ML20035D378

Notice of Violation & Proposed Imposition of Civil Penalties in Sum of $225,000.Violations Noted:Listed Procedures Inadequate Resulting in Mispositioning of Specified Valves for Time Periods Indicated

ML20035D378
Person / Time
Site:	Sequoyah
Issue date:	03/23/1993
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20035D373	List: IR 05000327/1992036 ML20035D378
References
EA-92-257, EA-93-034, EA-93-34, NUDOCS 9304130146
Download: ML20035D378 (5)

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NOTICE OF VIOLATION AND i

PROPOSED IMPOSITION OF CIVIL PENALTIES i

Tennessee Valley Authority Docket Nos.

50-327 and 50-328 Sequoyah Nuclear Plant License Nos.

DPR-77 and DPR-79 Units 1 and 2 EA 92-257 and EA 93-034

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t During NRC inspections conducted from November 29, 1992 through January 29, 1993, violations of NRC requirements were identified.

In accordance with the

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

10 CFR Part 2, Appendix C, 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 penalties are set forth below:

f 1.

Violations Associated With Control of Throttle Valve Position A.

Technical Specification 6.8.1 requires, in part, that written

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procedures be established, implemented and maintained for applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Quality Assurance Program Requirements, Revision 2, February 1978. Appendix A to Regulatory Guide 1.33 requires administrative procedures for safe operation of nuclear power i

plants, and specific procedures for conducting surveillance tests.

l Contrary to the above the following procedures were inadequate resulting in the mispositioning of the specified valves for the i

time periods indicated:

j 1.

Surveillance Instruction 0-SI-0PS-067-682.M, ERCW FLOW BALANCE VALVE POSITION VERIFICATION, Revision 2, implements configuration control for the position of throttled valves in the Essential Raw Cooling Water (ERCW) system.

The procedure was inadequate in that it did not provide proper instructions for accounting for slack travel in valve hand-operators which resulted in the Containment Spray Heat Exchanger ERCW throttle valves 1-67-537A and B being improperly positioned from November 30, 1991, through December 16, 1992.

i 2.

Surveillance Instruction 2-SI-0PS-070-032.A, COMPONENT COOLING WATER VALVES POSITION VERIFICATION TRAIN A, Revision 1, implements configuration control for the position of throttled valves in the Component Cooling Water System (CCS).

The procedure was inadequate in that it did not provide proper instructions for accounting for slack travel in the valve hand-operator which resulted in the Residual Heat Removal (RHR) Heat Exchanger CCS throttle valve 2-70--

546A being improperly positioned from approximately March 1, 1989, through December 19, 1992.

3 9304130146 930323 PDR ADDCK 05000327

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B.

Technical Specification 6.8.1 requires, in part, that written procedures be established, implemented and maintained for applicable procedures recommended in Appendix A of Regulatory l

Guide 1.33, Quality Assurance Program Requirements, Revision 2, February 1978.

Appendix A to Regulatory Guide 1.33 requires i

administrative procedures for safe operation of nuclear power plants, and specific procedures for conducting surveillance tests.

Contrary to the above, procedure SI-566, ERCW FLOW VERIFICATION TEST - UNITS 0, 1, AND 2, Revision 22 was inadequate in that, it did not include a requirement to verify that newly established valve throttle positions were i

correctly transferred to procedure 0-SI-0PS-067-682.M.

Seven examples of improperly transferred valve positions were identified.

This is a Severity Level III Problem (Supplement I).

Civil Penalty - $50,000.

I II.

Violations Associated With Control of RWST Temperature i

A.

Technical Specification 6.8.1 requires, in part, that written procedures be established, implemented and maintained for j

applicable procedures recommended in Appendix A of Regulatory i

Guide 1.33, Quality Assurance Program Requirements, Revision 2, February 1978. Appendix A to Regulatory Guide 1.33 requires I

administrative procedures for safe operation of nuclear power plants, and specific procedures for conducting surveillance tests.

l Technical Specification (TS) 3.5.5, requires that the RWST be operable in Modes 1, 2, 3, and 4 and, in part, for the RWST to be operable, solution temperature must be maintained above 60 degrees F.

The action requirement for the TS r

requires that with the RWST inoperable it must be restored to operable status withia one hour or be in hot standby i

within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

j Contrary to the above, with the Unit 2 in Mode 1 the following

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procedures were either inadequate or not followed on December 23 i

and 24, 1992 resulting in the Unit 2 RWST solution temperature being below the TS minimum limit for approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> without the plant being placed in hot standby:

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1.

