IR 05000327/1989015
| ML20247B789 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 07/13/1989 |
| From: | Wilson B Office of Nuclear Reactor Regulation |
| To: | Kingsley O TENNESSEE VALLEY AUTHORITY |
| References | |
| NUDOCS 8907240209 | |
| Download: ML20247B789 (21) | |
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JULL 13.1989 h
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s Docket Nos. 50-327, 50-328.
License Nos. DPR-77, DPR-79 Mr. Oliver D. Kingsley, Jr.
. Senior Vice President, Nuclear Power-
Tennessee Valley Authority
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6N 38A Lookout P1 ace;
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1101 Market Street-Chattanooga, TN 37402-2801
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Dear Mr..Kingsley:
SUBJECT: -ENFORCEMENT CONFERENCE SUMMARY (NRC REPORT NOS. 327,328/89-15)
This letter refers" to the Enforcement Conference' held at.our request on June 29,-1989.
The' discussion at' this conference related to three issues;which indicate. apparent-weaknesses.in ;the implementation. of ' your programs.at
'q Sequoyah.
These issues lare the Residual Heat Removal (RHR) events' reported in'
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Licensee-Event Report (LER).89-011, the Boron Injection Tank-(BIT) recirculation issue, andL the Source Range / Intermediate' Range '(IR/SR) detector 1 relocation
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issue.
.. A summary, 'a list of attendees, and a copy of your handout are enclosed.
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It is our~ opinion that this 'me'eting was beneficial: and has provided a better understanding of the inspection findings, the enforcement issues,;and-the status of your ' corrective act' ions.. We are continuing our review of' these
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issues to determine the appropriate enforcement, action.
j In accordance with Section 2.790.of the, NRC.'s " Rules of Practice,".Part '2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosures will be placed in the NRC Public Document Room.
Shoulc you have any questions concerning this matter, please. contact us.
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Sincerely, i
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OriginalSigned By.
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BRUCE A. WILSON '
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Bruce AliWilson, Assistant Director
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forLInspection Programs
.l TVA Projects. Division
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Office of Nuclear Reactor Regulati'on
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i Enclosures:
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Enforcement Conferar;ce Summary 2.
List'of Attendees-
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Handout j
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8907240209 890713
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l PDR ADOCK 05000327
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Mr. Oliver D. Kingsley, Jr.
cc w/encls:
F. L. Moreadith, Vice President, Nuclear tng;iieering
M. O. Medford, Vice President and i
Nuclear Technical Director
County Judge, Hamilton County l
Courthouse Dr. Henry Myers, Science Advisor
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J. L. LaPoint, Site Director Sequoyah Nuclear Plant Manager, Nuclear Licensing and Regulatory Affairs M. Burzynski, Acting Site Licensing Manager
TVA Representative, Rockville
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Office General Counsel, TVA f
State of Tennessee bec w/encls:
D. M. Crutchfield, NRR l
B. D. Liaw, NRR 5. C. Black, NRR R. C. Pierson, NRR i
B. A. Wilson, NRR/RII
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.J. B. Brady, NRR/RII i
B. B. Desai, NRR/RII I
J. Rutberg, OGC l
NRC Resident Insoe: tor l
NRC Document Control Desk l
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ENCLOSURE 1 I
ENFORCEMENT CONFERENCE SUMMARY The NRC opened the meeting by expressing : concern that some Sequoyah licensed personnel told Sequoyah resident inspectors that the NRC should fix some of the Technical Specifications (TS) that are poorly written and hard to understand. This concern was not on the agenda for this enforcement conference but was identified to the Associate Director for Special Projects during a recent visit to the Sequoyah site.
Th's indicated that licensed personnel
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believe that the TS are NRC's TS and noc Sequoyah's TS. The NRC is concerned l
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with this attitude since TS and changes to them are prepared and submitted to the NRC for approval by the licensee.
Licensee management stated that they-were unaware of this attitude among their people and would investigate this i
concern.
l The NRC summarized the three issues that had occurred at Sequoyah.
