ML20155B266
| ML20155B266 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 09/28/1988 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8810060250 | |
| Download: ML20155B266 (6) | |
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rF TENNECCEE VALLEY AUTHORITY CH ATTANOOGA. TENNESSEE 37401 SN 157B Lookout Place Sil? 281988 U.S. Nuclear. Regulatory Commission ATTN: Document Control Desk Washington, D.C.
20555 Gentlemen:
In the Matter of
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Docket Nos. 50-327 Tennessee Valley Authority
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50-328 SEQUOYAH NUC4 EAR PLANT (SQN) UNITS 1 AND 2 - NRC INSPECTION REPORT NOS. 50-327, 328/88 RESPONSE TO NOTICE OF VIOLATION (NOV) 50-327, 328/88-33-01 Enclosed is TVA's response to F. R. McCoy's letter to S. A. White dated August 22, 1988, that transmitted the subject NOV.
Enclosure I provides TVA's response to the NOV.
Summary statements of commitments contained in this submittal are provided in enclosure 2.
If you have any questions, please telephone M. A. Cooper at (615) 87'-6549.
0 Very truly yours, TENNESSEE VALLEY AUTNORITY y (h R.
idley, Man e
Nuc14ar Licensing and Regulatory Affairs Enclosures
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See page 2 l
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9910060250 000920 PDR ADOCK 05000327-Q PNU ;
M An Equal Opportunity Employer
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U.S. Nuclear Regulatory Comission gp g g i
Enclosures cc (Enclosures):
Ms. S. C. Black, Assistant Director forProjects TVA Projects Olvision U.S. Nuclear Regulatory Commissicq I
One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Mr. F. R. McCoy, Assistant 01 rector for Inspection Programs i
TVA Projects 01 vision U.S. Nuclear Regulatory Commission
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Region II i
101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30523 i
Sequoyah Resident Inspector f
Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy Daisy, Tennessee 37379 i
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m Response to NRC Inspection Report No. 50-327, 328/88-33 F. R. McCoy's Letter to S. A. White Dated August 22, 1988 Violation 50-327. 328/88-33-01 "Technical Specification 6.8.1.e stated that, ' Written procedures shall be established, implemented, and maintained covering.... Site Radiological Emergency Plan (REP) implementation.'
REP Implementing Procedure IP-1, ' Emergency Plan Classification Logic '
stated, 'If there is any reason to doubt whether a giv e condition has actually occurred, the shift engineer or Site Emergency Olrector will proceed with the required notification without waiting for formal confirmation.'
Contrary to the above, on February 8, 1988, al1 hough there may have been reason to doubt the validity of a seismic alarm at time of receipt, the licensee failed to implement the REP until 64 minutes after the conditions had been met for declaring a Notification of Unusual Event.
This is a Severity Level IV violation (Supplement VIII)."
Admission or Denial of the Alleged Violation i
TVA admits the violation occurred as stated.
l Reason for the Violation IP-1 is intended to provide logic for determining whether the REP shculd i
be activated and, if it is activated, at what level it should be classified.
As stated in the Purpose section of IP-1, it "... guides the Shift Engineer (SE) or Site Emergency 01 rector (SED) in determining the class of an accident based on plant conditions." Section 3 of that procedure states, "The Shift Engineer is responsible for declaring the
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emergency and providing the initial activation of the REP." and that the t
i logic procedure "... should be combined with the sound judgement of the i
Shift Engineer and/or the Site Emergency Director to arrive at a i
d classificarica fr a particular set of circumstances." In other words, activation of the REP is to be based on the guidance in IP-1 and on the l
training, experience, and knowledge of the SE. A copy of page 1 of IP-1 is enclosed.
In an effort to provide the SE/ SED latitude in classifying the event I
(based on his training, experience, and knowledge), the procedure inadvertently imposes conflicting requirements for activating the REP in the event of suspected false or spurious alarms.
In this particular event, the SE was certain the seismic alarm actuated was of a spurious nature and relled upon his previous experience with seismic activity at SQN, knowledge of work activity in the area, and the latitude provided in 3
IP-1 to not classify the event and not initiate the REP. As recorded in the SE's log, employees were dispatched to the plant at the time the j
spurious alarm was received to determine the cause of the spurious alarm, 1
not its validity.
