ML20217L780
| ML20217L780 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 08/11/1997 |
| From: | Bajestani M TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-327-97-05, 50-327-97-5, 50-328-97-05, 50-328-97-5, NUDOCS 9708190043 | |
| Download: ML20217L780 (12) | |
Text
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Tennessee Vaney Authority, Post omce Box 2000. Soddy Daisy. Tenressee 37379-2000 Masoud Bajestani Site Vice Pmssdent S8QJoyah Nuclear Rant August 11,_1997 U.S. Nuclear Regulatory Commission 10 CFR 2.201 ATTN:
Document Control Desk Washington, D.C. 20555 Gentlemen:
In the Matter of
)
Docket Nos.
50-327 Tennessee Valley Authority
)
50-328 SEQUOYAH NUCLEAR PLANT (SQN) - NRC SPECIAL INSPECTION REPORT NOS. 50-327/97-05 AND 50/328-97 REPLY TO NOTICE OF VIOLATION (NOV)
This letter provides TVA's reply to NOVs 50-327/97-05-01 and 50-327/97-05-02 as documented in the subject NOV dated
-July 10, 1997.
The NOV' identified one Severity Level III problem that contained two violations.
The violatio :s are characterized as: 1) failure to identify and take corrective actions for a significant condition adverse to quality.
relative to deficiencies in the control of reactor coolant system-inventory-during a reduction-of pressurizer level and previous backfills of pressurizer level instrumentation, and
- 2) failure to follow procedure in that the plant's status was either.not logged or incorrectly logged. contains -TVA's response 'to the NOV including the actions _taken and planned.
In addition to these actions, we
-are pursuing the broader actions that were identified in the enforcement conference presentation.
These actions focus on
- increasing management-monitoring of activities to preclude future events,. review and improvement of other process controls, and implementation of. plant material condition i
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&D 9708190043 970811
' V PDR-ADOCK 05000327
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U.S._ Nuclear Regulatory Commission Page 2 August 11, 1997 s
initiatives.
Some examples of management initiatives to preclude events are:
review of twenty eight areas identified in the 1985 through 1988 3ON Nuclear Performance Programs, review of 1993 restart programs, review of the corrective action program database from 1988 e
to 1997 for adequacy of corrective actions and root cause evaluations in:
operational events, reactivity management issues, hold order problems, post maintenanLo testing problems, and configuration problems.
review of four recent reactor trips and two operational events.
Status of these actions will be updated periodically in future management meetings between TVA and NRC.
Commitments asscciated with this submittal are iurluded in.
w.
, U.S. Nuclear Regulatory Commission Page 3 August 11, 1997 If you have questions regarding this response, please contact me at (423) 843-7001 or Pedro Salas at (423) 843-7170.
Sincerely, Masoud
-'estani Sworn to and subscribed before me this
//
day of w2zd 1997 APL$et) e
/drra Notary Public
/E
.My Commission Expires
/0/2/ 97 Enclosures cc (Enclosures):
Mr. R.
W. Hernan, Project Manager Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852-2739 NRC Resident Inspector
-Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy-Daisy, Tennessee 37379-3624 Regional Administrator U.S. Nuclear. Regulatory Commission Region II Atlanta Federal Center 61 Forsyth Street, SW, Suite 23Te5 Atlanta, Georgia 30303-3415
ENCLOSURE 1 TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT (SQN)
UNITS 1 AND 2 INSPECTION REPORT NUriBERS 50-327/97-05 AND 50-320/97-05 REPLY TO NOTICE OF VIOLATION (NOV)
I.
RESTATEMENT OF VIOLATION A A.
"10 CFR 50, Appendix B, Criterion XVI, requires, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances, are promptly identified and corrected.
In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.
Contrary to the above, the licensee failed to establish measures to assure that a signif1 cant condition adverse to quality was promptly identified and corrected and corrective action was taken to preclude repetition.
Specifically, 1.
On March 23 and 24, 1997, during an evolution to drain the pressurizer to 25% level, the licensee failed to identify the inability to accurately monitor and control reactor coolant system (RCS) inventory, a significant condition adverse to quality.
Specifically, several operations personnel c:caerved a malfunction of the cold calibrated pressurizer level instrumentation and failed to pronptly identify that the pressurizer cold calibration level indication wes mallunctioning and take corrective action.
This unidentified malfunction contributed to the inadvertent draining of the pressurizer to less than 0% cold calibration level.
2.
On September 11, 1995, and on April 24, 1996, the cold calibration reference legs for Unit 1 and Unit 2, respectively, were backfilled after rapid depressurization of the RCS, and the licensee failed to take measures to ensure that RCS inventory could i
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be properly monitored and controlled in that the cause of the reference leg voiding was not identified and corrective actions to preclude repetition of the reference leg voiding were not taken.
