IR 05000327/1997004

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-327/97-04 & 50-328/97-04.Agrees That 970720 NOV Did Not Constitute Violation as Written.Nrc Exercising Discretion

ML20199F724
Person / Time
Site:	Sequoyah
Issue date:	01/28/1998
From:	Jerrica Johnson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Zeringue O TENNESSEE VALLEY AUTHORITY
References
50-327-97-04, 50-327-97-4, 50-328-97-04, 50-328-97-4, EA-98-030, EA-98-30, NUDOCS 9802040091
Download: ML20199F724 (7)

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s JAN 2 81998 EA 9t! 030 Tennessee Valley Authority '

ATTN: Mr. O. ,

Chief Nuclear Officer and Executive Vice President 6A Lookout Place 1101 Market Street Chattanooga, TN 37402 2001 Subject: NRC INSPECTION REPORT NOS. 50 327/97 04 AND 50 328/97 04 l

Dear Mr. Zeringue:

l Thank you for your response of July 21, 1997, to our Notice of Violation-issued on June 20, 1997, concerning activities conducted at your Sequoyah facility. We have evaluated your response and fcund that it meets the requirements of 10 CFR 2.201..

After reviewing your letter and consulting with the Office of Nuclear Reactor Regulation and the Office of Enforcement, we agree with your conclusion that Violation A of the June 20, 1997. Notice of Violation did not constitute a violation as written. - Accordingly, we will adjust our records to reflect that no violation of Technical Specification surveillance requirements occurred with respect to Violation A.

Our review, however, identified that your procedure steps for declaring the initiation of physics testing, Mode 2 entry, and the initiation of control bank withdrawal were in conflict, which resulted in a failure to implement them as written. Our inspectors determined that you have since corre:ted this conflict to provide consistency. Therefore, due to the low safety significance of.the procedure conflict and NRC's prior determinations regarding this overall matter, the NRC is exerc;:ing discretion in accordance with Section VII.B.6 of the Enforcement Policy, NUREG 1600, and is not citing this violation.

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TVA 2 A detailed analysis of your response and NRC's conclusions are enclosed. If you have any additional questions regarding this matter, please contact me.

Sincerely, A Sye . .

Jon R. Johnsor. Director Division of Reactor Projects Docket Nos.: 60 327 and 50 328 License Nos.: DPR 77 and DPR 79 Enclosure: Evaluations and Conclusion

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cc w/ encl: (See page 3)

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TVA 3 cc w/ encl:

Senior Vice President Mr. P. Salas, Manager Nuclear Operations Licensing and Industry Tennessee Valley Authority Sequoyah Nuclear Plant 6A Lookout Place P. O. Box 2000 1101 Market Street Soddy Daisy, TN 37379 '

Chattanooga, TN 37402 2801 rir. J. T. Herron Plant Manager *

Mr. J. A. Bailey Sequoyah Nuclear Plant Vice President Tennessee Valley Authority Engineering and Technical Servi es P. O. Box 2000 6A Lookout Place Soddy Daisy, TN 37379 1101 Market Street Chattanooga, TN 37402 2801 Director Division of Radiological Health Mr. M. Bajestani 3rd Floor, L and C Annex Site Vice President 401 Church Street Sequoyah Nuclear Plant Nashville, TN 37243 1253 Tennessee Valley Authority P. O. Box 2000 -County Executive

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Soddy Daisy, TN 37379 Hamilton County Courthouse Chattanooga. TN 37402 2801 General Cou:sel Tennessee Valley Authority Distribution w/ encl: (See page 4)

ET 10H 400 West Summit Hill Drive Knoxville, TN 37902 Mr. R. R. Baron General Manager Nuclear Assurance 4J Blue Ridge 1101 Market Street Chattanooga, TN 37402 2801 Mr. M. J. Burzynski, Manager Nuclear Licensing Tennessee Valley Authority 4J Blue Ridge 1101 Market Street Chst.tanccp , TN 37402 2801

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TVA 4

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Distribution w/ encl:

J. R. Johnson, RII H. S. Lesser. RII S. E. Sparks, RII F. J. Hebdon, NRR R. W. Hernan, NRR W. C. Bearden. RII C. F. Smith, RII D. H. Thompson, RII L. S. Mellen, RII E. D. Testa,-RII PUBLIC NRC Resident Inspector U. S. Nuclear Regulatory Commission 2600 Igou Ferry Soddy Daisy, TN 37379

, NRC Resident Inspector U. S. Nuclear Regulatory Commission 1260 Nuclear Plant Road Spring City. TN 37381

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EVALUATIONS AND CONCLUSION On June 20, 1997, a Notice of Violation (Notice) was issued for failure to meet the requirements of performing a channel functional test on the nuclear instrumentation system (NIS) within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of initiating physics testing.

