ML20148H209

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Notice of Violation from Insp on 871026-30 & 880104-14. Violation Noted:Licensee Failed to Perform or Failed to Adequately Perform Written Safety Evaluations for 15 Mods
ML20148H209
Person / Time
Site: Sequoyah  Tennessee Valley Authority icon.png
Issue date: 03/09/1988
From: Barr K
NRC OFFICE OF SPECIAL PROJECTS
To:
Shared Package
ML20148H201 List:
References
50-327-87-73, 50-328-87-73, NUDOCS 8803290352
Download: ML20148H209 (2)


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6 ENCLOSURE 1 NOTICE OF VIOLATION Tennessee Valley Authority Docket Nos.: 50-327 and 50-328 Sequoyah Units 1 and 2 License Nos.: DPR-77 and DPR-79 During the Nuclear Regulatory Commission (NRC) inspection conducted on October 26-30, 1987 and January 4-14, 1988, a violation of NRC requirements was identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions, " 10 CFR Part 2, Appendix C (1988), the violation is listed below with examples:

10 CFR 50.59 states that the holder of a license authorizing operation of a utilization facility may make changes in the facility as described in the safety analysis report, without prior Commission approval, unless this proposed change involves a change in the Technical Specifications incor-porated in the license or involves an unreviewed safety question. The licensee should maintain records of changes in the facility which shall include a written safety evaluation which provides the bases for the determination .that the change does not involve an unreviewed safety question.

Contrary to the above, as documented on condition adverse to quality report (CAQR SQP871738) Rev. O, the licensee either failed to perform or failed to adequately perform written safety evaluations for 15 modifi-cations to the facility which involved compensatory actions for defeated safety functions. Examples of this violation include the following:

Example #1: A flexible hose installed between the essential raw cooling water system and the emergency diesel generator coolers has not been qualified to withstand a seismic event. A compensatory measure has been initiated requiring visual inspection of the hose after each diesel generator start. The licensee could not produce an unreviewed safety question determination for this issue, I i

Example #2: To avoid diesel generator overloading in the event of a l loss of offsite power, fire pumps 2A-A and 28-B are to be placed in "manual" to prevent their starting from ~a signal during a loss of coolant accident resulting from hi.gh containment temperatures.

Diesel generator loading analysis did not include loads associated i with these two pumps. The licensee could not produce an unreviewed l safety question determination for this issue, j l

Example #3: The Department of Nuclear Engineering has determined that twenty-four additional plant doors must be opened during a tornado watch or warning due to incorrect models used during the  !

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4 Tennessee Valley Authority 2 Docket Nos.: 50-327 and 50-328 Sequoyah Units 1 and 2 License Nos.: DPR-77 and DPR-79 original tornado analysis. A compensatory measure was implemented to require that these doors be opened. The licensee could not produce an unreviewed safety question determination for this issue.

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

Pursuant to the provisions of 10 CFR 2.210, you are hereby required to submit to this Office within 30 days of the letter transmitting the Notice a written scatement or explanation in reply including: (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 good cause is shown, consideration will be given to extending the response time.

FOR THE NUCLEAR REGULATORY COMMISSION Kenneth P. Barr Acting Assistant Director Division of TVA Projects Office of Special Projects Dated at Atlanta, Georgia this 96 day of March 1988