ML20149E425

Notice of Violation from Insp on 871006-1105.Violations Noted:Transitional Design Change Program Implemented by IA-19 & SQEP-13 Did Not Ensure That FSAR Updates Reflect Changes to Facility within 6 Months of Filing

ML20149E425
Person / Time
Site:	Sequoyah, 07100006
Issue date:	01/14/1988
From:	Barr K NRC OFFICE OF SPECIAL PROJECTS
To:
Shared Package
ML20149E379	List: IR 07100006/2011005 ML20149E375 ML20149E452
References
50-327-87-65, 50-328-87-65, NUDOCS 8802110045
Download: ML20149E425 (2)

Text

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ENCLOSURE 1

. NOTICE OF VIOLATION Tennessee Valley Authority Docket Nos. 50-327 and 50-328 Sequoyah 1 and 2 License Nos. DPR-77 and 79 During the Nuclear Regulatory Commission (NRC) inspection conducted from October 6, 1987 to November 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:

1. 10 CFR 50, Appendix B, Criterion XVI, as implemented by TVA's QA Topical Report, TVA-TR-75-1A, Rev. 9, paragraph 17.2.16, requires that significant conditions adverse to _ quality be promptly identified and corrected.

Additionally, the cause of the condition should be determined and corrective measures to preclude repetition must be identified.

10 CFR 50.71.(e).(4) requires that revisions to the FSAR be filed no less frequently than annually and shall reflect all changes to the plant up to a maximum of 6 months prior to the date of filing.

a. Contrary to the above, CAR 86-04-021 (which documented the fact that TVA had not established adequate controls to ensure the requirements of 10 CFR 50.71 were satisfied) did not ensure that adequate corrective measures _were established to prevent recurrence, in that, the transitional design change program impleraented by AI-19 and SQEP-13 did not ensure that FSAR updates reflect changes to the facility within 6 months of filing.

b. Contrary to the corrective action requirements above, resolution of significant test deficiency DN-6 of Post Modification Test PMT-23 (specified on test deficiency report 2-PT-789 concerning unexpected 4

opening of reactor head vent throttle vaives) was inadequate, in that, it did not ensure that emergency procedures were revised or personnel trained to minimize impact on above reactor coolant inventory loss.

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

2. Technical Specification 4.3.2.1.3 requires that containment spray response time be demonstrated to be within the limit at least once per 18 months.

Surveillance Instruction SI-247.900, Engineered Safety Features Response Time Verification, implements this Technical Specification requirement.

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2 b Contrary to the above, this surveillance requirement is not being met in-l that the containment spray pump start interlock is not included as part of the response time for containment spray actuation.

This.isia Severity Level IV violation (supplement I).

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3. 10 CFR 50, Appendix B, Criterion VI, document control, requires that' I measures shall be established 'to control the issuance of documents, such as instructions, procedures and drawings, including changes thereto, for all activities affecting quality. These measures shall assure that documents, including changes thereto, are reviewed for adequacy and approved for release by authorized personnel.

Contrary to the requirements above, changes to the primary control room drawings are made by plant modifications engineers with no second party verification to ensure the adequacy or accuracy of the changes to those drawings.

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

Pursuant to the provisions of 10 CFR 2.201, Tennessee Valley Authority is hereby required to submit a written statement or explanation to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555, with a copy to the Regional Administrator, Region II, and a copy to the NRC

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Resident Inspector, Sequoyah, within 30 days of the date of. the letter transmitting this Notice. This reply should be clearly marked as a "Reply to a Notice of Violation" and should include [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 gcod cause is shown, consideration will be given to extending the response time. If an adequate reply is not received within the time specified in this Notice, an order may be issued to show cause why the license should not be modified, suspended, or revoked or why such other action as may be proper should not be taken.

l FOR THE NUCLEAR REGULATORY COMMISSION f

f Kenneth P. Barr, Acting Assistant Director for Inspection Programs TVA Projects Division Office of Special Projects Dated at Atlanta, Georgia this g:Lday of January 19ES

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