ML20066B719
| ML20066B719 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 12/27/1990 |
| From: | Medford M TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9101080287 | |
| Download: ML20066B719 (6) | |
Text
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DEC 271980 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C.
20555 Gentlemen!
In the Matter of
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Docket Nos. 50-327 Tennessee Valley Authority
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50-328 SEQUOYAl{ NUCLEAR PLANT (SQN) - UNITS 1 AND 2 - NRC INSPECTION REPORT NOS. 50-327, 328/90 RESPONSE TO NOTICE OF VIOLATION (NOV) 90-34-01 Enclosed is TVA's response to Bruce A. Wilson's letter to 0. D. Kingsley, Jr.,
dated November 16, 1990, shich transmitted the subject NOV.
In a telecon with Joe Brady of your office on December 17, 1990, the due date of this response was extended to January I., 1991. provides TVA's response to the NOV. Enclosure 2 contains the summary statements of commitments contained in this submittal.
If you have any questions concerning this submittal, please telephone M. A. Cooper at (615) 843-6422.
Very truly yours, TENNESSEE VALLEY AU1110RITY h
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Mark 0. Medford Enclosure cci See page 2 9101080287 901227 PDR ADOCK 05000327
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2 U.S. Nuclear Regulatory Commission DEC 271990 cc (Enclosure):
Ms. S. C. Black. Deputy Director Project Directorate II-4 U.S. Nuclear-Regulatory Concission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Mr. J. N. Donohew, Project Manager U.S. Nuclear Regulatory Commissic4 Onc White Flint, North 11555 Rockville Pike Rockville, Maryland 20s52 NRC Resident Inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy Dsisy, Tennessee 37379 Mr. B. A. Wilson, Project Chief U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NV, Suite 2900 Atlanta, Georgia 30323
ENCLOSURE 1 RESPONSE TO NRC-INSPECTION REPORT NOS. 50-327/90-34 AND 50-328/90-34 B. A. WILSON'S LETTER TO 0. D. KINGSLEY, JR.,
DATED NOVEMBER 16, 1990 Violation 50-3fr-i08/90-34-01 Technical Specification 6.8.1 requires that written procedures shall be establi;hed, implemented and maintained covering Fire Protection Program implementation.
Physical Security Instruction (PHYSI) 13 Revisinn 55, " Fire,"
Attachments E and H, detail the controls imposed on transient fire itsda in safety-related areas.
The procedure requires, in part, thtt equipment shipped in untreated combustible containers may be unpicked in safety-rele*-a areas only if the containers are imm ediately removed followiui unpacking process.
Contrary to the above, for the period of October 1 through October 11, 1990, a large amount of non-fire-rated wood was left unattended in the auxiliary building on Elevation 669'.
This is a Severity Level IV violation (Supplement I).
Admission or Denial of the Alleged Violation TVA admits the violation.
Reason for the Violation The non-fire-rated _wocd of the subject violation was a shipping crate for a replacement residual heat reme val pump motor. The " lac rical Maintenance (EM) i?rsonnel responsible for the motor wc e informed by adiological Control that t ied motor could not be uncrated in the turbine building DoO9Use it was contaminated. The EM foreman contacted Fire Operations to request a transient fire load (TFL) permit.
Fira Operations informed him that because the wood was: untreated (i.e.. not fl retardant), he could not obtain a permit.
Fire Operations did not-suggest
- r alte rna tives.
The EM personnel, a general foreman and a foreman, chom
- o violate the known fire protection requirements rather than escalating the cor.flict to manage:aent in order to complete their work in a timely manner. The crate was not removed from the auxiliary building,immediately following unpacking, as maintenance personnel intended to use' it to remove the replaced motor after the work was completed.
Problems with the pump and a larger than expected workscope delayed the motor replacement, and hence, the' crate removal.
The responsible EM personnel were notified on two-occasions by Fire Operations and Work Control to remove the crate prior;to the NRC inspector's identification of the nonconformance.
