ML20070B557

Responds to NRC Re Insp Repts 50-327/90-34 & 50-328/90-34 & Proposed Imposition of Civil Penalty in Amount of $30,000

ML20070B557
Person / Time
Site:	Sequoyah
Issue date:	01/28/1991
From:	Medford M TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9101310246
Download: ML20070B557 (7)

Text

_

\\..

k re, < n u, v e

. n w ww n

'e w

-m'

.. m c

s MitfF O % Kibfd v: t sm ve w s a Lv un t w,, 2 w a t.-

JAli 281991 U.S. Nuclear Regulatory Commission ATTN:

Document Control Desk Washington, D.C.

20555 centlemen:

In the Matter of

)

Docket Nos. 50-327 Tennessee Valley Authority

)

50-328 SEQUOYAH NUCLEAR PLANT (SQN) - NRC INSPECTION REPORT NOS. 50-327/90-34 AND

$0-328/90 NOTICE OF VIOLATION (NOV) AND PROPOSED IMPOSITION OF CIVIL PENALTY - $30,000 Enclosed in TVA's response to S. D. Ebneter's letter to 0. D. Kingsley, Jr.,

dated December 28, 1990, which transmitted the subject NOV and proposed imposition of civil penalty involving administration of overtime use.

TVA admits the violation, and payment of the civil penalty in the amount of

$30,000 is being wired to the Director, Office of Enforcement.

TVA recognizes that the actions taken in response to previously identified problems regarding overtime use and administration were insufficient to effect total correction. While a comprehensive corrective action plan was initiated, the plan was unrealistic considering the extensive use of overtime in the past at SQN, the short timeframe initially proposed for implementation of substantial corrective action, and the magnitude of the Unit 2 Cycle 4 refueling outage that was scheduled to begin just before completion of the initial corrective actions. As discussed in the enforcement conference held November 27, 1990, and detailed in Enclosuce 1, extensive additional corrective actions have been initiated to both address minimizing overtime use and ensuring effective administration of overtime When required.

TVA will continue to monitor performance regarding overtime use and administration to verify effectiveness of corrective actions.

9101310246gQ$27

/

FDR ADOCK ppg f

I 1

c[ '

JAN 281991 2

4 U.S. Nuclear Regulatory Commission j

1 One additional cormnitment is made in this response and stated in Enclovero 2.

The remaining corrective actions reflect commitments made in the ast.ociated enforcement conf erence, which were previously transmitted by letter to NRC dated January 23, 1991.

If you have any questions concerning this submittal, please telephone M. A. Cooper at (615) 843-8422.

l Very truly youro, TENNESSEE VA1. LEY AUTHORITY I#

Mark O. Madford Cworn to and subucribed before me h.

h Notary Public

//

My Comntunion Expirop

/[/Y/ M Enclosures cc (Enclosures):

Ms. S. C. Black, Deputy Director Project Directorato 11-4 U.S. Nuc1 car Regulatory Commicolon One White Flint, North 11555 Rockville Pike Rockville Haryland 20852 Mr. J. N. Donohew, Project Manager U.S. Nucicar Reguintory Commission One White Flint, North 11555 Rockville Piko Rockvillo, Maryland 20852 NRC Resident inopoctor Sequoyah Nucicar Plant 2600 Isou Ferry Road Soddy Daley, Tennesseo 31379 Mr. B. A. Wilson, Project Chief U.S. Nucicar Regulatory Commission Region II 101 Mariotta Street, NW, Suite 2900 Atlanta Coorgia 30323 l

i

l ENCLOSURE 1 RESPONSE TO NRC INSPECTION REPORT NLS. 50-327/90-34 AND 50-328/90-34

5. L. EBNETER'S LETTER TO 0. D. KINGSLEY, JR.,

DATED DECEMBER 28, 1990 Violation 50-327, 328/90-34-01 10 CFR Part 50, Appendix B, Criterion V, requires in part that activities affecting quality shall be prescribed by procedures and accomplished in accordance with those procedures. Control of overtime for individuals performing safety-related tasks is an activity af f ecting quality.

Site Standard Practice (SSP) 32.53, Administration of Overtime, is the procedure that implements the controls of overtime for individuals performing safety-related tasks.

SSP 32.53, Section 2.1.3, states that an employee performing safety-related work may work no more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in any 24-hour period, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any 48-hour period, or 72-hours in any 7-day period without the required documentation and without approval by the Plant Manager or Duty Plant Manager on the overtime limitation Exception Report.

