ML20198K601
| ML20198K601 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 01/07/1998 |
| From: | Bajestani M TENNESSEE VALLEY AUTHORITY |
| To: | Lieberman J NRC OFFICE OF ENFORCEMENT (OE) |
| References | |
| 50-327-97-13, 50-328-97-13, EA-97-409, NUDOCS 9801150053 | |
| Download: ML20198K601 (14) | |
Text
'
b w
s.
~
fyL e 5
Termessee Valley Authority, Post Omce Dox 2000, Soddy Dasy Tennessee 37379-2000 Mas (xd Bajestard Site Vice Prowdont Sewah Nucktar Plant 7
January 7, 1998 Mr. James Lieberman 10 CFR 2.201
- Director, Office of Enforcement 10 CFR 2.205 U.S.. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738 Gentlemen:
In the Matter of
)
Docket Nos. 50-327 Tennessee Valley Authority
)
50-328 SEQUOYAH NUCLEAR PLANT (SQN) - REPLY AND ANSWER TO NOTICE OF
-VIOLATION (NOV) AND PROPOSED IMPOSITION OF A CIVIL PENALTY -
$55,000 - NRC INSPECTION REPORT NOS. 50-327, 328/97 ENFORCEMENT ACTION 97-409 A.
This letter provides TVA's' reply and answer to the subject NOV dated December 8, 1997.
The NOV cites three violations and proposes a civil penalty.
The first violation addresses the failure to maintain four direct current vital battery channels energized and operable as required by plant technical
' specifications'.
The second violation is associated with the
. failure to follow procedure during realignment of vital-batteries and vital battery boards.
The third violation addresses the failure to follow procedure for inclusion of independent' verification requirements for component positioning 4
of'the 125-volt direct current distribution system breakers.
These violations were categorized in the aggregate as a Severity-' Level III problem with a base civil penalty of
$55,000.
1
. >v r2 0 TvA met with NRC in a predecisional enforcement conference in
. NRC's Region II of fice on November 19, 1997.
During that I
hfb!I
~ conference, TVA discussed these apparent violations, their l
b w
c u
O U.S. Nuclear Regulatory Commi ssion Pego 2 January 7, 1998 root cause, and the corrective actions, as well as the safety significance. contains TVA's response to the NOV including the actions taken and planned. provides the list of commitments associated with TVA's reply.
While TVA agrees that these violations occurred, TVA respectfully disagrees with the determination that, under the criteria established in NRC's Enforccment Policy, TVA is not entitled te credit for id9ntifying the problem.
Therefore, in accordance with the provisions of 10 CFP 2.205, TVA requests that NRC consider the following reasons why the civil penalty should not be imposed.
T1.0 alert observation of a SON Operations training instructor lead to the discovery of the vital battery board problem, and he further took prompt action to notify Operations.
NRC's acknowledgment and commendation of the training instructor's actions is found on page 2 of its December 8, 1997 letter.
Ilowever, NRC determined that credit was not warranted for identification because TVA had prior opportunities to identify the violation.
Earlier in the text of the letter, NRC pointed out that problems with assistant unit 'perator rounds existed since it is likely that the battery voltage was below required surveillance limits when the rounds were conducted.
- Also, control room operators and subsequent oncoming crews did not identify the lack of an expected main control room alarm, and procedures did not highlight that an alarm was expected.
TVA maintains thar under NRC's Enforcement Policy, these circumstances should not have been considered as a basis for disqualifying TVA f om obtaining credit under Identification.
According to Section VI.B.2 (b) (1) of NUREG-1600, " General Statement of Policy and Procedures for NRC Enforcement Actionc," the decision whether to credit identification requires considering all the circumstances of identification including
U.S. Nuclear Regulatory Commission Patje 3 January _7, 1998 Whether the problem was licensee-identified (as opposed to e
1 NRC-identified or identified through an event )
-Whethor prior opportunities existed to identify the problem,.
e and -it' so, the age and number of those opportunities
.Whether the problem vas revealed as a result of licensee self-monitoring effort, sucr. as conducting an audit, a test, a surve-111ance, a design review or troubleshooting Given thesu examples, it is clear that.the vital battery problem was identified through a self-monitoring effort.
For such licensee-identified matters, NUREG-1600, Section t.
VI.B.2. (b) ('.1) (1), states:
When a. problem requiring corrective action is licensee-identif f ed (i.e. o identifled before the problem has resulted in an event) the NRC should normally give the licensee. credit for actions related to identificatione regardless of whether prior opportunitier enisted to identify the event.
