ML20207E188

Notice of Violation from Insp on 861016-23.Violation Noted: Failure to Perform Adequate 10CFR50.59 Evaluation of Temporary Mod to Control Bldg Ventilation Sys,Falsely Concluding That Unreviewed Safety Question Did Not Exist

ML20207E188
Person / Time
Site:	River Bend
Issue date:	12/29/1986
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20207E180	List: ML20207E176 ML20207E188
References
50-458-86-36, EA-86-183, NUDOCS 8701020084
Download: ML20207E188 (2)

Text

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NOTICE OF VIOLATION Gulf States Utilities Docket No. 50-458 River Bend License No. NPF-47 EA 86-183 During an NRC inspection conducted on October 16-23, 1986, a violation of NRC requirerents was identified. The violation involved failure to perform an adequate 10 CFR 50.59 evaluation of a temporary modification to the control building ventilation system. In accordance with the " General Statement of Folicy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1986), the violation is listed below:

10 CFR 50.59(a) allows the holder of a license to make changes in the facility as described in the safety analysis report (SAR) without prior Commission approval unless it involves a change in the technical specifications or involves an unreviewed safety question. An unreviewed safety question is created if the probability of occurrence or the consequences of an accident or the mal-function of equipment important to safety previously evaluated in the SAR are increased, or if a possibility for an accident or malfunction of a different type than any evaluated previously in the SAR may be created, or if the margin of safety as defined in the basis for any technical specification is reduced.

10CFR50.59(b)requiresinpartthatthelicenseemaintainrecordsofchanges in the facility to the extent that such changes constitute changes in the facility as described in the SAR. These records shall include a written safety evaluation which provides the bases for the determination that the change does not involve an unreviewed safety question.

Section9.2.10.5oftheRiverBendFinalSafetyAnalysisReport(FSAR) states that low air flow through an air conditioning unit trips the associated operating chilled water recirculation pump. Control logic is provided so that low chilled water flow through a chiller automatically starts the redundant system's chilled water recirculation pump. Section 9.4.1.3 of the River Bend

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FSAR further states that the single failure criterion is met by the redundant design of equipment and controls so that the controls automatically switch from the failed piece of equipment to the redundant equipment.

Contrary to the above, the licensee failed to meet the requirements of 10 CFR 50.59 in that the licensee improperly analyzed changes made to its facility, as described in the FSAR, and concluded that an unreviewed safety question did not exist when, in fact, an unreviewed safety question did exist. The unreviewed safety question was created when the control building ventilation system was modified on October 29, 1985 and June 27, 1986 so that low air flow through an air conditioning unit would no longer trip the associated operating chilled water recirculation pump. Without this trip, failure of an operating air conditioning unit would not result in the automatic start of the redundant air conditioning unit. Therefore, the change involved an unreviewed safety question because a possibility for a malfunction of a different type than any evaluated in the FSAR was created.

ThisisaSeverityLevelIIIviolation(SupplementI).

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Notice of Violation Pursuant to the provisions of 10 CFR 2.201, Gulf States Utilities is hereby required to submit to this Office within 30 days of the date of the letter transmitting including:- (this Notice, a written statement or explanation in reply,1)thereas steps which have been taken and the results achieved, (3) the corrective steps which will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending the response time.

Dated a Arlington, Texas, this day of December, 1986.

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