ML20236J659
| ML20236J659 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 06/26/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20236J656 | List: |
| References | |
| 50-327-98-06, 50-327-98-6, 50-328-98-06, 50-328-98-6, NUDOCS 9807080299 | |
| Download: ML20236J659 (3) | |
Text
__-
NOTICE OF VIOLATION Tennessee Valley Authority Docket Nos. 50-327 and 50-328 Sequoyah Nuclear Plant License Nos. DPR-77 and DPR-79' During NRC ins)ection conducted between April 26 through June 6,1998.
. violations of 1RC requirements were identified.
In accordance with the l
" General Statement of Policy and Procedures for NRC Enforcement Actions."
L NUREG-1600, the violations are listed below:
A.
Technical Specification 4.0.5. Inservice Testing Program, requires that inservice-testing of ASME Code Class 1. 2. and 3 pumps and-valves shall be in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50.55a.
10 CFR 50.55a. Section (b) references OMa-1988 Addenda to the OM-1987 Edition which is the applicable edition and addenda to the code.
ASME/ ANSI OMa-1988 Addenda to ASME/ ANSI OM-1987. Operation and Maintenance of Nuclear Power Plants. Part 10. Section 4.2.1.2 Exercising Requirements. Part (a) states, in part. " Valves shall be tested to the positions required to fulfill its function (s)."
ASME/ ANSI OMa-1988 Addenda. Part 10 references OM-1987. Part 1 for relief. valve requirements Part 1. Paragraphs 8.1.1.8. 8.1.2.8. and 8.1.3.7 require a minimum 10 minute hold time between valve openings.
Additionally Paragraph 8.3.3(e). requires that the hold time be specified in a written procedure.
'10 CFR 50.55a (a)(3) states that alternative tests to inservice testing requirements may be used when authorized by the Director Office of buclear Reactor Regulation (NRR).
Contrary to the above, inservice testing of valves was not in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and Applicable Addenda as required by 10 CFR 50.55a in that:
1.
As of March 22, 1998, the component cooling water system (CCS) outlet isolation valves to the residual heat removal (RHR) heat exchangers. FCV-70-153 and FCV-70-156 were not tested to both of the positions required to fulfill their functions in that the CCS valves for both units were only tested in the open direction.
These valves have safety functions which would require them to be operated in both the open and close direction during accident conditions.
2.
Procedure 0-SI-SXV-000-264.0. Testing Setpoints of Safety and Relief Valves (ASME Section IX Category C Valves). Revision 0, did not specify a minimum hold time of 10 minutes for testing Class 2 and 3 pressure relief valves.
7 pg 7
a
NOV 2
3.
As of May 22. 1998, the' licensee had continued to perform alternative tests related to relief request RP-03 since September 20. 1996, and relief requests RV-05 and RV-06 since March 20, 1996. without authorization from the Director. NRR.
This is a Severity Level IV Violation (Supplement I).
B.
10 CFR 50.59 (a)(1) allows the holder of a license to make changes to the facility and arocedures as described in the Updated Final Safety Analysis Report (JFSAR) without prior Commission approval unless the proposed change involves a change to the Technical Specifications or an unreviewed safety question (US0).
10 CFR 50.59 (b)(1) requires that the licensee shall maintain records of changes to the facility and that these records include a written safety evaluation which provides the bases for the determination that
.the change does not involve an unreviewed safety question.
The Sequoyah Updated Final Safety Analysis Report (UFSAR). Amendment
- 13. Section 11.3. Gaseous Waste System, states that the online gas analyzer determines the quantity of oxygen and hydrogen in the volume control tank, pressurizer relief tank, holdu) tanks gas decay tanks, and spent resin storage tank by monitoring t1e waste gas header, or by selecting the individual sample point.
Contrary to the above, on October 6. 1997, the licensee made changes to the facility as described in the UFSAR without an adequate written safety evaluation when the waste gas analyzer system was modified to remove the online capability to monitor the oxygen and hydrogen concentrations in the volume control tanks, waste holdup tanks.
pressurizer relief tanks, and spent resin storage tanks and was replaced by grab sample only capability.
This is a Severity Level IV Violation (Supplement I).
C.
The Tennessee Valley Authority Sequoyah Nuclear Plant Units 1 and 2 Facility Operating Licenses. Section 2.E states that the licensee shall fully implement and maintain in effect all provisions of the Commission approved physical security, guard training and qualification, and safeguards contingency plans including amendments.
1 The Secuoyah Nuclear Plant Physical Security / Contingency Plan Revision i
4 datec September 10. 1996. Paragraph 5.2.4 states " Verification of each individual will be with the hand geometry system which provides a nontransferable means of identifying individuals, coupled with the badgecard reader.
Both the badgecard and hand geometry shall be necessary for normal access to the protected area (PA).
Hand geometry shall provide assurance that only authorized personnel are allowed access to the PA."
]
Physical Security Instruction - 32. Revision 16. Appendix N. Post 12.
and 13 - Vehicle Search / Access Control. Paragraph 3.6, states. " Ensure
l l
l NOV 3
individuals with PA badges utilize the hand geometry readers."
Contrary to the above, on May 8. October 22. December 11. 1997, and March 27, 1998, an individual did not utilize the badge and hand-geometry system prior to entering the PA at the vehicle sally port.
The four individuals were licensee employees who were authorized unescorted access.
This is a Severity Level IV violation (Supplement III).
Pursuant to the provisions of 10 CFR 2.201. Tennessee Valley Authority is hereby required to submit a written statement or explanation to the U.S.
Nuclear Regulatory Commission. ATTN:
Document Control Desk. Washington. D.C.
20555 with a copy to the Regional Administrator. Region II, and a co)y to the NRC Resident Inspector at the Sequoyah facility, within 30 days of t1e date of the letter transmitting this Notice of Violation (Notice).
This reply should
{
be clearly marked as a "Realy to a Notice of Violation", and should include for each violation:
(1) t1e reason for the violation. or, if contested, the basis for disputing the violation. (2) the corrective steps that have been taken and the results achieved. (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your res)onse may reference or include previously docketed correspondence if t1e correspondence adequately addresses the required response.
If an adequate reply is not received within the time specified in i
this Notice, an order or Demand for Information may be issued as to why the license should be modified, suspended, or revoked or why such other action as may be proper should not be taken. Where good cause is shown. consideration will be given to extending the response time.
If you contest this enforcement action. you should also provide a copy of your response to the Director. Office of Enforcement. United States Nuclear Regulatory Commission. Washington, DC 20555-0001.
Because your res)onse will be placed in the NRC Public Document Room (PDR). to the extent possi ale, it should not include any personal privacy. 3roprietary, i
or safeguards information so that it can be placed in the PDR witlout redaction.
If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information.
If you request withholding of such material, you must s)ecifically identify the portions of your response that you seek to have withleld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information).
If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.
Dated at Atlanta Georgia this_26 day of June 1998 I
J