ML20116C589
| ML20116C589 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 10/29/1992 |
| From: | Medford M TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF ENFORCEMENT (OE), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9211040172 | |
| Download: ML20116C589 (5) | |
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October 29, 1992 Director, Office of Enforcement U.S, Nuclear Regulatory Commission ATTN: f$ocument Control Dusk Washington, D.C.
20555 Centlemen:
In the Matter of
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Docket. Noe. 50-327 Tennesseo Valley Authority
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50-328 SFQUOYAH NUCLEAR PLANT (SQN) - NHC INSPECTION rep 0RT NOS. 50-327, 50-328/92 REPLY TO NOTICE OF VIOLATION (NOV) 50-327/92-29 AND pHOI'OSED IHp0 SIT 104 0F A CTVII. PENALTY The enclosure cont'.s'ns TVA's reply to Stewart D. Ebneter's letter to TVA dated September 29, 1992, which tratmmitted the subject NOV and proposed imposition of a civil penalty. This violation portains t.o operation in Mode I with the Unit 1 B train safety injection pump inoperable in excess of technical specification permitted outage time.
NRC noted a concern in the letter transmitting the NOV regarding ineffective wanatetuent actions to correct problems associated with inadequacios in postmaintenanco testing and personnel performance.
TVA has recognized the nood for improvement and, as a renuit of this and other performanco-rolated evento, significant actions have been t aken to reinforce appropriate performance utandards. While TVA has seen improvement, overall perform"nce in not yet at the desired level.
Parsonnel performanco oxpoetations had not been consistently defined, comunicated, demountrated, and enforced. Accordingly, extensivo communication meetings were conduct.od by 'ho Vien president of Nuclear Operations, the Sito Vice president., and the plant. Manager with all sito personnel.
TVA will continue to evaluate progress and refine performance improvetoent 9, ne necesuary. TVA considers that. the path to achieve success has been charted and is being followed.
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l 9211040172 921029 PDR ADOCK 05000327 PDR 0
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U.S. Nuclear Regulatorf Commission Page 2 October 29, 1992 The event associated with this violation was previously reported 8-accordance with 10 CFR 50.73 by Licensco Event Report 50-327/920' There are no new connitments associated with this responso.
Payment of 3
the proposed civil penalty in the amount of $62.500 was made by niectronic fund transfer Ho-. 921029001187.
If you have any questions concerning this submittal, please toicphone H. A. Cooper at (615) 343-8924.
Sincerely, hlA 1 Mark O. Medford Sworn to 9nd subsSt; Abo ~ @.1992 iofore me i
this d' day of LV b
Notary Public My Connission Expiros Enclosure cc (Enclosure):
Mr. D. E. LaBarge, Project Manager U.S. Nuclear Regulatory Conniction one White Flint, North 11555 Rockvillo Pike Rockvillo, Maryland 20852 NRC Hosident. Inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy-Daisy, Tennesseo 37379 Mr. B. A. Wilson, Project Chief-U.S. Nuclear Regulatory Connission Region 11 101 Marietta Street, NW, Suite 2900 Atlanta, Ceorgia 30323 v-e e < v t-e v
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ENCLOSURE o
REPLY TO NOTICE OF VIOLATION l
NRC INSPECTION rep 0RT No. 50-327/92-29 l
STEWART D. EBNETER'S LETTER TO H. O. HEDFORD DATED SEPTEMBER 29, 1992 V,lolation 50-327/92-29
" Technical Specification 3.5.2 requires that two independent Emersoney i
Core Cooling System (ECCS) subsystems shall be OPERAllLE with each subsystem comprinod oft i
a.
One OPERABLE contrifugal charging pump b.
One OPERAHl.t. tafety injection pump c.
Ono OPERABLE residual heat removal heat exchanger d.
Ono OPERAliLE residual heat removal pump, and a.
An OPERABLE flowpath capable of taking suction from the refueling water storage tank on a safety injection nignal and y
automatically transferring suction to the containment cump i
during the recirculation phano of operation.
" Technical Specification 3.5.2 ACTION statement a. requires that with one ECCS subsystem inoperable, rostore the inoperable subsystem tr OpKRAllLE ntatus within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least il0T STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in 110T SilUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
" Contrary to the above, from July 31 to August 10, 1992, Unit 1 operated
.at approximately full power with the B train safety injoction pump inoperable.
"This is a Soverity Level III violation (supplement 1).
Civil penalty - $62,500" Admisalon or Denial _of the Violation TVA admits the violat. ion.
Reason for the Violation Although the cause of this event could not be conclusively established, TVA considers the cause to have been a combination'of failure of the breaker trip button to function properly and lack of attentivonoss.
It appours that during the process of racking in the breakor, thc manual trip button became depressed and stuck in the trip position.
It was determined ti... thn close tolerances assoalated with the manual trip button, such as etJid be created by slight bowing of the small cover plato and differences in-the travel distance of.the trip button relativo to button sleeve length, might tend to introduce the potential for the manual trip button to becomo stuck after being depressed.
