ML20197F514
| 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: |
| 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
conference was conducted in the Region II office on November 19, 1997, with
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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,
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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
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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
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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
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:
which compromised his ability to oversee the work independently, procedure
yet, the SRO was closely involved in performing the steps of the
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
two years,ps been the sub4ect of escalated enforcement actions within the last
facility h
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.
8 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
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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
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specified in the enclosed Notice when preparing your response.
In your
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response, you should document the specific actions taken and any additional
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actions you plan to prevent recurrence of the violations. After reviewing
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your response to this Notice. including your proposed corrective actions and
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the results of future inspections. the NRC will determine whether further NRC
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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.
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Sincerely.
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Original signed by
Bruce S. Mallett
Luis A. Reyes
Regional Administrator
Docket Nos. -50 327. 50 328
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Enclosures:
1. ~ Notice of Violation and Proposed
Im>osition of Civil Penalty
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2.
NRC 'resentation Materials
3.
TVA Presentation Materials
4.
List of Attendees
cc w/encls:
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Senior Vice President
Nuclear Operations
,
Tennessee Valley Authority
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6A Lookout Place
,
1101 Market Street
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- Chattanooga TN 37402 2801
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Jack A. Bailey. Vice President
Engineering & Technical Services
Tennessee Valley Authority -
6A Lookout Place
- 1101 Market Street
>
Chattanooga. TN 37402 2801
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cc w/encls cont'd: See page 5
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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
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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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1260 Nuclear Plant Road
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