ML20115C185

Forwards Response to Violations Noted in Insp Repts 50-327/96-04 & 50-328/96-04.Corrective Actions:Listed SIs Placed on Administrative Hold,Appropriate Disciplinary Action Taken & Assessment of Controlled EPIPs Performed

ML20115C185
Person / Time
Site:	Sequoyah
Issue date:	07/05/1996
From:	Adney R TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9607110203
Download: ML20115C185 (11)

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i Tennessee Valley Authority, Post Office Box 2000, Soddy-Daisy. Tennessee 37379-2000 R.J Adney l Site Ace President l Sequoyah Nuclear Plant  ;

L July C,1996 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Gentlemen: ,

i in the Matter of ) Docket Nos. 50'327 Tennessee Valley Authority )60-328  ;

SEQUOYAH NUCLEAR PLANT (SON) - NPC INSPECTION REPOR1 NOS. 50-327, I 328/96 REPLY TO NOTICE OF VIOLATIONS (NOVs) 50-327,328/96-04 Enclosed is TVA's reply to Mark S. Lesser's letter to Oliver D. Kingsley, Jr., dated June 5,1996, which transmitted the subject NOVs. The violat;ons arc associated with procedure inadequacies, failure to follow procedures, and f ailure to comply with regulatory requirements.

Of the five violations cited, one was in the Operations area, and four were associated with our Emergency Preparedness Program (EPP). Enclosure 1 contains TVA's response to the NOVs. As noted in the response to the specific violations, TVA is denying one of the cited violations associated with the EPP, as well as one of the enmples cited in another EPP violation. The remaining EPP violations indicate . lack of attention to detail in carrying out various program elements; however, based on recent graded exercises and TVA drills, we do not believe the violations represent a decline in performance. Additionally, TVA has taken aggressive steps to ensure that performance does not decline in this area. These steps are described below and within the response to the notice of violation.

^ s you know, the SON EPP has long been considered by TVA and NRC as a strong and affective perforer. In view of NRC's inspection findings, TVA conducted a comprehensive seH avessment of the SON EPP ucing personnel from Browns Feny  !

and Watts Bar Nuclear Plants and our corporate office. This assessment evaluated )

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• , 1 U.S. Nuclear Regulatory Commission Page 2 July 5,1996  ;

pro 0 ram administration, training, procedures, maintenance of equipment, and tracking of drill critique items. Only minor attention to detailissues were identified, anJ those issues have been corrected. In addition, the assessment also recommended that SON perform a site accountability drill based on the activation of a new security system in

! th fall of 1995. The accountability drill was successfully performed on i June 25,1996. The results of the self-assessment provided us with additional confidence that the SON EPP will remain a strong performer.

l As indicated to you in responso to NRC Inspection Reports 50-327,328/95-26,

! 95-27, and 96-02 and in a meeting on May 29,1996, SON has taken extensive corrective actions to improve personnel performance at the site, particularly in regard to procedure adherence. These corrective actions apply to the issues identified in the subject inspection report rti will help ensure continued progress. f Commitments associated with the submittal are included in Enclosure 2.

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If you have any questions concerning this submittal, please telephone me at (423)843-7001.

Sincerely, r

l R. .Adney I

Enclosures cc (Enclssures):

l Mr. R. W. Hernan, Project Manager Nuclear Regulatory Commission i One White Flint, North i 11555 Rockville Pike Rockville, Maryland 20852-2739 NRC Resident inspector ,

I Sequoyah Nuclear Plant i 2600 lgou Ferry Road  ;

j Soddy-Daisy, Tennessee 37379-3624 l

1 Regional Administrator j U.S. Nuclear Regulatory Commission  !

i Region ll 101 Marietta Street, NW, Suite 2900 i Atlanta, Georgia 30323-2711 i

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ENCLOSURE 1 _

i RESPONSE TO NRC INSPECTION PEPORT NOS. 50-327,328/96-04 i MARK S. LESSER'S LETTER TO OLIVER D. KINGSLEYiJR. ,

DATED JUNE S,1996 VIOLATION 50-327.328/96-04-02

" Technical Specification 6.8.1.a requires, in part, that procedures shall be established, '

implemented, and maintained covering the activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978," Quality Assurance Program Requirements (Operations)." Appendix A of Regulatory Guide 1.33, Section 1 includes administrative procedures for shift and relief turnover and log entries and  ;

Section 8 provides procedures for surveillance tests. '

1. 2-SI-OPS-082-26.A, LOSS OF OFFSITE POWER WITH SAFETY INJECTION-DG 2A-A CONTAINMENT ISOLATION TEST, Revision 11, Section 6.10, Return to r Normal, requires that systems be returned to their no mal alignment following  ;

performance of the test.