(Emphasis added).
In the section entitled, " Identified Through an Event,"
NUREG-1600 mentions that a prior opportunity to identify the problem may override the credit for identification, but only if such a consideration is particularly noteworthy or particularly egregious.
However, that discussion is in the context of a problem identified through an event, and not one that is licensee-identified as in TVA's case.
Likewise, the section entitled, " Mixed Identification," discusses instances where there are several violations and a mix of identification facters (licensee,-NRC, and event-identified), and also recognizes the notion of missed opportunities.
However, since there is no mixed identification issue in TVA's case, that
-discussion is not applicable.
In a further discussion-of credit for. actions related to 7 identification,Section VI.B.2. (b) (2) (v) contains a separate
. discussion'of missed opportunities, and mentions that a
- 3. An " event" is characterized in NUREG-1600 as having an active adverse
- impact on equipment or personnel, readily obvious by human observation or instrumentation.- For example, an equipment failure discovered through a liquid spill,ia loud noise or the failure of a system to respond properly would be considered an event. A syst,a discovered to be inoperable through-a document review would not.
Using such criteria, the circumstances surrounding the vita 1Lbattery misalignment.. problem certainly do not qualify as-an. event.
\\
___________1_u_______.____
____ - i J
U.S. Nuclear ~ Regulatory Commission f
Page 4
=.
January 7, 1998 i
reasonable indication of a potential problem and failure to take effective corrective steps can qualify as such.
It i
mentions that a missed opportunity may include prior findings by the licensee where it is reasonable to expect the licensee to take action to identify or prevent similar problems.
However, the policy also mentions that a missed opportunity would not normally be applied where the licensee appropriately reviewed:the opportunity and took reasonable action to address the matter.
In the NOV, NRC specifically cites as an example the fact that previous events involving similar operator errors have occurred and corrective action did not preclude repetition of the problems.
TVA agress that prior to the vital battery problem, it had recognized operator _ performance as an area that warranted improved performance.
As indicated in the enforcement conference, TVA had initiated corrective actions to improve operator performance prior to the violation through actions such as management rotations and changes to cre adules.- At the time of the predecisional enforcement confe.
- e, operator performance had shown signs of improvement, as evident through performance indicators such as reduced operator errors and status control problems.
The effectiveness of these corrective steps was further demonstrated during the Unit 2 Cycle 8 refueling outage, where operator performance was significantly Setter than during the Unit 1 Cycle 8 refueling outage, which took place just five months earlier.8 TVA believes that the significant actions it has taken, and the positive results it has achieved, constitute the type of reasonable actio..
contemplated under the Enforcement Policy that override the consideration of_ missed opportunities.
The NRC's Enforcement Manual makes a strong statement about licensee-identified problems:
Generally, if the licensee identifies a problem before an event occurs or before the NRC identifies it, the
~ licensee should normally get credit for the identification (even-if missed opportunities eststed, including the fakture of past corrective action for similar violations).
[Section 5.5.2.3)
Emphasis added.
8 A more detailed discussion of this area of improved operator petiormance is included in Enclosure 1.-
w i
U.S. Nuclear Regulatory Commission Page 5 January 7,11998
-t Here, the Enforcement Manual states that the failure of past corrective actions should not be considered and the licensee is entitled to credit when the licensee identifies a problem._
Further, in a listing of examples where the licensee should be given credit for identification, the following is givent 1
Identification credit is given for discovery of inoperable equipment during surveillance testing that is performed to determine the operability of that l
equipment.
If as a result of the surveillance testing, an event occurs because of other equipment
[
(i.e., equipment not being tested) failing, missed
. opportunities should be considered when evaluating i
identification for failure of the Other" equipment, e
However, as noted above, there was no event which occurred relative to the vital battery testing that would give rise to I
any examination of missed opportunities.
Furthermore, if NRC l
considers that it is appropriate to credit identification following discovery through scheduled activities, then it follows that NRC would credit a condition discovered by an alert employee, as was the case here.
In a listing of examples where missed opportunities should be considered before giving the licensee credit for
- 4 identification, the following is givent As a result of an event or NRC questions the I
e licensee identifies violations that it should have found earlier if it had been responsive to previous audit findings, deficiency reports, or contractor reviews, where conditions adia::e to quality were not corrected in a timely manner.