Section 2.1.3 further states that personnel affected by these controls include Senior Reactor Operators, Reactor Operatorr, Assistant Unit Operators, Health Physicists, Health Physics iechnicians and key maintenance personnel (defined therein).

Contrary to the above, twenty-two operations department personnel performing safety-related work on Units 1 and 2 covered by Section 2.1.3 of SSP 32.53 worked more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> during the week of October 8-14, 1990.

For 21 employees, the approvals were signed without the required documentation, such as justification f or exceeding overtime guidelines, on the Overtime Limitation Exception Report (Appendix A to SSP 32s53), and for one individual no documentation or approval was obtained.

This is a Severity Level IV violation (Supplement I).

Civil Penalty - $30,000 Admission or Denial of the Alleged Violation TVA admits the violation.

Reason for the Violation TVA evaluated the corrective action plan developed as a result of the violation identified in Inspection Report 50-327, 328/90-22, to determine the reason the actions taken in response to this violation were not effective in preventing recurrence. While the initial corrective action plan was comprehensive and some improvement in overtime administration was noted during the Unit 2 Cycle 4 outage, TVA determined that the previous plan was

. +

unrealistic in several respecto.

Management did not recognize the extent of personnel attitudes regarding the use of overtimo at SQN and accordingly, the magnitude of the task of effecting full and lasting correction.

Becauce of this, management reinforcement of its expectations regarding the use of overtime was insufficient to ensure total effectiveness of the initial correctivo actions.

Inconcistencies in management's perspectives regarding the use of overtime were also identified; in some cases, insufficient priority and focus were given to overtimo limitations and the importance of carefully evaluating and documenting the justification when granting approvals.

2 Additional weaknecces were discovered in processes and procedures utilized to document management's approval to exceed overtimo limits and to track overtimo

used, procedural ambiguity lod to inappropriate use of " blanket" approvals by some organizations, i.e.,

a singic request and approval for a large number of individuale performing vicious tasks over an extended period of time.

Also, the unclear format of ty..

zuestionc added to the approval form to prompt comprehensive considersd ;on and documentation of justification for overtime use contributed to in onsistent implementation. The manual systems utilized to track overtime use were inadequate to ef fectively and accurately project where overtime use would exceed the guidelines.

Additionally, the timoframo initially proposed to accomplish significant change was chort, especially in light of t he magnitudo of the Unit 2 Cycle 4 outage coincident with a significant Unit I forced outage.

i Golig.c_tly9,lttep That Have Been Taken and Resulto Achieved Although the subject violation focuses on procedural compliance regarding administration of overtime. TVA recognizes that further improvement to needed both in minimizing the use of overtime and in properly administrating use when it to determined noconnary. Accordingly, an integrated corrective action plan was developed to address both areno.

Sequoyah Gite Standard practice (ssp) 32.53, " Administration of Overtino," has been revised to addreco identified procedural inadequacies and further otrongthen controis governing overtimo uso. The overtime limitation exception report form has been revised to f acilitato proper documentation from a human performance perspective. Additionally, blanket approvals of overtime for an entire staff have been disallowed.

To ensure that nanagement's reinforcement of the overtimo policy is adequate, several corrective actions have been completed.

A memorandum, along with face-to-face discussions to ensure consistency, was issued to the duty plant managers stating that procedural adherence must be observed to enstre the overtime limitation exception report is properly completed before overtime L

- approvr! is granted.- The supervinors not complying with program requirements-for complellon of overtime limitation exception reports during the Unit 2 Cycle 4 outage have received appropriate disciplinary action.

A computerized tracking system has been implemented in the Operations organization to aid in monitoring and controlling overtime.

Based on Operations' experience with the cyclem, computerized tracking will be impicmented throughout the cite.

Further details are enumerated in the

" corrective Steps That Will be Taken to Avoid Further Violations" section of this responso, i

l l

+,--

.---.n

--...,--.~,c

1 1,

i Also, to reinforce the priority and significance of overtime une requirements and in accordance with Generic Letter 82-16. "NUREG-0737 Technical Specifications," a technical specification change was submitted on December 14, 1990, to include overtimo restrictions ao part of the SQN technical specifications.

4 A number of corrective actions have been taken that are intended to minimize the uso of overtimo, pre-approval requirements have been strengthened by instituting a policy stating that only the SQN plant Manager can approve overtimo requests to excood 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in a 7-day period.

