ML20042G977
| ML20042G977 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 05/09/1990 |
| From: | Medford M TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9005160362 | |
| Download: ML20042G977 (14) | |
Text
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i T'ENN ESSEE : VALLEY AUTHORITYL
' CHATTANOOGA' TENNESSEE 37401 !
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6N'38A. Lookout Place
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MAY 091990
)
i U.S. Nuclear Regulatory Commission j
ATTN: Document Control Desk-7 Washington, D,C.
20555 r
-Gentlemen:
Inithe Matter of:
)~
Docket Nos. 50-327
- TennesseeValley(Authority.
)
50-328; r
SEQUOYAH NUCLEAR' PLANT (SQN). NRC' INSPECTION REPORT NOS. 50-327, 328/90-0l?--
RESPONSE'AND ANSWER.TO NOTICE OF VIOLATION (NOV) AND PROPOSED IMPOSITION OF-
-CIVIL PENALTY' t
. This letter, including enclosures, is submitted to NRC in ascordancetwith-(
10 CFR 2.201: and 2.205 in response to NRC's letter of. AprilL12,1990,- which transmitted the-subject NOV and proposed. imposition'of civil penalty regarding residual'heatiremoval _(RHR). pump deadheadingvissues. : Pursuant'to-10.CFR 2.201, Enclosure':1 provides TVA's response to the NOV.'
Similarly,-
pursuant to 10:CFR-2'.205,- Enclosure 2lprovides"TVA's: answer to)the proposed imposition of civil penalty.
I TVA acknowledges that'the. violations cited in the subject..NOV occurred.
Accordingly, Encloture 1 provides TVA's-discussion of the violations, root causes, and corrective act'lons.
i As discussed during the enforcement conference held February 14,I l990Fand as-
. described in Licensee Event Report (LER) 50-327/89031LRevision.1,'TVADhas-1 implemented extensive corrective. actions that address the causes'of.these:
violations, Many of these corrective actions were already in place or underway to. address key programmatic weaknesses at:the' time'..the R!lR pump-e problem was discovered.
j Further, as discussed in Enclosure 2, Inspection. Report No.- 50-327, 328/90-01' identifies November 29, 1989, as the-date when the NRC resident-inspector
'l first identified the RHR pu a problem. -Before this date, TVA had discovered data suggesting the problem and was in the process of determining the-1 1
significance of the data.
IVA's actions to address'this issue both preceded and occurred in parallel-to NRC'.s involvement leading up to full.
,l identification.and confirmation of the RHR pump problem.' Given the important roles played by both TVA and NRC personnel, TVA questions the escalation of-i the proposed base civil penalty based on NRC identification of the problem.
Accordingly, for the reasons given above and further detailed in the enclosures, and after careful consideration of the NRC enforcement policy
. outlined in110 CFR, Part 2, Appendix C, TVA respectfully. requests NRC to reconsider the escalation of the proposed base civil penalty based on NRC idcitification. As detailed in Enclosure 2 to this submittel, TVA believes thet this event resulted from past programmatic weaknesses that hed been 9'
9005160362 900509
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-U.S. Nuclear' Regulatory Commission:
MAY:091980L previously-recognized and for which extensive. corrective actions had already been implemented or, initiated.
TVA further believes thatithe condition was-discovered as-a result of ongoing-programmatic-enhancements-in the Systems Engineering organization.
InTlight;of this perspective, TVA believes that--
J escalation of.the. civil penalty as proposed.15 unnecessary to emphasize-the-
?-d significanccLof-past problemscor to emphasize-the need for..TVA to; aggressively-il identify and correct l problems.
~
If you have any; questions concerning th1s submittal,;please do not hesitate toL telephone'me at?(615)-751-4776...
y
.Very truly.yours, l
-TENNESSEE VALLEY AUTHORITY Mark 0. Medford, Vice, President Nuclear Technology' andL Licensing 1
i
)
Sworn to and subscribed before' me' i
t s da of
, ~ 1990 -
Notary Public
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My Commission Expires n/V/91
.l i
Enclosures
. i cc: Ms. S. C. Black, Assistant Director (Enclosures) for Projects TVA Projects Division U.S. Nuclear Regulatory-Commission l!