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2. 2-SI-IRT-099-699.A, RESPONSE TIME TEST OF ESFAS SAFETY INJECTION  :

SIGNAL WITH STATION BLACKOUT TRAIN A, Revision 1, Section 7.2, Restoration, requires that equipment be a;igned as desired for plant conditions upon completion of the response time testing.

3. 2-PI-OPS-000-038.1, AUXILIARY BUILDING AUO DUTY STATION SHIFT REllEF ,

AND ROUNDS SHEETS- MODES 5 & 6, Revision 3, Appendix B, Rounds Sheets, l requires that the Spent Fuel Pit temperature be logged each day during the day j shift.

" Contrary to the above, the followir g examples of procedures were either inadequate or not followed and contributed to the loss of cooling to the Spent Fuel Pool for apporximately 28 hour3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br />s:

1. On April 22,1996,2-SI-OPS-082-026.Awas inadequate in that it did not contain instructions for restoration of the Spent Fuel Pit Cooling.

2. On April 23,1996,2-SI-IRT-099-699.Awas inadequate in thet it did not contain instructions regarding the tripping of the C S spent fuel pit pump and did not contain instructions for restoration of the Spent Fuel Pit cooling system following the test. Furthermore, 2-SI-IRT099-699.Awas inadequate in that it incorrectly l indicated that the A spent fuel pit pump was required for the response time test.

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3. On April 23,1996,2-PI-OPS-000-038.1 was not followed in that the Aux;liary Building Assistant Unit Operator failed to record the Spent Fuel Pit temperature as required.

"This is a Severity Level IV Violation (Supplement 1)."

Reason for the Violation The root cause of the violation was inadequate procedural guidance resulting in the failure to restore spent fuel pool cooling (SFPC) after the completion of testing. Some equipment require multiple restorations because of alignments and actuations that result from individual test segments contained in the surveillance instructions (Sis) identified in the subject violation. The signoff for " Return to Normal" of equipment affected by testing was contained in only one SI. After the completion of a test segment, Operations personnel would restore the affected equipment as soon as practical by using the applicable portions of the " Return to Normal" section. Since only one signoff existed for the SFPC system and that signoff had been completed for an earlier test segment, Operations personnel that performed a subsequent test segment believed that the SFPC system restorations had already been completed.

This resulted in the SFPC system not being returned to normal. The procedure containing the " Return to Normal" signoff did not have guidance to indicate that additional return to normal verifications were necessary. Additionally, one of the Sls contained incorrect information. Test alignment required the A-A spent fuel pit pump to be started for performance of the Si instead of the C-S spent fuel pit pump. This is in error because the A-A pump is not affected by the Si performance. The SI performance resulted in the C-S pump being removed from operation. Removing the C-S pump from service resulted in the termination of cooling to the spent fuel pool.

A contributor to fuel pool heat-up was inadequate awareness of and sensitivity toward the SFPC system. This inadequate watch standing is exemplified by the following: 1) field operators did not monitor the system closely enough to detect the misalignment before the high temperature alarm annunciated in the main control room,2) the pool temperature was not recorded during one of the operator rounds, and 3) the data sheet omission was not identified during the review.

Inadequate procedural guidance also contnbuted to the increase in pool temperature.

The associated periodic instruction (2-PI-OPS-000-038.1)specified a nominal temperature range of 70 to 150 degrees Fahrenheit (F) which was not consistent with

alarm annunciation. The high temperature alarm setpoint is 125 degrees F.

