ML20197F514

Discusses Insp Repts 50-327/97-13 & 50-328/97-13 & Forwards Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $55,000

ML20197F514
Person / Time
Site:	Sequoyah
Issue date:	12/08/1997
From:	Reyes L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Zeringue O TENNESSEE VALLEY AUTHORITY
Shared Package
ML20197F518	List: ML20197F514 ML20197F554
References
50-327-97-13, 50-328-97-13, EA-97-409, NUDOCS 9712300237
Download: ML20197F514 (8)

See also: IR 05000327/1997013

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December 8, 1997

EA 97 409

Tennessee Valley Authority

ATTN: Mr. O. J. Zeringue,

Chief Nuclear Officer and

Executive Vice President

6A Lookout Place

1101 Harket Street

Chattanooga, Tennessee 37402 2801

SUBJECT: NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY -

$55,000 (NRC SPECIAL INSPECTION REPORT NOS. 50 327/97 13 AND

50 328/97 13)

Dear Mr. Zeringde:

This refers to the special inspection conducted on July 25 through

September 4,1997, at the Sequoyah facility. The purpose of the inspection

was to review the misalignment of spare vital battery No. V to vital battery

board No. IV on July 24, 1997. The results of the inspection were sent to you

by letter dated September 11, 1997. An open, predecisional enforcement

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conference was conducted in the Region II office on November 19, 1997, with

you and members of your staff, to discuss the violations, the root causes, and

your corrective actions to preclude recurrence. A list of conference

attendees and copies of the Nuclear Regulatory Commission's (NRC) and

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 Penalty

(Notice), and the circumstances surrounding them are described in detail in

the subject inspection report.

On July 24, 1997, a Senior Reactor Operator (SRO) failed to realign rpare

vital battery No. V to vital battery board No. IV properly, after hanging a

clearance on 125 volt direct current (DC) vital battery No. IV. As a result, j

vital battery board No, IV was inoperable for approximately 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. Based /

on the additional information that was provided during the conference, the NRC

concluded that three violations of regulatory requirements occurred. The

violations include: (1) the failure to meet Technical Specification (TS)

3.8.2.3 requirements to maintain four DC vital battery channels energized and

operable: (2) the failure to follow procedures associated with realigning the

spare vital battery No. V to a vital battery board: end, (3) the failure to

follow administrative procedures to ensure that the position of 125 volt DC

distribution system breakers were subject to independent verification. These

violations and a number of other concerns described below indicate serious

weaknesses in the performance of the operations staff. In this case, the 'f,

operations staff demonstrated a lack of inquisitiveness and a lack of strict 'l([U

adherence to procedures in performing the realignment of the vital Lattery. /

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During this event, the SR0 went to the wrong distribution panel to close a l

breaker and found a breaker with similar labels already closed, Although the

SR0 questioned the unexpected breaker status, he failed to adequately

investigate the discrepancy, did not notify the control room of the >otential

configuration control issue, and did not note the failure to close t1e breaker

as a deviation from the procedure. Several steps later in the procedure, he

opened the same breaker yet failed to recognize the incongruity. At the

conference, you stated that your procedures and expectations in this situation

allow the cognizant supervisor, i.e., the SRO, to resolve the discrepancy:

yet, the SRO was closely involved in performing the steps of the

which compromised his ability to oversee the work independently, procedure

Problems with auxiliary unit operator (AVO) rounds practices were also noted.

Tests of the batteries indicated that it is likely that the battery voltage

was below required surveillance limits at the time AVO rounds were performed;

however, the AVO failed to identify reduced voltage at the board. Control

room operators initially performing the battery realignment, and subsequent

oncoming crews, did not identify the lack of an expected main control room

alarm, and the procedure did not highlight that an alarm was expected.

Lastly, an SRO entered an incorrect Technical Specification action statement

during the initial vital board realignment.

The root causes of the misalignment event, i.e., the failure to evaluate the

unexpected as found condition and/or weaknesses associated with component

labeling, were similar to previous events. NRC Inspection Report 50 327,-

328/97 03 documented an event in which an operator found a valve in an

unexpected position and did net notify the control room, resulting in the

isolation of the spent fuel pool cooling pump for about two hours while the

pump was running. Enforcement Action 97 232, issued on July 10, 1997,

documented operator errors in investigating discrepant indications of reactor

coolant system (RrS) level resulting in an RCS drain down event. Licensee

Event Report (LER) 95 08 documented a reactor trip which occurred when an

operator opened a wrong breaker on the wrong vital 120 VAC board.

The NRC recognizes that the actual safety and risk significance of the

inoperable vital battery board was mitigated by the fact that a spare battery

charger was aligned to the board and the charger would have provided power to

the board in all scenarios except for a loss of offsite power. In addition,

the NRC commends the training instructor who recognized that the vital battery

board su) ply breaker was not in the correct >osition and took prompt action to

notify tie Operations staff. Nonetheless, t1ese violations are of significant

regulatory concern to the NRC due to: (1) problems in the performance of the

operating staff: (2) the fact that multiple opportunities existed to prevent

and detect the inoperability of the vital battery board; and, (3) previous

events involving similar operator errors and problems attributable to

component labeling have occurred and corrective action did not preclude

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repetition of the problems. Therefore, the violations have been categorized

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 !!! problem.