(The racking l
mechantum automatically causes the button to depress slightly.)
l Additionally, although-procedures wore followed, had the individuals-exercised increased attentiveness, the misaligned button might have boon L
identified earlier.
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A contribut ing f actor to this event was thut. the proceduro requiring verificatton of breaker operability did not specifIcally require the position of the manual t rip button t.o be verified.
TVA recognirca that testing of the end device following roracking of the breaker woul havo identifled the condition prior to llo return to servico.
It has previously been TVA's policy not to tout the end-dnvice following teracking of the ausociated breaker.
Heracking wan conaldered to be notwal operation of the coroponent in accordance with itu doelgn, i.e.,
an "on/off" operation.
Correctlyn Actionn Takettand Hecults Achieved.
Operations personnot identified that the snanual trip button on the breaker wau stuck in tho trip position during routino survellianco activitico and limnediatok w rected the problem.
The survoillance on the pump wau uuccoopful?< m s W.o ad the 1.co was exited.
The safety-related 6.9 k. Mo's 4 Th.asts on both unitu were inspected by operations pu w n 4 w set t that. no other breakoc was in an inoperablo condition an a ree< at of misalignment of the manual t. rip button.
A memorandum was inoued to all Operations personnel alerting them of the pote s* int of the mno w! trip button t.o nt ick, af fecting breakor opernh111ty.
This information was covered at ahitt turnover until all crewa woro briefed.
An inspection of the breaker by plant personnel was perfotwed in conjunction with the vendor.
It identified no physical defectc; however, the small cover plato on the breaker face was slightly bowed and may have contributed to the potential for the manual trip b Lton to becomo atuck.
Appropriato Electrical Maintenance personnel havo been inforwed of the potential for the breaker trip button to stick in the trip posit.lon.
Electrien1 Halntenance und Operations training lescon plane have been reviced to include infotwat ion on the potential for misalignment of the inanual trip button on tho 6.9-kV breakuro when racking in tho breakor.
The appropriate general operating instruction and maintenance instruction have been revised to includo verifleation of the manual trip button position.
The verification procedure has been revised to enhanco nelf-checking techniques in the performance of work, prior to thin event, extenalvo correctivo measurco designed to enhance tho verification and postmaintenance testing processes and practicon were identifled. These included initiating a review of proceduren for appropriate specification of pMT and verification type, extensive training of personnel, enhancement af the pontmaintenance tout saatrix and verificotton program, strengthened in-lino load planner and general foreman review of work orders / documents, and broader application of postmaintenance and end-dovice teating, irroupectivo of verification type performed. These measures have been reviewod, additional enhancements have been mado an appropriate, and controls / guidance are being inatitutionalized. These measures est.ablish bot.h interim and long-term responson to the underlying concern regarding controls on the return of safety-related equipment to service.
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3 Administrative guidelinen concerning end-dovice testing after manipulat.lons of the 6.9-kV breakers have been incorporated into site procedures. The proceduro requires that when remoto-operated 6.9-kV circuit brookers for technical specification equipment have boon racked out of the connect position, the end device shall be operated to ensure breaker operability prior to the component. boing declared operable. This requirement may be waived only on an individual-case basis following review and approval by the shif L operations supervisot or the Duty plant Manager.
l CorreeLive SLons_That WJ11 be Takop to,Aypjd_ FutLhor Vi_olat,jofg An evaluation of the unual trip button sticking mechanisms was perforwod, and enhance nents are being made to the breaker. The inanuni trip buttons on the 1K breakers are being replaced with longer buttons to reduce the potential of sticking.
The buttons are being replaced in accordance with sito procedureu no routino breaker maintenanco permits.
j To addrons the potential lack of attentivenous of persono involved in 1
this event, comprohannivo sito-wido offorts have boon implemented to emphautro to porponnel the importance of proper job perfotwanco. -In particular, confor site and Nuclear power management. mootings woro hold with all cito groupe to communicato manatomont's view of Sequoyah Nuclear i
plant (SQN) perfot1 nance and management expectations rogarding personnel porforraanco and riuk connit.tvity. Additional management efforts have been implemented to otrongthen accountability and awarencuo of f
obligations regarding personnot perfotwance. Actions will be taken for poor performanco in accordance with TVA policy and practicon.
A nonior managor group was assigned to inonitor, coach, and counsol employoon during perfotwance of work activition to 1:nprovo performance and elevato individual expectations and awareness of management.'s perfot1nanco expectations.
Additionally, an operationo performance ovaluation la being conducted by the alto Quality organization, and a performanco ovaluation.is scheduled to be conducted in the Maintenance organization.
This long-term evaluation uses definitivo critoria for the monitoring activit.lon and providos a quantitativo moacuro of perforwance i
lovels.
The resultu of thono ovaluations provido plant management with useful and timely foodback of changes in perfotwance levolo.
Dato When Full Compilance Will be Acjjleved SQN le in full compliance.
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