ML20133F589
| ML20133F589 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 12/24/1996 |
| From: | Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Kingsley O TENNESSEE VALLEY AUTHORITY |
| Shared Package | |
| ML20133F592 | List: |
| References | |
| EA-96-414, GL-91-15, IEB-78-14, NUDOCS 9701140273 | |
| Download: ML20133F589 (7) | |
See also: IR 05000327/1996013
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NUCLEAR REGULATORY COMMISSION
UNITED STATES
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REGION 11
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101 MARIETTA STREET. N.W., SUITE 2900
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ATLANTA, GEORGIA 303234199
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December 24, 1996
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'EA 96-414
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Tennessee Valley' Authority
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ATTN:
Mr. Oliver D. Kingsley Jr.
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President. TVA Nuclear and
Chief Nuclear Officer
6A Lookout-Place.
1101 Market Street
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Chattanooga, TN 37402-2801
NOTICE OF VIOLATION AND 'ROPOSED IMPOSITION OF CIVIL PENALTIES -
SUBJECT:
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$100.000 (NRC INSPECTION REPORT NOS. 50-327 AND 50-328/96-13)
Dear Mr. Kingsley:
This refers to the special inspection conducted between September 19 and
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November 2. 1996 at the Sequoyah facility.
The purpose of the inspection was
to follow up on the equipment problems experienced during the Unit 2 reactor
trip on October 11, 1996, and the maintenance and corrective actions
associated with an ino)erable Unit 2 reactor trip breaker (RTB) on
September 19, 1996. T1e results of this inspection were sent to you by letter
dated November 25, 1996. An open, predecisional enforcement conference was
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conducted in the Region II office on December 16, 1996, with members of your
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staff to discuss the apparent violations, the root causes, and corrective
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actions to preclude recurrence. A list of conference attendees. NRC slides,
and a copy of Tennessee Valley Authority's (TVA) presentation materials are
enclosed.
Based on the information developed during the ins)ection and the information
that was provided during the conference, the NRC 1as determined that
violations of NRC requirements occurred. The violations are cited in the
enclosed Notice of Violation and Proposed Imposition of Civil Penalties
(Notice), and the circumstances surrounding them are described in detail in
the subject inspection report.
Violations A(1). A(2) and A(3) have been evaluated in the aggregate and
assigned a single increased severity level due to the similarity of the
corrective action program deficiencies identified as a result of the equipment
problems experienced during the trip on October 11. 1996.
Violation A(1)
involves the failure to identify the root cause and take adequate corrective
actions for recurring failures of a main feedwater isolation valve (MFIV)
motor brake. This valve has failed to stroke on four previous occasions since
1989. .The failure to implement corrective actions to control use of a
material susceptible to rapid aging at high temperatures in safety-related and
quality-related ASCO solenoid valves is cited in Violation A(2).
The failure
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y-related ASCO valve, which caused excessive reactor. coolant pump
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9701140273 961224
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ADOCK 05000327
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seal leakage, resulted in the reactor shutdown on October 11, 1996. A number
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of other valves were subsecuently determined to be degraded.
In this case.
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your staff had been alertec by NRC Bulletin 78-14 Generic Letter 91-15 and by
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a Sequoyah Problem Evaluation Report documenting problems with the material.
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yet you failed to implement effective corrective action.
Violation A(3)
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involves the failure to adequately implement site procedures described by your
corrective action process in that, when a fire system deluge actuation in July
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1996 wet plant equipment, your extent of condition review failed to bound the
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affected equipment, and adequate corrective action was not taken for water
intrusion into plant equipment. On October 11, 1996, a turbine runback
resulted due to failed turbine impulse pressure switches affected by water
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intrusion, which caused the need for a manual reactor trip.
Operators were
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also unaware of the interlock between the turbine runback and the locked in
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auxiliary feedwater (AFW) actuation signal and did not reset the main
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feedwater pump in order to allow AFW reset.
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The NRC is particularly concerned that the apparent root cause of
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Violations A(1) A(2) and A(3) is the inadequate implementation of your
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corrective action program. As described in detail in the inspection report.
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the issues related to Violations A(1) A(2) and A(3) have been known by TVA
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for some time but were never fully evaluated to determine the extent of
condition or the effectiveness of the corrective actions in resolving the root
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cause of the conditions.