This example recognizes that past conditions adverse to quality should-be taken into account as a missed opportunity, but only when linked to violations identified as the result of an event or NRC questions,.neither of which is the case here.
As discussed above, TVA believes that,the terms of NRC's
-Enforcement Policy _and Enforcement Manual do not support the imposition of a civil' penalty in this case.
Beyond their express-terms, however, TVA also believes the overall purpose
~
U.S. Nuclear Regulatory Commission Page 6 January 7, 1998 of the Enforcement Policy would not be served by imposing a civil penalty.
It is undisputed that the vital battery misalignment was discovered through the alert observation of a SON employee.
Negating this fact and imposing a civil penalty would send a confusing and contradictory message, which would undercut two of the stated purposes of the revised Enforcement
- Policy,
- 6. hat is, to "E:nphasize the importance of licensees identifying violations before events occur or before NRC identification," as well as to " Place more emphasis on current
_ Excerpted from the cover letter signed by James
. performance."
(
Liberman accompanying the publication of NUREG-1600, and also i
contained in the SUPPLEMENTARY INFORMATIOti section of the Revised Enforcement Policy, 60 Fed. Reg. 34381 [ June 30, 1995)).
For all of the reasons discussed above, TVA believes that application of NRC's Enforcement Policy, as further described in the NRC's Enforcement Manual, should result in the award of credit for licensee identification as part of the civil penalty assessment process.
Application of the Identification factor, coupled with the application of the Prompt and Comprehensive Corrective Actions factor which NRC has already applied, leads to a "no civil penalty" result, which TVA believes is fully warranted in this case.
If you have any questions regarding this responsc, please contact me at extension (423) 843-7001 or Pedro Salas at extension (423) 843-7071.
Sincerely,
_A Masoud jestani
' S QH. 'S
> Vice President Sworn to and subscribed before me Q is
]
day of
/]fX/l(lllL/
1998 WYY l YA
/L
~N6t(r) Fublic
~
/
My Commission Expires 88 j/ /
' ' ~
-Enclosures cc: 'See Page 7 pr
j f
+
t-1 U.S. Nuclear Regulatory Commission Page 7 January 7, 1998 P
cc (Enclosures):
t Mr. R. W. Hernan, Project Manager
[
Nuclear Regulatory Commission.
One White-Flint,' North 11555 Rockville Pike Rockville, Maryland.20852-2739 NRC' Resident Inspector i
Sequoyah Nuclear' Plant 2600 Igou: Ferry Road Soddy-Daisy, Tennessee 37379-3b24
. Regional Administrator.
U.S. Nuclear Regulatory Commission Region II Atlanta Federal Center, 61 Forsyth St.,
SW, Suite 23T85 Atlanta, Georgia 30303-3415 U.S. Nuclear Regulatory Commission i
Document Control Desk-Washington, C.C. 20555
.?
i I
i Ji;
ENCLOSURE 1 j
TENNESSEE VALLEY AUTSORITY SEQUOYAE NUCLEAR PLANT (SQN)
UNITS 1 AND 2 I
INSPECTION REPORT NUMBERS 50-327/97-13 AND 50-328/97-13
)
REPLY TO NOT.tCE OF VIOLATION (NOV) i i
RESTATEMENT OF THE VIOLATIONS "A.
Technical Specification 3.8.2.3 requires four direct current (DC) vital battery channels to be energized and operable, with each channel consisting of a 125 volt DC board, a 125 volt DC battery bank, and a full capacity charger.
Contrary to the above, on July 24, 1997, at approximately 6:13 a.m.,
125 volt DC battery Bank No. IV was disconnected from 123 volt DC Board No. IV causing the No. IV DC vital battery channel to be inoperable.
The channel remained inoperable until 11:32 a.m. on July 25, a period of approximately 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. (01013) 8.
Technical Specification 6.8.1.a requires, in part, that procedures shall be established, implemented, and maintained covering the activitius recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978, ' Quality Assurance Program Reauirements (Operation).'
Appendix A of Regulatory Guide 1.33, Section 3, includes procedures for onsite emergency power sources (DC system).
System Operating Instruction (SOI) 0-SO-250-1, '125 Volt DC Vital Power System,' Revision 9, Section 8.4, provides instructions for placing vital battery V in service for battery boards I, II, III, or IV.
Step 8.4.8 of SOI 0-SO-250-1 required the operator to ' Place Distribution Panel
...B-S breaker (107) in "ON" position to align feed to desired Vital Battery Board.'
