ML20236V998

Notice of Violation from Insp on 870906-1005.Violations Noted:Train a of Unit 2 Containment Hydrogen Monitor Inoperable Since Installation & Changes Made to Facility W/O Performance of Safety Evaluation

ML20236V998
Person / Time
Site:	Sequoyah
Issue date:	11/25/1987
From:	Barr K NRC OFFICE OF SPECIAL PROJECTS
To:
Shared Package
ML20236V976	List: IR 05000327/1987060 ML20236V974 ML20236V998
References
50-327-87-60, 50-328-87-60, NUDOCS 8712070212
Download: ML20236V998 (2)

Text

ENCLOSURE 1 l i

NOTICE OF VIOLATION Tennessee Valley Authority Docket Nos. 50-327 and 50-328 Sequoyah 1 and 2 License Nos. DPR-77 and DPR-79 During the Nuclear Regulatory Commission (NRC) inspection conducted from September 6, 1986 to Octobey 5, 1987, violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions" 10 CFR 2, Appendix C (1987), the violations are listed below:

A. Technical Specification 3.6.4.1 requires that two trains of containment hydrogen monitors be operable while in modes 1 and 2. The action statement for this specification requires that, "with one hydrogen monitor inoperable, restore the inoperable monitor to OPERABLE status within 30 days or be in at least hot standby within the next six hours."

Section 6.2.5.2 of the Sequoyah FSAR specifies the sampling capability of the hydrogen monitoring system and states that, "when the system is actuated, containment atmosphere is continuously drawn through a series of sample conditioners.... The atmosphere from the upper and lower compartments is mixed before entering the analyzer. As a result of the analyzer capability and the mixing afforded by the hydrogen collection system which draws from compartments within the containment and the containment dome, a true indication will be given of hydrogen concentration within the containment.

Contrary to the above, with the Unit 2 reactor in modes 1 and 2 on numerous occasions since initial licensing, train A of the Unit 2 containment hydrogen monitor has been inoperable since installation, due to design and construction errors associated with water traps and sample point location, and was unable to perform its intended function as stated in the FSAR.

This is a Severity Level IV violation (Supplement I) and applies to Unit 2 only.

B. T.S. 6.8.1 states that written procedures shall be established, implemented and maintained covering the activities referenced in Appendix "A" of Regulatory Guide 1.33, Revision 2, February 1978.

Appendix "A" of Regulatory Guide 1.33 requires procedures for startup, operation, and shutdown of safety-related PWR systems.

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Tennessee Valley Authority 2 Docket Nos. 50-327 and 50-328 Sequoyah 1 and 2- License Nos.'DPR-77 and DPR-79 Contrary to the above, changes to the operation and control of the strainers and screen wash systems of the essential raw cooling water- .

'(ERCW) system were implemented by a night order -issued - on' May 16, 1986, without the licensee having issued appropriate procedures.

Contrary to the above, safety related plant readings necessary to prompt compensatory actions for defeated automatic safety functions were accomplished by an inappropriately reviewed and approved section. letter, OSLA-99, in lieu of plant procedures. Additional instances were observed where conditions were recorded as out of specification and no compensatory action was taken. ,. q This is a Severity Level IV violation (Supplement I).

C. 10 CFR 50.59. states that .the licensee may make changes to the facility or to the procedures as described in the safety analysis report without prior Commission approval unless the proposed changes involve a change -

in the Technical Specifications incorporated in the licensee or an unreviewed safety question.

Contrary to the above, changes were made to the facility as described in the safety evaluation' report and to procedures without-proper determination that an unreviewed safety question did not exist by performing a safety evaluation. The changes made were to the operation of the ERCW strainers and the screen wash system from automatic operation to manual operation.

These changes were made with no safety evaluation in place prior to their implementation as required by the requirements of 10 CFR 50.59 described

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above.

I This is a Severity Level IV violation (Supplement I).

Pursuant to the provisions of 10 CFR 2.201, Tennessee Valley Authority is hereby required to submit to this Office within 30 days of the date of the letter transmitting this Notice a written statement or explanation in reply including (for each violation): (1) admission or denial of the violation,

-(2) the reason for the violation if admitted, (3) the corrective steps which >

have been taken and the results achieved, (4) the corrective steps which will be taken to avoid further violations, and (5) the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending the response time.

FOR THE NUCLEAR REGULATORY COMMISSION Kenneth P. Barr, cting Assistant Director for Inspection Programs TVA Projects Division Office of Special Projects Atlanta, Georgia Datedag5dayofNovember1987 this 45 l

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