(01013)"
TVA's REPLY TO THE VIOLATION A 1.
Reason For The Violation The primary cause of the violation was inadequate operator performance. TVA management contributed to the condition by failing to provide the proper combination of operator training and procedural guidance necessary to identify the malfunction of the cold calibrated pressurizer level instrument.
As a result, Operations personnel failed to properly identify the malfunctioned cold calibrated pressurizer level instrument during the March 1997 event (NRC's first example of the violation).
Also they did not fully understand or evaluate the reference leg voiding condition in September 1995 and April 1996, when instrument backfilling was performed following rapid depressurization (NRC's second example of the violation).
2.
Corrective Steps Taken And Results Achieved TVA evaluated the condition following the March 1997 pressurizer level event.
TVA took actions in the following areas: personnel performance, training, procedures, and hardware.
Personnel performance was the primary weakness associated with the event.
The specific areas of this weakness were:
attention to instrument indications, e
pre-job briefings, and e
communications among shift personnel.
e Management also unknowingly conditioned the operating crews to treat the initial pressurizer level change (from water-solid operation to 25 percent) as a noncritical evolution through lack of specific training and additional procedural guidance. I l
T To correct the personnel performance weakness, Operations management has reinforced expectations for:
- attention to instrument indication and conservative decision-making, thoroughness of pre-job briefings, and improved communications.
The Operations management took the appropriate constructive disciplinc with the involved individuals.
Operations management continues to monitor conduct of Operations, adherence to standards and enpectations, and continues to hold Operations personnel accountable for performance.
An independent assessment was conducted by the Operations 4
department using selected peers from other utility operating nuclear plants.
A report of this assessment was issued and is being evaluated by Operations management.
Training did not emphasize draining the RCS from water-sclid operation.
Also, specific guidance on monitoring the pressurizer level by use of cold and hot calibrated level instruments was not adequately emphasized.
Traditional training has focused, to a large degree, on reduced inventory (mid-loop operations).
Similarly, Just-In-Time training did not provide simulator training for pressurizer level changes in the normal operating range of 60 to 25 percent.
Training material to improve operator knowledge relative to the principles, use, and expected response of the pressurizer level instruments has been developed and provided to operators.
The appropriate procedure was revised after the 1997 event to:
provide guidance in use and relationship of the cold and hot calibrated level instruments, require positive inventory control while draining from solid water condition, l
l require installation of the Mansell level gauge, and require backfill of the pressurizer cold calibrated level reference leg.
In 1988 TVA identified that a bow existed in the cold calibrated transmitter sense line.
Although the bow did not contribute to the reference leg loss, the line was repaired after the 1997 event.
3.
Corrective Steps That Will Be Taken To Prevent Recurrence In the area of personnel performance the following actions will be taken:
Specific expectations will be developed for Operations personnel.
These expectations will be communicated to each member of the Operations staff in one-on-one meetings with Operations management to ensure the individual's understanding and acknowledgment of those expectations.
This action will be completed by September 12, 1997.*
Operations crew interaction and performance will be improved by:
O evaluating individual performance attributes, O strengthening and balancing crew composition, O returning on-shift personnel to a common-crew rotation schedule, and 0 developing and using crew-specific performance i:.dicators to monitor performance.
This action will be completed by September 22, 1997.8 Additional management self-assessments in the Operations area will:
These items are considered regulatory commitments. They were either verbal commitments that were made at the enforcement conference or they were actions that NRC credited as a mitigating factor in its application of the Enforcement Policy.
These items are not considered regulatory commitments.
_ 4_
4 4 O focus on specific problem areas such as logheeping, pre-job briefings, and conservative decision-making, O include extended tours with Assistant Unit Operators and control room personnel, O expand participation to include additional senior management and line management, and 0 expand emphasis on backshifts and weekends.
This action will be completed by September 2, 1997.8 The pre-job briefing process, including special training, special management oversight, and worker feedback needs will be evaluated and necessary improvements intarporated before the start of the Unit 2 Cycle 8 (U2C8) reiueling outage '
The Operations department procedures will be reviewed to ensure that other opportunities to loose pressurizer cold calibration level are recognized and that actions are taken to backfill the reference leg as appropriate.
This action will be completed by September 26, 1997
- The procedure change process will be evaluated to determine whether any weakness exists in the interface among organization (s) in conducting cross-discipline reviews for procedure changes affecting equipment and/or plant operation.
Any necessary improvements to the process will be incorporated by October 31, 1997.8 The equipment performance monitoring process will be evaluated and necessary improvements will be incorporated by September 30, 1997.8 In 1988, TVA initiated, but did not complete, a design change notice (DCN) to replace uppdr pressurizer tap angle root valves with straight valves.