Corrective Actions That Have 8een Taken and the Results Achieved l Sls 1- and 2-SI-OPS-082-026.A have been placed on administrative hold to prevent use until the instructions are revised. The performance of these procedures and 1- and 2-SI-lRT-099-699.A occur on a refueling outage frequency.

i The appropriate disciplinary action has been taken relative to the failure to record the spent fuel poo; temperature and the omission dJring the review of the periodic instruction data sheet. The importance of comparing recorded data to expected parameters while walking down a system has been stressed with Operations j personnel. The past performance of the individuals involved has been reviewed and l

found to be good. Management monitoring and coaching in the plant and during ,

l training has been extensive, and personnel performance is improving. Observations l from these activities are reviewed weekly and no generic operator watch standing l deficiency has been ' ' 'ified. l The period % instructions used for monitoring fuel pool temperature have been revised to reduce the temperature band, consistent with alarm annunciation. Additionally, the instruction revision enhanced the fuel pool monitoring frequency from once every ,

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to once each 8-hour shift. j The Corrective Steos Taken to Avoid Future Violations The appropriate procedures will be reviewed at.d revised to correct testing inadequacies relative to equipment alignmc.n cr.c restoration which resulted in the violation. The procedures that will be reviewed and revised are performed on a refueling outage frequency. The necessary procedure revisions will be completed by January 24,1997, which is before the next use during the Unit 1 Cycle 8 refueling outage. An independent assessment of operator watch standing will be performed by August 9,1996, to evaluate the quality of operator performance.

Date When Full Comoliance Will be Achieved With respect to the examples cited, TVA will be in full compliance by January 24, 1997 after placedure revisions are completed.

VIOLATION 50-327,328/96-04-06

" Technical Specification 6.8.1.e identifies the Siw Radiological Emergency Plan implementation as written procedures that shali be established, implemented and maintained.

" Contrary to the above, on April 3,1996, NRC identified that the Emergency Plan Implementing Proccbares were not adequately maintained. The following out-of-date procedures identified:

1. In the Controi Room, Revision 17 of the Emergency Plan implementing, Procedure - 1 (EPIP), " Emergency Plan Classification Matrix," was placed in back l

of and behind EPIP-1 Revision 16 tabs. Revision 16 had not been removed as

required.

2. In the Technical Support Center (TSC), three of the four controlled volumes of l

EPIPs in the TSC, contained old revisions for EPIP 6, " Activation And Operation i Of The Technical Support Center".

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3. The licensee maintained and controlled volume of the EPIPs in the NRC office, l contained old revisions of EPIP 4, " Site Area Emergency," EPIP-5, " General Emergency", and EPIP-6, " Activation And Operation Of The Technical Support Center."

"This is a Severity Level IV violation (Supplement Vill)."

Reason for the Violation The cause of the violation was personnel error in that personnel performing procedure filing duties did not perform adequate self-checking. Interviews conducted with these ,

individuals indicated that the proper performance of self-checking following the filing I of procedures would have precluded these errors. 1 Corrective Actions That Have Been Taken and the Results Achieved Errors identified by the NRC inspector were immediately corrected. A full assessment of controlled EPIPs at SON was performed. Tha ascessment indicated that the majority of the filing errors were associated with procedure attachments. Additional random assessments were performed of other controlled documents in the main control room and site libraries which indicated an average error rate of 0.8 percent.

Errors identified by these assessments were immediately corrected. In addition, a '

review of previous assessment results for assessments performed over the past year of a variety of documents (including EPIPs) filed in key distribution points revealed an average error rate of 0.6 percent. Based on these and previously performed assessments, it was determined that no adverse trend relative to filing errors existed.

The Corrective Steos Taken to Avoid Future Violations Filing errors that were identified in the EPIP inspection and subsequent assessments were discussed with the appropriate employees to stress the importance of accurately filling procedure changes. EPIP attachments have been integrated into the controlling EPIPs, except for call-in lists. Call-in lists will continue to be an attachment to the Le:Ps.

Date When Full Compliance Will be Achieved With respect to the examples cited, TVA is in full compliance.

VIOLATION 50-327,328/96-04-07 "10 CFR 50.47(b)(8) requires that adequate emergency facilities and equipment to support the amergency responsa are provided and maintained. Section 8.1.5,

" Equipment, Supplies, and Supplemental Data," of Sequoyah's Radiological Emergency Plan requires the site to have sufficient equipment and supplies for the operation of the site emergency facilities. Emergency Plan Implementing Procedure

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• l (EPIP)-17, Emergency Equipment and Supplies, Appendix 1, identified ten emergency two way radios (with batteries) and ten spare batteries as equipment to be provided and maintained.

" Contrary to the above, on April 13,1996, batteries for the emergency two way radios in the Operational Support Center were not adequately maintained. When the twenty batteries were tested,it was determined that six of the batteries were discharged and not capable of being charged, and ten were marginal.

