ML20213D169

Notice of Violation from Insp on 860806-0905

ML20213D169
Person / Time
Site:	Sequoyah
Issue date:	11/05/1986
From:	Zech G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20213D154	List: ML20213D152 ML20213D169 ML20213D178
References
50-327-86-46, 50-328-86-46, NUDOCS 8611100449
Download: ML20213D169 (3)

Text

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1 ENCLOSURE 1 NOTICE OF VIOLATION Tennessee Val' ley Authority Docket Nos. 50-327 and 50-328 Sequoyah Units 1 and 2 License Nos. DPR-77 and DPR-79 During the Nuclear Regulatory Commission (NRC) inspection conducted on August 6 -

September 5,1986,. violations of NRC requirements were identified. The viola ~

tions involved a failure to comply with health physics requirements, Technical Specification (TS) preventive maintenance requirements, TS PORC activity require-

.ments, and TS reporting requirements. In accordance with the " General Statement-of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1986), the violations are listed below:

4 A. TS 6.12 states that in-lieu of the control device or alarm signal required by paragraph .20.203(c)(2) of 10 CFR 20, each high radiation area in which

. the intensity of radiation is greater than 100 mrem /hr but less than 1000 mrem /hr shall be barricaded and conspicuously posted as a high radiation

area and entrance .thereto shall .be controlled by requiring issuance of a special Radiation Work Permit (RWP).

t Sequoyah Nuclear Plant . Radiological Control Instruction RCI-1, Radiological Hygiene Program, states that each high radiation area shall be conspicuously '

posted with a sign or signs bearing the radiation caution symbol and -the words: DANGER or CAUTION HIGH RADIATION AREA and RWP required.

l Contrary to the above, on September.3,1986, two maintenance personnel entered a high radiation area and failed to-return either of the two avail-able entry barriers- to a position which barricaded access to the high radiation area thus removing the postings.

This'is a Severity Level IV violation (Supplement IV).

B. TS 6.8.1.a requires .the licensee to establish, implement and maintain I written procedures- covering ~ the applicable activities in Appendix A of L. Regulatorv Guide 1.33, Revision 2, February 1978.

l Regulatory Guide 1.33, Revision 2, February 1978, recommends procedures for i contamination control and access control to radiation areas including a

! radiation work permit (RWP) system. Plant procedure RCI-1 states that protective clothing requirements are specified on a RWP time sheet and that the protective clothing shall be worn as required.

Contrary to the above, the requirement that protective clothing be worn as required by the RWP was not met in~ that on September 3,1986, three persons were observed to be in nonconformance with the protective clothing dress requirements specified in RWP 86-2-216-117, time sheet 3, in that none of the three individuals wore a protective hood.

!~ This is a Severity Level IV violation (Supplement IV). _

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Tennessee Valley Authority Docket Nos. 50-327 and 50-328 Sequoyah Units 1 and 2 2 License Nos. DPR-77 and DPR-79 C. TS 6.8.5.a.(i) requires that a program to reduce leakage from those portions of systems outside containment that could contain highly radioactive fluids be implemented. The TS states that the program shall include preventive maintenance and periodic visual inspection requirements.

Contrary to the above the licensee's program intended to meet TS 6.8.5 does not include preventive maintenance, but is composed only of the SI-632 series visual inspections and random vibration analysis of specific pumps.

The maintenance performed as a result of a SI-632 (series) visual inspection is viewed by the NRC to be corrective and not preventive maintenance.

This is a Severity Level IV violation (Supplement I).

D. TS 6.5.1 addresses the Plant Operations Review Committee (PORC).

1. TS 6.5.1.6 requires that PORC shall be responsible for review of those

-items liated in sub paragraphs 6.5.1.6.a'through m.

Contrary to the above, the review of the items addressed in sub para-graphs 6.5.1.6.a through m has been informally delegated to subor-dinates by the permanent PORC members over the last two years. The permanent members subsequently base their decision for approval on memoranda from the subordinates and/or their initials on the informal PORC documen; routing sheets. Consequently, due to the limited discus-sion format of the PORC. meetings and the informal routing process, the

-members do not achieve full personal knowledge of the issues being addressed. Additionally, temporary PORC members are further removed from the review process.

2. TS 6.5.1.5 states that the minimum quorum of the PORC necessary for the performance of th_e PORC responsibility and authority provisions of these TSs shall consist of the Chairman or his designated alternate and four members including alternates.

Contrary to the above SQA 21, Section 5.3, is inadequate in that it allows an alternative means of establishing a quorum after consultation with the licensee's appropriate central office supervisor.

This is a Severity Level IV violation (Supplement I).

E. TS 4.4.5.5.a states that, following each inservice inspection of steam generator tubes, the number of tubes plugged in each steam generator- shall be reported to the Commission within 15 days.

Contrary to the above, on October 12, 1985, the licensee completed tube

, plugging activities on Unit 1 and failed to submit the required report.

Additionally, twice before this outage the licensee plugged steam generator

-tubes and failed to submit the appropriate report.

This is a Severity Level V violation (Supplement I).

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c '3 Tennessee Valley Authority Docket Nos. 50-327 arid 50-328 Sequoyah Units 1 and 2 3 License Nos. DPR-77 and DPR-79 Pursuant to the provisions of 10 CFR 2.201, Tennessee Valley Authority is hereby required to submit to this Office within 30 days -of_the date of the letter transmitting this Notice a written statement.or explanation in reply including 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. Whera good cause is shown, consideration will be given to extending the response time.

FOR THE NUCLEAR REGULATORY COMMISSION

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ORIGINAL SIGN (c Q (GARYG.2ECH, 1

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. Gary G. Zech,' Director Division of TVA Projects Dated at Atlanta, Georgia this S ttday of November 1986 4

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