Surveillance Instruction 2-SI-SXP-072-001.B, CONTAINMENT SPRAY PUMP 28-B QUARTERLY OPERABILITY TEST, Revision 0, was l

inadequate in that no precautions or limitations were identified with regard to system interactions. As a result, I

performance of the Surveillance Instruction on December 23, 1992, in conjunction with coincident ERCW testing cooled the Unit 2 RWST solution below the TS minimum temperature limit.

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Notice of Violation 3

2.

Site Standard Practice SSP-12.1, CONDUCT OF OPERATIONS, i

Revision 2, establishes requirements for control of equipment and system status, and requires operators to maintain cognizance of operational status of equipment and systems. This procedure was not followed between i

approximately 5:00 a.m. on December 23, 1992, and 3:00 a.m.

on December 24, 1992, in that three operating shifts failed to identify the below minimum required solution temperature for the RWST despite performing shift turnovers and monitoring ongoing test evolutions.

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

Civil Penalty - $75,000 111.

Violations Associated With the December 31. 1992, Dual Unit Trip Recoverv A.

Technical Specification 6.8.1 requires, in part, that written procedures be established, implemented and maintained for applicable procedures recommended in Appendix A of Regulatory i

Guide 1.33, Quality Assurance Program Requirements, Revision 2, j

February 1978. Appendix A to Regulatory Guide 1.33 requires administrative procedures for the safe operation of nuclear power plants, and procedures for abnormal, offnormal, or alarm conditions.

Contrary to the above, the following procedures were either not followed or were inadequate in that the following examples resulted in the degradation of the Unit 2 high head safety injection capability for approximately one minute, increasing the probability of a reactor coolant pump seal loss-of-coolant-accident.

i 1.

Abnormal Operating Instruction (A01) 34, EMERGENCY BORAT10N, l

Revision 7, provides the necessary actions to initiate emergency boration when the reactor is shut down and directed by pracedure. On December 31, 1992, Unit 2 operators failed to follow the requirements of A01-34, in that, when reactor coolant system temperature dropped to 537 degrees F, the operators used a normal boration flowpath, rather than the emergency boration flowpath required by the l

A01.

2.

A01-34, EMERGENCY BORATION, Revision 7, provides instructions to operators to adequately realign and restore components utilized in normal charging operations and i

boration flowpaths.

These include precise steps to return the centrifugal charging pump (CCP) suction to the volume control tank (VCT) from the RWST source. On December 31, 1992, Unit 2 operators failed to follow the requirements of 4

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1 Notice of Violation 4

l A01-34 during restoration of the VCT as the suction to the operating CCP as described in the following examples.

a.

RWST suction valve handswitches, 2-HS-62-135 and 2-HS-62-136, were not pulled to the A-P AUTO position i

after manipulation as required. This resulted in the disabling of the process function to automatically open the RWST suction supply valves upon a closure of the VCT suction supply valves.

b.

During VCT/RWST valve manipulations the operator inadvertently closed the VCT outlet suction supply valves, 2-LCV-62-132 and 2-LCV-62-133. At the time, these valves were providing the suction supply to the operating CCP.

3.

Sequoyah Nuclear Plant Final Safety Analysis Report (FSAR)

Section 9.2.1.3.3, Thermal Barrier Booster Pumps, states that the purpose of the thermal barrier booster pumps (TBBP) is to provide the additional head necessary to overcome high head loss through the thermal barriers.

Each of the four 3

pump motors receives ' electric power from normal or emergency l

sources and is connected to one of the four shutdown boards.

Tennessee Valley Authority Design Criteria for the Component Cooling Water System, SQN-DC-V-13.9.9, specifies that the TBBPs (two per unit) shall be loaded to the diesel-generators simultaneously with the Component Cooling System pumps after a loss of offsite power (LOOSP).

Placement of the control room TBBP handswitches in the A-P AUTO position i

ensures the above requirements are met.

System Operating Instructions (501) 1-50-70-1, Component Cooling Water System'- A Train, Revision 3, and 2-50-70-1, Component Cooling Water System - A Train, Revision 1, provides the procedure requirements for controlling the TBBP 3

control room handswitch positions, but were inadequate, in that, the procedure required the subject handswitches to be in the A-AUTO in lieu of the A-P AUTO position. This resulted in a failure of the TBBPs on both units to automatically restart as required, during the December 31, 1992 LOOSP event.

t 4.

