ML20128B011

Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $112,500.Violations noted:in-core Detector Sys Inoperable,Per Tech Spec 3.3.3.2 & Unusable Thimble Tube Paths Blocked

ML20128B011
Person / Time
Site:	Sequoyah
Issue date:	05/07/1985
From:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20128A955	List: ML20128A952 ML20128B011
References
EA-84-119, NUDOCS 8505240386
Download: ML20128B011 (5)

Text

NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTIES Tennessee Valley Authority Docket No. 50-327 Sequoyah Nuclear Plant License No. DPR-77 EA 84-119 As a result o_f the special inspections conducted on August 27 through 31, 1984 and on October 4 through 5, 1984, several violations of Nuclear Regulatory Commission (NRC) requirements were identified. During plant startup activities in April 1984, twenty-three of fifty-eight thimble tube paths associated with the incore instrumentation system were identified as blocked. This condition rendered the movable incore detector system inoperable per Technical Specification 3.3.3.2 and therefore unusable to meet the surveillance requirements of Technical Specification 4.2.2.2 with respect to power distribution limits. The unit was taken to 30 percent power and allowed to stabilize in preparation for power distribution surveillance, while methods were investigated for cleaning the blocked thimble tubes sufficient to restore movable incore detector system operability. The thimble tubes had previously been cleaned during outages using a drybrushing method followed by a water flush. This activity had only been performed previously with the unit in cold shutdown.

Based on the results of an inconclusive industry survey, the Sequoyah Nuclear Plant management decided to drybrush the blocked thirrble tubes at 30 percent power in an effort to save two days of critical path time. This decision was made without a formal meeting of the Plant Operations Review Committee to review the potential nuclear and personnel safety hazards associated with the proposed cleaning activity.

During those cleaning activities and activities to support them, numerous examples of failure to follow procedures or to establish adequate procedures were identified. One significant example was the use of a maintenance procedure which was not established for the purpose of cleaning thimble tubes at. power and, in fact, specifically disallowed such use of the cleaning system.

In addition, the thimble cleaning tool was modified from its vendor-supplied condition without technical evaluation, safety review, or mockup tests. This tool was subsequently used to clean thimble tubes on April 19, 1984. Due to inappropriate modifications of the tool, abnormal stresses associated with the cleaning activity were applied to the high pressure seals of thimble tube D-12, resulting in failure of the seal and ejection of the irradiated thimble tube.

Not only did this activity degrade the reactor cociant pressure boundary, it also

- had the potential to scald eight workers with primary coolant.

These violations were indicative of a failure of the Sequoyah facility management controls to ensure that safety-related maintenance activities are properly prescribed, critically reviewed for safety impact, and properly implemented.

To emphasize the seriousness of these violations and the importance of adequate management controls, the Nuclear Regulatory Commission proposes to impose a civil penalty in the amount of One Hundred Twelve Thousand Five Hundred Dollars ($112,500). In accordance with the " General Statement of Policy and A k$

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Notice of Violation Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1985) and pursuant to Section 234 of the Atomic Energy Act of 1954, as amended, 42 U.S.C. 2282, PL 96-295, and 10 CFR 2.205, the particular violations and the associated civil penalties are set forth below:

1. Technical Specification 6.8.1 requires the licensee to establish, implement, and maintain procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Items 1.c, 1.e., 1.1, 7.e(1) and 9 of Regulatory

~ Guide 1.33 specify that procedures are required for equipment control, procedure review and approval, access to containment, access control to radiation areas including a radiation work permit system, and performing maintenance, respectively.

Contrary to the above, the licensee failed to establish and implement adequate procedures for the conduct of equipment control, procedure review and approval, performance of maintenance, radiation work permit access control, and access to containment. Examples of these failures are cited below:

a. On April 19, 1984, maintenance procedure SMI-0-94-1 for instrument thimble tube cleaning and flushing was not implemented in that Step 1.1 of the procedure forbids use of the thimble cleaning system at power and cleaning activities were performed with Unit I at 30 percent power. The procedure established at that time was inappropriate for use at elevated reactor coolant system pressures and temperatures.

b. Maintenance procedure SMI-0-94-1 was inadequately established when issued on July 10, 1981, in that it contained no initial conditions and l no post-maintenance inspection or quality assurance requirements for the thimble tube high pressure seals which constitute a reactor coolant pressure boundary,

c. Maintenance request implementing procedures for control and review of maintenance activities associated with Maintenance Request (MR)

A-238084 dated April 18, 1984, were not implemented in that:

(1) MR A-238084 did not delineate the applicable sections of SMI-0-94-1 to be performed and thus provided inadequate work instructions,

-(2) MR A-238084 did not delineate requirements associated with the job safety analysis as required by procedure SQM2, Maintenance Management System, L_ m

Notice of Violation (3) MR A-238084 did not reference the incore instrument disassembly / reassembly instructions of Maintenance Instruction 1.9, and (4) as of April 19, 1984, the Field Quality Engineering review of MR-238084 did not identify the deficiency of (a) above and did not identify that the post-maintenance testing and quality assurance requirements referenced in MR-238084 did not exist.

d. Administrative Instruction -8, Access to Containment, was not adequately established as of April 19, 1984, in that:

(1) no guidance or positive controls are delineated in the procedure to ensure that airlocks remain accessible for egress during activities in containment in Modes 1 through 4 or to ensure that workers are kept informed of changes in available egress routes and (2) paragraph 2.4 did not clearly delineate those maintenance activities on the incore flux monitoring system for which the clearance on the incore flux drive motors could be removed; this resulted in incore detector system disassembly activities being performed without the appropriate clearance in effect.

e. Administrative Instruction -3, Clearance Procedure, paragraph 5.1.4, requires that no work begin on equipment under clearance until the clearance is issued to the person responsible for the work. This requirement was not properly implemented in that as of April 19, 1984, the clearance for the incore detector drive motors covering thimble tube cleaning activities was issued to a member of the operations staff and not to a field services supervisor responsible for the cleaning activity.

f. Radiation Work Permit 02-1-00102 issued January 1, 1984, for seal table area inspection and maintenance required workers to verify the presence of a clearance on the incore instrument probes prior to entering the containment lower compartments and annulus.

This requirement was not implemented on April 18 and 19,1984, by workers entering the s al table area in that the clearance was not in effect on the probes during work activities.

This is a Severity Level III violation (Supplement I).

(Civil Penalty - $37,500)

2. Technical Specification 6.5.1.6 requires that the Plant Operations Review Committee review unit operations to detect potential nuclear safety hazards and review all procedures required by Technical Specifi-l cation 6.8.1.

Contrary to the above, these requirements were not implemented in that i the Plant Operations Review Committee:

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Notice of Violation (1) did not meet and review the operational hazards associated with thimble tube cleaning activities to be conducted in containment with the unit at power on April 19, 1984 and' (2) did not adequately review maintenance procedure SMI-0-94-1 for thimble tube cleaning and flushing on July 10, 1981, as evidenced l by the deficiencies identified in violation 1.(b) above.

This'is a Severity Level III violation (Supplement I).

(Civil Penalty - $37,500)

3. 10 CFR Part 50, Appendix B, Criterion II requires that activities affecting quality shall be accomplished under suitably controlled conditions which, includes the use of appropriate equipment. In addition, Criterion III

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I requires that appropriate measures be estabitshed for the selection and review for suitability for the application of equipment.

Contrary to the above, as of April 19, 1984, the modified incore flux monitoring system thimble cleaning tool used for thimble cleaning activities at power was not appropriate equipment for use on the reactor coolant pressure boundary in that excessive stresses were -

transferred to the high pressure seal on incore thimble D-12. This resulted in a breach of the reactor coolant pressure boundary. In addition, management controls for and reviews of modifications to the original vendor-supplied cleaning tool were inadequate to prevent

' inappropriate modification of the tool and subsequent use.

This is a Severity Level III violation (Supplement I).

(Civil Penalty - $37,500)

Pursuant to 10 CFR 2.201, Tennessee Valley Authority is hereby required to submit to the Director, Office of Inspection and Enforcement, U.S. Nuclear Regulatory Commission, Washington, D. C. 20555, with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region II, 101 Marietta Street, Suite 2900, N.W., Atlanta, Georgia 30323, within 30 days of the date of this Notice a written statement or explanation including for each alleged violation: (1) admission or dental of the alleged violation, (2) the reasons for the violation if admitted, (3) the corrective steps which have been taken and the results achieved, (4) the corrective steps which will be taken to avoid further violations, and (5) the date when full compliance will be achieved. Consideration may be given to extending the response time for. good cause shown. Under the authority of Section 182 of the Act, 42 U.S.C. 2232, the response shall be submitted under oath or affirmation.

Within the same time as provided for the response required above under 10 CFR 2.201, Tennessee Valley Authority may pay the civil penalties in the amount of One Hundred Twelve Thousand Five Hundred Dollars ($112,500) or may protest imposition of

.the civil penalties in whole or in part by a written answer. Should Tennessee Valley Authority fail to answer within the time specified, the Director, Office of Inspection and Enforcement, will issue an order imposing the civil penalties

Notice of Violation in the ;. mount proposed above. Should Tennessee Valley Authority elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalties, such answer may: (1) deny the violations listed in this Notice in whole or in part, (2) demonstrate extenuating circumstances, (3) show error.in this Notice, or (4) show other reasons why the penalties should not be imposed. In addition to protesting the civil penalties in whole or in part, such answer may request remission or mitigation of the penalties. In requesting mitigation of the proposed penalties, the five factors addressed in Section V(B) of 10 CFR Part 2, Appendix C (1985) should be addressed. Any written answer in accordance with 10 CFR 2.205 should be set forth separately from the statement or explanation in reply pursuant to 10 CFR 2.201 but may incorporate by specific reference (e.g., citing page and paragraph numbers) to avoid repetition. The attention of Tennessee Valley Authority is directed to the other provisions of 10 CFR 2.205 regarding the procedures for imposing a civil penalty.

Upon failure to pay the penalties due which have been subsequently determined in accordance with the applicable provisions of 10 CFR 2.205, this matter may be referred to the Attorney General, and the penalties, unless compromised, remitted, or mitigated may be collected by civil action pursuant to Section 234c of the Act, 42 U.S.C. 2282.

FOR THE NUCLEAR REGULATORY COMMISSION ORIGINmL SIGNED BY JOHN A. OLSHINSKl J. Nelson Grace Regional Administrator >,.

Dated at Atlanta, Georgia this74 day ef May 1985