ML20128A952

Discusses Insp on 840827-31 & 1004-05 & Forwards Notice of Violation & Proposed Imposition of Civil Penalty

ML20128A952
Person / Time
Site:	Sequoyah
Issue date:	05/07/1985
From:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Parris H TENNESSEE VALLEY AUTHORITY
Shared Package
ML20128A955	List: ML20128A952 ML20128B011
References
EA-84-119, NUDOCS 8505240374
Download: ML20128A952 (4)

Text

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[Od pa MAY 0 7 885 Tennessee Valley Authority ATTN: Mr. H. G. Parris Manager of Power and Engineering 500A Chestnut Street Tower II Chattanooga, TN 37401 Gentlemen:

SUBJECT:

NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTIES:

EA 84-119, UNIT 1 SEAL TABLE LEAK AND THIMBLE TUBE EJECTION EVENT (REFERENCE INSPECTION REPORT NO. 50-327/84-24)

This refers to the two Nuclear Regulatory Commission (NRC) special inspections of activities authorized by NRC License No. DPR-77 for the Sequoyah Nuciear Plant, Unit 1. The inspections were conducted as a result of the Sequoyah Unit I seal table leak and thimble tube ejection event which occarred on April 19, 1984. The results of a special NRC team inspection which was conducted during the period August 27 through 31, 1984, were discussed with the Sequoyah Nuclear Plant management during an exit meeting on August 31, 1984. A Management Meeting was subsequently held at the Sequoyah facility on September 25, 1984, during which safety concerns relative to the NRC inspection findings were expressed. Based on the safety concerns raised during this meeting, another special NRC inspection was conducted during the period October 4 through 5, 1984. The resuits of this inspection were discussed with the Sequoyah Nuclear Plant management by telephone on October 22, 1984. Based on these extensive discussions, we determined that a separate and formal Enforcement Conference was not necessary.

The special inspection team was dispatched to the Sequoyah facility when the NRC became aware of a Tennessee Valley Authority (TVA) Nuclear Safety Review Staff (NSRS) report of the seal table leak and thimble tube ejection event. NSRS reviewers had identified breakdowns in the controls to prevent reactor coolant leakage incidents and discovered that maintenance was conducted without adequate planning and review. The NRC inspection team identified substantive failures to implement regulatory requirements, many of which were identified in the NSRS report.

Item 1 in the. enclosed Notice involves violations of Technical Specification requirements which collectively represent a programmatic breakdown of the procedural controls used for the maintenance activity that resulted in the seal table leak and thimble tube ejection event. Examples of failure to establish adequate procedures and to follow existing procedures were identified. Specifi-cally, the maintenance request which authorized this activity did not establish adequate controls over the cleaning activity and did not conform to documentation CERTIFIED MAIL RETURN RECEIPT REQUESTED 850524037(

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1 Tennessee Valley Authority MAY 0.7 885 requirements. The maintenance procedure used to perform this cleaning activity was inappropriate for use and specifically disallowed such use for the cleaning of this system while the facility was at power. The required reviews performed by the Quality Assurance Staff did not identify these deficiencies in maintenance controls.

Item 2 involves the violation of Technical Specification requirements regarding the failure to adequately conduct required Plant Operations Review Committee reviews associated with cleaning of the movable incore detector system thimble tubes. In this regard, plant management decided to conduct the cleaning activity using the results of an inadequate industry survey and without performing a formal review of the potential nuclear and personnel safety hazards associated with the activity.

Item 3 involves a 10 CFR Part 50, Appendix B,' violation regarding the use and modification of the thimble cleaning tool. This tool was first modified prior to Unit 1 initial criticality and was subsequently replaced after its loss. In addition, this tool was remodified on several occasions. These tool modifica-tions were not reviewed to ascertain potential detrimental safety effects caused by these modifications. The unreviewed modifications made the cleaning tool inappropriate for use on the thimble tubes because of an unrecognized potential for transfer of excessive stress to the high pressure seals. As a result, incore

.htmble D-12 was subjected to excessive stress and an unisolable breach of the reactor coolant pressure boundary occurred. Because of pre-maintenance training and the alert reaction by the persons involved, injury to plant personnel was avoided.

These violations indicate weaknesses in the Sequoyah Nuclear Plant management controls for ensuring that safety-related maintenance activities are properly prescribed, critically reviewed for safety impact, and properly implemented.

The NRC considers these violations to be significant in that serious injury or death of plant personnel could have resulted. These violations indicate a lack of management oversight which could lead to more serious events if adequate corrective actions are not taken. In this regard, the NRC does recognize that portions of the Browns Ferry Regulatory Performance Improvement Program have been voluntarily implemented at the Sequoyah plant and the resulting changes should minimize the possibility for recurrence of similar events.

However, to emphasize the seriousness of these violations and the importance of adequate management controls, I have been authorized, after consultation with the

- Director, Office of Inspection and Enforcement, and the Commission, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalties in the amount of One Hundred Twelve Thousand Five Hundred Dollars ($112,500) for the violations described in the enclosed Notice. The violations have been categorized as Severity Level III violations in accordance with the " General L_

Tennessee Valley huthority Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1985). The base civil penalty for each violation is $50,000.

Typically, due to the multiple examples of violations identified, escalation of the civil penalty would be considered. However, the NSRS report findings reflected considerable effort on the part of NSRS to identify deficiencies and their root causes, involving both NRC and internal requirements. In recognition of this in-depth, critical, and aggressive audit of the event conducted by the TVA Nuclear Safety Review Staff, and to encourage such reviews, the base civil penalty for each violation is being reduced by 25 percent.

You are required to respond to this letter, and in preparing your response, you should follow the instructions in the Notice. Your response should specifically address the corrective actions planned with regard to improving management administrative controls and personnel training to ensure procedural adherence and the establishment of adequate procedures to control activities affecting plant operations. In your response, appropriate reference to previous submittals is acceptable.

In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosure will be placed in the NRC Public Document Room.

The responses directed by this letter and accompar.ying Notice are not subject to clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.

Sincerely, J. Nelson Grace Regional Administrator

Enclosure:

Notice of Violation and Proposed Imposition of' Civil Penalties cc w/ enc 1:

H. L. Abercrombie, Sequoyah Nuclear Plant Site Director P. R. Wallace, Plant Manager J. W. Anderson, Manager Office of Quality Assurance K. W. Whitt, Chief, Nuclear Safety Staff D. L. Williams, Jr., Supervisor Licensing Section J. E. Wills, Project Engineer L_

Tonnessee Valley Authority Distribution PDR LPDR SECY ACRS CA JTaylor, IE-RVo11mer, IE JAAxelrad, IE.

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