IR 05000327/1996010
| ML20134Q191 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 11/19/1996 |
| From: | Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Kingsley O TENNESSEE VALLEY AUTHORITY |
| Shared Package | |
| ML20134Q194 | List: |
| References | |
| EA-96-269, NUDOCS 9612020174 | |
| Download: ML20134Q191 (6) | |
Text
SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY -
$50.000 (NRC INSPECTION REPORT NOS. 50-327 AND 50-328/96-10)
Dear Mr. Kingsley:
This refers to the inspection conducted during the Jeriod July 8 through August 22. 1996, at your Sequoyah Nuclear Plant.
T1e inspection included a review of the fire protection program and associated corrective actions previously identified by the Nuclear Regulatory Commission (NRC) and Tennessee Valley Authority's (TVA's) Quality Assurance (0A) organization.
The results of this inspection were sent to you by letter dated September 27, 1996. A closed, predecisional enforcement conference was conducted in the Region II office on October 24, 1996, with members of your staff to discuss the apparent violations, the root causes, and corrective actions to preclude recurrence. A list of conference attendees. NRC slides, and a copy of TVA's presentation materials are enclosed.
Prior to the conference. TVA provided, in a letter dated October 18. 1996. its views on the application of the Enforcement Policy to this case.
Subsequently, on October 31. 1996. TVA submitted the supplemental information requested by the NRC at the predecisional enforcement conference.
Based on the information developed during the inspection, the information that was 3rovided during the conference, and TVA's letter of October 31. 1996, 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 Penalty (Notice) and the circumstances surrounding them are described in detail in the subject inspection report.
Violation A involved three examples of TVA's failure to promptly resolve adverse conditions related to the fire protection program at Sequoyah.
Specifically the first example addresses fire protection program discrepancies which were identified by your 0A organization during 1992, 1994 and 1995. for which corrective actions have yet to be completed. The second example addresses numerous fire dampers that did not comply with the vendor's design and installation requirements.
Although this issue was identified in 1993. it has yet to be fully resolved.
The final example relates to the continuing failure to control combustibles and transient fire loads in the
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plant in accordance with 3rocedure requirements, including expired transient fire load permits and lacc of engineering analyses and approval of the Site Fire Protection Engineer to support continued. storage of transient
- combustibles.
Violation B involves the inoperability of the carbon _ dioxide (CO ) system for
the plant computer room. This system was rendered inoperable.in May 1990 during modifications to the Control Building HVAC system which added penetrations to the room but failed to equip the penetrations with fire dampers designed to close and isolate the room upon actuation of the CO2 system. Although an hourly fire watch patrol has been established-to comply with Technical Specification (TS) requirements, the system remains out of service.
Violation C involves your failure to perform the required 18-month surveillances for the Auxiliary Building penetrations in high radiation areas.
Violation D involves your failure to demonstrate the operability of fire hose stations in the reactor buildings due to the_ failure to hydrostatically test
- fire hoses at these locations.
This latter violation was attributable to the failure of TVA's Surveillance Procedure Nos. 1/2-SI-FPU-026-191.R. Fire Hose Inspections. -to assure that the fire hose for these locations had been hydrostatically tested as required by TSs.
At the conference. you identified the overall root cause of these violations as ineffective management involvement in the fire protection program and a
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lack of ownership for the program due to the division of responsibilities
between various onsite groups.
In addition, you stated that the TVA OA i
3rogram failed to promptly recognize the collective significance of the issues
)eing. identified and to raise this concerr to the appropriate levels of management in order to achieve resolution.
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- Although compensatory measures, in the form of fire watches are in place to
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assure compliance with TSs. collectively, the violations are of significant
regulatory concern because they represent a significant lack of attention and priority to the overall fire protection program.
Specifically, the violations are associated with long standing fire protection issues of which TVA was aware; but, due to a lack of management prioritization, they have not been I
corrected in a timely manner.
In addition the use of fire watch 3atrols, j
such as those being implemented at Sequoyah, are required by the NRC as
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interim, short-term compensatory measures until degraded fire protection features can be repaired or replaced.