On each occasion, the general foreman felt the work completion was imminent-and chose to leave the crate to remove the replaced motor.
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Poor judgement was exercised throughout this event by the EM personnel i
involved. Had the conflict been aopropriately escalated, the fire protection engineer would have allowed the crate to enter the auxiliary building after an action plan had been approved by plant management to ensure proper measures were in place consistent with the fire load hazard.
Paragraphs 5.1.3 and 5.1.4 of PHYSI-13, Attachment E, are unclear in this aspect of TFL control; and the EM personnel were unaware this ' avenue existed.
This event was an example of individuals (a foreman and general foreman) violating known requirements.
Reliance on worker adherence to procedures must be expected. Therefore, this event is not considered to have resulted from a weakness in the fire protection program's control of combustibles entering safety-related areas.
Corrective Steps That Have Been Taken and Results Achieved The crating material was removed at approximately 1700 hours0.0197 days <br />0.472 hours <br />0.00281 weeks <br />6.4685e-4 months <br /> on October 11, 1990.
An evaluation of the safety implications of the unattended transient fire load was pecfarmed.
If a fire had occurred the flame spread would have been slow since the majority of the crate consisted of thick timbers.
The fire detection system was operable in the area and would have alerted the plant's fire response team before the flame spread could have affected nearby systemt.
In addition, the-roving fire watet rounds were conducted hourly in the area and workers were present a significant amount of time.
For these reasons TVA concluded that the load was within the capability of the plant's fire protection system.
A problem evaluation panel was hald wi.
the respoasible personnel and-plant management to understand the circumstances under which the poor judgements were made and to determine the proper corrective action to prevent recurrence. The EM personnel involved have been counselled on the requirements of PHYSI-13 and the importance of escalating conflicts for appropriate resolution. They have also been given appropriate disciplinary action for knowingly violating procedures.
L As a result of a number of recent events related to the fire protection program at SQN, a qualf y assurance audit and a generic event investigation were performed to deteriine if weaknesses exi,ted in the program.
The audit concluded that fire pro ection responsibilities and interfaces are not well understood and are not clearly defined.
This conclusion was a contributing factor in this event; and corrective actions, including a clear definition of responsibilities and additional training, are in process. The generic event investigation concluded that additional priority should be placed on fire-protection-related issues in each responsible organization.
This finding was also a contributing factor to the previously noted poor judgement. To address this finding, plant management will place additional emphasis on fire protection requirements and the responsibility of each organization in the plant plan of the day, staff, and safety meetings.
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Correntire_fLtepi_That Will Be Iaken To Avoid Further_.Xinlations PllYSI-13, Attachment E Paragraphs 5.1.3 and 5.1.4, will be revised by January 4, 1991, to clarify the requirements for allowing entry of untreated wood into safety-related areas. Paragraph 5.1.3 will discuss using treated wood for scaf folding when suitable noncombustible substitutes are not avalloble.
Paragraph 5.1.4 will clearly address the requirements related to unpacking equipment in safety-related areas that is shipped in untreated combustible packaging. This revision to P"YSI-13 will also clearly define and proceduralize ort.inizational responsibilities.
Training for maintenance personnel on this event will be factored into Nuclear Experience Review (NER) training. The lesson plan for NER training will be updated to include thic event by January 4, 1991. Maintenance personnel will be trained by February 1, 1991.
DAtc Mhen_ lull._Camplianc.e Will Be Achieved TVA is in full compliance.
ENCLOSURE 2 Summary of Commitments
- 1. ' PHYSI-13 will be; revised to clarify the' requirements for allowing entry of l
. untreated wood into safety-related areas by January-4, 1991.
f2. Training for maintenance personnel on this event will be factored into NER training. The lesson plan for NER training will be updated to incl'ide this event by. January 4, 1991.
3.
Maintenance personnel will be trained by February 1, 1991.
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