ML20206B959
| ML20206B959 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 04/20/1999 |
| From: | Reyes L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Scalice J TENNESSEE VALLEY AUTHORITY |
| References | |
| NUDOCS 9904300135 | |
| Download: ML20206B959 (5) | |
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April 20, 1999 Tennessee Valley Authority ATTN: Mr. J. A. Scalice Chief Nuclear Officer and Executive Vice President 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801
SUBJECT:
NOTICE OF ENFORCEMENT DISCRETION FOR TENNESSEE VALLEY AUTHORITY REGARDING SEQUOYAH NUCLEAR PLANT UNIT 1 (NOED NO. 99-2-001)
Dear Mr. Scalice:
By letter dated April 17,1999, you requested that the Nuclear Regulatory Commission (NRC) exercise discretion not to enforce compliance with the actions required in Unit 1 Technical Specification (TS) 3.1.2.2, 3.1.2.4, and 3.5.2. Your letter documented information previously discussed with the NRC in a telephone conference on April 16,1999, at 2:30 p.m. The principal NRC staff members who participated in that telephone conference were Bruce Mallett, Director, Division of Reactor Safety and Herb Berkow, Director Project Directorate 11-2, Office of Nuclear Reactor Regulation. You stated that on April 18,1999, at 4:19 p.m. Sequoyah Ur t 1 would not be in compliance with 3.1.2.2,3.1.2.4, and 3.5.2, Action Statements which required the return of the 18-B centrifugal charging pump (CCP) to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. You requested that a Notice of Enforcement Discretion (NOED) be issued pursuant to NRC's policy regarding exercise of discretion for an operating facility, set out in Section Vll.c, of the " General Statement of Policy and Procedures for NRC Enforcement Actions"(Enforcement Policy), NUREG-1600, and be effective for the period from 4:19 p.m., on April 18,1999, to 4:19 p.m. on April 20,1999.
This letter documents our telephone conversation on April 17,1999, at 2:30 p.m. when we orally issued this NOED. The principal NRC staff members who participated in that telephone conference were Bruce Mallett, Director, Division of Reactor Safety, Loren Plisco; Director, Division of Reactor Projects and me.
This condition was the result of the failure of the 18-B CCP to provide charging flow at the desired rate. Your inspection of the 1B-B CCP revealed that there was excessive seal leakage, that the locknut that secured the balance drum in place was loose, and that there were increased pump vibrations. Although you indicated you did not have clear evidence of the cause of the 1B-B CCP problems these observations were indicative of symptoms associated with shaft failures. You requested an additional 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after the expiration of the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of (
l TS 3.1.2.2,3.1.2.4, and 3.5.2, to complete the repairs, operability tests, and return the 1B-B 6
CCP to service.
You provided as your safety rationale for issuing the NOED that the results of your probabilistic safety assessment indicated that the extension request would increase core damage frequency and the large early release frequency a negligible amount. Additionally, a significant reduction in the margin of safety would not occur because plant parameters would continue to be maintained consistent with the safety analysis assumptions and the risk analysis, which shows an insignificant increase in risk.
1 3000#l3 9904300135 990420 PDR ADOCK 05000327 G
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You stated that compensatory measures would include the monitoring of the 1 A-A CCP vibration levels to provide an early warning of pump problems. Operations personnel were to monitor the pump locally, at least twice each shift, for any abnormal indications (e.g., leakage, noise). Work activities that could adversely impact operations of the 1 A-A CCP will be suspended until 18-B CCP was returned to operable status. Additionally, the impact on risk for other maintenance activities has been assessed and adjustments made for any significant or sensitive activities.
During this extension, you were going to enter Action Statements for TS 3.0.3 and place the unit
- in a safe condition if the capability of the 1A-A CCP was determined to be adversely affected.
During the telephone conversation of April 17,1999, we requested and you agreed to ensure the following actions were completed, in addition to those indicated in your April 17,1999, letter; 1.
