ML20082T457
| ML20082T457 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 09/13/1991 |
| From: | Joshua Wilson TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9109180262 | |
| Download: ML20082T457 (5) | |
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September 13, 1591
-U.S. Nuclear Regulatory C mmission ATTN: Document Control Dt.sk Washington, D.C.
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Gentlemen:
In the Matter of
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Docket Nos.30-327 Tennessee Valley Authority
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50-328 SEQUOYAH NUCLEAR PLANT (SQN) - NRC !NSPECTION REPORT 50-327, 328/91 RESPONSE TO NOTICE OF VIOLAI!ON (NOV) 50-32/, 328/91-17-01 Encloseo is.TVA's response to B. A. Wilson's le'.ter to Dan A. Nauman dated August 14, 1991, which transmitted the subject NOV concerning examples of failing to follow plant procedures that resultad in the loss of fire protection water suppression system pressure. Adt
'nal details of this event were provided to NRC in Licensee Event Report 327/91020 dated August 21, 1991.
If you have any questions concerning this submittal, please telephone Russell R. Thompson at (bl5) S43-74 70.
Very truly yours, TENNESSEE VALLEY AUTilCRITY 5%
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kilson Enclosure ec: See page 2 9109180262 910913
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- PDR ADOCK 05000327 Q-PDR
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l 2-U.S. Nuclear Regulatory' Commission
-September 13, 1991-cc=(Enclosure):L Mr. D. E. LaBarge, Project Manager U.S. Nuclear Regulator) Commission One White Flint, North 11555 Rockville' Pike Rockville, Maryland-20852 NRCLResident !nspector.
Sequoyah Nuclear Plant-
~2600 Igou Ferry. Road Soddy-Daisy. Tennessee 37379 Mr.-B. A. Vilson, Project Chief U.S. Nuclear-Regulatory Commission
-Region ~II-101-Marietta Street, MJ, Suite 2900 Atlanta, Georgia l30323 l
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a ENCLMURE--
RESPONSE-TO NRC INSPECTION REPORT i
NOS. 50-327/91-17 AND 50-328/91-17 B.
A,-' WILSON'S LETTER TO DAN A. NAUMAN i
p DATED AUGUSi M, 1991 i~
Violation 50-327, 328/91-17-01 1
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-Technical _ Specification 6.8.1 requires that procedures recommended in-4 l-Appendix A of Regulatory Guide 1.33, Revision 2 be established, implemented-and maintained.
This includes maintenance, operating, surveillance, administrative, and fuel handling procedures.
Ite requirements of TS 6.8.1 I
are implemented in pr.rt by the following procedures:
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" Site Standard Prnetice (SSP) 8.1, Conduct of Teting. _ requires, in part, that
- test activities are performed in a manner to reduce the possibility of an
- undesired manipulation or actuation of plant equipment. Section 2.12.7, Procedural Adherence, f urther requires that test directors, performers, SOS, and responsible supervisors adhere to the test instruction, and follow the
- procedure step by step unless specifIcally allowed by the test instruction or l:
other site implementing documents.
" Contrary to_the above, on July 22, 1991, two AU0s performed _ valve i
manipulations-for SI-73.4, Fire Pump 2 B-B Performance Test, outside the L
' procedural' steps ordered in the test instruction.
These actions resulted in
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- the plant fire protection suppression ratem becoming inoperable for apprraimately 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />.
"This-is a Severity level IV violation (Supplement I)"
I Admission or Denial of the Alleged Viold ton 4
TVA admits the violation.
- Reason for-the Violation-e
- The root cause of this event was the failure of two auxiliary unit _ operators (AU0s) to follow approved plant procedure SSP 8.1.
The'AUOs were the-
- designated test directors f or these. tect evaluations.
They violated the requiremen;s of SSP-8.1, which addresses saety issues, precautions, and limitations; the chronological test log;: pretest briefings; operations
- notification; configuration control; ter, deficiencies; and out-of-sequence
. test performance.
If these sections bid been followed, the_ unauthorized valve-alignment would not have been made.
