ML20210P277
| ML20210P277 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 08/20/1997 |
| From: | Bajestani M TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-327-97-03, 50-327-97-3, 50-328-97-03, 50-328-97-3, NUDOCS 9708270043 | |
| Download: ML20210P277 (5) | |
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Torvsessee Valley Autterity. Post otroe Box 2000. Smi1v Damy Tuvuswe 3737mro Masoud B:4estaN Sito Vce Prosdan Semyah Nudoar F%nt i
August 20, 1997 U.S. Nuclerr Regulatory Commission 10 CFR 2.201 ATTN Docament Co'itrol Desk Washington, D.C. 20555 Gentlement In the Matter of
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Docket Nos.
50-327 Tennessee Valley Authority
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50-328 SEQUOYAH NUCLEAR PIANT (SQN) - NRC INSPECTION REPORT NOS.
50-327/97-03 AND 50-328/97 REPLY TO NOTICE OF VIOIATION (NOV)
This letter provides TVA's reply to NOV 50-327/97-03, Violation G.
The violation was documented in the subject inspection report dated May 12, 1997, and reaf firmed in NAC's July 23, 1997 3etter that reviewed TVh's June 11, 1997~ denial of the violation. -The violation was characterized as a failure to maintain adequate design control relative to accident dose calculations.
i TVA, understands that no response is required for Example 1 of
.the. violation based on NRC's evaluation and withdrawal of the example as documented jn NRC's July 23, 1997 letter.
The enclosure contains TVA's response to Examples 2 and 5 of the NOV.
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'.1.B. Nuclear Regulatory Commission Pqge 2 August 10. 1997 l
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If you have questians regarding this response, please contact l
me at (d23) 843 7001 or Pedro Salas at (423) 843-7170.
Sincerel y.,
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-Masoud a estani i
Enclosure I
cc (Enclosure):
Mr. R. W. Hernan, Project Manager Nuclear Regulatory Commission l
i One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852-2739 l
NRC Resident Inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy-Daisy, Tennessee 37379-3624 Regional Administrator U.S. Nuclear Regulatory Commission Region II Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta, Georg;a 30303-3415
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ENCLO8URE l
L TENNE 8SEE VALLEY AUTHORITY 8EQUOYAH NUCLEAR PLANT (8QN) l UNITS 1 AND 2 l
INSPECTION REPORT NUMBER 8 50-327/97-03 AND 50-328/97-03 REPLY - TO NOTICE OF VIOLATION (NOV) l l
RESTATEMENT OF VIOLATION G (50-327, 328/97-03-09) l i
"10 CPR 50, Appendix B, Criterion III,' Design Control, l
requires in part that measures be established to assure that applicable regulatory requirements are correctly translated into drawings and procedures.
The measures shall include provisions to assure that appropriate quality standards are specified and included in design documents.
The design L
control measures shall also provide for verifying or checking i -
the adequacy of design.
l Tennessee Valley Authority Nuclear Quality-Assurance Plan TVA-NOA-PLN89-A, Revision 6, Section 7.0, Design Control, t
requires that measures be established to ensure that the performance of design analysis shall be planned and controlled.
Additionally, it requires that-measures to control plant configuration and ensure that'the actual plant.
- configuration is accurately depicted on drawings and other-l L
- appropriate design output documents and reconciled with the l
applicable design _ basis shall be established, documented, and implemented.
- TVA-NOA-PLN89-A, through Section 7.0 and Appendix B, endorses the requirements of ANSI N45.2,11-1974, Quality Assurance Requirements for the Design of Nuclear Power Plants. Section 4.0 of this standard requires that design analyses shall be performed in a. planned, controlled, and correct manner.
Design. analyses shall also be.in a form suitable for reproduction, filing, and retrieving.
I contrary to the above the established design control measures were deficient in that_the following deficiencies were i~dentified:
L 1.
As of July 30, 1990, radiation dose 1 values contained in design basis Calculation.TI-RPS-48, Integrated Accident Dose Inside Primary Containment and Annulus, Revision 3, were never incorporated.in Calculation TI-ECS-55, Summary of Harsh Environment Conditions for Sequoyah Nuclear
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plant, to ensure revision of environmental data drawing l
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.O series number 47E235.
Additionally, FSAR Figures 3.11.2-1, ano 3.11.2-2 were never revised to reflect the new 100-day integrated accident doses based on a source term of 1000 EFPD.
This failure to control plant configuration and ensure that actual plant configuration was accurately depicted on drawings resulted in discrepancies in design basis information listed in FSAR Table 15.1.7-1 and FSAR Figures 3.11.2-1 and 3.11.2-2.
2.
On December 12, 1991, TVA management approved design basis calculation TI-RPS-48, Revision 5, " Integrated Accident Dose Inside of Primary, Containment and Annulus,"
to document the 100-day integrated beta and gamma radiation doses based on a source term of 650 EFPD.
Radiation dose values contained in this calculation were incorporated into Calculation TI-ECS-55, " Summary of Harsh Environment Conditions for Sequoyah Nuclear Plant.
Additionally, plant modification DCN No. 508114A, Revision 16, revised Environmental Drawings Number 1,2-47E235 Sheets 45, 47, and 48 to replace radiation values that were no longer conservative.
These drawing revisions did not accurately depict actual plant configuration in that on the following dates listed the core average exposure for both units exceeded 650 EFPD operation.
Unit No.
Cycle No.
Date EFPD Exceeded 1
4 12-29-89 1
5 06-09-91 2
3 12-30-88 2
4 05-24-90 2
5 09-28-91 This failure to control plant configuration and ensure that actual plant configuration was accurately depicted on drawings resulted in discrepancies between the units' current licensing basis of 1000 EFPD burnup criterion and aoproved design basis information depicted on the e..vironmental drawings.
3.
From February 11, 1994, to November 15, 1996, the licensee failed to perform a calculation to determine the integrated maximum hypothetical accident gamma and beta doses inside the primary containment to support a justification for continued operation for SQ PER-900372 PER.
This is a Severity Level IV Violation (Supplement I)."
TVA's REPLY TO THE VIOLATION G l =,
Reason For The Violation The cause of the violation was inadequate management overcight and direction.
TVA management failed to develop and implement timely and comprehensive corrective actions after discovering thu discrepancies between the unit's current licensing basis of 1000 EFPD burnup criterion and approved design basis information as depicted on the environmental drawings (NRC's second example of the violation).
This included failing to develop a calculation to support a justification for continued operation (JCO) (NRC's third example of the violation).
I 2.
Corrective steps-Taken And Results Achieved TVA revised and issued the calculations fort 1) the integrated accident dose inside primary containment and the annulus, and 2) the summary of harsh environment 4
conditions.
Design Criteria No. SON-DC-V-21.0, i
" Environmental Design," was issued incorporating the revised calculations and superseding the environmental drawings.
The FSAR was revised consistent with design l.
output documentation.
These actions resolved the plant configuration issue.
TVA issued a formal calculation that provides the supporting documentation for the JCO.
Site management is more aggressive.n the corrective action program providing increased oversight and 1
direction.
Key department managers participate as 4
members of the management review committee (HRC).
The j
MRC reviews each problem evaluation report-(PER) that is i
init1ated and corrective actions (including implementation schedules) on Levels A and B and on selected Level C PERs.
The management review ensures that problems are being, properly elevated for additional attention, and problem resolution is commensurate with i
the importance of the condition.
3.
Corrective steps That Will Be Taken To Prevent Recurrence No additional actions are' required.
4..
Date bien Full Compliance Will Be Achieved With respect-to the cited violation, TVA is in full compliance.