The Tennessee Valley Authority (Sequoyah) responded to the Notice on July 21, 1997. Sequoyah based its denial of this violation on the fact that there is not a clear definition for the initiation of physics testing. The NRC'c evaluations and conclusion regarding the licensee's arguments are as foliows:

Restatement of Violation A Technical Specification (TS) 4.10.3.2, Physics Tests Surveillance -

Requirements, recuires that each Intermediate and Power Range Channel shall be subjected to a ClANNEL FUNCTIONAL TEST within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> prior to initiating PHYSICS TESTS, Contrary to the above, on May 11, 1997, each Intermediate and Power Range Channel was not subjected to a CHANNEL FUNCTIONAL TEST within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> prior to initiating PHYSICS TESTING. in that the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> channel functional test for Power Range Channel instrument NI 42 and Intermediate Range Channel NI 36 expired prior to the initiation of Physics Testing.

Sumary of Licensee's Response to Violat19D_8 The licensee argued that their procedure for conducting low power physics testing explicitly defines the start of physics tests as the time that permission from the Senior Reactor Operator (SR0) has been obtained to begin the first withdrawal of control rod bank A. The procedure also states that this time would stop the clock for nuclear instrumentation testing for startup. The licensee further stated that in accordance with this procedure, permission was obtained at 2:13 a.m., from the SR0 to begin low power physics testing and to perform rod pulls to critical. Personnel then began low power physics test activities which included data collection to obtain average NIS baseline count rates before pulling control banks. The licensee stated that the data collection was both necessary and essential and were well within the TS definition of PHYSICS TESTS.

The licensee noted that there is a wide range of industry practices in defining the start of physics testing. Some facilities define the start of physics testing at the point at which the operators begin to pull the shutdown banks and others at the point of pulling control banks. The licensee also stated that there was a lack of specific regulatory guidance on the issue.

The licensee was also concerned with the negative impact of starting physics tests at the point where the reactor was critical due to potentially being required to remove a channel for test while performing a startup.

Enclosure

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I MLC Evaluation of Licensee's Response The NRC staff has carefully reviewed the licensee's respor.se. The staff acknowledges the licensee's finding that there is a wide variation throughout the industry in the interpretation / definitions of " starting physics testing".

The staff does not have a preference for the specific point at which the initiation of physics tests can be declared. Therefore, since the licensee performed the required surveillances ilthin 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of declaring the initiation of physics testing, the v1olation, as written did not take place.

The staff notes that tha initiation point should be consciously, logically, and ccasistently determined. The staff determined that there was a procedural conflict which, in tnis case, resulted in a failure to implement the procedure as written.

The licensee's response did not address the problem of procedural conflict as described in the inspection report. Elsewhere the licensee's procedure states, " Declare Mode 2 entry and initiation of physics testing, and record the time, and initiate control bank withdrawal in manual mode." This step -

clearly indicates that these all happen at the same time. In the situation involved, the 1icensee declared that physics tests were initiated when the SR0 gave permission to begin the withdrawal of control bank A. The staff notes that in granting >ermission, the SR0 must ensure that the control bank is capable of both 31ysically and procedurally being withdrawn. In this case, control bank wit 1drawal was not initiated for 27 minutes due a procedural problem with a feedwater purrp, which was in the process of being corrected.

It is apparent that the SR0 gave permission to withdraw control banks prematurelv in order to meet the TS surveillance requirement, as it was to expire witflin the next five minutes. It is also apparent that the procedural steps conflicted and were not implemented as written. This would constitute a violation of Technical Specification 6.8.1, which requires written procedures to be established, implemented and maintained covering such activities.

The licensee's response stated that personnel began low power physics test activities which includeo data collection to obtain average baseline count rates before pulling control banks. The NRC agrees that obtaining baseline count rates is both necessary and essential: however, this task appears to be required in a procedural step (6.1.4) 3rior to declaring the initiation of physics testing (6.1.6). This is anotler indication that the licensee's ,

expectation is different than the requirement of the procedure.

In addition, the licensee's response noted the negative impact of starting

)hysics tests at the point whsre the reactor was critical due to potentially aeing required to remove a channel for test while performing a startup. The staff agrees with the basis of the statement that the nuclear instruments should not be removed for testing during a startup.

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Canclusion The staff concluded that the licensee met the requirements of TS surveillance 4.10.3.2, and therefore the violation is withdrawn.

The staff also concluded that the licensee's procedure provided conflicting guidance'for initiating the start of physics testing and performing a plant startup. This resulted in a failure to implement the procedure as written.

Subsecuently, the resident inspectors verified that the licensee revised the procecural guidance in the Low Power Physics Test procedure, to clarify conditions for the start of physics tests and for initiating rod withdrawal and Mode 2 entry. Based on the satisfactory completion of corrective actions by the licensee, the reduced safety significance of the violation, and NRC's n

'd prior regulatory determination regarding this matter, the NRC is exercising discretion and not citing this violation in accordance with Section VII.B.6 of the Enforcement Policy.

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