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There_is an' additional example of_these.AUOs' failure _to' follow procedurer, iSpecifically, Valve 2-26-575 was not exosed as required by Step _16 of Section.6.2 of Surveillance Instruntion (SI) 73.4, " Fire Pump 2B-B Perf ormance i _-
LTest." Several other steps in SI-73.4 were not performed that might have alerted the operators in the. main control room (MCR) to the changes being-made--
to the high pressure" ftre protection system alignment. The AU0s did not i
document the plant configuration in the SI package, impeding the ability of the MCR operate s to determine actual plant status.
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i Discussions with other AUOs and an evaluation of their performance have led managcment to the conclusion that the performance problems described above are isolated to the two AUOs specifically involved.
Poor communications used by personnel also contributed to this event.
The of infornal terminology associated with the status of the surveillance test inhibited the MCR personnel's ability to determine actual plant configuration.
If the AU0s arid the MCR personnel had used precise terminology when discussing the status of SI-73.4, the event might have been prevented and/or better mitigated.
The timing surrounding work authortt<. tion and actual start of work activities relative to testing on the 2B-B tir; pump was also reviewed.
Initial permission for starting the test was given on July 18, 1991; but because of the need to repair the 13-B fire pump, the testing en the 2B-B fire pump was delayed. Verbal permission by the same senior reactor operators (SR0s) who originally authorized the performance of the test was given to the ACOs to perform the test on July 22.
The SR0s who provided the verbal authorization to perform SI-73.4 were cognizant of pl<nt conditions and considered that additional documentation was not required.
Reauthorization to perform SI-73.4 in this manner for delayed testing is not consistent with provisions in SSP-8.1.
SSP-8.1 requires the test director to obtain permission from the SOS to resume testing. The shift operatiors supervisor is to document re-review of the activity against current conditions and approval in the test director's chronological test log.
Management has reviewed the t imef rame when the instruction was initially approved and verbally approved to be performed as well as Operations' cognizance of plant condition at the time of the verbal approval.
It was concluded that although the reviews appear to have been adequate, the authorization to perform the instruction was not documented properly. An additional review of related provisions of SSP-8.1 was performed to evaluate the adequacy of controls for reauthor ization of delayed test activities.
It was further determined that controls for reauthorization of delayed test activities may not be fully understood by Operations' personnel when Operations' personnel are serving as the test director.
Additional details cancerning this event were provided in Licensee Event Report 50-327/91020 dated August 21, 1991.
Corrective Actions That Have Been Takun and Results Achieved The ACOs responsible for incorrectly positioning the valvas have received appropriate disciplinary action for their failure to follow procedures.
A memorandum was issued on August 7, 199t, to Operations personnel directing the reactor operator (RO) and che sRO to ensure that a pretest briefing is performed in the MCR by the test director for tests performed by the 0,nerations section tnat involve the inanipulation of plant equipment.
This will ensure that testing is deknowledged by the MCR staff and increase the awareness of the Ros and SR0s of plant configuration.
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s Corrective Actions To Be'Taken to-Avoid Further Violations
.An Operations review team'will evaluate this event relative to the role that communications played.
The results of this evaluation will be discussed with-Operations personnel as " lessons learned" inf ormat ion.
These actions will'be completed by September 20, 1991.
Test director: responsibilities are being reinforced to Operaticas' personnel during turnover-meetings.
Retraining, testing, and Operations emnager certification of test directors and the responsible managers are being
. performed as a -result: of several events to ensure pr 3per understanding of requirements for conduct of testing.
Given the importance of this function
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and to further ensure that-test directors clearly understand their
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responsibilities and management's expectations, the selection and qualification of test directors are being controlled by a senior plant ma nag e r. - This is intended 4o ensure that an adequate level cf exper'.ence-for each individual-evolution is maintained during the perf ormance and during the I
review of test results to obtain a thorough and accurate finished product for i
plant. instructions.. This training will be complete by October 1,1991.
Date When Full Compliance Will Be Achieved TVA is in full compliance.
-PLO90204/99 t
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