ML20215F401

Discusses Safety Insp Repts 50-327/85-01 & 50-328/85-01 on 850114-18 & Forwards Notice of Violation.Notice Issued W/O Civil Penalty Due to Lack of Clarity Re Fire Protection Requirements & Significant Time Lapse Since Insp

ML20215F401
Person / Time
Site:	Sequoyah
Issue date:	06/08/1987
From:	James Keppler NRC OFFICE OF SPECIAL PROJECTS
To:	White S TENNESSEE VALLEY AUTHORITY
Shared Package
ML20215F404	List: IR 05000327/1985001 ML20215F401 ML20215F440
References
EA-85-048, EA-85-48, NUDOCS 8706220369
Download: ML20215F401 (6)

See also: IR 05000327/1985001

Text

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8' 7go NUCLEAR REGULATORY COMMISSION

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JUN 0 8 1987

Docket No. 50-328

. License No. DPR-79

EA 85-48

Tennessee Valley Authority

ATTN: Mr. S. A.. White

Manager of Nuclear Power

6N 38A Lookout Place

1101 Market Street <

Chattanooga, TN 37402-2801 l

SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORT NOS. 50-327/85-01

AND50-328/85-01)

Gentlemen:

As a result of deficiencies identified by the NRC during a July 16-20, 1984 i

Appendix R inspection at Tennessee Valley Authority's'(TVA) Watts Bar facility,

a Confirmation of Action Letter concerning t.he implementation of 10 CFR Part 50, ,

Appendix R, Sections III.G, III.J, III.L and III.0 was issued to the Sequoyah ,

NuclearPlant(SNP)byRegionIIonAugust 10, 1984. TVA's_re-evaluation at i

SNP was completed on December 21, 1984. A special safety inspection was l

conducted on January 14-18, 1985 at SNP Units l'and 2 to evaluate the adequacy -

of TVA's performance with respect to fire protection at SNP. As a result of

the inspection, numerous violations of NRC requirements were identified, some ,

of which you had identified previously. The report which documents'this i

.

inspection was sent to you with a letter dated March 29, 1985. An Enforcement

Conference to discuss the violations was held in the NRC Region II Office on

February 28, 1985. The enforcement action c,n .this matter. was then held in

abeyance while the Commission resolved a number of. issues pertaining to

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Those~ actions have now been I

Appendix R implementation and enforcement.

resolved and we a're proceeding to issue this enforcement action.

Violation I.A.1 described in the enclosed Notice of Violation'(Notice) involves

36 examples in 19 different plant areas in which both trains of redundant hot

shutdown systems could have been rendered inoperable in the event of a fire.

Thus, the plant's ability to achieve and maintain hot shutdown was not assured.  ;-

Violation I.A.2 involves 245 circuits that had a common power source with other

shutdown equipment and which were not properly electrically protected from the

circuit of concern. These circuits could have prevented operation or caused

malfunction of equipment necessary to achieve and maintain hot-shutdown

conditions in the event of a fire. Violation I.B involves 13 examples in which

both redundant trains of cabling for systems'necessary.to achieve and maintain

cold shutdown were located in the same fire area and therefore could have been

rendered inoperable had there been a fire.

.;

The number of examples of noncompliance that were identified. in;1984 are of- '

concern to the NRC because they are' indicative of weaknesses in TVA's original

review, design, construction and modifications made to implement the requirements

of 10'CFR Part 50, Appendix R for.Sequoyah Unit 2. We recognize that since this

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inspection you have taken actions to correct the deficiencies. We expect that

SNP 2 will either be in compliance with Appendix R or have approved compensatory

measures in place prior to restart. However, in accordance with the " General

Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2,

Appendix C (1987), Violations I.A and I.B described in the enclosed Notice have

been categorized in the aggregate as a Severity Level II problem because the

numerous violations identified in hot shutdown and cold shutdown systems lead

us to conclude that a fire in these areas would have damaged equipment to the

extent that safe shutdown would not have been achieved and maintained in the

event of a fire.

A civil penalty is normally proposed for a Severity Level II violation or problem

absent mitigating circumstances. However, after consultation with the Commission

and the Deputy Executive Director for Regional Operations, I have been authorized

to issue the enclosed Notice without a civil penalty. Because of the apparent

lack of clarity which existed regarding the fire protection requirements, the

significant time that has elapsed since the inspection associated with these

violations, and after considering the unique circumstances at TVA involving the

extensive efforts to identify and correct problems including some of the cited

violations, I have concluded that issuance of a civil penalty at this time is

unnecessary. -

Violation II.A in the enclosed Notice involves design deficiencies associated

with the reactor coolant pump oil collection systems; Violation II.B involves

deficiencies associated with cable fire barrier assemblies; and Violation II.C

involves deficiencies associated with the emergency lighting units. Collectively,

these violations have been characterized as a Severity Level IV problem.

You are required to respond to this letter and should follow the instructions

specified in the enclosed Notice when preparing your response.. In your response,

you should document the specific actions taken and any additional actions you

plan to prevent recurrence. You may reference previous submittals regarding this

matter in your response to this letter.

In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2,

Title 10, Code of Federal Regulations, a copy of this letter and its enclosure

will be placed in the NRC's Public Document Room.

The responses directed by this letter and its enclosure are not subject to the

clearance procedures of the Office of Management and Budget issued under the

Paperwork Reduction Act of 1980, PL 96-511.

Sincerely,

g a b /yd ~ 0a- - l

VJamesG.Keppfek, Director  !

Office of Special Projects

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Enclosure:

Notice of Violation

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H. L.:Abercrombie, Site Director

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J. A. Kirkebo, Acting Director

Nuclear Engineering.

R. L. Gridley, Director

Nuclear Safety and Licensing i

M. R. Harding, Site Licensing

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cc:

General Counsel Regional Administrator, Region II

Tennessee Valley Authority U.S. Nuclear Regulatory Commission 1

400 West Summit Hill Drive 101 Marietta Street, N.W. '

Eli B33 Atlanta, Georgia 30323

Knoxville, Tennessee 37902

Resident Inspector /Sequoyah NP  !

Mr. R. L. Gridley c/o U.S. Nuclear Regulatory Commission l

Tennessee Valley Authority 2600 Igou Ferry Road i

5N 157B Lookout Place Soddy Daisy, Tennessee 37379 j

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Chattanooga, Tennessee 37402-2801

Mr. Richard King

Mr. H. L. Abercrombie c/o U.S. GA0

Tennessee Valley Authority 1111 North Shore Drive j

Sequoyah Nuclear Plant Suite 225, Box 194 '

P.O. Box 2000 Knoxville, Tennessee 37919

Soddy Daisy, Tennessee 37379

Tennessee Department of

Mr. M. R. Harding Public Health

Tennessee Valley Authority ATTN: Director, Bureau of

Sequoyah Nuclear Plant Environmental Health Services

P.O. Box 2000 Cordell Hull Building

Soddy Daisy Tennessee 37379 Nashville, Tennessee 37219

Mr. D. L. Williams Mr. Michael H. Mobley, Director

Tennessee Valley Authority Division of Radiological Health

400 West Summit Hill Drive T.E.R.R.A. Building

W10 B85 150 9th Avenue North

Knoxville, Tennessee 37902 Nashville, Tennessee 37203

County Judge

Hamilton County Courthouse

Chattanooga, Tennessee 37402