Contrary to the above, on July 24, 1997, an SRO failed to implement step 8.4.8 of SOI 0-SO-250-1, in that, while
-aligning vital battery V to feed vital battery board No. IV, he did not place distribution panel B-S breaker (107) in the "ON" position to align feed to vital battery board No. IV.
(01023)
S1-1 i'
C.-
'10_CFR_50, Appendix B, Criterion V requires, in part, that activities _affecting quality shall be prescribed by documented instructions, procedures, or drawings of a~ type appropriate to the circumstances and shall-be accomplished in accordance with those instructions, procedures, or drawings.
Site Standard Practice SSP-12.6, Equipment Status Verification and-Checking Program, Revision, Fection 3.3, Verification Instructions, Step 3.3.1,. Independent Verification Requirements, states, ' Independent verification ~
is required for the following situations on. breakers, valves, andLeomponents in those' systema listed in Appendix A....'
one situation listed stated, 'Any. activity that, if done improperly, could remain undetected until that structure, system or: component i,as called on.to mitigate an-accident-or
-transient as described in the FSAR,...'
Appendix A, List of Systems and Components-Requiring Independant Verification,_
includes the '1?5V Vital DC Distribution System Components that supply control power essential for the Shutdown doards to function properly.'
Contrary to the above, on July 24, 1997, the licensee failed to include requirements for independent verification, as specified by SSP-12.6, in Systems Operating Procedure 0-SO-250-1, 125 Volt DC Vital Power System, Revision 9, Section 8.4, Placing vital batteri No. V in Service for Battery Board I,
II, III,.or IV.
Placing vital battery No. V in service, if done improperly, could remain undetected until that structure, system or component was called on to mitigate an accident or transient as described in the FSAR.
Vital battery board No. V, while in service for battery boards I,
-II, III or IV, would, supply control power essential for the shutdown boards to function properly. (01033)
These violations represent a Severity Level III problem
.(Supplement.I)."
TVA's REPLY TO TNE VIOLATIONS ii.
Reason For The Violations The< reason for_the; violations is personnel error.- The-Operations personnel who were' implementing the instruction forfsparing out Vital Battery IV misread an-instructional stop.. -This(failure to follow procedure resulted in the
-misalignment of'VitalLBattery V and noncompliance with plant-
~ technical: specifications (TSs).
El-2
m
=*..
4 There are-two contributing factors associated with'the
> violations:
- a. The procedure being implemented was -inadequate.
The procedure did not contain verification requirements as required by Site Standard Practice 12.6, " Equipment Status Verification and Checking Program."
Additionally,
-the procedure did not fully use the system capability'in
,that the procedure did not-reference the main control room alarm associated with sparing out Vital Battery IV.
- b. The 125-volt direct current vital battery boards-contein insufficient breaker identification.
2.
'corrootive Steps Taken And Results Achiev_ed
)
After an Operations training instructor identified the vital battery board breaker misalignment, the main control room operators were immediately informed of the condition.
Operations personnel evaluated the condition and promptly took action to connect Vital Battery V to Vital Battery Board-IV.
This action restored the system configuration in compliance with the TSs.
Other actions taken following the misalignment weres a.
Issued a " Caution Order" warning of multiple breakers with a 107 label.
The caution order was placed on each of the multiple 107 breakers used to align Vital Battery V to Vital Battery Board IV as an additional positive barrier to ensure the correct breaker is manipulated, b.
Issued a standing order addressing the misalignment.
The
. standing order provided additional emphasis on human performance by reinforcing requirements for independent
-verification and concurrent verification.
- c. Developed lessons learned describing the misalignment problem, its root cause, and corrective actions.
The
' lessons learned emphasized the use of STAR (Stop, Think, Act, and Review), correct implementation of independent and concurrent verification, and the need to stop and get help when questions are raised.
The senior reactor (operator who was: involved in the misalignment-discussed
- the lossons learned with each cperating crew.
- d. Management reinforced the need to escalate and resolve
-problems and/or issues prior to continuing with a task.
El-3
c
- e. Discussed crew performance and expectations between senior management'and each <hift crew to reinforce personnel accountability.
Senior-management provided positive disciplinary action to the involved individuals, f.. Revised _the implementing _ procedure to add cautions concerning manipulation of breakers with the same number, independent verification requirements, and alarm function verification.