One White Flint, North 11555 Rockville Pike j
Rockville, Maryland 20852 j
NRC Resident Inspector (Enclosures)
Sequoyah Nuclear Plant
{
2600 Igou Ferry Road
-l Soddy Daisy, Tennessee 37379 l
Mr. B. A. H11 son, Assistant Director (Enclosures) o for Inspection Programs TVA Projects Division U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 i
-j
s 1
3 n-N ENCLOSURE 1-
- RESPONSE TO NRC INSPECTION REPORT-NOS. 50-327/90-01 AND 50-328/90-01 D. M. CRUTCHFIELD'S LETTER T0.0 D. KINGSLEY,1JR.',1 DATED APRIL 12, 1990
' Violation 50-327, 328/90-01-03 "A.
10 CFR.Part 50,. Appendix B, Critericn XVI,' Corrective Action, requires'ini part,.that measures shall.be established to assure that" conditions?
. adverse t_o: quality, such as failures,ideviations'and nonconformances are-cpromptly identified and corrected.
4 NRC-Bulletin 88-04,.-Potential Safety Related: Pump; Loss,41ssued May 5,11988, alerted' licensees'to'a significant condition adversesto.
quality that involved the potential-forlthe.deadheading of-'one:or more:
. pumps in safety-related systems that have~a-mlniflow line common to'two or more pumps -or._other piping configurations -that:dolnot preclude pump-to-pump interaction:dur.ing.miniflow operation.-
Licensee engineering calculation DNE:SQN-74-D053, dated July 22,~' 1988, determined that RHR pump damageLwould occur for a pump;that was run deadheaded for' greater than 11-minutes.
i 10 CFR 50.9 requires, in.part,.that'information_provided to the>
Commission' byLa licensee, be complete and accuratetin' all. materlalz s
respects.
l Licensee letter to the NRC in response to NRC Bulletin 88-04, dated
' August 2, 1988;2 stated!that;the potential existed for deadheading a l
safety-related.RHR pump due to pump-to-pump interaction under mlniflow 4
conditions when the head differential:between the pumps exceeded y
11 pounds per square inch (psi).
The letter also stated that recent; i
surveillance test data demonstrated that the-head differential: between the two RHR pumps was less than 11. psi, ensuring a'minimumLflow of L
100 gallons per minute to allow' pump operation for up to'20 minutes without requiring operator intervention.
Contrary to the above, as of December 5, 1989, the licensee fallod to adequately identify and correct a-significant condition adverse-to.
quality regarding the potential for safety-related RHR pump. damage from j
deadheading due to pump-to-pump interaction during mlniflow conditions'in.
i that:
1.
No action had been taken to preclude damage'to'a RHR pump should i
deadheading develop due to pump-to-pump interaction under mlniflow-conditions, until a special test demonstrated that the Unit 1 RHR H
pumps deadheaded under those conditions on December 5, 1989.
2.
The licensee's evaluation of Unit 1 RHR pump surveillance test data, referenced in their' August 2, 1988 letter to the NRC, was inadequate to identify that an RHR pump was likely to-deadhead due to pump-to-pump interaction,-as the majo ity~of the test data from July 1987 through August 1988 indicated that the head differential.
pressure between the pumps exceeded 11 ps1. 'As.a result inaccurate information was provided to the Commission ontAugust 2, 1988."
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- -Admission or' Dental of'the~Alleied Violation'(Violations A.~1 and A.2)
TVA admits the violation.
. Reason ~for the' Violation (Viol'ations'A.1-and A.2) 7 The cause of'this. violation w3s an inadequate evaluation of and response to NRC Bulletin 88-04 in:1988.
Albrief review of:the event chronology.will
- 1llustrate this cause.
._ During TVA's evaluation-of the bull _etiii, -the potenttal Lfor RHR pump-to-ptimp; interaction was recognized, and an' analysis was performed by_ Nuclear Engineering (NE) personnel-in Knoxville, Tennessee.
Thisievaluation showed:
.that pump,deadheading could occur;if the head difference between the residual d
heat removal: (RHR) pumps exceeded llEpounds'per square. inch differential-
-(psid).
However, based on'an evaluation of the most recent pump test; data' 3
(second quarter:1988), the de.adheading problem was thought-not to exist on the RHR pumps at that time. Other historical pump test data was not. considered
'during this evaluation, This oversight was the" result of. Inadequate coordination and communication 1between Knoxville NE and knowledgeable' site-organizations.
To provide for continued monitoring of thezRHR~' pumps,J a surveillance test-program was set'up to be performed during each refueling outage.
The surveillance test program averaged RHR pump performance data collected ~
during routine testing.over-the operating cycle and specified an 8-psid-
. acceptance criterion as the' threshold value above which an evaluation of-the 4
data by.NE'would be required.
