are based on the Westinghouse Owners Group (WOG) generic guidelines revision 1 dated September 1983. The WOG guidelines utilize the RVHVS but do not utilize the pressurizer FORV as described in the above notice of deviation.
It is TVA's intention to continue to utilize these WOG guidelines and a letter clarifying the configuration of the RVHVS and how it will be utilized will be submitted to NRC by September 1, 1986, to revise the commitments made in the July 16, 1982 submittal.
ENCLOSURE 2 COMMITMENTS 1.
By December 31, 1986, DNE will prepare an evaluation which addresses
.the requirements of TS 6.15 items d through g.
2.
Within two weeks of the plant staff's acceptance of this evaluation, it
~' will be PORC reviewed and approved to satisfy the requirements of item h.
3.
In the next Semi-Annual RERR following completion of item h (PORC
- approval of evaluation) the information relative to this evaluation of TS 6.15 will be submitted to the Commission.
ByOctober1,1986,theDesignControlProcessprocedureswillbe 4.
issued / revised to insure that the requirements of TS 6.15 are met for any future " major changes" to the radwaste systems.
5.
By September 1, 1986, TVA will make a submittal clarifying the configuration of Sequoyah RVHVS and how it will be utilized. This will
. revise the commitments made in the July 16, 1982 submittal.
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,