The added cautions highlight the fact'that when transferring 125-volt direct current Vital Battery IV, two breakers labeled 107 will be manipulated and details the locations of those breakers. 'The breaker manipulation' step now: requires both the performer and the independent verifier document the activity.
The 'evision
-requires the performer to-verify alarm actuation in the
, main' control room when Vital-Battery V is placed in service.
These actions have raised operations personnel sensitivity to personnel performance, reinforced personnel accountability, and incorporated additional tools to ensure successful
-performance of'the vital battery sparing evolution.
3.
Corrective steps That [Mave-Been or] will Be Taken To Prevent Recurrence TVA management had recognized the need'to improve human performance and as such, appropriate corrective actions had been developed before the occurrence of the vital battery misalignment.
Implementation of these actions occurred subsequent to this problem.
As discussed in the predecisional enforcement conference, the following actions have.been completed to improve human performance:
a.
Specific expectations were developed and communicated to Operations personnel in face-to-face sessions with
. management.
This action was completed on September 12, 1997.
These expectations are reinforced as an ongoing management action.
'b.
Shift' crew interaction and performance has been improved by evaluating individual performance attributes, stren_gthening and balancing crew composition, and returning;on-shift. personnel to a common crew rotation t
schedule.
These actions improved each crew's performance and strengthened accountability of individuals in each crew-to the shift manager.
This action was completed cut August l 18,11997.
El-4
-)
________---___-___Y
i l
- c. Crew-specific performance indicators were developed on September 22, 1997, and are being used to monitor crew performance, d.
Management involvement in the field has been increased.
Management observations of assistant unit operators and unit operators are conducted, both in the field and main control room.
Additionally, management observations are being conducted of daily work activities.
These observations are providing immediate feedback to the individuals relctive to expectations and work performance and an indicator on effectiveness of human perfoi.tance improvement efforts.
Effectiveness cf those actions is shown in the reduction of plant events such as status control errors.
As can be seen from the chart below, the status control human performance indicator is showing overall improvement.
Past Trend of Status Control Errors a
w.-
6 7
ihq e)
P 4
li yd Q
j 1
d r1 1
h) y g
2 pl h, M e p(1 yu j1 [d Q
}d Fi
-d M
j d hs li Li_21_LL 0 M-il_...d o
- E E
E E
E E
E E
E E
E h8 E
k h
N $E E
E5 8
h As a direct result of the vital battery misalignment problem, the following actions were developed:
- a. Requalification training has been enhanced by development and implementation of " Job Performance Measures" for sparing out the 125-volt direct current vital batteries with Vital Battery V.
El-5
t,
i e
t
.i
- b. : Unique identification will-be-provided for the. breakers
- on the.125-volt direct current vital' battery boards, f
250-volt direct current battery _ boards, and the 120-volt
[
alternating current' vital instrument boards.
This action i
r will be completed by February 17, 1998,.-as verbally.
committed during the predecisional enforcement conference.
- c. Applicable plant procedures in the Operations, Maintenance, and ' Chemistry areas have been riviewed -to f
ensure-that verification requirements are <-
rect and" standardized.' = Procedures that do not contt 4 the l
appropriate verification requirements will t revised by March 27,-1998, as verbally committed during De predecisional enforcement conference.
[
t 4..
Date When Full Coselianoe Will Be' Achieved j
i t
With respect:to the cited violations, TVA.is in full J;
-compli,snce, s
I e
I i
t
- i F
t y
1
?
-l 5
e Y
I El '
=
4 fa py ry c
$4 gy-y--wyw-+s.y9-y-m--t-t*"'w*'4-*WPT V-"w'-'-
$T-Pi 7
'"T""-
-M--y W-4' 4
5 g
U-#? "T**G3' 4
9
ENCLOSURE 2 j
TENNESSEE VALLEY AUTNORITY SEQUOYAN NUCLEAR PLANT (SQN)
UNITS 1 AND 2 INSPECTION REPORT NUMBERS 50-327/97-13 AND 50-320/97-13 i
LIST OF CODWITiRNTS
- 1. Unique identification will be provided for the breakers on the l
125-volt direct current vital battery boards, 250-volt direct current battery boards,.and the.120-volt alternating current vital instrument boards.
This action will be completed by February 17, 1998.
i
- 2. Applicable plant procedures in the operations, Maintenance, and Chemistry areas have been reviewed to ensure that verification requirements are correct and standardized.
Procedures that do not contain the appropriate verification requirements will be revised by March 27, 1998.
?
4 E21