ML20113H582
| ML20113H582 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 07/31/1992 |
| From: | Medford M TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF ENFORCEMENT (OE), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9208050056 | |
| Download: ML20113H582 (6) | |
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y.,s t e July 31, 1992 Director, Office of Enforcement U.S. Nuclear Regulatory Commisalon Attna Document Control Desk Washington, DC 20553 Gentlement In the Matter of
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Docket Nos. 50-327 Tennessee Valley Authority
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50-328 SEQUOYAH NUCLEAR PLANT (SON) - REPLY TO NOTICE OF VIOLATION (NOV) AND PROPOSED IMPOSITION Or CIVIL PENALTY (NRC OF/ ICE OF INVESTIGATIONS REPORT NO. 2-90-019)
Pursuant to 10 CPR 2.201, this letter and Enclosure 1 providos TVA's reply to S. D. Ebneter's letter to M. O. Medford dated July 2,
- 1992, which transmitted the subject NOV and proposed imposition of a civil penalty resulting from findings of the NRC's Office of Investigations.
Where appropriate, TVA's reply incorporates by reference information provided to NRC by.TVA's previous correspondence on this matter dated May 20, 1992.
Payment of the proposed civil penalty in the amount of
$75,000 is being made by electronic fund transfer.
A list of commitments la contained in Enclosure 2.
TVA fully recognizes the significance of these events.
In particular, we share NRC's concern that in this situation, the TVA personnel aware of
-the status of unissued Cable Test Program Calculation SON-CSS-009 did not immediately take action to assure the validity of the calculation.
We are also concerned that the status of the calculation was not conveyed to other organizations within TVA.
This breakdown in communication is the primary reason for TVA's failure to provide complete and accurate information to NRC.
As NRC recognisas in its cover letter accompanying the HOV, prior to this enforcement action, TVA had initiated long-term corrective action to change personnel attitudes-about problem reporting and to ensure the completeness and accuracy of information provided to NRC.
As described in our reply, additional actions have been taken to reinforce the importance of open and forthright communications with URC.
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Director, Office of Enforcement Page 2 July 31, 1992 Questions regarding TVA's response may be directed to Mark J. Bursynski at (615) 751-2687.
Sincerely, f
Yl Mark O. Medford l
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Sworn t nd subscribed before me this
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Notary Public
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My Commission Expiros Enclosures cc (Enclosures):
U.S. Nuclear Regulatory Commission Region 11 101 Marietta Street, NN, Suite 2900 Atlanta, Georgia 30323 Mr. D. E. LaBarge, Project Manager U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 NRC Resident inspector Seguoyah Nuclear Plant 2600 Igou Ferry Road Soddy Daisy, Tennessee 37379 a.
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ENCLOSURE 1 i
Reply to Notice of Violation j
(NRC Office of Investigntlons Report No. 2-90-019) i 4
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10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, requires, in a
part, that measures be established to assure that conditions adverse to quality such as failures, malfunctions, and deficiencies be promptly l
identified and corrected.-
Contrary ~to the above, an early as July of 1989 several managers at TVA learned of cor.ditions-adverse to quality which includes that calculation SON-CSS-009 had not been signed and issued, that the calculation had at least one counting error, that portions of data in the appendices were j
missing the_ signature of tJun preparer and checker, and that the number of electrical conduits which met specified criteria _ identified in the t
calculation and its attachments could not be reproduced from the data in the appendicea,_and that those managers failed to initiate corrective action.
Subsequently, the licensee determined the calculation was in error, resulting in the necess'lty to test additional cables.
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B.; 10 CFR 50.9 requires, in part, that information provided to the Commission by a licensee be complete and accurate in all material respects.
Contrary _to the above, the licensee failed to provide complete and accurate information in a March 28, 1990 submittal to the Commission regarding the licensee's review of the Sequoyah Nuclear Plant (SQN) Cable Test Program.
The' licensee became aware during 1989 that the 1987 SON Cable Test Program was incomplete-as it rolled upon an unissued calculation (SQN-CSS-009), The calculation was used to perform the selection of the worst-case'condults for-testing. The March 28, 1990 submittal inaccurately represented the' tested conduits as worst case, i
inaccurately stated that_the.results of the 1987 program.were still accurate, and failed to indicate that the 1987 program hed not been completed, The inaccurate and incomplete submittal was material in that, had NRC been aware of'the complete and accurate information, there would have been substantial further inquiry by NRC, such as a formal request for information. This failure was also material-because-further testing was necessary when the inaccuracles were identified.
