ML20207Q854
| ML20207Q854 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 03/02/1987 |
| From: | Domer J TENNESSEE VALLEY AUTHORITY |
| To: | Grace J NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8703100089 | |
| Download: ML20207Q854 (3) | |
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TENNESSEE VALLEY AUTHORITY CH ATTANOOGA. TENNESSEE 374o1 SN 157B Lookout Place MAR 021987 U.S. Nuclear Regulatory Conunission Attn: Document Control De.k Office of Nuclear Reactor Regulation Washington, D.C. 20555 Attention:
Dr. J. Nelson Grace f
In the Matter of
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Docket Nos. 50-327 Tennessee Valley Authority
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50-328 SEQUOYAH NUCLEAR PLANT (SQN) UNITS 1 AND 2 - NRC-0IE REGION II INSPECTION REPORT NOS. 50-327/86-69 AND 50-328/86-69
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Enclosed is our response to Gary G. Zech's January 29, 1987 letter to S. A. White which transmitted NRC Inspection Reports 50-327/86-69 and 50-328/86-69. This response is provided to address the results of our corrective action review for the cited example of Violation 50-327, -328/86-19-06.
Our response is provided in the enclosure.
If you have any questions, please call 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, TENNESSEE VALLEY AUTHORITY
)J.A.Domer,AssistantDirector Nuclear Safety and Licensing Enclosure cc: See page 2 07031000 g { $o$$27 l
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An Equal Opportunity Employer
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. U.S. Nuclear Regulatory Conmission MAR 021987 cc (Enclosure):
Mr. J. J. Holonich Sequoyah Project Manager U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue Bethesda, Maryland 20814 Mr. James Taylor, Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. B. J. Youngblood U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue
~ Bethesda, Maryland 20814 Mr. G. G. Zech, Director TVA Projects U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Sequoyah Resident Inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy Daisy, Tennessee 37319 i
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ENCLOSURE RESPONSE - NRC-OIR INSPECTION REPORT NOS. 50-327/86-69 AND 50-328/86-69 GARY G. ZECH'S LETTER TO S. A. WHITE DATED JANUARY 29, 1987 As requested in the subject inspection report, we have reviewed our corrective actions for Violation 50-327, -328/86-19-06 to ensure that these actions also address the concerns identified in the cited example of r
Violation 86-19-06.
As identified in our responses dated August 19, 1986, and February 17, 1987, to Violation 86-19-06 and the additional example of the violation as cited in Inspection Report Nos. 50-327, 328/86-60, the root cause for the violations has been identified as personnel error, in that in each case, personnel failed to follow procedures which were established to accomplish activities affecting quality. For the example of violation 86-19-06 cited in Inspection Report 86-69, the error resulted from personnel not adequately implementing the assumptions made in a design calculation. Since the procedures at that time did not call for detailed design output for field routed tubing, the root cause of this example would be identified as a procedural inadequacy instead of a personnel error. Personnel error may be considered a contributing factor, since the procedure specified a minimum amount of detail to be included, but did allow for more detail as necessary.
The design calculation was performed (as required by the Unreviewed Safety Question Determination (USQD) for Engineering Change Notice (ECN) L5856) to predict the effect of a level transmitter sharing a process connection with a sampling line. This calculation was based on assumed tubing lengths. The
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calculation indicated that the shift in level transmitter output during sampling would be acceptable. However,.the design output drawings did not specify adherence to the assumed tubing lengths, and the installed tubing length was different from that assumed in the calculation. This difference caused the transmitter shift during sampling to be large enough to require the level transmitter to be declared inoperable.
The details of this event were transmitted to NRC as Licensee Event Report (LER) 50-327/84025, revision 1.
As stated in the LER, interim administrative controls and tubing changes were used until the level transmitter and sampling lines were placed on separate process taps.
As described above, this example of Violation 86-19-06 is a case where the assumed design was not communicated to the implementor.
In the August 19, 1986 response to Violation 86-19-06, TVA committed to establish a design basis for each plant modification. As described in our February 17, 1987 response to an example of Violation 86-19-06, the
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implementation of Sequoyah Engineering Procedure (SQEP)-13, " Transitional l
Design Control Process," will provide more detailed design output. This l
ensures the modification is installed as designed and is supported with proper calculations.
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