"This is a Severity Level IV violation (Supplement Vill)."

Reason for the Violation The cause of the violation was personnel error in that personnel responsible for i equipment maintenance incorrectly believed that they understood the operation of the battery analyzer and the associated indicator codes. This resulted in six discharged batteries and ten other batteries being maintained in a marginal condition.

Corrective Actions That Have Been Taken and the Results Achieved

Batteries that were identified as discharged or marginal at the time of the inspection

! were replaced. Personnel responsible for equipment maintes ance have reviewed tl.e vendor supplied instruction manual on the battery conditiceu/ analyzer and underr.tand the operating methodclogy. A preventive maintenance (PM) instruction has been

! revised to include the requirements for battery rotation, automatic reconditioning, and analysis of each battery consistent with battery conditioner / analyzer documentation.

The PM is performed on a monthly basis. A subsequent PM review indicates that the batteries for the Operations Support Center two-way radios are being properly

! maintained. Equipment maintenance for other Emergency Preparedness (EP) l equipment was reviewed to ensure that maintenance requirements are appropriate.

No other problems were identified.

The Corrective Steos That Will be Taken to Avoid Future Violations The corrective actions to prevent future violations are complete as stated above. The r ppropriate personnel have been counseled on management's expectations relative to onderrtanding equipment operation under their responsibility.

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, Date When Full Compliance Will be Achieved i With respect to the examples cited, TVA is in full compliance.

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VIOLATION 50-327.328/96-04-08 "10 CFR 50.54(q) requires that a licensee authorized to possess and operate a nuclear power reactor to follow their emergency plan. Section 15.1, Training, Onsite, of l i

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l l - Sequoyah's Radiological Emergency Plan states that personnel with specific duties l

involvim the Radiological Emergency Plan, will have initial training classes and annual  ;

retrainiq).

" Contrary to the above,

1. On April 17,1996, the NRC identified that the seven Technical Support Center i Radeon personnel had not received their annual retraining in 1995,in the use of Forecast Radiological Emergency Dose. Their training expired on January 1, 1996.

2. On April 17,1996, the NRC identified that the Shift Technical Advisors had not received their required annual retraining on procedure 0-TI-CEM-030-030.0,

" Manual Offsite Dose Calculation [ sic)."

"This is a Severity Level IV violation (Supplement Vill)."

Reason for the Violation l

Regarding the first example contained in the violation, TVA does not agree that the

! selected Radiological Control personnel were required to receive an'1usi retraining in

the use of the Forecast Radiological Emergency Dose (FRED) program. TVA's

Radiological Emergency Plan (REP) does not require site personnel to use FRED or any other offsite dose assessment or projection methodology. (A more detailed discussion l of the use of offsite dose calculation methodology is contained in TVA's response to l Violation 50-327,328/96-04-10.) TVA's REP, Section 15.1, Training, Onsite, l requires initial training and annual retraining of " personnel with specific duties

! involving the REP." While some initial training in the use of FRED was provided to selected Radcon personnel, this training was provided on a one-time basis for informational purposes. TVA did not intend for annual retraining to occur since TVA had not committed to use the FRED program onsite. At the time the training took l place, TVA believed that providing information about FRED and its capabilities would benefit TVA's EP program overall. TVA should not now be penahzed for taking proactive measures to increase awareness about offsite dose assessment capabilities.

Regarding the second example contained in the violation, TVA agrees that a violation occurred. The cause of the violation was a failure to recognize the differences in training frequencies between operator and EP program-related training requirements.

l The initial training on this procedure was provided to shift technical advisors (STAS) with retraining on a frequency consistent with operator requalification. As a result of

the difference in training frequencies between the operator requalification training and EP training, the STAS did not receive EP training within the required EP frequency.

Although STA were not trained at the required intervals, they were capable of implementing procedure 0-TI-CEM-030-030.0. STA knowledge was verified at annual

intervals by overview by appropriate EP personnel.

I For the purpose of clarification within this second example as stated by the NRC, Procedure 0-TI-CEM-030-030.0is entitled " Manual Calculation of Plant Gas, lodine 1

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l and Particulate Release Rates for Offsite Dose Calculation Manual (ODCM)

Compliance." This clarification is important because the procedure is not an offsite dose assessment or projection procedure; rather, it is a radioactive release rate calculation procedure that provides source term data intended to alert the operators about approaching ODCM limits and radioactive limits at the site boundary.

