ML20043F930

Responds to NRC Re Violations Noted in Insp Repts 50-327/90-17 & 50-328/90-17.Corrective Action:Test Director & Supervisor Involved Given Appropriate Level of Disciplinary Action

ML20043F930
Person / Time
Site:	Sequoyah
Issue date:	06/13/1990
From:	Medford M TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9006180317
Download: ML20043F930 (3)

Text

g;;

s y+

T y

1 pg. w,p s.; 7;)

u.

g pm --

-.' 4 m

g-j m

1, TENNESSEE VALLEY AUTHORITY j

CHATTANOOGA, TENNESSEE 37401.

{.

6N-38A Lookout Place

'JUN 181990 s

U.S.. Nuclear Regulatory Commission

}

ATTN:- Document, Control' Desk

!?

Hashington, D.C.

20555 Gentlemen:-

l l

In the Matter of-

)

Docket Nos. 50-327

I

-Tennessee Valley Authority.

)

50-328 i

i

SEQUOYAH NUCLEAR. PLANT (SQN)' - NRC INSPECTION REPORT NOS. 50-327, 328/90-17 LRESPONSE TO NOTICE OF VIOLATION'50-327, 328/90-17-01 i

Enclosed is TVA's response.to'B' A. Wilson's letter-to 0.'O. Kingsley, Jr.,

l dated May :16,1990,.which transmitted the subject notice.of violation.

L l,.

lIf you have'any-questions concerning this submittal, please telephone

=M.'A. Cooper at (615) 843-6651.

j Very truly yours, j

r TENNESSEE VALLEY. AUTHORITY asas/ M2e

\\

Mark 0. Medford, Vice President Nuclear. Technology and.icensing.

e D\\.

Enclosure;-

't cc (Enclosure):

'N Ms. S. C. Black, Project Chief j

(N I-IV.

W

'U.S. Nuclear Reguldtory Commission

.One White' Flint, North

.11555 Rockville Pike,' MS 13H2 y

~Rockvi11e, Maryland 20852 l

i w.y JNRC Resident Inspector-

-Sequoyah Nuclear Plant 2600 Igou Ferry Road:

Soddy Daisy, Tennessee 37379 i

LMr..

B'. A. Wilson, Chief f

of TVA Projects-M U.S. Nuclear Regulatory.ComM ssion

{

Region II i

101 Marietta Street, NN, Suite 2900 Atlanta,' Georgia 30323 p

/

~'9606180317'900613

\\\\

4

+ PDR ADOCK 05000327 T

9 rJ.,,

PDC kn Equal Opportunity Employer

& D.k

. L.. :.

E

. m. -

y p3 ENCLOSURE 1 4

+

E RESPONSE TO NRC INSPECTION REPORT NOS. 50-327/90-17 AND 50-328/90-17 E

B. A. WILSON'S LETTER 10 0. D. KINGSLEY, JR.,

DATED MAY 16, 1990 Violation 50-327. 328/90-17-01 f

."TechnicairSpecification 6.8'.1 requires that procedures recommended in 3'

, Appendix.A of Regulatory Guide 1.33, Revision 2, be established, implemented' and-maintained.

This includs administrative and surveillance procedures.

The~reautrements of TS 6.8.1 are implemented in part by the following proceuur as:

SI-90.82, Surveillance iesting of the Unit 2 Train B SSPS AI-47, Conduct of Testing 4

SI-90.82 specifies that the steps-in the procedure be completed in the order 7

in which they are written, and that the provisions of AI-47 apply. AI-47 requires that step sequence deviations.are to be dispositioned_as test deficiencies.

This would require analysis of sequence errors and concurrence from management and the Shift Operating Supervisor prior to implementation of corrective actions to recover from a sequence error.

Contrary to-the above, Instrument Maintenance personnel did not implement the requirements of AI-47 after discoveringLthat steps were performed out of sequence during performance of SI-90.82..Instead, the test director continued mk the test. A reactor trip was generated due to'the errors when the test was 4

resumed.

,b This_ls.a Severity Level IV violation (Supplement I)."

V Admission or Dental of the Alleged Violation TVA admits 1the violation, i

Reason for the Vi_olation The-violation resulted_when a test director (TD) performing Surveillance M

Instructico (SI) 90.82, " Reactor Trip Instrumentation Monthly Functional Test (SSPS)," f ailed to perform the SI steps in sequence as required by Administrative Instruction (AI) 47, " Conduct cf Testing.".While trying to recover from performing the SI steps out of sequence, the TD failed to follow AI-47 resulting in a reactor trip. AI-47 requires an out-of-sequence situation-to be-documented as a test deficiency and requires the proposed (corrective action to be reviewed and cpproved by tlie responsible supervisor 4

and by the shift operations supervisor. A review of. Instruction prerequisites, preceding steps,' control lcigic, and equipment configuration is also required. AI-47' urges the TD to exercise caution'and judgement before v 4 S

proceeding and' advises the TD to resist the strong tendency-to simply skip s

-back and perform the omitted steps. AI-47 training is a prerequisite before 3

b'ecoming a4TD..Although review of the personnel errors indicated there may

}.\\ ;

t :

t

\\

y 4

i d, '

J

' ('

~

v p

il.

.h

~

l}

., JC

-2 i

i g

have'been minor contributing factors, it was concluded that'the root cause of l

this event was' inattention to detail.(i.e., unacceptable performance given the i

. subject procedures and training).

Resolution of this issue was documented in Licensee Event Report 50-328/90008.

t

' Corrective Steps That Have Been Taken and Results Achieved j

.)

Several corrective actions have been implemented as recurrence controls.

The

{

TD and supervisor involved have been given the appropriate level of j

disciplinary action.

To provide a lesson learned to site personnel, a

]

sitewide message was issued by the Site Director describing this event and its I

cause and emphasizing-the personal responsibility of each employee-for performing his or her work correctly.

The message also reiterated the policy on what to do if a mistake is made in performing a task, i.e., work is stopped

. h immediately and any problems are resolved as required before proceeding,

'l Corrective Steps That Will Be Taken to Avoid Further Violations t

i As a long-term effort to reduce personnel errors, a Human Performance Enhancement System (HPES) program and a personnel error awareness seminar s

program are being implemented at SQN.

This aggressive program, recommended by-q the Institute of Nuclear Power Operations, consists of an Il-part seminar 11 developed from industry experience gained through the evaluation of hundreds of situations involving human performance.

These seminars describe the major.

i variables that have been identified as impacting human performance and are 1

= designed to provide a better understanding of human performance and the i

factors that influence human behavior.

The.information presented builds on previously acquired technical, academic, and practical knowledge and is expected to result in a reduction of the number of events resulting from hu' man errors.

Additionally, SQN has implemented a personnel error reduction board

)

to review personnel errors to ensure the root cause is determined, and event investigators are being trained in accordance with the HPES program.

Date When Full Compliance Will Be Achieved 3

-TVA is in full compliance.

i 0875h / 3705m s

a

)

1 s

+

I hl.

i a>

_ _