ML20245J152

Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $50,000 from Insp on 880711-15,0822-23 & 1116-1201.Violations Noted:Feedwater Control Sys Failed to Perform as Described in FSAR

ML20245J152
Person / Time
Site:	Sequoyah
Issue date:	02/23/1989
From:	Crutchfield D NRC OFFICE OF SPECIAL PROJECTS
To:
Shared Package
ML20245J148	List: IR 05000327/1988035 ML20245J152
References
50-327-88-35, 50-327-88-55, 50-328-88-35, 50-328-88-55, EA-88-307, NUDOCS 8903060184
Download: ML20245J152 (3)

Text

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NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY Tennessee Valley Authority Docket Nos. 50-327 and 50-328 Sequoyah Units 1 and 2 License Nos. DPR-77 and DPR-79 EA 88-307 ,

i During the Nuclear Regulatory Commission (NRC) inspections conducted from July 11-15, August 22-23, and November 16 - December 1, 1988, violations of NRC requirements were identified. In accordance with the " General Statement of P,olicy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1988), the Nuclear Regulatory Commission proposes to impose a civil penalty pursuant to Section 234 of the Atomic Energy Act of 1954, as amended (Act),

42 U.S.C. 2282, and 10 CFR 2.205. The particular violations and associated civil penalty are set forth below I. 10 CFR 50.59, Changes, Tests, and Experiments, allows a licensee to make changes in a facility, as described in the safety analysis report, without prior Commissica approval, provided the change does not involve an unreviewed safety question. In part, a change is deemed to involve an unreviewed safety question if the probability of occurrence or the conse-quences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report may be increased, or if the margin of safety as defined in the basis for any technical specification is reduced.

Sequoyah Final Safety Analysis Report (FSAR), Sections 7.7 and 15.1, require, in part, that the feedwater control systems prevent the average reactor coolant temperature (Tavg) from dropping below the 547 F programmed no-load temperature following a reactor trip to ensure that adequate shutdown margin is maintained.

Contrary to the above, the feedwater control system failed to perform as described in the FSAR in that during the reactor trips of May 19, 23 and June 6, 1988 Tavg dropped below the 547 F programmed no-load temperature needed to assure adequate shutdown margin. This would result in an end-of-life condition for the subject cores which would have violated the Technical Specification limit for shutdown margin after a reactor trip, and increased the probability of occurrence and consequences of an accident previously evaluated and, therefore, an unreviewed safety question. There was no evaluation supporting this deviation from the FSAR pursuant to 10 CFR 50.59(b), ,

and this change was implemented without prior Commission approval as required l by 10 CFR 50.59(a).

II. 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, requires j that measures be established to assure that conditions adverse to quality such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and non-conformances are promptly identified and  !

corrected.

Contrary to the above, licensee corrective actions which included procedure /

I changes and operator training as outlined in TVA's October 5 and October 14, l 1988 letters to the NRC to prevent excessive post-trip reactor cooldowns i

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Notice of Violation were not adequately implemented as demonstrated by the excessive cooldown ,

following the November 18, 1988 Unit 1 reactor trip. This excessive cool- i '

down feedwater(AFWresulted,)in part,and control dueunclear to insufficient training instructions in manual for manual AFWauxiliary control in emergency operating procedure ES-01, Reactor Trip Response.

III. 10 CFR Part 50, Appendix B, Criterion V, Instructions, Drawings, and Procedures, requires that activities affecting quality shall be prescribed '

by documented instructions, orawings, or procedures of a type appropriate to the circumstances and shall be accomplished in accordance with those instructions, drawings, or proceoures. Instructions, drawings, or proce-dures shall include appropriate quantitative or qualitative acceptance criteria for determining that 1mportant activities have been satisfactorily accomplished.

Contrary to the above, AI-18. Reactor Post-Trip Review Procedure, established to identify and correct conditions adverse to quality occurring during a reactor trip, failed to provide sufficient guidance and acceptance criteria i to evaluate plant performance. The procedure did not compare actual post-trip parameters with FSAR values. Consequently, the post-trip reviews performed following the May 19, 23 and June 6, 1988 reactor trips were inadequate to identify and correct the reactor coolant system over cooling problem.

Collectively,)these (Supplement I . violations are categorized as a Severity Level III Problem Civil Penalty - $50,000 (assessed equally among the violations).

Pursuant to the provisions of 10 CFR 2.201, Tennessee Valley Authority is hereby required to submit a written statement or explanation to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, within 30 days of the date of the letter transmitting this Notice. This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each alleged violation: (1) admission or denial of the violation, (2) the reasons for the violation if admittea, (3) the corrective steps that have been taken andtheresultsachieved[5)thedatewhenfullcompliancewillbeachieved.(4) further violations, and the If correctiv an adequate reply is not received within the time specified in this Notice, an order may be issued to show cause why the license should not be modified, suspended, or revoked or why such other action as may be proper should not be ta ken. Consideration may be given to extending the response time for good cause shown. Under the authority of Section 182 of the Act, 42 U.S.C. 2232, this response shall be submitted under oath or affirmation. ,

Within the same time as provided for the response required above under 10 CFR 2.201, the licensee may pay the civil penalty by letter addressed to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, with a check, draft, or money order payable to the Treasurer of the United States in the amount of the civil penalty proposed above, or may protest imposition of the civil penalty in whole or in part by a written answer addressed to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission..Jhould the licensee fail to answer within the time specified, an order imposing the civil penalty will be issued. Should the licensee elect to file an answer %

accordance with 10 CFR 2.205 protesting the civil penalty, in whole or in part,

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i l-Notice of Violation such answer should be clearly marked as an " Answer to a Nutice of Violation" l and may: (1) deny the violation listed in-this Notice in whole or in part, (2) demonstrate extenuating circumstances, (3) show error in this Notice, or  !

In addition to (4) show other reasons why the penalty should not be imposed.

protesting the civil penalty, such answer may request remission or mitigation of the penalty.

In requesting mitigation of the proposed penalt Section V.B of 10 CFR Part 2, Appendix C (1988)y, the five factors Anyaddressed in

, should be addressed.  !'

l written answer in accoroance with 10 CFR 2.205 should be set forth separately from the statement or explanation in reply pursuant to 10 CFR 2.201 but may incorporate parts of the 10 CFR 2.201 reply by specific reference (e.g., citing page and. paragraph numbers) to avoid repetition. The attention of the licerisee is directed to the other provisions of 10 CFR 2.205 regarding the procedure for

, imposing a civil penalty.

Upon failure to pay the penalty due, which has been subsequently determined in accordance with the applicable provisions of 10 CFR 2.205, this matter may be referred to the Attorney General, and the penalty, unless compromised, remitted., or mitigated, may be collected by civil action pursuant to Section 234c of the Act, 42 U.S.C. 2282.

The responses to the Director, Office of Enforcement, noted above (Reply to a

. Notice of Violation, letter with payment of civil penalty, and Answer to a Notice of Violation) should be addressed to: Director, Office of Enforcenient, U.S. Nuclear Regulatory Commission, ATTN: Document. Control Desk, Washington, DC 20555, with a copy to the Associate Director for Special Projects, Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission and a copy to the NRC Resident inspector, at Sequoyah.

FOR THE NUCLEAR REGULATORY COMMISSION

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Dennis M. Crutchfield, ing Associate Director for Special Projects Office of Nuclear Reactor Regulation Dated at Rockville, Maryland this 23rdday of February 1989 J