Ttese issues being the RHR event which placed the system in an unanalyzed condition as reported in LER 89-11, remeval of the BIT from continuous recirculation to periodic recirculation and thereby placing it in a configuration that is outside the description in the FSAR, and the relocation of the SR/IR Detectors without resetting the intermediate range high flux bistables resulting in the i
trip functions being inoperable.
The NRC expressed concern that these issues j
represented failures in the licensee's implementation of 10 CFR 50.59, i
failures to follow procedures, and failures to comply with TS. The NRC stated j
that when viewed collectively these issues represent a significant. concern in f
relation to the control of licensed activities. Additionally, the NRC stated that these issues also indicate weaknesses 1.n the licensee's ennfiguration control program and the qualified reviewer process.
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TVA made a slide presentation on the three issues including a review of the sequence of events and conclusions for each event (see enclosure 3). TVA then presented the common weaknesses identified in these events and their programmatic corrective actions. TVA admitted the violations and acknowledged I
that weaknesses existed in their 10 CFR 50.59 program. They also stated that a lack of attention to detail, failure to follow procedures, and inadequate l
corrective actions led tc the three events.
Regarding the RHR issue, the NRC questioned why it took Mechanical Test ten days, efter they were alerted by the SOS that changing the position of valve j
63-172 would degrade cold leg injection flow, to conclude that Information Notice (IN) 87-01 was applicable in this particular case.
The NRC al so questioned whether the process to review Information Notices and other generic -
communications was in place TVA. replied that the process was in place.
j However, the reason Mechanical Test was slow in realizing that IN 87-01 was
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applicable was that the IN was not referenced in the procedure file.
l Concerning the BIT recirculation issue, the NRC asked the licensee tf l
a TS interpretation was used in making the decision to take the BIT out of j
l recirculation and if it was, whether that TS interpretation Lhad been reviewed
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l for technical adequacy and clarity as part of their corrective action for i
Violation 327, 328/88-20-03.
The licensee stated in their response to f
Violation 327, 338/88-20-03 that all TS interpretations had been reviewed for l
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Enclosure 1
technical clarity and adequacy a r.d that those needing changes had been corrected. The licensee stated that a TS interpretation had been involved in the BIT recirculation issue.
This interpretation had been reviewed as a part of the corrective action for Violation 327, 328/88-20-03. The licensee stated that all TS interpretations have now been taken out of the control room for review. All TS interpretations returned to the control room will have had a review pursuant to the requirements of 10 CFR 50.59. The licensee also stated that some TS interpretations would be incorporated in TS amendments as well as procedure upgrades.
TVA acknowledged that management initially believed the BIT was operable in toe once a week recirculation mode.
The licensee further acknowledged that a safety evaluation pursuant to the requirements of 10 CFR 50.59 was not performed until after concerns were raised by the NRC.
This late evaluation ch'd not adequately address the BIT volume / concentration / temperature require-ments when out of recirculation in light of the fact that boron dilution was occurring. TVA stated that this was a technical misjudgment.
The NRC empha-sized that changing the mode of operation of the BIT to a periodic recircula-tion mode without being able to justify BIT operability appeared to be an unreviewed safety questiun.
NRC questioned the licensee's conclusion outlined in the handout that the SR/IR detector event was caused nainly by administrative errors. TVA clarified that administrative errors occuared.
However, the root cause of the IR detector relocation event was the failure in the review process to identify and correct screening review deficiencies. In addition, when asked by the NRC if Operations had icoked at the procedure change that dictated the relocation, TVA replied that neither Operations nor Reactor Engineering were involved in this review.
The NRC expressed concern that the operators' sole source of monitoring the core neutron flux had been permanently adjusted without their knowledge or approval.
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TVA then discussed the programmatic corrective actions that they have planned to rectify deficiencies in the 10 CFR 50.59 review process. The new safety analysis form which has been added to the screening review form was brie /ly discussed.
- VA also discussed the establishment of the two levels of qualifications.