Your failure to fully evaluate the cause and
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adequately correct recurring problems with moisture intrusion and brake
corrosion in the MFIV resulted in its failure to close on demand upon
receiving a valid feedwater isolation signal.
In another case, the corrective
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action plans for a significant generic issue were never implemented.
Other
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deficiencies in plant material condition were also identified as a result of
the October 11, 1996 trip.
These deficiencies caused a spurious turbine
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runback, loss of manual auxiliary feedwater control and a water hammer in the
steam dump system which caused damage to piping and hangers.
The NRC is
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concerned that problems experienced in ensuring effective and timely
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corrective actions at the Sequoyah site, as described in EA 96-269 which was
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issued on November 19, 1996, are continuing to occur.
Therefore Violations
A(1), A(2) and A(3) are classified in the aggregate in accordance with the
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" General Statement of Policy and Procedures for NRC Enforcement Actions"
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(Enforcement Policy). NUREG-1600 as a Severity Level III problem.
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Violations B(1), B(2) and B(3) have also been evaluated in the aggregate and
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assigned a single increased severity level because the violations contributed
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to or were a direct consequence of the underlying problem.
Violation B(1)
involves inadequate maintenance and testing on a RTB which resulted in
installation of an inoperable RTB in Unit 2.
Violation B(2) involves the
failure to maintain the minimum required channels of the reactor trip P-4
permissive function.
The failure to follow plant procedures requiring an
evaluation of the operability of the RTB and an assessment of the
reportability of the event is cited in Violation B(3).
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The root causes of Violations B(1). B(2) and B(3) were poor communications-
between Operations, Maintenance and Engineering: non-conservative decision-
making: training deficiencies; and poor event analysis. -These root causes and
the following significant concerns indicate inadequate control of licensed
activities:
(1)
Maintenance supervision made a nonconservative decision to proceed with
post maintenance testing of the RTBs when subsequent steps required
partial disassembly.of RTB components.
Inadequate training on RTB
maintenance and vendor manual deficiencies also contributed to the
violations.
(2)
Maintenance and engineering personnel failed to recognize the
significance of the rod deviation computer alarm, which was received
when the RTB was installed, and failed to understand its potential
impact on o]erability. This was evidenced by a proposal'to troubleshoot
the RTB pro 31 ems online and divert resources towards clearing the rod
deviation alarm by inserting a " dummy" signal into the computer prior to
determining the cause for the signal. ' These issues should have led
management to take prompt action to ensure operability of the RTB prior
to exceeding the Limiting Condition for Operation (LCO).
(3)
Although Operations was proactive in questioning operability of the RTB,
they failed to make a conservative decision to remove the RTB for- a
number of hours. An early, conservative decision on RTB operability
could have precluded a violation of the LCO.
(4)
The event critique did not address operability of the refurbished RTB,
the functions of the auxiliary contacts, and a deficient revision to the
maintenance procedure for lubricating the RTB inertia latch.
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(5)
The event was not fully evaluated until after prompting by NRC
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inspectors. TVA staff then conducted a more extensive evaluation and
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determined that the auxiliary contacts: (1) supplied signals for the
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reactor trip alarm, high steam flow interrupt, a computer point for the
rod deviation program, turbine trip, feedwater isolation: and.
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(2) allowed blocking of the safety injection (SI) signal after a SI so
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that the SI signal could be reset. This evaluation revealed the
violation of the LCO for the reactor trip P4 permissive and the
violation of plant procedures with regard to the operability /
reportability determination.
(6)
Operations and the engineering staff did not recognize that the turbine
trip contacts on the RTB were part of the P-4 function.
Therefore. Violations B(1). B(2) and B(3) are classified in the aggregate in
accordance with the " General Statement of Policy and Procedures for NRC
Enforcement Actions" (Enforcement Policy). NUREG-1600, as a Severity Level III
problem.
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In accordance with the Enforcement Policy, a base civil 3enalty in the amount
of $50,000 is considered for each Severity Level III pro 3lem.
Because your
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facility has been the subject of escalated enforcement actions within the last
two years , the NRC considered whether credit was warranted for
Identification and Corrective Action in accordance with the civil penalty
assessment process described in Section VI.B.2 of the Enforcement Policy.
With regard to Violations A(1), A(2) and A(3), the NRC concluded that credit
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was not warranted for Identification because the violations were revealed
through an event. However, credit was warranted for the factor of Corrective
Action, based on the extensive corrective actions to improve (1) plant
material conditions
(2) management effectiveness, and (3) implementation of
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the corrective action program. Therefore, application of the civil penalty
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assessment process resulted in the base civil penalty of $50.000 for the
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Severity Level III problem.
