ML20217K375

Notice of Violation from Insp on 980126-0213.Violation Noted:On Listed Dates,Licensee Made Changes to Facility as Described in FSAR W/O Adequate Written SE Which Provides Bases for Determination That Changes Did Not Involve USQ

ML20217K375
Person / Time
Site:	Sequoyah
Issue date:	03/30/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20217K359	List: ML20217K353 ML20217K375 ML20217K380
References
50-327-98-01, 50-327-98-1, 50-328-98-01, 50-328-98-1, EA-98-118, NUDOCS 9804070210
Download: ML20217K375 (3)

Text

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NOTICE OF VIOLATION Tennessee Valley Authority Docket Nos. 50-327. 50-328 Sequoyah Nuclear Plant License Nos. DPR-77, DPR-79 EA 98-118 During an NRC inspection conducted on January 26, 1998 through February 13, 1998, a violation of NRC requirements was identified. In accordance with the

" General Statement of Policy and Procedure for NRC Enforcement Actions."

NUREG-1600. the violation is listed below:

10 CFR 50.59 (a)(1) allows the holder of a license to make changes to the facility and procedures as described in the Final Safety Analysis Report (FSAR) without prior Commission approval unless the proposed change involves a change to the Technical Specifications or an unreviewed safety question (US0).

10 CFR 50.59(b)(1) requires that the licensee shall maintain records of changes to the facility and that these records 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, in the following examples the licensee made changes to the facility as described in the FSAR without an adequate written safety evaluation which provided the bases for the determination that the changes did not involve an USO:

A. On October 13. 1987, work request B232398 documented that the rotating element on the 2A-A motor driven auxiliary feedwater pump (MDAFWP) was replaced. Post maintenance testing identified that the pump performance characteristics changed such that the discharge pressure of 1660 pounds per square inch gauge (psig) at the 30 gallons per minute (gpm) recirculation flow value exceeded the piping design pressure (1650 psig) and that there was a 100 psig increase in the pump shutoff head. The parameter changes indicated that the pump performance curves were changed. These were changes in the facility as described in the FSAR Table 10.4.7-2 which listed the AFW system design pressure as 1650 psig and the pump design head at 2900 feet at 440 gpm. Also, the AFW pump composite curves in FSAR figures 10.4.7-6 and 10.4.7-7 were impacted.

The licensee's Problem Evaluation Report (PER) S0P 871598 dated October 29. 1987. included a technical evaluation which concluded that this was an accept-as-is condition. There was no documented 50.59 evaluation / screening until September 7, 1990, and this screening incorrectly concluded that the change did not impact the information in the FSAR.

B. On October 19, 1996, work order 96-038636 increased the impeller / casing wear ring clearance on the 2A-A MDAFWP to resolve excess thrust Enclosure 1 9004070210 980330 PDR ADOCK 05000327 G PDR

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. conditions. During the maintenance activity, the licensee identified that the pump casing tolerances exceeded the vendor specifications and initiated PER SOR962756, dated October 29, 1996. This PER corrective actions included procuring a new pump and providing an interim. accept-as-is evaluation for the pump with the changed impeller dimensions. The impeller dimension change was a compensatory action to address the pump thrust problems due to the casing / impeller clearance deficiency, until the pump was replaced in December, 1997. On November 1. 1996. PER SO 962788 identified that the design control process was not implemented for this maintenance activity which resulted in changes to the pump performance characteristics. A technical evaluation in the PER stated that the new impeller and old impeller did not share the same pump curve, the new impeller would drive the full system flow upwards on the system resistance curve, and the additional flow from the stronger new impeller was calculated to require additional horse power (hp) for a total of 555 hp. This 555 hp value was greater than the.544 hp value listed in the Shutdown Board load listing in FSAR tables 8.3.1-1 and 8.3.1-2. The impeller clearance change also impacted the AFW pump composite curves in FSAR figures 10.4.7-6 and 10.4.7-7. The PER did not include or require a 50.59 evaluation / screening.

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

Pursuant to the provisions of 10 CFR 2.201, Tennessee Valley Authority is hereby required to submit a written statement 'or explanation to the U.S.

Nuclear Regulatory Commission. ATTN: Document Control Desk. Washington. D.C.

20555 with a copy to the Regional Administrator. Region II, and a copy to the )

NRC Resident Inspector at the Sequoyah facility, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should {

be clearly marked as a " Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or, if contested. the basis for disputing the violation or severity level. (2) the corrective steps that have been taken and the results achieved. (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response. If an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.

If you contest this enforcement action, you should also provide a copy of your response to the Director, Office of Enforcement, United States Nuclear

-Regulatory Commission. Washington, D.C. 20555-0001.

I Enclosure 1

NOV. 3 Because.your response will be placed in the NRC Public Document Room (PDR). to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed-in the PDR without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that'should be protected and a redacted copy of.your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you week to have withheld and provide in detail the bases

.for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy-or provide the

.information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of

. protection described in 10 CFR 73.21.

Dated at Atlanta, Georgia this 30th day of March 1998 Enclosure 1 L