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TVA' admits the violations.
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EnatonsJnr_tha._Y191s119na Elolation_A The violation eccurred because of insufficient sensitivity to the importance of prompt problem identification and resolution.
Contributing factors included con,peting priorities, perceived resource constraints, and lack of knowledge that Calculation SON-CSS-009 contained substantive errors.
These circumstances are discussed more fully in TVA's May 20, 1992 letter (response to Question 2).
Yinantinn_D The violation occurred because at the time the March 28, 1990 letter was submitted action had not been taken to determine whether the calculation was valid and because the unissued status of Calculation 009 was not viewed as significant.
As indicated in TVA's May 20, 1992 letter (response to Questions
_2 and 4d), prior to the March 28,-1990 letter, TVA employees apparently limited to the_ electrical engincoring discipline knew that C31culation 009 was not issued and knew of one counting error, but did not know of other errors in the calculation. Neither the calculation's unissued status nor its counting error were viewed as significant. Had prompt action been taken to review, approve, and issue Calculation 009 at the time it was first identified as being unissued, the administrative problems and substantive errors subsequently found to exist in the calculation would most likely have been identitled.
Other TVA organizations involved in the preparation and approval of the March 28, 1990 letter were not infermed'of the calculation's unissued status or of the fact that it contained a counting error. As indicated in TVA's May 20, 1992 letter (response to Question 4b), TVA relied on the knowledgeable engineering personnel to ensure that the letter was technically correct and supporting documentation was prepared.. The Engineering organization's concurrence with_ respect to the technical adequacy of the letter, and the absence of knowledge regarding Calculation 009's afstus, did not allow other TVA personnel to question the statements subsequently determined to be inaccurate, the completeness of the letter, or the appropriateness of relying on.an unissued calculation in the Cable Test Program.
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-As indicated during its Enforcement Conference presentation, concurrent with the events that are the subject-of this enforcement _ action, TVA recognized that there_was inrufficient sensitivity to the importanto of problem L
identification.
In response, TVA took steps during the first half of 1990 at SON to change poreonnel attitudes about problem identification. These actions
-included lowering tho threshold for incident investigations and instituting a restructured problem identification program that utilized a single problem
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reporting document.
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The TVA Office of the Inspector General (OIG) made several recommendations based on the events it had investigated, and action was taken in response to those recommendations.
TVA's actions in response to the OIG's recommendations are discusse( at length in the May 20, 1992 letter (response to Question 7).
In brief, these actions included discussing the findings of the OIG report with the TVA employees involveds requiring use of the Calculation Cross Referonce Index System (CCRIS) for tracking calculations from the time the need for a calculation is identified; and taking additional steps, primarily in the form of additional training, to ensure the completeness and accuracy of communications with URC.
TVA's May 20, 1992 letter (response to Question 7) also described the results of an independent ansessment of engineering work practices performed by an outsido consultant in the fall of 1991. The Engineering organization avaluated the consultant's conclusions and observations and found that a number of recommendations had been or are being implemented. These include improvements in the areas of calculations, procurement of engineering services, corrective action, design verification, testing / engineering support, training, and clarification of site and corporate engineering responsibilities.
Carnctin_Ricp a._That_1lill.JA_T oken_Tn_ Avoid _In tihur_liolellon a Subsequent to TVA's May 20, 1992 letter and its Enforcement Conference presentation, several relevant TVA procedures were reviewed to determine whether any clarification regarding the nebd for complete and accurate information might be appropriate. TVA Business practice (Bp) 213, " Managing TVA's Interface with NRC," incorporates the requirements of 10 CFR 50.9 and is used to define the requirements that must be satisfied by TVA organizations prior to any cominunication, whether written or ora 2, with NRC.
TVA Standard 4.5, " Regulatory Reporting Requirements," specifies the requirements for various reports to NRC and other regulatory agencies to ensure compliance with applicable reporting requirements. The administrative requirements of Bp-213 are applicable to the reports prepared in accordance with Standard 4.5, and in practice TVA is now implementing the requirements of 10 CFR 50.9.
However, to ensure that the need for completeness and accuracy is recognized by the individuals preparing reports submitted to NRC, the requirements of Section 50.9 are being incorporated into a revision of Standard 4.5.
Included in this revision is the requirement to report information having significant implications for the public health and safety or the common defense and security. The revision will be issued by August 30, 1992.
DALLHhen. lull. Compli AncLWill_Ba_ Achieve.d TVA is in full compliance.
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