Le/el 1 is conposed of senior engineers with proper 10 CFR 50.59 training and level 2 is composed of engineers with integrated systems and l
accident analysis knowledge. The NRC asked the licensee how their new review t
i process was different from the previous one.
The licensee stated that the added sa'ety analysis form and the level 2 reviewers were the principal l
improvements.
The level 2 reviewers are expected to challenge the technical l
conclusion drawn by level I revi. ewers and not just concur administrative 1y.
l The licensee indicated that these programmatte improvements would e< sure the
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adequacy of future safety reviews.
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The NRC asked ' the licensee what corrective acticns they had plannea to check the adequacy of past safety reviews which could leed te future events. The NRC
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pointed out that two of the three issues currently being discussed were caused l
by reviews that were done in the past and that the new safety review process would only prevent fut;re relapses.
The licensee replied that they had not considered going back to examine past reviews for adequacy but would determine a nethod to accomplish this that will be acceptable to the NRC.
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' ENCLOSURE 2 LIST OF ATTENDEES i
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TVA l
J. Bynum
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J. LaPoint l
S. Crowe
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W. Elliot
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W. Lagergrr.n M. Medford
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H. Rogers l
M. Cooper
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P. Polk l
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NRC i
D. Crutchfield B. Liaw B. Wilson i
S. Black i
J. Donohew
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J. Brady i
K. Jenison i
P. Harmon T. P.,tella
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R. Borchardt
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B. Desai I
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ENCLOSDRE 3
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HANDOUT
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TVA/NRC ENFORCEMENT CONFERENCE SEQUOYAH NUCLEAR PLANT IE INSPECTION 89-15
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JUNE 29,1989
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SPECIFIC ISSUES H. R. ROGERS (1) RHR EVENT
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(2) REMOVING BIT FROM RECIRCULATION
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(3) SR/lR DETECTOR RELOCATION i
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PROGRAMMATIC ASSESSMENT J.. T. LAPOINT
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CORRECTIVE ACTIONS J. T. LAPOINT IV.
SUMMARY J.R.BYNUM
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I EVENT MATRIX i
BIT / SR/
RHR BAT IR 10 CFR 50.59 WEAKNESSES X
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PERSONNEL AWARENESS /
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KNOWLEDGE LIMITATIONS
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ATTENTION TO DETAIL /
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PROCEDURES
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CORRECTIVE ACTIONS lNADEQUATE X
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SEQUENCE OF EVENTS RHR EVENT 12-08-88
PROCEDURES REVISED WITH INCORRECT VALVE LINEUPS 02-24-89
DEFICIENT PROCEDURES USED DURING PERFORMANCE OF 03-01-89 PUMP TESTING 04-02-89
, SRO QUESTIONED SYSTEM VENTING PROCEDURE 04-12-89
NRC IE INFORMATION NOTICE 87-01 REVIEWED AND ADDITIONAL PROBLEMS IDENTIFIED; CAOR INITIATED ON DEFICIENT PUMP TESTING AND SYSTEM VENTING PROCEDURES 04-13-89
CAOR AND TEST DATA REVIEWED--NRC~ NOTIFIED OF TECNNICAL SPECIFICATION VIOLATION FROM PAST PERFORMANCES 04-15-89
VENTING PROCEDURE PERFORMED FOR UNIT 2 04-17-89
MECHANICAL TEST SUPERVISOR DIRECTED TO RESTRICT USE OF VENTING PROCEDURE.
CONTROLS OF PROCEDURE IMPLEMENTED WITHIN SECTION 04-20-89
VENTING PROCEDURE PERFORMED BY OPERATIONS.
ADMINISTRATIVE HOLD PLACED ON VENTING PROCEDURE.