The routine test data was from tests performed on each RHR pump individually. The tests were not performed with both RHR pumps running at the same time and were not performed on'both_RHR pumps on the same day. Consequently, the RHR surveillance test program did.not contain a i
. ready mechanism to signal developing pump-to-pump ~ interaction problems between -
s refueling outages.
The first performances of the surveillance test program were scheduled for the Unit 2 Cycle 3 and Unit 1 Cycle 4 outages.
.In preparation for the Unit 1 Cycle 4. outage, the RHR system engineer reviewed the Unit 1 surveillance test procedure during the week of November 20, 1989.
The system engineer determined that the 8-psid acceptance' criterion would not be met based on existing Unit 1 test data.
He nottfled his supervisor of-the
^
situation on November :22,1989. The system engineer also notified NE of the-situation by correspondence dated November 27, 1989.
At this point, the.
system engineer was not familiar with.the ~ problems identified in Bulletin 88-04 and did not' recognize the full significance of not meetin.g the-j 8-psid acceptance criterlon.
1 In parallel with but unrelated to,the above-described system engineer's actions, routine quarterly American Society of~ Mechanical Engineers (ASME) pump testing was conducted on Unit 2 on November 28, 1989. During this 3
testing, the 2A-A RHR pump exceeded the developed head acceptance ci1teria specified in the test procedure. Additional testing was performed, but the pump still exceeded the-pump suction-to-discharge differential pr essure requirements.
The pump was determined to be acceptable and operable in accordance with ASME,Section XI, pump testing requirements-on 1
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. November 29, 1989.
However, because NE was concerned with the' potential of a
- pump-to-pump interaction from.the increased head.on the 2A-A pump, an engineering evaluation was performed. The results ofj that evaluation i
demonstrated that the.dtfferential pressure between A and B train pumps-did-not exceed the 11-psid limit established forLthe NRC' bulletin response.
As.a; result of:the disposition of the. Unit.2 pump problem, the NRC residenti.
-inspector. questioned the, system engineering supervisor.on November 30. 1989, a
about the Unit 1.RHR pump-to-pumpLdifferential' head data.
The:NRC inspector.
was informed that NE wast evaluating the1 Unit I data based on the November-27 notification by ths, system engineer.
In parallel,LTechnical Support was:
< further evaluating the Unit 1: RHR data in which considerable scatter had ' beer..
. observed; The data scatter, while not significant for evaluating differential'.
. pressure across>the pump,1did cause the system engineer to question the validtty of-the data'for use in determining. pump-to-pump differential pressures.
Review and evaluation of-the Unit l'RHR puap data from quartsrly testing continued onjDecember-1,-1989..Two basic.' problems were-noted with the data.
First, _when data on a single. pump was compared from one run to the'next, there was sign _1ficant data scatter.
RHR Pump 11A-A-~showed up to'14'psid.between-.
performances with-an average of approximately 7 psid.
RHR-Pump 1B-B showed up to 11 psid-with an average of 4 psid.
Second,- -when.compari ng < s i ngl e-pol n t.
-j data over the-time period followinglthe Unit 1 Cycle 3 refueling outage, seven-1 instances were observed when the pump-to-pump data would pass theyll-psid.
criteria and 10 other instances where it would not. When.the. data points since the last refueling were averaged, the computed value was between 12:and J
13 psid as indicated in the memorandum to NE from.the system engineer dated-November 27, 1989; By the end of the day of' December-1. Technical Support was l
not able to reach a firm conclusion because of ' doubts about both the accuracy of the data and the averaging methods used to evaluate deadheading. - To' resolve'these doubts, a special surveillance' test was proposed to' test both.
RHR pumps:at the same time to obtain a direct reading of: pump-to-pump differential pressure. ^0perations. management reviewed the~ system operating instruction for RHR and determined that both' pumps could be run in parallel in 1
accordance with that procedure. Operation of.both pumps in parallel was-
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conducted on the evening cf December 5,1989, and the Unit 1 -RHR deadheading
'l problem was confirmed.
In' summary,.the cause of this violation was an inadequate program review of
=the pump' data in preparing the response-to NRC Bulletin 88-04.
This' bulletin response contained a conclusion that was correctly drawn from the data used as
)
its basis, but that was not predicated on'a sufficient-data base, i.e., only the most recent data pair was utilized rather=than all previous data.
t Corrective Steps That Have Been Taken and Results Achieved '(Violations A.1 I
and-A.2)
~
Immediate corrective actions included placing the 18-B RHR pump lhandswitch'in the pull-to-lock position to ensure one train'of emergency core. cooling system (ECCS) was operable.
