ML20235N436
| ML20235N436 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 07/22/1988 |
| From: | Partlow J NRC OFFICE OF SPECIAL PROJECTS |
| To: | Lieberman J NRC OFFICE OF ENFORCEMENT (OE) |
| Shared Package | |
| ML20235N439 | List: |
| References | |
| EA-88-086, EA-88-86, NUDOCS 8903010210 | |
| Download: ML20235N436 (2) | |
Text
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g[ ua jo UNITED STATES
'g NUCLEAR REGULATORY COMMISSION y
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,p WASHING TON, D. C,20555 JUL 2 21988 l
Docket Nos. 50-327/328
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EA 88-86
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l MEMORANDUM FOR:
James Liebermen, Director Office of Enforcement i
FROM:
James G. Partlow, Director i
Office of Sp6cial Projects j
j
SUBJECT:
TENNESSEE VALLEY AUTHORITY - SEQUOYAH UNITS 1 AND 2 l
PROPOSED IMPOSITION OF CIVIL PENALTY Enclosed for your review and concurrence is an enforcement package that proposes a $50,000 civil penalty for a Severity Level III violation associt.ted with TVA's failure to satisfy the fire protection requirements set forth in their License Ccndition 2.c.13.c specifically the failure to meet 10 CFR Part 50, Appendix R, Section III.G.2.
The root cause of the violation was the failure of licensee personnel to properly assess and implement the requirements of 10 CFR Part 50, Appendix R.
Specifically, TVA failed to provide an Appendix R protected reactor coolant system letdown path for all Appendix R scenarios.
In adoition, TVA failed to adequately address cable-to-cable spurious interactions.
In doing its original Appendix R fire hazards analysis, TVA determined that such interactions were not credible and did not do further analysis. However, TVA was notified in Generic Letter 86-10 that such interactions must be addressed for high-low pressure interface situations. TVA did not reexamine its analysis after receipt of the Generic Letter and instead relied on previous Region 11 reviews and approvals of its interaction analyses.
The escalation and mitigation factors set forth in the enforcement policy were considered as follows:
1.
Prompt Identification and Reporting The potential violation was identified by the licensee during a special inspection, Inspection Report 50-327,328/88 24 (copy enclosed) ccaducted by the NRC cn the Sequoyah Appendix R Program from March 14-18, 1988.
TVA identified the interaction that proved to be of concern once the NRC advised them that they had to consider some cable-to-cable interactions.
The licensee initiated corrective action immediately following identification to allow prompt restart of Sequoyah. Because of the NRC's role in prompting the identification of the violation, no mitigation on this adjustment factor is appropriate.
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James Lieberman l 2.
Corrective Action to Prevent Recurrence I
Short-term corrective actions taken by TVA were adequate and were motivated by the scheduled restart of Sequoyah Unit 2 for which these were critical l
path items.
However, some corrective actions involved short-term interim j
l measuret. Long-term plant configuration changes will be necessary to l
remove interim fire watches.
No increase or mitigation ~is warranted on this adjustment factor.
3.
Past. Performance Sequoyah was previously cited for a Severity Level 11 violation with no 1
civil penalty (copy enclosed) for failura to meet the requirements of 10 CFR Part 50, Appendix R Section III.G in Inspection Report 50-327,328/85-01.
This would suggest that the penalty should be escalated for prior poor performance.
However, the Severity Level 11 violation arose from a 1984 reevaluation of Appendix R at Sequoyah performed by TVA pursuant to a Confirmatory Action Letter (CAL) issued by the staff on August 10, 1984 as a result of an NRC staff inspection at Watts Bar Nuclear Plant, July 16-20, 1984 Since the present violation arose during this 1984 reevaluation, no escalation is appropriate.
l 4.
Prior Notice of Similar Events i
TVA had addressed cable-to-cable spurious interactions in a 1984 analysis and concluded that the likelihood of spurious interaction between the cables at issue was so low that further analysis was unnecessary. That evaluation and the specific interactions with one exception had been reviewed by the NRC at least in part.
In 1986, the NRC issued Generic Letter 86-10 which provi ed guidance to licensees for implementation of d
the requirements of 10 CFR 50, Appendix R.
This could be considered prior notice requiring escalation of the penalty. However, it was not completely unreasonable for TVA to have implied acceptance of TVA's position by NRC inspectors. Therefore, no increase or mitigation is warranted on this adjustment factor.
1 5.
Multiple Occurrences The violation identified the 11r.ensee's failure to address cable to cable spurious interactions.
As a result there were multiple areas within the plant where these interactions were improperly dispositioned. There was only one root cause, however, and this represented the only serious deficiency in the Appendix R program at Sequoyah. No increase or mitigation is warranted on this adjustment factor.
If you have any questions regardir,g this case, please contact Steve Richardson of my staff.
Jame G. Partlow, Director Offi e of Special Projects
Enclosures:
1.
Notice of Violation and Proposed Imposition of Civil Penalty 2.
Supporting Documentation j
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