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The NRC concluded that credit was not warranted for Identification of
Violations B(1), B(2) and B(3), because the red deviation alarm provided a
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reasonable indication of a potential problem and NRC prompted review of
several aspects of the underlying issues. With regard to Corrective Action,
corrective actions included disciplinary actions, reinforcement of management
expectations, and procedural revisions.
During the predecisional enforcement
conference, you also discussed your site-wide initiatives to improve
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management ownership and control of plant activities.
Based on the above, the
NRC determined that credit for the factor of Corrective Action was
appropriate. Application of the civil penalty assessment process for
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Violations B(1), B(2) and B(3) resulted in the base civil penalty of $50,000
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for the Severity Level III problem.
Therefore to em]hasize the importance of management oversight of plant
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activities and t1e need for prompt effective corrective actions
I have been
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authorized, after consultation with the Office of Enforcement, to issue the
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enclosed Notice of Violation and Proposed Imposition of Civil Penalties
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(Notice) in the amount of $100.000 for the two Severity Level III problems.
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An apparent violation was identified in NRC Inspection Report No. 50-327,
328/96-13 for the failure to take adequate corrective actions to prevent
flexible conduit damage on the MFIVs. At the predecisional enforcement
conference, you indicated that the flexible conduit on the MFIV had not been
damaged as originally thought.
In addition, you provided additional
information on your corrective actions to preclude damage to flexible
conduits.
This apparent violation is therefore withdrawn.
IA severity Level III violation and proposed civil penalty of $50,000 were issued on
November 19. 1996. (EA 95-269) related to fire protection program deficiencies. A Severity
Level II violation and proposed civil penalty of $80.000 were issued on February 20. 1996,
(EA 95-252) related to employee discrimination in Department of Labor Case Nos. 92-ERA-19
and 92-ERA-34.
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You are required to respond to this letter and should follow th
specified in the enclosed Notice when preparing your response. e instructions
The NRC will
consider your response, in part, to determine whether further enforcement
action is necessary to ensure compliance with regulatory requirements.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice." a copy of
this letter, its enclosures, and your response will be placed in the NRC
Public Document Room (PDR).
Sincerely.
Original Signed by
Stewart Ebneter
Stewart D. Ebneter
Regional Administrator
Docket Nos. 50-327. 50-328
Enclosures:
1.
Notice of Violation and Proposed
litposition of Civil Penalties
2.
Conference Attendees
3.
NRC Presentation Materials
4.
Licensee Presentation Materials
cc w/encls:
0. J. Zeringue. Senior Vice President
Nuclear Operations
Tennessee Valley Authority
6A Lookout Place
1101 Market Street
Chattanooga. TN 37402-2801
R. J. Adney
Site Vice President
Sequoyah Nuclear Plant
Tennessee Valley Authority
P O. Box 2000
Soddy-Dai.sy. TN 37379
General Counsel
Tennessee Valley Authority
ET 10H
400 West Summit Hill Drive
Knoxville. TN 3790P
cc w/encis: (Cont'd on next page)
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cc w/encls (Cont'd):
Raul R. Baron, General Manager
Nuclear Assurance and Licensing
Tennessee Valley Authority
4J Blue Ridge
1101 Market Street
Chattanooga. TN
37402-2801
Pedro Salas Manager
Licensing and Industry Affairs
Tennessee Valley Authority
4J Blue Ridge
1101 Market Street
Chattanooga, TN 37402-2801
Ralph H. Shell. Manager
Licensing and Industry Affairs
Sequoyah Nuclear Plant
P. O. Box 2000
Soddy-Daisy. TN 37379
Michael H. Mobley. Director
Division of Radiological Health
3rd Floor. L and C Annex
401 Church Street
Nashville. TN 37243-1532
County Executive
Hamilton County Courthouse
Chattanooga. TN 37402
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NRC Resident Inspector, Operations
V. S. Nuclear Regulatory Commission
1260 Nuclear Plant Road
Spring City. TN 37381
NRC Resident Inspector
Sequoyah Nuclear Plant
U. S. Nuclear Regulatory Commission
2600 Igou Ferry Road
-Soddy Daisy. TN 37379
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