Subsequent corrective actions included: consulting with Westinghouse Electric Corporation and then revising Emergency-Instruction E-0,
" Reactor Trip or Safety Injection," to ascertain if one RHR pump should be' stopped. This revision resulted in the'following change to the procedure:
If
.the reactor coolant system (RCS) pressure is greater than 180 pounds per
'h e
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.3 3
, l square; inch gauge,and both RHR' pumps are: running; then one' RHR pump is' stopped -
and placed in standby. -Because.this action ensures RHR. pump operability, 1t:
eliminated the need for future evaluation of the pump' data for indications of deadheading. _ Consequently, that surveillance test program was cancelled. ;In.
1
' addition, the RHR system l operating instruction has'been revised'to ensure-that:
the RHR; pumps are not run-in: parallel:on'miniflow for'greateri than 10 minutes.
As-a result of confirmation of;the.RHR pump deadheading condition,'TVA also'.
reevaluated its response lto NRC Bulletin 88-04, A revised response was-
- submitted to NRC on' March 15, 1990,7 describing the. revised short-term-corrective actions (as described'above) and long-term correctivefactions, The'
-long-term correctiveraction pertalning1to the1RHR pumps is to install check valves in the discharge piping downstream.of-the miniflow lineibranch.
Thls>
measure will-preclude the possibility of. pump-to-pump interaction. LAsl committed in the revised bulletin response, this installation 1will be complete 1
before' start-up from the' Cycle 5 refueling' outage for each unit.- Installation a
of the check valves will alleviate the need for one of;the RHR pumps to:be?
j stopped, as currently required by Emergency Instruction E-0.
Following-identification of the' inadequate' Bulletin 88-04-response, TVA; conducted a review of the 1987-1989 SQN bulletin. responses and records'.
The 1
conclusion reached was that the responses.are appropriateLand valid ~withithis single exception,Bulletin 88-04.
The review also established that condition adverse to quality reports (CAQRs) were written when' deficiencies were identified, with'the exception of a single prerestart item that was. tracked as a specific nuclear performance plan restart item, rather thania CAQR.
3 TVA also reviewed the ASME,Section XI, program following this event to
~
determine the cause for recent testing problems, including the'RHR pump test-L data scatter mentioned previously.
TVA. concluded that the program is in overall compliance with requirements; however,'severalorecommendations were i
made regarding (1) the use of-snubbers on. test instruments-to reduce data q
scatter, (2) the use of dedicated test equipment for ASME,Section XI, testing, and (3) the consideration to upgrade Installed ~1nstrumentation as an l'
alternative to test equipment.
The NRC senior resident inspector reviewed this report during routine monthly activities in January 1990. As reported in the associated exit meeting and subsequent inspection report,-no specific safety or technical issues were identified.
l Prior to discovery of this event, TVA had. instituted major programmatic changes that improved the methods used to manage significant licensing issues, such as responses to NRC bulletins.
The Licensing project management system l
was instituted in January '1989.
In particular, Site Licensing now has the L
lead responsibility for evaluation of and responses'.to NRC bulletins. A L
licensing project manager (LPM) is assigned to each issue and is responsibile l-for developing detailed acticn plans defining tasks, scope, schedules, and l-responsibilities.
Additionally, the LPM ensures that the appropriate a
l Individuals, disciplines, and organizations are involved and are assigned l'
clearly defined responsibilities regarding plan development and issue l
resolution.
Information provided by the various organizations'1s handled through the formal licensing information request process that Las the necessary controls to ensure completeness and accuracy.
The LPM initiates and drives bulletin investigations and evaluations.
Specific CAQRs are written o
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-5.
[
. when: deficiencies are identified.
In summary, this change, init1ated after.
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the: Bulletin 88-04 response but before this enforcement action, ensuresLthat
.the appropriate parties are involved 11n evaluating licensing issues and:
developing responses.
This;new process addresses the root cause.of the-violation.
I Several other programmatic changes that are having a positive. impact on the resolution of'Itcensing issues had been made at SQN priorJto discovery;of this.
1 event. For example, the SQN NE Project Engineer now has the sole responsibility for and control of engineering. design' activities at SQN. ;In.
addition, 90 percent of all-engineering is now done at the SQN siteL Technical Support is now the focal point at the plant for system-related.
i problems..The close proximity and direct involvement of.these' organizations-1 are contributing to a more systematic and thorough: evaluation of plant ~
j problems.
j l;j In addition, major organization and management changes were made to the' Technical Support group during the June to October:1989 timeframe to. Improve o
performance. A new Technical Support manager with experience in managing a successful system engineering-. program was hired from.outside-TVA,':and the-Institute of Nuclear Power Operations was requested to perform a peer j
evaluation of the Technical Support area during the. November plantL
- q evaluation. A complete assessment of Technical Support-was recently :
completed, and needed improvements are bei,ng; implemented.