Site Standard Practice Procedure SSP-12.9, Incident Investigations and Root Cause Analysis, provides detailed guidance on post-trip review requirements, including the requirement to assure that plant equipment operated as designed to mitigate the event, and identify the true root cause of the event such that it can be corrected prior to resumption of power operation.

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Notice of Violation 5

The post trip review performed pertaining to the trip of Sequoyah Unit 2 on December 31, 1992, was inadequate in that the personnel performing the review did not analyze tank level chart recorder traces to verify the cause of the volume control tank outlet valves 2-LCV-62-132 and 133 closing after having been opened by the operators. The personnel assumed the level in the VCT had decreased below the low level isolation setpoint, when in fact, it had not.

B.

10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, requires in part, that measures be established to assure that conditions adverse to quality such as failures, malfunctions, and deficiencies be promptly identified and corrected.

Contrary to the above, a condition adverse to quality existed since March 14, 1992, when the hand switch for the 2A-A TBBP was recognized as being misaligned during the performance of test procedure 2-SI-0PS-082-026.A, " Loss of Offsite Power with Safety Injection-DG-2A-A Containment Isolation Test", and the test resolution of the test deficiency did not correct the condition.

Consequently, the hand switches for all four of the TBBPs (2 per unit) remained inappropriately aligned, such that the TBBPs would not automatically restart following a momentary loss of offsite power.

This condition adverse to quality existed until the December 31, 1992, event.

i This is a Severity Level III Problem (Supplement I).

Civil Penalty - $100,000.

Pursuant to the provisions of 10 CFR 2.201, Tennessee Valley Authority (Licensee) is hereby required to submit a written statement or explanation to i

the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, within 30 days of the date of this Notice of Violation and Proposed Imposition j

of Civil Penalties (Notice).

This reply should be clearly marked as a " Reply i

to a Notice of Violation" and should include for each alleged violation:

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(1) admission or denial of the alleged violation, (2) the reasons for the violation if admitted, and if denied, the reasons why, (3) the corrective 9

J steps that have been taken and the results achieved, (4) the corrective steps i

that will be taken to avoid further violations, and (5) the date when full l

compliance will be achieved.

If an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be i

l 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.

Consideration may be given to extending the response time for good cause shown.

Under the l

authority of Section 182 of the Act, 42 U.S.C. 2232, this response shall be j

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 penalties by letter addressed to i

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the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, with a check, raft, money order, or electronic transfer payable to the Treasurer of the laited States in the amount of the civil penalties proposed above, or l

may protest imposition of the civil penalties in whole or in part, by a written answer addressed to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission.

Should the Licensee fail to answer within the time specified, an order imposing the civil penalties will be issued. Should the l

Licensee elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalties, in whole or in part, such answer should be clearly marked as an " Answer to a Notice of Violation" and may:

(1) deny the violations listed in this Notice, in whole or in part, (2) demonstrate extenuating I

circumstances, (3) show error in this Notice, or (4) show other reasons why the penalties should not be imposed.

In addition to protesting the civil penalties in whole or in part, such answer may request remission or mitigation of the penalties.

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In requesting mitigation of the proposed penalties, the factors addressed in l

Section VI.B.2 of 10 CFR Part 2, Appendix C (57 FR 5791, February 18,1992),

should be addressed. Any written answer in accordance with 10 CFR 2.205 should be set forth separately from the statement or explanation in reply l

pur.suant to 10 CFR 2.201, but may incorporate parts of the 10 CFR 2.201 reply i

by specific reference (e.g., citing page and paragraph numbers) to avoid repetition.

The attention of the Licensee is directed to the other provisions i

of 10 CFR 2.205 regarding the procedure for imposing a civil penalty.

Upon failure to pay any civil penalties due which subsequently has'been i

determined in accordance with the applicable provisions of 10 CFR 2.205, this matter may be referred to the Attorney General, and the penalties, unless compromised, remitted, or mitigated, may be collected by civil action pursuant j

to Section 234(c) of the Act, 42 U.S.C. 2282(c).

The response noted abe.

(Reply to Notice of Violation, letter with payment of civil penalties, and Answer to a Notice of Violation) should be addressed to: Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the l

Regional Administrator, U.S. Nuclear Regulatory Commission, Region II, Atlanta, Georgia, and a copy to the NRC Resident Inspector at the Sequoyah Nuclear Plant.

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t Atlanta, Georgia Dated a/ day of March 1993 this #d I

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