ML20093F134

Responds to NRC 840214 Ltr Re Violation Noted in IE Insp Repts 50-327/84-01 & 50-328/84-01.Corrective Actions: Abnormal & Emergency Procedures Revised to Provide More Control Over Review Process.Violation B Denied

ML20093F134
Person / Time
Site:	Sequoyah
Issue date:	03/15/1984
From:	Mills L TENNESSEE VALLEY AUTHORITY
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20093F072	List: ML20093F082 ML20093F091 ML20093F134
References
NUDOCS 8407180274
Download: ML20093F134 (3)

Text

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TENNESSEE VALLEY AUTHORITY CHATTANOOGA

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. TENyJESSEE March 15,1984 U.S. Nuclear Regulatory Commission Region II Attn: Mr. James P. O'Reilly, Regional Administrator 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30303

Dear Mr. O'Reilly:

SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 - NRC-0IE REGION II INSPECTION REPORT 327/84-01 AND 50-328/84 RESPONSE TO VIOLATIONS The subject OIE inspection report dated February 14,1984 from R. C. Lewis to H. G. Parris cited TVA with one Severity Level IV violation and one Severity Level V violation. Enclosed is the response to the items of violation in the subject inspection report.

If you have any questions, please get in touch with R. H. Shell at FTS 858-2688.

To the best of niy knowledge, I declare the statements contained herein are complete and true.

Very truly yours, TENNESSEE VALLEY AUTHORITY L. M. Mills, nager Nuclear Licensing Enclosure cc: Mr. Richard C. DeYoung, Director (Enclosure)

Office of Inspection and Enforcement j U.S. Nuclear Regulatory Commission i Washington, D.C. 20555 l i

Records Center (Enclosure)

Institute of Nuclear Power Operations 1100 circle 75 Parkway, Suite 1500 Atlanta, Georgia 30339 hG DO O 1983-TVA SOTH ANNIVERSARY An Equal Opportunity Employer

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y .- -ENCLOSURE RESPONSE '- IRC INSPECTION REPORT b

NOS. 50-327/84-01 AND 50-328/84-01 R. C. LEWIS'S LETTER 'IO _ H. G. ' PARRIS h

DATED FEBRUARY 14, 1984 i

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Item 327, 328/84-01-01 A, y'- '

i _.10_ CPR 55, Appendix A, Paragraph 3.d, requires that each licensed operator i ,

' and senior operator review the contents of all abnormal and emergency j; Lprocedures on al regularly scheduled basis, i Contrary to the above, .each licensed operator and senior operator has not L

I reviewed the contents of all abnormal and emergency procedures in that the i

licensee could not present objective evidence to verify that any of four i '

licensed operators seleeted for review had -completed their . required p reading.

k This is a Severity Level IV Violation (Supplement. I). i T- t 3

i 1. Admission or Denial of' the Alleed Violation i

d- TVA admits the violation . occurred as stated.

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! 2. Reasons for the Violation if Admitted ..

The cause of this violation-has been attributed to insufficient .

s administrative control of the Abnormal Operating Instruction (AOI) and i i

j Emergency Operating Instruction (E0I) monthly review process,'

aggravated by the 24-month myiew cycle.

i 3 Corrective Steps Which Have Been Taken and the Results Achieved j 1

l- An audit was performed to v,erify the review status for all licensed - l I operators. _ Based on the information gained from this audit, an AOI and  ;

l E0I monthly myiew letter was issued to each licensed operator i

indicating the instructions to be reviewed to update each operator's i j review requirement.-

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4. Corrective Steps Which Will-Be Taken To Avoid Further Violations '

j l Procedures have been' revised to provide more positive control over the review process.: Additionally, the AOI and E0I' review cycle ~ has been changM 'a a 12-month cycle. [

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5. Date When Full Compliance Will Be Achieved

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$ ' Full compliance' will be achieved by May 1,1984.

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Item 327, 328/84-01-02 10 CFR 50, Appendix B, Criterion XIII as implemented by the licensee's QA ,

Program (TVA-TR75-1) require that measures shall be established to control storage of materials to prevent damage. TVA-TR75-1 commits to Regulatory Guide 1.38, Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items fbr Water Cooled Nuclear Power Plants. This guide endorses ANSI N45.2.2-1972, Packaging, Shipping, Receiving, Storage, and Handling of Items fbr Nuclear Power Plants.

Section 6.3.2 of this standard requires that items stacked for storage shall be arranged so that racks, cribbing, or crates are bearing the full weight without distortion of the item.

Contrary to the above, several boxes containing reactor plant equipment identified as control rod drive mechanisms, located in Outside Building One, were stacked in such a manner that allowed bending of some containers which could result in distortion of the parts inside the containers.

This is a Severity Level V Violation (Supplement I).

1. Admission or Denial of the Alleged Violation TVA denies that a violation occurred.

2. Reason for the Denial ANSI N45.2.2-1972, Section 6.3.2, " Arrangement of Items," specifies that items stacked for storage shall be arranged so that the racks, cribbing, or crates are bearing the full weight without distortion of the items. This mquirement is to prevent permanent distortion of the items contained in the storage container. Although the crate was marked as containing a control rod drive mechanism (CRDM), the crate actually contained only gaskets. In a recent telecon, Westinghouse stated that had the crate in fact contained a CRDM and had the CRDM been subjected to the same deflections as the crate (13/4 inch over 10 ft.), no adverse effects to the CRDM or its intended function would have occurred. Additionally, there is no evidence to indicate that the deflection of the crate would have resulted in an equal deflection of any items in the crate. The deflection of the crate containing gaskets may have resulted in minor deflection of the gaskets but not in a way that permanent distortion of any gasket would occur. All items stored in the crates identified by the NRC inspector were evaluated and inspected and no distortion was found.