1 s
TVA is also actively recruiting experienced-system engineers'and has-established a lead engineer concept to best utilize existing. strengths.. An s
evaluation of existing supervisors and engineers ts-also being-conducted.
In addition, the key elements of system engineering,(ownership of problems,.
leadership in problem resolution, sensitivity-to. regulatory and operational-aspects, and focus on operability and problem solving)~ will continue to:be reinforced through direct involvement of senior plant and' Technical Support i
management. These changes are intended to further strengthen the system j
engineering-capabilities at SQN.
In addition, in February 1990, TVA conducted a-review of'two previous nuclear i
experience review (NER) items (NRC Information Notice 87-59 and a Westinghouse letter issued on October and November 1937).
These items discussed two poter,tlal problems with the RHR system:
deadheading of pumps with common miniflow= lines and adequate mlniflow capacity for single-pump operation, l.ater, Westinghouse correspondence (November 1987) concluded that the earlier information was not applicable to SQN bet ause of-separatenRHR mlniflow lines and the hydraulic isolation of other ECC5 pumps with. common miniflow' lines j
through the use of separate flow restricting orifices for.each pump.
TVA's 1
evaluation of these items led to the same conclusion and also confirmed the j
adequacy of mlniflow capacity for single RHR pump operation.
The pump-to-pump j
interaction discussed in Bulletin 88-04 was not sufficiently defined until receipt of another Westinghouse letter in late May 1988, which described the-interaction and noted that previous conclusions regarding pump deadheading
{
potential were no longer correct. As a result, the.RHR pumps were included in the evaluation for Bulletin 28-04 after receipt of the Westinghouse letter.
- li
- Hhile the NER program was not directly involved in this problem, several
' changes to improve the NER program were made in June 1989. A dedicated and l
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! expanded staff'is now onsite at TVA' plants. -The experience and qualification l
of personnel in the NER program have-been upgraded. Weekly reviews are j
conducted by conference: calls between the. sites and corporate _NER groups to:
j
-identify significant safety _ issues.
The new organization.and staffing provide improved capability to recognize and'act on CAQRs'and potential significant.
j safety issues.
In particular, items: that are -identified as-potentially safety significant-are designated as immediate attention, items,and hand carried to-the appropriate _ principal managers for evaluation.
TheLline-managers. complete-
- the evaluation-and make operability and immediate'reportability".
determinations.
Items that meet the criteria are written as;CAQRs and are d
reviewed by the Management; Review Committee.
j 1
Recent management actions have been taken to change personnel attitudes'about i
problem reporting and-to encourage problem identification to' supervisors and j
management. Two site dispatches were' issued _from the Vice President, Nuclear
-F Power Production, statingLthese expectations. This: topic was also emphasizedL in the:recent Site 40lrector's quarterly meetings: held with over 1,300_-SQN i
employeesf(16 meetings).,The CAQR Management Review Committee-has'been restructured to' include senior site management to, assess theLextent.to which the message regarding problem reporting is-being-understood,'to ensure prompt-corrective actions-to identified problems, and1 to ensure quick resolution >of potential, problems. A-multisite; task force.was formed in early November 1989:
i to evaluate _the implementation'and-structure of theiproblem identification.
3 process and recommend improvements.
The ViceLPresident, Nuclear; Power.
Production, was briefed on the team recommendations in January 1990.
The l
planned changes to this program include the-utilization of a single problem j
reporting document, a lower threshold for incident investigations, and the n
establishment of criteria to ensure the appropriate resolution'of potential
. i problems. The change to utilize a single problem reporting' document'will be E
implemented by June 1, 1990.
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l 1
In summary, it is clear from the above discussion that the programmatic problems that led to these violations had been previously:1dentified by.TVA.
i Corrective actions to address these broad problem areas had been put in place or were ongoing at the time the deadheading issue was identified.. Specific efforts were underway and continuing to improve engineering evaluations, to emphasize timely identification and resolution of problems, to upgrade the 1
Technical Support organization, and to l'mprove: licensing submittals (including.
bulletin responses).
1 Corrective Step' That Will Be Taken to Avold Further Violations (Violation _s I, 1 and A.2)
No further actions are required.