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NRC NOTIFIED OF TECHNICAL SPECIFICATION VIOLATION i
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RHR EVENT CONCLUSIONS PERSONNEL INVOLVED IN PROCEDURE CHANGE WERE NOT
KNOWLEDGEABLE OF SON ACCIDENT ANALYSR ASSUMPTIONS AND FSAR WAS NOT CLEAR IEN 87-01 WAS NOT REFERENCED DURING
PROCEDURE CHANGE PREPARATION AND REVIEW SCREENING REVIEW DID NOT ADDRESS VALVE ALIGNMENT
CHANGE; REVIEW PROCESS DID NOT IDENTIFY INADEQUATE SCREENING REVIEW REVIEW PROCESS DID NOT IDENTIFY IMPACT TO BOTH
TRAINS AND RESULTING VIOLATION OF TECHNICAL SPE CONDITION ADVERSE TO QUALITY PROGRAM WAS:NOT
UTILIZED WHEN DEFICIENT PROCEDURE INITIALLY IDENT!
ADEQUATE CONTROLS WERE NOT IMPLEMENTED TO STOP
USE OF THE DEFICIENT PROCEDURE
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SE0VENCE OF EVENTS l
REMOVING BORON INJECTION TANK (BIT) FROM RECIRCULATION EVENT i
04-06-89
BIT INJECTION VALVE BACKLEAKAGE CAUSING DILUTION OF BIT AND BORIC ACID TANK (BAT).
Bli RECIRCULATION ISOLATED BASED UPON TECHNICAL SPECIFICATION INTERPRETATION
04-07-89
PROCEDURES DEVELOPED TO CONTROL BIT RECIRCULATION / ISOLATION AND T!.USHING OF INJECTION CHECK VALVE--SUPPORTING SAFliY EVALUATION INITIATED 04-08-89
PROCEDURE AND SAFETY EVALVATION PROVIDED TO ONSHIFT OPERATIONS PERSONNEL 04-10-89
MANAGEMENT CONSIDERED BIT OPERABLE; HOWEVER, AS I
RESULT OF NRC QUESTIONS, OPERATIONS DIRECTED TO MAINTAIN RECIRCULATION.
PROCESS DEVELOPED TO PREVENT RCS BACKLEAKAGE WITHOUT ISOLATING BIT
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BIT RECIRCULATION EVENT CONCLUSIONS l
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- ROOT CAUSE OF EVENT WAS TECHNICAL ERROR
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- SHIFT OPERATING SUPERVISOR CONSIDERED INITIAL AllGNMENT CHANGE ALLOWED WITHIN GUIDELINES OF ADMINISTRATIVE INSTRUCTION
- USE OF HANDWRITTEN PROCEDURE WAS NOT CORRECTLY IMPLEMENTED FOR SUBSEQUENT AllGNMENT CHANGES
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SEQUENCE OF EVENTS SR/lR DETECTOR RELOCATION 02-06-89
SOURCE RANGE DECLARED INOPERAGLE DUE TO NOISE PROBLEMS.
WESTINGHOUSE ONSITE TO ASSIST IN CORRECTIVE ACTIONS 03-02-89
ISSURD DESIGN CHANGE NOTICE TO REMOVE / ISOLATE GROUND STRAP ON NIS DETECTOR CABLES 03-10-89
REVISED PROCEDURES TO RELOCATE DETECTORS CONCURRENT WITH GROUND STRAP REMOVAL DETERMINATION MADE THAT RELOCATION OF DETECTORS WOULD NOT AFFECT DETECTOR OPERATION 03-20-89 a
GROUND STRAPS REMOVED AND DETECTORS RELOCATED 03-25-89
NOISE PR03LEM CLEARED--SR DECLARED OPERABLE 04-13-89
UNIT 2 CRITICAL--IR DETECTOR CURRENT APPEARED NORMAL 04-19-89
THREE REACTOR TRIPS AND SUBSEQUENT RESTARTS 04-30-89
REACTOR POWER AB0VE BISTABLE SETPOINTS 05-05-89
SOS NOTED IR BISTABLE LIGHTS NOT ENERGlZED--
INVESTIGATION PURSUED AND NRC NOTIFIED l
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SR/lR DETECTOR EVENT CONCLUSIONS
- SCREENING REVIEW CONTAINED ADMINISTRATIVE ERRORS AND INCORRECTLY STATED DETECTOR REPOSITIONING WOULD NOT ADVERSELY AFFECT DETECTOR OPERATION REVIEW PROCESS DID NOT IDENTIFY / CORRECT