Corrective Actions That Have Been Taken and the Results Achieved The EP program has been redefined to remove the training process interface. Upon identification of the condition, eight individuals (six Chemistry shift supervisors and two EP personnel) were trained on Procedure 0-TI-CEM-030-030.0. This training provides source term data capabi!ity in accordance with the Radiological Emergency Plan (REP). The shift technical advisors have been informed that they are no longer required to perform these activities. Operations' shift managers have been informed that the Chemistry shift supervisors are the individuals assigned the duties. This change in duty assignment enhances main control room performance by reducing operator burden. Additionally, pr% ram interfaces between the EP program and other site programs were reviewed to ensure that the interfaces are appropriate. No other problems were identified by he review.

The Conective Steos That Will be Taken to Avoid Future Violations l The corrective actions to prevent future violations are complete as stated above.

Date When Full Comoliance Will be Achieved With respect to the examples cited, TVA is in full compliance.

1 VIOLATION 50-327.328/96-04-10 j i

"10 CFR 50.54(q) requires that a licensee authorized to possess and operate a nuclear power reactor to follow their emergency plan. Section 9.2.4, Dose Assessment, of the Sequoyah's Radiological Emergency Plan states that releases of radioactivity are analyzed by the plant staff. A preliminary dose projection is performed following receipt of measured effluent release data and meteorological data. The preliminary dose projection is followed up by a moro detailed assessment using computerized dose models. Manual dose assessment methods are available for use in the event that the computer is unavailable.

" Contrary to the above, on April 16-17,1996, the NRC identified that a preliminary dose projection could not be performed in that the Shift Technical Advisors were not i trained in the use of Forecast Radiological Emergency Dose, the licensee's

( computerized dose assessment methodology and no procedure existed for manually j calculating an offsite Dose Assessment.

"This is a Severity Level IV violation (Supplement Vill)."

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. I TVA Resocnse TVA denies that a the violation of NRC requirements exists in this instance.

TVA's REP does not require the pant staff to perform offsite dose assessment.

Within TVA's REP, Section 9.2.4, ' Dose Assessment" states, in part

"Offsite doses from accidental releases of radioactivity are estimated using a combination of calculations, field measurements and laboratory analyses of environmental samples. Data on meteorological conditions are used in i determining offsite dispersion factors. Using plant operational data, field measurements, and effluent monitor readings, actual or potential releases of radioactivity are analyzed by the plant staff and/or the CECC Plant Assessment Team to generate or modify a source term for use in the dose assessment."

"With this information, the CECC dose assessment team can predict offsite doses through the use of several models and/or methods described in the CECC-EPIPs. These models provide a means of estimating public exposures throughout the emergency and recovery period. Environs measurements are used, to the extent possible, to confirm doses projected by modeling."

i The REP is SON's licensing basis document. In accordance with the REP, site personnel are fully capable of analyzing actual or potential releases of radioactivity to generate source term data. This data is provided to the Central Emergency Control Center (CECC) dose assessment team. The CECC Team provides preliminary dose projections using source term and meteorological data, followed by a more detailed assessment using computerized dose models.

Because the REP does not require site personnel to be capable of performing the offsite dose projections, NRC is incorrect in asserting that the REP requires the STAS to perform such projections. Therefore, it is improper for NRC to cite TVA for faVing to follow its REP as the basis for this violation.

Additionally, NRC is incorrect in stating that no procedure existed for manually calculating an offsite dose assessment. CECC EPIP-8, " Dose Assessment Staff Activities During Nuclear Plant Radiological Emergencies," is used by the CECC dose assessment team. This procedure describes several methods and models for offsite dose assessments, including both manual and computerizad models. l For the reasons stated above, TVA does not believe that any violetion of its REP or NRC's requirement took place.

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ENCLOSURE 2  ;

COMMITMENTS FOR RESPONSE TO NRC INSPECTION REPORT NOS. 50-327,328/96-04 MARK S. LESSER'S LETTER TO OLIVER D. KINGSLEY, JR.

DATED JUNE S,1996  :

L NOV 50-327,328/96-04-02

1. The appropriate procedures will be reviewed and revised by January 24,1997, l to correct testing inadequacies relative to equipment alignment and restoration l that resulted in the violation. '

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2. An independent assessment of operator watch standing will be performed by August 9,1996, to evaluate the quality of operator performance.

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