ML20113H586
| ML20113H586 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 07/31/1992 |
| From: | Medford M TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9208050061 | |
| Download: ML20113H586 (5) | |
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me are Mmk O Medfard V m Fewrq tmW Assm e lie eg aM Fw July 31, M U.S. Nucicar Regulatory Comission 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 SEQUOYAH NUCLEAR PLANT (SQN) - NRC INSPECTION REPORT NOS. 50-327, 328/92 REFLY TO NOTICE OF VIOLATION (NOV) 50-328/92-17 AND PROPOSED IMPOSITION OF A tIVIL PENALTY The enclosure contains TVA's reply to Stewart D. Ebneter's letter to me dated July 2, 1992, which transmitted the subject NOV and proposed imposition of a civil penalty. This violation portains to the entry into and operation in Mode 4 without two operable containment spray subsystems. The specifie svent resulted from the f ailure of operating personnel to properly implement the configuration control process.
The event associated with this violation was previously reported in accordance with 10 CFR 50.73 by Licenseo Event Report 50-328/92007.
There are no new commitments associated with this response, payment of the proposed civil penalty in the amount of $75,000 is being mado by electronic fund transfer.
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' July 31, 1992 If you have any questions concerning this submittal, please telephone M. A. Cooper at (615) 843-8924.
Sincerely, l
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Mark O. Medford Sworn and subscribe before me t.his day of.
1992 Notary Public My Comission Expires Enclosure cc (Enclosure):
Mr. D. E. LaBarge, Project Manager U.S. Nuclear Regulatory Comis -lon One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 NRC Resident Inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy-Daisy, Tennessee 37379 Mr. B. A. Wilson, Project Chief U.S. Nuclear Regulatory Comission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323
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ENCLOSURE REPLY TO NOTICE OF VIOLATION NRC INSPECTION rep 0RT NOS. 50-327/92-17 AND 50-328/92-17 STEWART D. EBNETER!S LETTER TO M. O. M3DFORD DATED JULY 2, 1992 Violation 50-328/92-17 l
" Technical Specification (TS) Limiting Condition of Operation (LCO) 3.0.4 requires, in part, that entry into an Operational Mode shall not be made unless the Limiting Condition for Operation (LCO) is met. TS 3.6.2.1 LCO requires, in part, that in MODE 4, two independent containment spray subsystems shall be OPERABLE with each system comprised of, in part, an OpEPAHLE Containment Spray pump flow path capable of taking ruction from
":' refueling water storage tank, t
- ary to the above, on May 7, 1992, the requirement for TS LCO 3.0.4 s
t followed in that TS 3.6.2.1 LCO was not met when the unit entered
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t from MODE 5.
Unit 2 was in MODE 4 with both trains of the inment Spray _ Subsystems inoperable from 5:48 p.m. on May 7, 1992, 3:30 a.m. on May 8, 1992, due to the pump suction valves from the a faling water-storage tank being shat.
~"This is a Severity Level III violation (Supplement I).
" Civil penalty - $75,000" Reason for the Violation Failure to appropriately control configuration resulted in failure to ensure that Technical Specification Limiting Condition for Operation (LCO) 3.6.2.1,'which requires two independent containment spray subsystens-to be operable in hudes' l-4, was satisfied. Technical Specification 3.0.4-prohibits entry into an " operating mode" unless LCOs are satisfied.
-During the time period of April 30 to May 3, 1992, several test activities were conducted, requiring containment spray system operation.
Following completion of these activities, operators closed the auction valves to ensure that maintenance activities did not result in a flow
. path from the refueling water storage tank to the containment cump. This action was not positively controlled by uso of the configuration control process. However, operators believed that procedural exceptions allowed these manipulations without a configuration log entry and that other pre-mode change activities would result in-the valves being placed in the correct configuration.
1due failure to appropriately contcol configuention was caused, in part, by operating personnel not oppreciating the importance of rigorous and consistent application of operational tools. The tools, such as
- configuration control, shif t turnover, proceduro use, and daily journal entries-wore-viewed'as requirements; the usefulness of these requirements for performing everyday activitics was not recognized. For example, l
Operations personnel had, in some cases, considered that " paperwork" was more of a formality and a hindrance in performing duties than an opportunity to help them avoid mistakes.
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o Additionally, overall performance of some Operations personnel did not meet expectations. In the conduct of the periodic instructions in the daily shif t turnover and durlug performance of evolutions on the containment spray system, several operators did not question the valvo positions and, as a result, did not ensure system flowpath alignment.
Corrective Actions Taken and Results Achieved Upon discovery of the condition, hCO 3.0.3 was entered, the containment spray pump suction valves were opened, and LCO 3.0.3 was exited. A "stop work" action was implemented until plant configuration was verified.
A walkdown of the main control room switch and benchboard alignments for Units 1, 2, and common was conducted, which included recording the as-found condition and comparing it to the status files. As a result of this effort, the plant status was determined to be consistent with the required configuration with the exception of two pressurizer relief tank 3
valves for each unit, which were in the position desired but not logged as such upon discovery; a configuration log entry was made to document the position of these valves.
As interim measures to restore confidence in configuration control acceptability, a standing order was issued that disallowed use of procedural exceptions to the configuration control process.
It also required routine control board walkdowns during shift turnover for licensed positions to be conducted jointly by the outgoing and incoming shift personnel; off-normal conditions are now required to be supported by a journal entry.
Additional resteletions on tagging out suction valves were slso implemented by the standing order, and configuration log entries are now required for in-progress surveillance instructions, system operations, and system operating ir.structions that require deviation from the normal system status file alignment.
Meetings were conducted between the Operations Manager and Superintendent and the on-shift crews. Recept Sequoyah Nuclear plant (SQN) operatio..al events and Operations' performance relative to those events were discussed at those meetings. The use of basic operational tools, such as configuration control shif t turnover, procedure uso, and daily journal entries as an aid in performing duties was discussed in detail.
The absence of propcr use of operational tools in recent events was evaluated, and the need for rigorous, consistent application of operational tools in everyday performance of work was stressed.
To effect overall, long-term performance improvements, a meeting was conducted with the on-shift assistant shift operations supervisors (ASOSs) to discuss performance and required improvements. The Plant kanager opened the meeting by discussing his perception of Operations' performance and his expectations for the ASOSs regarding improvement.
The ASOSs ware tacked with identifying problem areas, and recommending and implementing associated solutions.
The ASOSs evaluated performance and determinod appropriate methods to implement improvements.
Initial improvements involved professionalism, delegation of responsibilities, shift manning, succession planning and encouraging performance, senior
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reactor operator input to plant work activities, communications, and configuration control, preliminary results were demonstrated immediately in several areas, including professionalism, delegation of responsibilities, and configuration control.
As an ongoing effort to achieve long-term performance improvements, the Asoss will continus those meetings regularly to identify weak areas and correct the weaknesses.
Corrective Steps That Will be Taken to Avoid Further Violations specific-corrective actions regarding configuration control process improvements are being developed. A task force is being convened to review the contiguration control procons. This effort is intended to streamline, clarify, and simplify the process and eliminate ambiguity, as needed. Administrative instructions will be revised, as appropriate, to incorporate the results of the task force review.
In-depth training on the revised configuration control process will be conducted with affected personnel following the upgrado of the requirements.
Additionally, improvements in performance monitoring are being implemented that better quantify day-to-day performance icvels and, therefore, provide a better indication of long-term et'f.ct' ness of current initiatives.
Date When Full Compliance Will he Achieved SQN is in full compliance.
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