ML20043F930
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) | |
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1, TENNESSEE VALLEY AUTHORITY j
CHATTANOOGA, TENNESSEE 37401.
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6N-38A Lookout Place
'JUN 181990 s
U.S.. Nuclear Regulatory Commission
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ATTN:- Document, Control' Desk
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Hashington, D.C.
20555 Gentlemen:-
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In the Matter of-
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Docket Nos. 50-327
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-Tennessee Valley Authority.
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50-328 i
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- 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.
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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
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Mark 0. Medford, Vice President Nuclear. Technology and.icensing.
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Enclosure;-
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'N Ms. S. C. Black, Project Chief j
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'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
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Region II i
101 Marietta Street, NN, Suite 2900 Atlanta,' Georgia 30323 p
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~'9606180317'900613
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PDC kn Equal Opportunity Employer
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- y p3 ENCLOSURE 1 4
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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
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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
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TD and supervisor involved have been given the appropriate level of j
disciplinary action.
To provide a lesson learned to site personnel, a
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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
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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
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