SCREENING REVIEW DEFICIENCIES OPERATIONS AND REACTOR ENGINEERING PERSONNEL
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EVENT MATRIX l
BIT / SR/
RHR BAT IR 10 CFR 50.59 WEAKNESSES X
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PERSONNEL AWARENESS /
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KNOWLEDGE LIMITATIONS
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CORRECTIVE ACTIONS INADEQUATE X
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PROGRAMMATIC CORRECTIVE ACTIONS
- COMPLETED 10 CFR 50.59 PROGRAM ASSESSMENT AND INITIATED AN UPGRADF PLAN
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- INITIATED 10 CFR 50.59 AND 10R PROBLEM
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ASSESSMENT (MAY 6)
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- SENIOR MANAGEMENT ASSESSED RESULTS AND INITIATED COMPREHENSIVE ACTIONS (JUNE 2)
- INTERIM SAFETY ASSESSMENT CHECKLIST ESTABLISHED TO SUPPLEMENT SCREENING PROCESS (JUNE 2)
- SAFETY EVALUATION TASK FORCE ESTABLISHED (JUNE 5)
- DETAILED SAFETY REVIEW UPGRADE PLAN PRESENTED TO MANAGEMENT (JUNE 23)
- ESTABLISHED QUALIFICATIONS REVIEW BOARD TO
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APPROVE 50.59 PREPARER QUALIFICATIONS (JUNE 23)
- ESTABLISHED INTERIM LIST OF INDIVIDUALS WITH I
SYSTEMS AND ACCIDENT ANALYSIS KNOWLEDGE TO REVIEW SCREENING REVIEWS AND SAFETY EVALUATIONS (JUNE 27)
- CONDUCTED TRAINING ON CHECKLIST, ADDITIONAL REVIEW REQUIREMENTS, AND LESSONS LEARNED (JUNE 28)
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10 CFR 50.59 UPGRADE PLAN CONSOLIDATE SAFETY ASSESSMENT /10 CFR 50.59
EVALUATION INTO A SINGLE INTEGRATED SAFETY ASSESSMENT
-- SAFETY ASSESSMENT SUPPORTED BY CHECKLISTS
-- GRADED SAFETY ASSESSMENT
-- SAFETY EVALUATIONS /USODs ESTABLISH TWO LEVELS OF QUALIFICATIONS
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LEVEL i - SENIOR ENGIN.EERS WITH 50.59
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TRAINING
-- LEVEL 11 - LEVEL I WITH INTEGRATED SYSTEMS AND ACCIDENT ANALYSIS KNOWLEDGE REQUIRE REVIEW BY LEVEL 11 QUALIFIED INDIVIDUALS F00
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INTENT CHANGES TO NON-ADMINISTRATIVE PROCEDURES EaTABLISH QUALIFICATIONS REVIEW BOARD TO APPROVE
50.59 PREPARER QUALIFICATIONS e
INCORPORATE NSAC-125 GUIDANCE INTO STANDARD 6.1.3
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i PROGRAMMATIC CORRECTIVE ACTIONS
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- EMPHASIZED ATTENTION TO DETAll AND RESPONSIBILITIES FOR ENSURING OVALITY USING l
LESSONS LEARNED
- SITE DIRECTOR MESSAGE ISSUED AND EVENTS l
TRAINING CONDUCTED (JUNE 28)
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- MANAGEMENT FOCUS INCREASED ON RELATED
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l SUMMARY
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- TVA ADMITS THE VIOLATIONS OCCURRED l
- COMMON WEAKNESSES IDENTIFIED
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- EXTENSIVE LONG TERM CORRECTIVE ACTIONS HAVE BEEN INI7 LATED