In accordance with the Enforcement Policy, a base civil penalty in the amount

of $55.000 is considered for a Severity Level !!! problem. Because your

facility h

two years,ps been the sub4ect of escalated enforcement actions within the last

theNRCconsideredwhethercreditwaswarrantedforidentification

and Cg rective Action in accordance with the civil penalty assessment process

descri >ed in Section VI.B.2 of the Enforcement Policy. NRC determined that

credit was not warranted ' * identification because prior opportunities to

identify the violations existed. Your corrective actions included:

(1) revising the operating procedure to require independent verification of

breaker position: (2) hanging caution tags on the five No. 107 breakers to

ensure proper identification: (3) plans to relabel all 125, and 250 volt DC

and 120 volt AC boards: (4) developing job performance measures for work on

the 125 volt DC batteries: (5) revising the battery procedure to identify the

No. V battery in service alarm, including the appropriate TS action statement

in the battery procedure: (6) reviewing other operations and me.intenanco

procedures to ensure proper independent verifications have been identified:

and (7) taking appropriate personnel actions. Based on the above, the NRC

determined that credit was warranted for the factor of Corrective Action.

Therefore, to emphasize the importance of attention to detail and appropriate

implementation of TS requirements, and in recognition of your previous

escalated enforcement actions. I have been authorized, after consultation with

the Office of Enforcement, to issue the enclosed Notice of Violation and

Proposed Imposition of Civil Penalty (Notice) in the base amount of $55,000

for the Severity Level 111 problem.

The apparent violations identified in NRC Inspection Report No. 50 327,

328/97 13 included a failure to stop the e?lution when a procedural step

could not be performed and failure to prom ly identify an adverse condition

(out of tolerance battery voltage). At ths predecisional enforcement

conference, you indicated that, although your expectations for operator

performance were not met in these areus, you concluded that procedural

requirements had been met. Because these circumstances were factored into our

assessment of prior opportunities to identify the breaker misalignment, these

apparent violations are withdrawn. In additich, at the conference, you

provided information indicating that AVO rounds to assess battery room

temperature and battery voltage on vital battery No. V were appropriate. This

apparent violation is also withdrawn.

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A severity Level til problem was issued on July 10.1997. (EA 97 232), for violat; .s

associated with a reactor coolant syttem (RCs) inadvertent drain down. Two severity Level 111

protlems and proposed civil penaltie- af $50,000 each were issued on December 24, 1996. (EA 96-

414L for inadequate corrective actions related to maintenance of reactor trip breakers and other

equipment. A severity Level !!! violation and proposed civil penalty of $50,000 was issued on

November 19.1996. (EA 9s 269), related to fire protection program deficiencies. A severity

level 11 violation and roposed civil penalty of $80,000 were issued on February 20, 1996. (EA

2 . related to emp oyee discrimination in Department of Labor Case Nos. 92 ERA 19 and 92-

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You are required to respond to this letter and should follow the instructions  !

specified in the enclosed Notice when preparing your response. In your i

response, you should document the specific actions taken and any additional  ;

actions you plan to prevent recurrence of the violations. After reviewing I

, your response to this Notice. including your proposed corrective actions and i

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the results of future inspections. the NRC will determine whether further NRC  :

enforcement action is necessary to ensure compliance with NRC regulatory  ;

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requirements.

In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice." a copy of

this letter and its enclosures will be placed in the NRC Public Document Room. j

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Sincerely.

Original signed by

Bruce S. Mallett

Luis A. Reyes

Regional Administrator

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Docket Nos. -50 327. 50 328

License Nos. DPR 77. DPR 79

Enclosures: 1. ~ Notice of Violation and Proposed

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Im>osition of Civil Penalty

2. NRC 'resentation Materials

3. TVA Presentation Materials

4. List of Attendees

cc w/encls: ,

Senior Vice President

Nuclear Operations ,

Tennessee Valley Authority t

6A Lookout Place ,

1101 Market Street i

- Chattanooga TN 37402 2801 -

Jack A. Bailey. Vice President

Engineering & Technical Services

Tennessee Valley Authority -

6A Lookout Place

- 1101 Market Street >

Chattanooga. TN 37402 2801  !

cc w/encls cont'd: See page 5 l

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cc w/encls cont'd:

HasoudBajestani

Site Vice President

Sequoyah Nuclear Plant

Tennessee Valley Authority

P, O. Box 2000

Soddy Daisy, TN 37379

General Counsel

Tenressee Valley Authority

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400 West Sumit Hill Drive

Knoxville, TN 37902

Raul R, Baron, Ge'1eral Hanager

Nuclear Assurance

Tennessee Valley Authority

4J Blue Ridge

1101 Harket Street

Chattanooga,TN 37402 2801

Hark J. Burzynski, Manager

Nuclear Licensing

Tennessee Valley Authority

4J Blue Ridge

1101 Market Street

Chattanooga, TN 37402 2801

Pedro Salas, Manager .

Licensing and Industry Affairs

Sequoyan Nuclear Plant

P. O. Box 2000

Soddy Daisy, TN 37379

J. T. Herron, Flant Manager

Sequoyah Nuclear Plant

Tennessee Valley Authority

P, O. Box 2000

Soddy Daisy, TN 37379

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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V. S. Nuclear Regulatory Commission

1260 Nuclear Plant Road

Spring City. TN 37381

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Seq,.oyah Nuclear Plant

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2600 Igou Ferry Road

Soddy Daisy, TN 37379

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1260 Nuclear Plant Road r

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NRC Resident Inspector

Sequoyah Nuclear Plant

U. S Nuclear Regulatory Commission

2600 Igou Ferry Road' ,

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