Date When full Compliance Will Be Achieved (Violations A.1 and A.2)
SQN is in full compliance.
___ !A
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(
, Vio'lation250-327.-328 90-01-01' "B.
Technical: Specification.6.8.1, requires >1n part,.~that' written procedures.
beLestablished,-. implemented and maintained covering the: applicable proceduresLrecommended in Appendlx;'A'-of' Regulatory Guide-1.33,.
Revision 2, February 1978..
Appendlx 'A' ofERegulatory Guide-1.33,: Revision.2, requires procedures
.for combating emergencies and other significant events.
Technical Specifications' [ sic] 6.8'.2,. requires in part,'that changes:to.
4 procedures be-reviewed and approved prior;to implementation as set forth' N
in Specification: 6.5,~1 A.
4 Technical Specification 6'.5.1.A,frequires in part, that each review determine'whether or not an unreviewed safety questionz is in_volved pursuant to.10 CFR 50.59.
Contrary to the above, on December'6, 1989-the= licensee performed an inadequate-review of Emergency Instruction _E-0, Reactor-Trip and Safety _
q
' Injection, Revision 7, required by Regulatory Guide h33 to combat -
emergency events.
The= procedure change would terminate!RHR: operation; l
prior to the procedure Gteps 'reqiliring operator examination'of,certain parameters 1to diagnose whether a.LOCA'was occurring. :Thefreview failedi j
to ensure-that the procedure change did-not involve an unreviewed safety:
j question pursuant to:1.0 CFR.50.59.
1 Ji Violations A.1, A.2, and B are a Severity Level III Problem k
(Supplement I).
y Civil Penalty - $/5,000 (assessed equally among the violations)"-
Admission or-Denial of the Alleged Violation (Violation B)
- TVA admits the violation.
Reason for the Violation (Violation B)
Revision 7 to E-0, which required stopping both RHR pumps, was technically; deficient. The technical evaluation performed for Revision 7 was done solely
- on.the basis of the accident analyses presented in the Final Safety Analysis:
4
. Report (FSAR).
During this evaluation, the reviewers-did'not' adequately '
review the potential impact of the change in that they only considered the specific break sizes addressed in theLFSAR.
Chapter 15 of the FSAR addresses a specific set of-bounding 10 CFR 50,.
Appendix K, breaks.
The-reviewers considered these breaks to be' bounding for all cases.
There were however other break sizes <than:those in-the FSAR that
.could be impacted'by the procedure change.
The FSAR did not explicitly. define the key assumptions regarding RHR operation.for'small break loss of coolant accidents (SBLOCAs); therefore, the : reviewers assumed that no credit was taken for RHR injection for these breaks.
The Operations' personnel responsible for i
implementation of the emergency: procedure program had recently assumed'this
f 3,4 3
s
. k responsibilit'y during realignment of Operations staff dutiese Special emphasis had not been provided during' indoctrination in this function,:and program requirements were not fully _ understood by.the personnel involved with-the subject revision. Although knowledgeable ~ personnel previouslyLresponsible--
.for changes to. emergency operating-procedures;were consulted for this revision, the program did not require the' appropriate checks;and_ balances'in that. Westinghouse. was not-consulted regarding the change.
Review by,the Plant:
Operations, Review Committee (PORC) was'not required, and the emergency procedure change evaluation was not well documented.-
During the preparation of the safety assessments.for both' Revisions 7 and 8 to-
,t E-0, the individuals involved made an incorrect determination that because the change had no consequences-(based on their. review of the accident analyses discussed in the FSAR), it had no-effect on.RHR--system operation or _
Information provided in the FSAR. Accordingly, the safety assessment'.
questions were checked "no,t' indicating that a safety evaluation wasinot.
required'.
In both Revisions 7 and-8, it was clear-that the. reviewers were concerned with whether E-0 itself-was described in the FSAR as well.as whether the RHR system operation, as controlled by'E-0, was described in the FSAR.
A safety evaluation was performed for, Revision 8 at the directionLof, plant' management.
Corrective Steps That Have Been Taken and Results Achieved'(Violation B) j TVA has taken prompt and comprehensive steps to address this aspect of'the-
)
violation. First, the administrative controls have been strengthened for emergency operating procedure changes.
PORC review and Plant Manager approval are now required for all emergency operating procedure changes.
Administrative-Instruction (AI) 2, " Guidelines for Preparing, Verifying and Validating Operating Instructions," has been revised to require Westinghouse concurrence with any change to the emergency operating procedures that deviates from the Westinghouse Owner's Group / Emergency: Response' Guidelines.
