ML20234D799
| ML20234D799 | |
| 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 8709220196 | |
| Download: ML20234D799 (4) | |
Text
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TENNESSEE VALLEY AUTHORITY l
CHATTANOOGA, TENNESSEE 374ol
]
SN 157B Lookout Place SEP 141987
'U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C.
20555 Gentiemen:
In the Matter of
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Docket Nos. 50-327 l
Tennessee Valley Authority
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.50-328 j
7 l
SEQUOYAH NUCLEAR PLANT (SQN) - PROGRAM FOR RESOLUTION OF 10 CFR 50.59 VIOLATION - FINAL SAFETY ANALYSIS REPORT (FSAR) REVISIONS WITHOUT PROPER UNREVIEWED SAFETY QUESTION DETERMINATION (USQD) EVALUATION During a recent NRC inspection of TVA's quality assurance (QA)/ design control program at SQN, the following violation was cited.
10 CFR 50.59 requires a written safety evaluation be performed for all changes in the facility as described in the FSAR.
This evaluation provides determination that an unresolved safety question (USQ) does not exist.
An item was identified as part of a previous inspection, Inspection Report Nos. 50-327/86-62 and -328/86-62, whereby hydrogen analyzer accuracy, as indicated in the FSAR, was amended.to reflect overall system accuracy versus indicator accuracy.
This change was made by TVA without a required USQD evaluation.
Actions taken in resolution of this 86-62 item focused on evaluation of l
the specific finding, with a subsequent USQD evaluation being performed, f
and on ensuring no future recurrence of this condition by updating applicable FSAR amendment procedures.
TVA actions did not ensure the previous FSAR revisions are supported by necessary safety evaluations in accordance with the requirements of 10 CFR 50.59.
Hence, the upgrade of this item to a violation.
A program to resolve this finding has subsequently been implemented at
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SQN. A description of our approach, including justification basis, and a schedule to coinpletion follows, Amendments 1, 2, and 3 of selected SQN FSAR chapters will be the primary program focus.
Amendments 1, 2, and 3 encompass revisions made since the f
issuance of the original document update, April 14, 1983.
This original j
update reflects a general rewrite of the initial FSAR in a refined l
format. Significant program revisions,- therefore, are not anticipated, j
Amendment 4, recently submitted.(April-20, 1987), was performed to the current FSAR update procedure, which requires documented USQDs be generated for all noneditorial FSAR changes.
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Chapters 3, 6, 7.1, 8.1, and 15 will be reviewed since those are most j
susceptible to revisions without proper USQD documentation.
Changes to l
these sections are not necessarily driven by engineering chango notices l
(ECNs) or procedural changes which subsequently require the performance l
of a USQ determination.
I Chapter 3 discusses " Design Criteria - Structures, Components, Equipment, and Systems"; Chapter 6, " Engineered Safety Features"; Chapter 7, section 7.1, " Instrumentation and Controls"; Chapter 8, " Electric Power,"
l section 8.1, systems discussion; and Chapter 15, " Accident Analyses."
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Revisions to the remaining sections of the SQN FSAR (i.e., " Introduction I
and General Description of Plant," " Site Characteristics," " Quality Assurance," " Conduct of Operations," etc.) are typically initiated by j
ECNs or procedural changes. These, in turn, have been accompanied by l
required USQD evaluations.
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This method of target bounding yields high confidenca that all r
noneditorial FSAR revisions that require USQD evaluations will be I
identified.
During the program implementation, NRC will be periodically updated by telephone conference calls with status and summary reports of I
findings.
If at any time it is determined that scope boundaries should l
be expanded, TVA will modify the above-defined program accordingly.
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1 Schedule for completion of this effort is September 18, 1987. A summary i
closure folder will then be available for inspection and closeout of this
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violation item.
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If any questions exist on the information above, please telephone M. R. Harding at (615) 870-6422.
Very truly yours, TENNESSEE VALLEY AUTHORITY
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1 R. Gridley, 1 rector Nuclear Saf ty and Licensing l
Enclosure j
cc:
See page 3 j
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l U.S. Nuclear Regulatory Conaission
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{g}} l cc (Enclosure): Mr. G. G. Zech, Assistant Director l for Inspection Programs Office of Special Projects U.S. Nuclear Regulatory Commission l Region II l 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 l l Mr. J. A. Zwolinski, Assistant Director I for Projects Division of TVA Projects ) Office of Special Projects l U.S. Nuclear Regulatory Commicsion j 4350 East-West Highway i EWW 322 Bethesda, Maryland 20814 Sequoyah Resident Inspector l Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy Daisy, Tennessee 37379 l l l l l l
J ENCLOSURE Program for Resolution of l 10 CFR 50.59 Violation 1 .4 Commitments 1. Prepare summary closure folder, for NRC inspection, documenting closeout l of this violation by September 18, 1987. i l i 4 i l 4 1 i l 1 i l ) i i i i l i 1}}