ML20235A680
| ML20235A680 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 09/16/1987 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8709230383 | |
| Download: ML20235A680 (4) | |
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TENNESSEE-VALLEY ' AUTHORITY CHATTANOOGA. TENNESSEE 374ot SN 157B Lookout Place SEP 161987 U.S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D.C.
20555 Gentlemen I
In the Matter of the
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Docket Nos. 50-327 Tennessee Valley Authority )
50-328 SEQUOYAH NUCLEAR PLANT (SQN) - NRC INSPECTION REPORT 50-327, 328/86 REVISED RESPONSE
Reference:
My letter to you dated March 23, 1987 The response to SQN violation B cited in the reference was discussed on May 5, 1987, with Inspectors Jenison and Branch. Based on this discussion, TVA is j
providing the enclosed revised response to the subject violation.
.I If you have any questions, please telephone D. L. Williams at (615) 632-7170.
To the best of my knowledge, I declare the statements contained herein are complete and true.
j Very truly yours, j
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. TENNESSEE VALLEY AUTHORITY f
R. Gridley, Dire
.r Nuclear Safety Licensing Enclosure cc:
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-U.S. Nuclear Regulatory Commission cc (Enclosure):
Mr.:G. G. Zech, Assistant Director for Inspection Programs l
Office of Special Projects U.S.' Nuclear Regulatory Commission Region II 101 Marietta Street, NW,, Suite 2900 Atlanta, Georgia 30323-Mr. J. A. Zwolinski, Assistant Director for Projects Divison of TVA Projects Office of Special Projects U.S. Nuclear Regulatory Commission 4350 East West Highway EWW 322 Bethesda, Maryland 20814 Sequoyah Resident Inspector Sequoyah Nuclear Plant L
2600 Igou Ferry. Road l
Soddy Daisy, Tennessee 37379 L-_-__-_..-_.--__.__
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ENCLOSURE t
l REVISED RESPONSE NRC INSPECTION REPORT NOS.
l 50-327/86-56 AND 50-328/86-56 JAMES M. TAYLOR'S LETTER TO S. A. WHITE DATED JANUARY 28, 1987 Item B L
Criterion V of 10 CFR Part 50, Appendix B, requires that activities affecting quality shall be prescribed by documented instructions and that procedures and activities shall be accomplished in accordance with those documents.
Section 17.2.5 of the TVA Quality Assurance Program (Report No. TVA-Ta75-1) implements these requirements. Additionally, TVA maintains a Statement of Policy dated May 2, 1977, governing design manuals (Guides and Standards) that indicates that failure to follow a design standard requires a followup notification to the Standards Board Chairman.
contrary to the above. TVA failed to implement its internal procedures for SQNCEB8409 regarding notification of the Standard Board Chairman in 1984 when it was known that the Sequoyah plant failed to meet the design standards in DS-El.3.3, " Protection of Electrical Equipment That Is Susceptible to Failure From Fluid Spray and Condensation," dated April 23, 1980 (Sample 1).
This is Severity Level V violation (Supplement I).
TVA's Response Admission or Denial of the Alleged Violation TVA denies that the violation occurred as stated.
Peason For the Denial The requirement that is cited as being violated is given in the last paragraph of a memorandum from Roy H. Dunham to Holders of Division of Engineering Design (EN DES) Standards Manual dated May 2, 1977, "EN DES Design Manual -
Statement of Policy." The requirement in question is restated below from this memorandum:
In the event an approved design standard cannot be used for either technical or other valid reasons (emphasis added) the engineer's group head is responsible for preparing a memo to the EN DES Standards Board Chairman outlining the reason the design standard was not followed and the design method or approach used in its place.
The intent of this portion of the policy memorandum is to provide appropriate guidance for situations where the engineer either could not or did not intend to follow the design standard.
NCR SQNCEB8409 was issued on May 18, 1984, to document a condition that did not meet the
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requirements of Design Standard DS-E1.3.1 (actual number of design standard in question) and,to, identify action required for the plant to meet these requirements. The issuance of NCR SQNCEB8409 documented EN DES's (now DNE)
I intent to follow.the design standard. Therefore, no violation of the policy memorandum requirements occurred.
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