Verification and validation requirements were also strengthened with.
particular emphasis on simulator validation whenever possible.
In addition, a
l-the step deviation document process has been enhanced by detal_ ling. specific evaluation criterla in AI-2.
Second, training on the above changes has been conducted;for the Operations personnel responsible for management of the emergency procedure change process. Westinghouse had previously confirmed the technical adequacy of the emergency procedures in September 1989.
Revisions 7 and 8 to E-0 were the
'only emergency procedure changes made since the Westinghouse evaluation.
Third, TVA reviewed the safety assessment problem and identified two areas for correction. A clarification to the FSAR regarding RHR operation for SBLOCAs was submitted in the April 1990 update. A training letter was sent to Level I 1
and Level _II 50.59 reviewers describing the RHR event, the subsequerit procedure changes, safety evaluations, and the lessons-learned.
Particular emphasis was placed on the fact that a change without ultimate adverse.
consequence could still result in having an effect on the system and therefr>re j
require a safety evaluation.
This training is considered an enhancement 4 J
the major 50.59 program changes made in November 1989.
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.The inadequate-safety evaluation is~the-single implementation problem:
' identified under'the revised 50.59 process as noted in NRC Inspection-
- Report 90-01,
. Corrective Steps'That~Will Be Taken to Avoid Further Violations (Violation B).
No'further actions are required.
-Date When full Compliance Will Be' Achieved-i SQN'is'in; full compliance.
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ENCLOSURE 2 5
i ANSWER TO PROPOSED IMPOSITION OF CIVIL' PENALTY o
INSPECTION REPORT'NO.- 50-327,-328/90-01 1
D. H. CRUTCHFIELD'S LETTER TO 0. D. KINGSLEY,-JR ~
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DATED _ APRIL:.12, 1990' t-
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Introduction Pursuant to.10 CFR_2.205c TVA hereby submits its answer to;the' proposed civil-penalty. As discussed below,-TVA has reviewed the history and chronology..of>
the residual heat removal (RHR) pump deadheading issue and TVA's response to' the-issue. TVA has reviewed the escalation and-mitigation factors: set!forth in Section-V,8.-of the," General. Statement of Policy and Procedure for:NRC Enforcement Actions" (10 CFR,' Part'2; Appendix C).
TVA concludes that_the Unit E RHR problem was identified by TVA with-subsequent identification of the relationship to Bulletin 88-04 by NRC.
Both the NRC and TVA management pursued resolution of the issue. ~In view of:the' chronology of: events and'the-Importance of TVA'.s efforts in identifyingithe; 4
issue, escalation'of the proposed base civil penalty on the grounds that NRC :
identified the. problem is not warranted. '
Additionally, TVA believes that the extensive programmatic corrective actions :
that had been put in place'both prior to_and following. discovery of theiRHR<..
pump proisicm merit consideration.. Accordingly TVA-respectfully. requests 1that-j in view of-these extensive corrective actions, NRC recon' sider-_the 50 percent escalation of the proposed base eM1 penalty.
Circumstances of Identification'and Reporting 1
Inspection Report No. 50-327, 328/90-01 identifies b/ceber 29, 1989, as the date when the NRC resident inspector _ identifled tb x9 pump deadheading problem. In the-subsequent notice of violation,'NRC identification ~of the 3
problem was cited as the sole basis for a 50 percent escalation of-the proposed base civil penalty.
While TVA recognizes that the NRC inspector _
played a role in this issue, TVA considers.that it had itself. discovered the-underlying facts before November 29, 1989-At the time:NRC became involved, TVA was in the process of. determining the significance of the Issue.
The chronology of events described in Enclosure 1-is incorporated herein by, reference.
Based upon that chronology of events, TVA concludes that its RHR system engineer began evaluation of the RHR pump deadheading problem as a-result of his preparations to perform the surveillance test during the Unit 1 Cycle 4 refueling outage.
Although the system engineer was not aware of the Bulletin 88-04 aspect of the issue, by discovering a problem with the test data and bringing it to the. attention of his supervisor and Nuclear Engineering (NE), a process had been started that would have resulted in.
identification of the full _ scope of the problem in a reasonable time. without the interaction of the NRC resident inspector.
While the inspector's interaction doubtless emphasized the identification and consequent resolution of the problem by focusing greater attention on the matter, TVA was already moving from discovery to full identification and resolution of the problem.
