ML20043F930

Responds to NRC 900516 Ltr 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)

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• • - TENNESSEE VALLEY AUTHORITY 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  !

!? 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.,

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

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

=M.'A. Cooper at (615) 843-6651. j r Very truly yours, j 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 I-IV .

(N W 'U.S. Nuclear Reguldtory Commission

.One White' Flint, North

.11555 Rockville Pike,' MS 13H2 .

y ~Rockvi11e, Maryland 20852 l

w. i 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

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~'9606180317'900613 ADOCK 05000327

\\ 4 9 rJ . , , PDC kn Equal Opportunity Employer

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.- ENCLOSURE 1

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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 7

SI-90.82 specifies that the steps-in the procedure be completed in the order 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 m sequence during performance of SI-90.82. .Instead, the test director continued k4 the test. A reactor trip was generated due to'the errors when the test was resumed.

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'- 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 v 4 also required. AI-47' urges the TD to exercise caution'and judgement before S s proceeding and' advises the TD to resist the strong tendency-to simply skip 3 -back and perform the omitted steps. AI-47 training is a prerequisite before b'ecoming a4TD. .Although review of the personnel errors indicated there may

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i g i 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. '!

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' Corrective Steps That Have Been Taken and Results Achieved j

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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,

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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. '

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