The duty plant managero are resteleted to approving requesto to work in exceso of 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in a 24-hour period or 24 hourn in a 48-hour period.

Additionally, an absoluto cap of 88 hours0.00102 days <br />0.0244 hours <br />1.455026e-4 weeks <br />3.3484e-5 months <br /> in a 7-day period han been instituted, i.e., no approvals will be granted to exceed this limit. The revision to SSP-32.53 reinforces that, if a control board operator must work in excess of the overtime guidelines, overy effort must be made to remove the operator from the control board position.

In addition, the SQN Site Vice pror.ident is now required to review the deviations from overtimo guidelines.

Becauso emergent issues during the Unit 2 Cycle 4 refueling outago contributed significantly to the large number of hourn worked, management is examining the scheduling methods for emergent innues.

Additional focus and emphanis will be appiled both in scheduling manloading contingencico for emergent incuen and reevaluating schedulos as appropriate when emcegent losues exceed allocated resourcos.

Quality Assuranco (QA) monitored the use of overtimo over the period of December 24-30, 1990, un committed in the revised response-to Notice of Violation 50-327, 328/90-22-01, to ansess the effectivenoco of the corrective action taken to this point.

No-employeen exceeded the overtimo limite during the monitoring period.

Additional monitoring scheduled for the Unit 1 Cycle 5 refueling outage will provido more meaningful resulto no anticipated work loado will then " test" control proconnes.

QA niso performed a follow-up investigation of an occurrence whero Operations discovered an individual had worked in execus of the overtimo limit of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in a 48-hour period without prior approval.

Ao soon au the disaropancy was discovered, the individual was removed from the control board and documentation was ionued oc required.

As a result of QA's review of this occurrence, improvemente in the software currently used in Operations to track overtime woro recommended.

The software changes recommended will facilitate

[

!mplementing the " rolling" timeframo concept and improvo data accensibility.

l A review of personnel errors that had occurred over the subject period was performed to determino if ovectime uso had been a contributing factor to the associated performance inadoquacy.

No obvious link between those errors and l

overtimo use was found.

Therefore, TVA concluded that the problems regarding overtime use had not resulted in a significant detrimental effect on safety.

l

~-

- - ~

l

. Corrective Steps That Will be Taken to Avoid Further Violations In an attempt to appropriately minimize overtime use, a review of methods for establishing manhour loadings for outages will be conducted. Considerable improvements in outage scheculing have been achieved over the past year, but additional refinements in capability and detail are still necessary and are ongoing; such improvements will significantly improve accuracy of resource projections. This review will determine how SQN will schedule work in relationship to the resources available and will be completed by May 31, 1991.

In addition, scheduling methodology and staffing composition studies will be performed for target areas, e.g., Operations and Instrument Maintenance, where additional resources are not readily available because of the training and experience required. These studies will develop contingencies, including augmenting the staff in the target areas during high demand periods.

The results of the studies will be issued by memorandum by March 31, 1991.

A computerized tracking system to aid in monitoring overtime similar to the system utilized by Operations is being established thrbughout the site.

TVA will obtain the required terminals and software, implement software changes, and establish capabilities to effectively utilize the system for outage and nonauta;;e periods including the resources to load data and processes to obtain data at the necessary frequency. These actions will be completed by January 31, 1991.

QA will perform additional monitoring of the use of overtime during the Unit 1 Cycle $ refueling outage to assess compliance with the requirements and the effectiveness of the previously described corrective actions.

Date When Full. Compliance Will be Achieved TVA cons.iders that the corrective actions taken to date should be effective in both minimizing overtime use and ensuring compliance with administrative procedures; monitoring conducted to date affirms the conclusion that TVA is in full compliance at this time.

However, the controls and processes will not be

" tested" in a meaningful manner until the next outage. Additional enhancements being taken, which are intended to further strengthen controls and prevent recurrence, have been described above.

As noted, TVA will monitor overtime use during the Unit 1 Cycle 5 refueling outage to confirm that full compliance has been achieved. The results of this monitoring will be subm1Lted to NRC within 30 days after completion of the outage.

-_____m.__m_

M

i ENCLOSURE 2 i

Conuni tmen t TVA will monito. osertime use during the Unit 1 Cycle 5 refueling outage to confir n that lull compliance has been achieved. The results of this monitoring will be submitted to NRC within 30 days after completion of the outage.

- - -. - _ _ _. _ _ _ _ _ _ _ _ _ _ _