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. Since TVA had not' completed the process of! analyzing the. issue at the time the NRC resident inspector became involved.,TVA is not suggesting.that the.
proposed base civil penalty should be mitigated on the basis of licensee j
identification. At the same time however, escalation of the proposed base civil penalty on the basis of NRC.identif.ication of the problem does not scem appropriate either.
TVA believes that.the-initial discovery of the. problem by.
the RHR system engineer and_the-actions he initiated that ultimately led to-identification of-the problem were complemented by the emphasis added by the NRC inspector's. involvement.
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further, and perhaps as significant, was TVA's previous-identification and
-correction of conditions that were ultimately determined to be the' underlying cause of this specific problem.
TVA maintains that this fact should also be considered in the staff's decision regarding identification ~of the problem.
For-this reason; TVA's extensive corrective. actions-addressing the root cause of this issue are summarized in the following discussion.
Extensiveness of Corrective Actions Further Offset the Escalation of the Proposed Base Civil Penalty-Section V.B.(2) of the NRC enforcement policy indicates that in evaluating the:
corrective action of a licensee, consideratl.on will be'given to,.among other things,."the timeliness of.the corrective action,' degree'of llcensee Initiative, and comprehensiveness of.the corrective action.. c.
TVA implemented extensive corrective actions to address-the causes of the RHR pump deadheading issue and the inadequate safety assessment, as described.in.
That description-is incorporated here_in by reference.
4 To summarize however, TVA's key corrective actions addressing aspects of both 0
violations include.
Revision of emergency procedures providing administrative controls to prevent pump damage.
1 Administrative changes regarding the requirements'for processing a
revisions to emergency procedures, t
Training letter to apprise Level I and Level II 50.59 reviewers of.
lessons learned from the RHR pump events.
Revision of the SQN response to Bulletin 88-04 and scheduling hardware l
modifications to replace administrative control in the long term.
}q Programmatic ~ changes affecting how licensing issues are managed using the
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'llcensing project management concept.
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Changes regarding how the Nuclear Experience Review program is staffed ll and managed.
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t Organizational and management changes made to the Technical Support organization.
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Functionalresponsibilitychangesmade[tothe*NEorganization~.
1-Management actions taken to encourage: safety consciousness with regard.to
-problem identificati_on and reporting.
- TVA's corrective actions can be divided?into two cat'gories: _ reactive and e
proactive. -The reactive corrective actions are those that were taken after the pump problem was identified and confirmed, to protect equipment and adjust the' methods for operating the plant during emergencies. TVA. believes ~that-it.
promptly took appropriate. actions to' address this violation once the condition was confirmed.
However, of'particular-significance in this case were TVA's comprehensive-proactive actions.
These proactive corrective actions are those'that'were implemented before discovery of the RHR pump problem to' address-underlying.
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weakr. esses that TVA had already recognized.- 'Several ofcthe'past weaknesses being' addressed by TVA at'the time thisiviolation was identified were in. fact.
- 1 the causes of the original. inadequate response to Bulletin 88-04.
The end-.
result of the proactive. approach taken.by;TVA was that corrective actionsLto address the key programmatic weaknesses had been putiin place before discovery.
- t of the' specific RHR pump deadheading-problem;- Further, the discovery of the-1 RHR pump-problem by the system engineer was a result of'the ongoing proactlle-norganizational and management improvements'being made within;the-Technical" Support.organtzation.
3 Overall, TVA's proactive and reactive corrective actions are' good examples of.
l prompt and effective corrective actions intended to' promote'the aggressive identification and resolution of problems.
TVA believes that the actions taken both before and after' identification of the subject problem demonstrate TVA's willingness and ability-to aggressively identify and correct problems. Additionally, because'many of the corrective
. actions addressing key-programmatic weaknesses had been put in place before-discovery of the RHR pump problem, escalation of the proposed civil. penalty to emphasize the need for TVA to identify and address these.past. problems is clearly unnecessary at this time.
Conclusion TVA believes that its efforts led to the discovery of the RHR pump deadheading-problem.
The RHR system engineer had taken the inttlative and was in the-process of determining the significance of the problem when NRC became involved. Consequently, TVA believes the escalation of the proposed base
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civil penalty, based on.NRC identification of the problem, is neither consistent with the facts nor with enforcement policy objectives, Additionally, TVA believes that the extensive programmatic corrective actions m
that were put in place both before and after discovery of-'the RHR pump problem merit some consideration when considering the identification and. corrective action factors.
For these reasons, TVA respectively requests that NRC-reconsider the 50 percent escalation of the proposed base civil penalty.
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