The procedures used for testing of the repaired 18-8 CCP would be approved by your Plant Operations Review Committee.
2.
You would conduct testing of the repaired pump to ensure output curves meet design requirements by matching at least three points on the pump curves and using a pre-determined acceptance criteria.
3.
.You would provide the results of the vendor's analysis and your pump test results to the NRC.
4.
You would conduct a full flow test of the 18-B CCP at the first outage opportunity.
The staff has reviewed the ahnve rationale regarding your request and the results of your probabilistic safety assessment. In addition, your compensatory measures are appropriate to support a conclusion that enforcement discretion should be given to avoid undesirable transients as a result of forcing compliance with the TS, and would thus minimize potential safety consequences and operational risks.
On the basis of the staff's evaluation of your request, we have concluded that an NOED is warranted because we are clearly satisfied that this action involves minimal or no safety impact; is consistent with the enforcement policy and staff guidance; and has no adverse impact on public health and safety.. Therefore, it is our intention to exercise discretion not to enforce compliance with TS 3.1.2.2, 3.1.2.4, and 3.5.2, for the period from 4:19 p.m. on April 18,1999, until 4:19 p.m. on April 20,1999. If, during the additional 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of enforcement discretion, you find that the root cause is other than a failure of the 1B-B CCP, or a new problem is identified during repairs or testing that would require the 1-B-B CCP to be declared inoperable, this enforcement discretion is terminated, after which you must immediately comply with TS 3.1.2.2, 3.1.2.4, and 3.5.2.
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As stated in the Enforcement Policy, action will be taken, to the extent that violations were involved, for the root cause that led to the noncompliance for which this NOED was necessary.
Sincerely, toriginal signed by Ioren R. Plisco for)
Luis A. Reyes Regional Administrator Docket No.: 50-327 License No.: DRP-77 cc:
Senior Vice President Nuclear Operations Tennessee Valley Authority 6A Lookout Placa 1101 Market Street Chattanooga, TN 37402-2801 Jack A. Bailey, Vice President Engineering and Technical Services Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Masoud Bajestani Site Vice President Sequoyah Nuclear Plant Tennessee Valley Authority P. O. Box 2000 Soddy-Daisy, TN 37379 General Counsel Tennessee Valley Authority ET 10H 400 West Summit Hill Drive Knoxville,TN 37902 N. C. Kazanas, General Manager Nuclear Assurance Tennessee Valley Authority SM Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 cc continued: See page 4 i
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- cc: Continued.
i Mark J. Burrynski, Manager Nuclear Licensing
- Tennessee Valley Authority 4X Blue Ridge -
1101 Market Street Chattanooga, TN 37402-2801
~ Pedro Salas, Manager Licensing and Industry Affairs Sequoyah Nuclear Plant Tennessee Valley Authority P. O. Box 2000 Soddy-Daisy, TN 37379' D. L. Koehl, Plant Manager Sequoyah Nuclear Plant k
Twaensee Valley Authority -
P. '.'. Box 2000 Sc.Jdy Daisy, TN 37379.
Michael H. Mobley, Director
. Division of Radiological Health TN Dept. of Environment and
- Conservation 3rd Floor, LNC Annex 401 Church Street Nashville, TN 37243-1532 County Executive Hamilton County Courthouse
- Chattanooga, TN 37402-2801 Distributen-L. R. Plisco, Ril H. N. Berkow, NRC -
R. W. Hernan, NRC Ril Coordinator, OEDO W. C. Bearden, Ril C. F. Smith, Ril D. W. Jones, Rll D. H. Thompson, Ril i
L. S. Mellen, Rll PUBLIC NRC Resident inspector, Operations -
U. S. Nuclear Regulatory Commission 1260 Nuclear Plant Road --
Spring City, TN 37381 Distribution continued: See page 5 1
6.
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Distribution: Continued NRC Resident inspector Sequoyah Nuclear Plant U. S. Nuclear Regulatory Commission 2600 Igou Ferry Road Soddy-Daisy, TN 37379 I
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