ML20117B283

Responds to NRC Re Violations Noted in Insp Repts 50-327/96-05 & 50-328/96-05.Corrective Actions:Evaluation of Problem Evaluation Rept Pertaining to FSAR Performed

ML20117B283
Person / Time
Site:	Sequoyah
Issue date:	08/16/1996
From:	Adney R TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9608260455
Download: ML20117B283 (5)

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Tennessee Valley Authority, Post Offce Box 2000, Soddy-Daisy, Tennessee 37379-2000 1 R.J. Adney l l

Site Voe President Sequoyah Nuclear Plant i I

1 August 16, 1996 i

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U.S. Nuclear Reguletory Commission l ATTN: Document Control Desk l l Washington, D.C. 20555 l

! 1 Gentlemen: l In the Matter of ) Docket Nos. 50-327 Tennessee Valley Authority ) 50-328 SEQUOYAH NUCLEAR PLANT (SON) - NRC INSPECTION REPORT NOS. 50-327, 328/96 REPLY TO NOTICE OF VIOLATION (NOV) 50-327,328/96-05-04 Enclosed is TVA's reply to Mark S. Lessor's lettar to Oliver D. Kingsley, Jr., dated July 22,1996, which transmitted the subject NOV. The violation is associated with the failure to update the Final Safety Analysis Raport as required by 10 CFR 50.71(e).

Enclosure 1 contains TVA's response to the NOV. Commitments associated with the submittal are included in Enclosure 2. ,

1 If you have any questions concerning this subrnittal, please telephone R. H. Shell at l (423)843-7170. l l l l Sincerely, I j R. .Adney j '

, Enclosures cc: See page 2 I 9608260455 960Bi6 PDR ADOCK 05000327 G PDR wam

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. U.S. Nuclear Regulatory Commission Page 2 August 16, 1996 Enclosures l

cc (Enclosures):

Mr. R. W. Hernan, Project Manager Nuclear Regulatory Commission One White Flint, North -

11555 Rockville Pike Rockville, Maryland 20852-2739 NRC Resident inspector i Sequoyah Nuclear Plant

! 2600 lgou Ferry Road Soddy-Daisy, Tennessee 37379-3624 Regional Administrator U.S. Nuclear Regulatory Commission Region 11 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323-2711 i

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ENCLOSURE 1 RESPONSE TO NRC INSPECTION REPORT NOS. 50-327,328/96-05 MARK S. LESSER'S LETTER TO OLIVER D. KINGSLEY, JR.

DATED JULY 22,1996 VIOLATION 50-327.328/96-05-04 "10 CFR 50.71(e) requires, in part, each person licensed to operate a nuclear power reactor pursuant to the provisions of 10 CFR 50.22, shall update periodically, as provided in paragraph (e) (4) of this w. tion, the final safety analysis report originally submitted as part of the application in' the operating license. Paragraph (e) (4) requires, in part, that the final sefety analysis report revisions must be filed annually or 6 months after each refueling outage and must reflect all changes up to a maximum of 6 months prior to the date of filing.  ;

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" Contrary to the above, Section 9.3.4.2.3, BORON RECOVERY SYSTEM, of the l Sequoyah Updated Final Safety Analysis Report was not updated in revisions of April 14,1994 (Amendment 10), and May 16,1995 (Amendment 11) to reflect current system operational practices for the Boron Recovery System. A plant modification (Design Change Notice M01965A, Revision 6) was implemented in December 1992, abandoning one of the boric acid evaporators, however Section 9.3.4.2.3 stated,in part, that liquid effluent in the holdup tanks is processed as a batch operation through two recycle processing trains ( A and B boric acid evaporator packages) which are shared by the two units.

"This is a Severity Level IV Violation (Supplement 1)."

Reason for the Violation The design change process requires a safety assessment to be performed to evaluate the effect that the proposed change has on the plant as described in the Final Safety Analysis Report (FSAR). The purpose of the original design change was to correct heat trace problems associated with the boric acid evaporator. This proposed design change did not affect the description of the plant in the FSAR. A later revision to the design change included the abandonment of the A-train boric acid evaporator. The revised safety assessment for the revision to the design change did not reference all j of the applicable FSAR sections and states that the design change does not affect any  ;

information presented in the FSAR or deviate from the description in the FSAR.

The cause of the violation was the failure of the preparer and reviewer of the revised safety assessment to adequately evaluate the effects of the associated design change on the FSAR. The responsible individuals were contractors and no longer work at Sequoyah. An investigation determined that th' individuals involved did not recognize the implications of the abandonment of the A-train boric acid evaporator as an impact on the FSAR. The boric acid evaporator was not physically removed. Instead, valve alignments were made to isolate the system. The individuals focused on the heat trace issues and did not adequately address the abandonment of the A-train boric acid

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2 evaporator. The preparer and reviewer relied too heavily on the original safety assessment and did not address the addition of the abandonment of the A-train boric )

acid evaporator. '

Corrective Actions That Have Been Taken and the Results Achieved I

An evaluation of problem evaluation reports pertaining to FSAR issues was performed. ,

The evaluation did not identify any additional examples where a design change that affected the plant as described in the FSAR was not identified. i A review of design changes associated with equipment that is no longer being utilized >

l for plant operations was performed to determine if the FSAR was accurate in its I description of the use and function of the equipment. The review did not identify any '

additional FSAR discrepancies.

The safety assessment process has been evaluated, and it was determined that the process provides sufficient guidance to ensure that changes to the plant which affect the FSAR are identified.

1 An FSAR change request to reflect the abandonment of the A-trein boric acid evaporator has been submitted in accordance with plant procedures. The FSAR will I be revised in the next required update to reflect the abandonment of the A-train boric I acid evaporator.

The Corrective Steos Taken to Avoid Future Violations A meeting was held with NRC on July 10,1996, to discuss FSAR compliance at TVA l nuclear plants. As described in that meeting, TVA has initiated a program to review the SON FSAR. Implementation of the program is ongoing. Any deficiencies identified during implementation will be dispositioned in accordance with the corrective action program.

Date When Full Comoliance Will be Achieved l With respect to the violation cited, TVA will be in full compliance after the next revision to the FSAR is submitted. The next FSAR update will be submitted by December 6,1996.

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', ENCLOSURE 2 l COMMITMENT FOR RESPONSE TO NRC INSPECTION REPORT NOS. 50-327,328/96-05 MARK S. LESSER'S LETTER TO OLIVER D. KINGSLEY, JR.

DATED JULY 22,1996 ]

l The Final Safety Analysis Report will be revised in the next required update to reflect 1 j the abandonment of the A-train boric acid evaporator. The FSAR update will be l l submitted by December 6,1996. '

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