ML20215F401
| ML20215F401 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 06/08/1987 |
| From: | James Keppler NRC OFFICE OF SPECIAL PROJECTS |
| To: | White S TENNESSEE VALLEY AUTHORITY |
| Shared Package | |
| ML20215F404 | List: |
| References | |
| EA-85-048, EA-85-48, NUDOCS 8706220369 | |
| Download: ML20215F401 (6) | |
See also: IR 05000327/1985001
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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JUN 0 8 1987
Docket No. 50-328
. License No. DPR-79
EA 85-48
Tennessee Valley Authority
ATTN: Mr. S. A.. White
Manager of Nuclear Power
6N 38A Lookout Place
1101 Market Street
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Chattanooga, TN 37402-2801
SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORT NOS. 50-327/85-01
AND50-328/85-01)
Gentlemen:
As a result of deficiencies identified by the NRC during a July 16-20, 1984
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Appendix R inspection at Tennessee Valley Authority's'(TVA) Watts Bar facility,
a Confirmation of Action Letter concerning t.he implementation of 10 CFR Part 50,
,
Appendix R, Sections III.G, III.J, III.L and III.0 was issued to the Sequoyah
,
NuclearPlant(SNP)byRegionIIonAugust 10, 1984. TVA's_re-evaluation at
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SNP was completed on December 21, 1984. A special safety inspection was
conducted on January 14-18, 1985 at SNP Units l'and 2 to evaluate the adequacy
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of TVA's performance with respect to fire protection at SNP. As a result of
the inspection, numerous violations of NRC requirements were identified, some
,
of which you had identified previously. The report which documents'this
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inspection was sent to you with a letter dated March 29, 1985. An Enforcement
Conference to discuss the violations was held in the NRC Region II Office on
February 28, 1985. The enforcement action c,n .this matter. was then held in
abeyance while the Commission resolved a number of. issues pertaining to
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Appendix R implementation and enforcement.
Those~ actions have now been
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resolved and we a're proceeding to issue this enforcement action.
Violation I.A.1 described in the enclosed Notice of Violation'(Notice) involves
36 examples in 19 different plant areas in which both trains of redundant hot
shutdown systems could have been rendered inoperable in the event of a fire.
Thus, the plant's ability to achieve and maintain hot shutdown was not assured.
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Violation I.A.2 involves 245 circuits that had a common power source with other
shutdown equipment and which were not properly electrically protected from the
circuit of concern. These circuits could have prevented operation or caused
malfunction of equipment necessary to achieve and maintain hot-shutdown
conditions in the event of a fire. Violation I.B involves 13 examples in which
both redundant trains of cabling for systems'necessary.to achieve and maintain
cold shutdown were located in the same fire area and therefore could have been
rendered inoperable had there been a fire.
The number of examples of noncompliance that were identified. in;1984 are of-
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concern to the NRC because they are' indicative of weaknesses in TVA's original
review, design, construction and modifications made to implement the requirements
of 10'CFR Part 50, Appendix R for.Sequoyah Unit 2.
We recognize that since this
8706220369 870608
ADOCK 05000328
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Tennessee Valley Authority
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inspection you have taken actions to correct the deficiencies.
We expect that
SNP 2 will either be in compliance with Appendix R or have approved compensatory
measures in place prior to restart. However, in accordance with the " General
Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2,
Appendix C (1987), Violations I.A and I.B described in the enclosed Notice have
been categorized in the aggregate as a Severity Level II problem because the
numerous violations identified in hot shutdown and cold shutdown systems lead
us to conclude that a fire in these areas would have damaged equipment to the
extent that safe shutdown would not have been achieved and maintained in the
event of a fire.
A civil penalty is normally proposed for a Severity Level II violation or problem
absent mitigating circumstances. However, after consultation with the Commission
and the Deputy Executive Director for Regional Operations, I have been authorized
to issue the enclosed Notice without a civil penalty. Because of the apparent
lack of clarity which existed regarding the fire protection requirements, the
significant time that has elapsed since the inspection associated with these
violations, and after considering the unique circumstances at TVA involving the
extensive efforts to identify and correct problems including some of the cited
violations, I have concluded that issuance of a civil penalty at this time is
unnecessary.
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Violation II.A in the enclosed Notice involves design deficiencies associated
with the reactor coolant pump oil collection systems; Violation II.B involves
deficiencies associated with cable fire barrier assemblies; and Violation II.C
involves deficiencies associated with the emergency lighting units.
Collectively,
these violations have been characterized as a Severity Level IV problem.
You are required to respond to this letter and should follow the instructions
specified in the enclosed Notice when preparing your response.. In your response,
you should document the specific actions taken and any additional actions you
plan to prevent recurrence.
You may reference previous submittals regarding this
matter in your response to this letter.
In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2,
Title 10, Code of Federal Regulations, a copy of this letter and its enclosure
will be placed in the NRC's Public Document Room.
The responses directed by this letter and its enclosure are not subject to the
clearance procedures of the Office of Management and Budget issued under the
Paperwork Reduction Act of 1980, PL 96-511.
Sincerely,
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VJamesG.Keppfek, Director
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Office of Special Projects
Enclosure:
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Enclosure:
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H. L.:Abercrombie, Site Director
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J. A. Kirkebo, Acting Director
Nuclear Engineering.
R. L. Gridley, Director
Nuclear Safety and Licensing
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M. R. Harding, Site Licensing
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Mr. S. A. White
Tennessee Valley Authority
Sequoyah Nuclear Plant
cc:
General Counsel
Regional Administrator, Region II
Tennessee Valley Authority
U.S. Nuclear Regulatory Commission
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400 West Summit Hill Drive
101 Marietta Street, N.W.
Eli B33
Atlanta, Georgia 30323
Knoxville, Tennessee 37902
Resident Inspector /Sequoyah NP
Mr. R. L. Gridley
c/o U.S. Nuclear Regulatory Commission
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Tennessee Valley Authority
2600 Igou Ferry Road
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5N 157B Lookout Place
Soddy Daisy, Tennessee 37379
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Chattanooga, Tennessee 37402-2801
Mr. Richard King
Mr. H. L. Abercrombie
c/o U.S. GA0
Tennessee Valley Authority
1111 North Shore Drive
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Sequoyah Nuclear Plant
Suite 225, Box 194
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P.O. Box 2000
Knoxville, Tennessee 37919
Soddy Daisy, Tennessee 37379
Tennessee Department of
Mr. M. R. Harding
Public Health
Tennessee Valley Authority
ATTN: Director, Bureau of
Sequoyah Nuclear Plant
Environmental Health Services
P.O. Box 2000
Cordell Hull Building
Soddy Daisy Tennessee 37379
Nashville, Tennessee 37219
Mr. D. L. Williams
Mr. Michael H. Mobley, Director
Tennessee Valley Authority
Division of Radiological Health
400 West Summit Hill Drive
T.E.R.R.A. Building
W10 B85
150 9th Avenue North
Knoxville, Tennessee 37902
Nashville, Tennessee 37203
County Judge
Hamilton County Courthouse
Chattanooga, Tennessee 37402