Sequoyah's practice of routinely using fire watch patrols in lieu of correcting fire protection deficiencies in a timely manner is not consistent with NRC policy or ex compromises the design objective of defense in depth.pectations and As a consequence, the fire protection program at Sequoyah has not been fully effective. resulting in the plant's safety related components being more-vulnerable to potential fire exposure or damage in the event of a fire.
Further the violations are of concern because the lack of centralization of responsibility for the fire -
protection program should have been identified earlier, specifically, during your previous organizational reviews conducted earlier in the 1990's.
Therefore, these violations 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 penalty in the amount of $50,000 is considered for a Severity Level III problem.
Because your 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.
In this case, the NRC concluded that credit was warranted for Identification because TVA. in general, identified the issues to be corrected in this case.
Regarding Corrective Action, at the conference and in TVA's October 31, 1996.
letter. TVA stated that its actions included:
(1) assignment of a new Fire Protection Manager on July 31, 1996: (2) conduct of a self-assessment of the fire protection program in September 1996: (3) revision of transient fire load procedures on August 16. 1996, and initiation of actions to reduce transient combustibles in the plant: (4) centralization of ownership of the fire protection program within the operations department: (5) weekly senior management involvement in fire protection program status: (6) establishment of schedules for completion of the remaining fire protection issues:
(7) appropriate procedure revisions and personnel training for fire hose testing; and (8) inspection of the fire penetration barriers in high radiation areas and implementation of disciplinary actions against the responsible individuals.
Based on the above, it appears that TVA's attention is now appropriately focused on this program area: however. NRC determined that credit for the factor of Corrective Action was not appropriate in that the
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actions were not timely. As discussed previously, many of these issues are longstanding, and licensee efforts to prioritize and correct the deficiencies have not been prompt.
Therefore, to emphasize the importance of management attention to and oversight of fire protection activities and the need for prompt corrective actions. I have been authorized after consultation with the Director. Office l
of Enforcement, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty (Notice) in the base amount of $50,000 for the Severity Level III problem.
Please be advised that the NRC did consider your October 18. 1996. letter in I
applying the Enforcement Policy in this case.
However, based on the NRC's
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determinations related to Identification and Corrective Actions. Sequoyah's
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escalated enforcement history related to employee protection had no impact on the resultant proposed civil penalty.
You are required to respond to this letter and should follow the instructions
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specified in the enclosed Notice when preparing your response.
The NRC will
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consider your response, in part, to determine whether further enforcement action is necessary to ensure compliance with regulatory requirements.
l I 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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In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a co]y of this letter, its enclosures, and your response will be placed in the NRC Public Document Room (PDR).
Sincerely
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Original Signed by L. A. Reyes Stewart D. Ebneter Regional Administrator Docket Nos. 50-327, 50-328 License Nos. DPR-77. DPR-79 Enclosures:
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Notice of Violation and Proposed Imposition of Civil Penalty 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 Dr. Mark 0. Medford. Vice President Technical Services 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-Daisy. TN 37379
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General Counsel Tennessee Valley Authority ET 10H 400 West Summit Hill Drive Knoxville, TN 37902 cc w/encls: (Cont'd on Page 5)
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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 Na.shville, TN 37243-1532 County Executive
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Hamilton County Courthouse
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Chattanooga, TN 37402
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Distribution w/encls:
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PUBLIC
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JTaylor, ED0 JMilhoan, DEDR SEbneter. RII LChandler, OGC JGoldberg OGC RZimmerman. NRR EJulian.'SECY BKeeling. CA.
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Enforcement Coordinators RI. RIII. RIV JLieberman. OE i
OE:EA File (BSummers) (2 letterhead)
-MSatorius. OE j
EHayden, OPA
GCaputo. OI-EJordan, AEOD HBell, OIG CEvans, RII Buryc. RII KClark, RII RTrojanowski RII
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EMerschoff.. RII MLesser. RII SSparks. RII AGibson, RII PFredrickson, RII (IFS Action)
WMiller, RII RHernan. NRR FHebdon, NRR TMarsh, NRR NRC Resident Inspector. Operations U. 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 f
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