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. 2-L However, after further consulting the general instructions (ssetton 3.0) of IP-1, the SE made a conservative decision to ceclare a Notification of Unusual Event (NOVE) to ensure that the requirements of IP-1 were tot violated.
This latter determination was made approximately one hour
'following initial raceipt of the alarm.
Subsequently, the appropriate notifications were mide (NOUE was declared at 1:13 p.m. and NRC was notified at 1:15 p.m.).
t Corrective Steps That_ lave Been Taken ard Results Achieved l
SQN has reviewed IP-1 to evaluate the events of February 8, 1988, and has identified that a potential for confusion exists in section 3.0 of IP-1 with regard to known or suspected spurious alarms, t
Corrective Steps That Will Be Taken to Avold Further Violations l
To prevent recurrence of this violation, SQN will review and revise IP-1 to clarify the requirements for initiation of the REP.
IP-1 will be t
revised to direct the SE/ SED to follow his indications; and, unless a suspected spurious or otherwise false alarm can be substantiated within a minimum timeframe (based on the potential severity of the event), he is to proceed with actions as required by IP-1 until such time as the alarm Is verified to be false.
Date When Full Complia_nce Will 8e Achieved SQN will review and revise IP-1 by October 31, 1988.
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h@ SITE D!b SITE LIC 615 070 7139 P.02 gg,28/1980 13:25 SQN-IPD SQN, IP=1 Page 1 of 42 Revision 11 EMERGENCY PLAN CLASSIFICATION LOGIC 1.0. PURPCSE 1his procedure guides the Shift Engineer (SE) or Site Emergency Director (SED).in determining the class of an accident based on plant conditions.
2.0 REFERENCES
2.1 SQN Radiological Emergency Plan 2.2 NUREC - 0654 "criteria for Preparation and Evaluation of F.;ilological Emergency Response Plans & Preparedness in Support of Nuclear Power Plants" 2.3 tases for Radiological Effluents / Releases or Radiatier. !!onitor Readings:
(1)
J. T. Dills, Jr. to T. H. Youngblood memo dated 8/14/86 (S53 860815 941)
(2)
M. S. Robinson's me.mo dated 10/28/85 (L61 851023 805) 3.0 GENERAL The TVA Radiological Emergency Plan (REP) will be act.ivated when any one of the conditions listed in this logic is detected. ihe Shift Engineer is respon-sible for declaring the en:ergency and providing the $nitial activation of the REP.
To determine the classification of the emergency, enter the logic with the known or suspected conditions and carry out the actification referenced.
If there is any reason to doubt whether a given condition has actually occurred, the shift engineer or Site Emergency Director will proceed with the required notification without waiting for formal confirmtion.
If followup investi-gations show that a suspected condition ).as n:t occurred, is less severe, or more severe than originally suspected, the classification will be cancelled, downgraded, or upgraded as required. The ^ctshest classification for which an emergency action level cur:ently exista shall be declared.
If an er.er-gency action level for a higher classification was exceeded but the present situation indicates a lower classificati4A, or ITthe emergency situation has been resolved, the fact that the higher classification occurred shall be reported to the NRC and CECC, but should not be declared.
The following actions are given for guidance only knowledge of actual plant conditions or the extent of the emergency nsy require that additional steps be taken.
In all cases, this logic procedure thould be combined with the sound judgement of the Shift Engineer and/or the Site Emergency Director to arrive at a classification for a particular set of circumstances.
TOTA., P.02
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List of Commitments 1.
SQN will review and revise IP-1 by October 31, 1988, to clarify the L
requirements for initiation of the REP.
IP-1 will be revised to direct the SE/SEO to follow his indications; and, unless a suspected i
spurious or otherwise false alarm can be substantiated within a minimum +timeframe' (based on'the potent'lal severity of the event), he Is to. proceed with actions as required by IP-1 untti such time as the 1
alarm ts vertfled to be false.
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