ML20234C496
| ML20234C496 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 09/14/1987 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8709210314 | |
| Download: ML20234C496 (4) | |
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TENNESSEE VALLEY AUTHORITY CHATTANOOGA. TENNESSEE 37401 SN 157B Lookout Place SEP 141987 U.S. Nuclear Regulatory Commission i
ATTN:
Document Control Desk l
Washington, D.C.
20555 Gentlemen:
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 INSPECTION REPORT NOS.
50-327. -328/87 RESPONSE TO VIOLATION Enclosed is our response to Gary G. Zech's August 7, 1987 letter to S. A. White that transmitted Notice of Violation Nos. 50-327, -328/87-42-01.
Enclosed is our response to the subject Notice of Violation.
If you have any questions, please telephone M. R. Harding at 615/870-6422.
To the best of my knowledge, I declare the statements centained herein are complete and true.
Very truly yours, TENNESSEE VALLEY AUTHORITY
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R.
- ridley, 1 rector Nuclear Safety and Licensing Enclosures cc: See page 2 8709210314 870914 PDR ADOCK 05000327 G
PDR An Equal Opportunity Employer
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-3 U.S.' Nuclear Regulatory Commisslaa-
$(({f}gg7 cc (Enclosures):
Mr. G. G.
Zech,' Assistant Director for Inspection Programs Office'of Special Projects U.S. Nuclear Regulatory Commission 101 Marietta Street, NW, Suite 2900
' Atlanta, Georgia 30323 Mr. J. A..Zwolinski,' Assistant Director-for Projects Division of TVA Projects office of Special Projects U.S. Nuclear Regulatory Commission l
4350 East-West Highway EWW 322 Bethesda, Maryland 20814 Sequoyah Resident Inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy Daisy, Tennessee '37379 1
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ENCLOSURE l
RESPONSE - NRC INSPECTION REPORT l
NOS. 50-327/87-42 AND 50-328/87-42 l
GARY G. ZECH'S LETTER TO S. A. WHITE DATED AUGUST 7, 1987 i
Violation 50-327. -328/87-42-01 During the Nuclear Regulatory Commission (NRC) inspection conducted on l
l June 15-26, 1987, a violation of HRC requirements was identified. The violation involved failure to perform a 10 CFR 50.59 safety evaluation for a change to the FSAR.
In accordance with the ' General Statement of Policy and Procedure for NRC Enforcement Actions,' 10 CFR Part 2, Appendix C (1987), the
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l violation is listed below:
i 10 CFR 50.59 states that modifications or design changes that cause a f
change in the system or component description in the FSAR require a written safety evaluation to assess whether the change constitutes an 4
unreviewed safety question or a change in the facility Technical Specifications.
Contrary to the above, Revision 3 of the Sequoyah FSAR changed the specified accuracy of the hydrogen analyzer from the previous value plus I
or minus 0.35% to plus or minus 1.5% without the support of a l
10 CFR 50.59 safety evaluation.
This is a Severity Level IV violation (Supplement I) and is applicable both units.
1.
Admission or Denial of Violation TVA admits the violation occurred as stated.
2.
Reason for the Violation The violation is a result of TVA not having adequate procedures in place to ensure that changes in the facility as described in the FSAR, i
resulting from sources other than procedure changes or modifications, require a 10 CFR 50.59 safety evaluation.
This programmatic deficiency was first recognized by TVA and was subsequently addressed by corrective action report (CAR) 86-04-021 dated April 16, 1985. Additionally, TVA was cited in NRC Inspection Report 50-327, -328/86-62 with unresolved item 86-62-11, which noted a non-Unreviewed Safety Quection Determination (USQD) revision to the stated hydrogen analyzer accuracy in the FSAR.
A safety evaluation was performed to ensure that the hydrogen analyzer, as described, would meet f
its intended safety function.
Inspection 87-42 recently upgraded this item to a violation, since TVA did not ensure other FSAR revisions had required USQD documentation, i
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Corrective Steps Taken and Results Achieved
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The immediate corrective action was to perform a 10 CFR 50.59 safety e
. evaluation on the hydrogen analyzer accuracy revision, to ensure that an unreviewed safety question (USQ) did not exist.
This has been completed, and no safety issue was identified.
I For other FSAR revisions, a program has been initiated to review the previous amendments to the Sequoyah FSAR.
Selected chapters 3, 6, 7.1, j
8.1, and 15 will be reviewed, since they are most susceptible to I
revisions without proper USQD documentation. All noneditorial changes in these chapters will have USQ determinations confirmed or prepared as required.
This program has been discussed in detail with the NRC inspection team leader and is described under separate submittal.
Completion of this review program is scheduled for September 18, 1987, in j
accordance with the above-referenced submittal.
4.
Corrective Steps Taken to Prevent Recurrence The action taken to prevent further violations is the establishment of a new FSAR update program, in accordance with a previous NRC commitment.
This program will provide the appropriate standard, division, and site procedures necessary to interface updating the FSAR with the responsible organizations. These procedures will provide guidance for organizations as to their responsibilities on how an FSAR change is submitted to ensure
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regulatory compliance.
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Reference:
TVA letter from J. A. Domer to J. Nelson Grace dated February J, 1987, "Sequoyah Nuclear plant Units 1 and 2 - Engineering Change Notice (ECN] Closecut and Final Safety Analysis Report (FSAR) Updates.")
5.
Date When Full Compliance Will Be Achieved Previous and current FSAR amendments will have compliance demonstrated by September 18, 1987.
The scheduled completion date for the new FSAR update program is October 15, 1987, which allows its use in preparing the 1988 update.