The evaluation of the March 1997 pressurizer level event determined that although replacement of these valves would have reduced the number of backfills at power, valve replacement would not have prevented the event. To address the broader These items are considered requiatory commitments. They were either verbal commitments that were marie at the enf orcement conf erence or they were actions that NRC credited an a mitigating factor in its application of the Enforcement Policy.
These items are not considered regulatory commitments. --
issue of reducing backfills at power, the pressurizer l
upper-tap angle root valves will be replaced with i
straight valves.
This action will be completed before restart from the Unit 1 Cycle 9 refueling outage and the Unit 2 Cycle 9 refueling outage.2 4.
Date When Full Compliance Will Be Achieved With respect to the cited violation, TVA is in full compliance.
I.
RESTATEMENT OF VIOLATION B B.
" Technical Specification 6.8.1.a requires, in part, that procedures shall be established, implemented, and maintained covering the activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978, " Quality Assurance Program Requirements (Operation)."
Appendix A of Regulatory Guide 1.33, Section 1, includes procedures for " Log Entries, Record Retention, and Review Procedures."
3SP-12.1, Conduct of Operations, Revision 16, Section 3.8.C.3, requires, in part, that relevant information reflecting static or changing plant conditions shall be recorded in at least one narrative log.
Section 3.8.5.D, requires, in part, that late entries shall be annotated by placing the current time and the words " LATE ENTRY",
followed by the time the entry shou 3d have been made, and then the entry.
Contrary to the above, on March 23 and 24, 1997, relevant information reflecting static or changing plant conditions was not recorded in at least one narrative log, in that: (1) on March 23, a Unit 1 RCS draindown was initiated at approximately 11:00 p.m. and was not recorded; (2) on March 24, a Unit 1 RCS draindown was terminated at approximately 2:00 a.m. and was not recorded; and (3) on March 24, 1997, a Unit 1 RCS drain down was logged at 8:25 a.m. as being natiated at approximately 7:15 a.m. and terminated at approximately 7:45 a.m.,
and the log entry was not annotated as a " LATE ENTRY."
(01023)
These items are concidered regulatory commitments. They were either verbal commitments that were made at the enforcement conference er they were actions that NRC credited as a mitigating factor in it s application of the Enf orce aent Policy.
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. _. _.. _ _, _....... ---.. _... ~.
e TVA's REPLY TO'THE VIOLATION B 1.
. Reason For The Violation Operations personnel failed to adhere to procedural requirements for logging the pressurizer level event.
This failure was caused by a lack of sensitivity for properly maintaining logs.
The nightshift crew members stated that, although they were not overburdened by.the amount of activity beir.g conducted in the-main control room, they were focused on diesel generator surveillance and log entries received a lower priority.
A team consisting of members from three different control room crews performed a root cause analysis (RCA).
The
- Operations' evaluation determined that the root cause of the-logkeeping condition-was failure of Operations Management to take adequate corrective action for prior logkeeping weaknesses and failure to adequately monitor the logkeeping program.
2.
Corrective Steps Taken And Results Achieved f
i TVA has reviewed the details of the pressurizer level event with Operations personnel to emphasize personnel i
performance issues including logkeeping, t
l Actions have been taken to address the root cause for poor logkeeping issues including:
constructive discipline for t he involved individuals, e
modification of the logkeeping program to allow the use of temporary logs, t
strengthening of the Operations department self-e assessments program, increased management oversight, and' follow-up assessments by Site Quality.
Consistent with the above actions, the on-shift managers have been making. formal observations of the logs of the j
previous shift.
Discrepancies are'then turned over to the fol-lowing shift for feedback and correction and the-4
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observation is forwarded to the Operations Manager for review.
The on-shift managers have noted that the assess:aents of logkeeping practices are critical, corrections are being made on the spot, and log quality has improved.
Additionally, the Quality Assurance (QA) organization's periodic observations of control room logs are being used in an ongoing effort to assess the effectiveness of actions taken to improve logkeeping.
The QA organization has noted that operator logs and logkeeping performance have improved.
3.
Corrective Steps That Will Be Taken To Provent Recurrence No additional actions are required.
4.
Date When Full Compliance Will Be Achieved With respect to the cited violation, TVA is in full compliance.
/
/ _
d
.T ENCLOSURE 2 4
TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT (SQN)
UNITS--1 AND 2 INSPECTION REPORT NUMBERS 50-327/97-05 AND 50-328/97-05 i
LIST OF COtedITMENTS VIOLATION A-
+
1.
Specific expectations will be developed for Operations personnel. _These expectations will be communicated to each member of the Operations staff in individual meetings with Operations-management to ensure the individual's understanding and acknowledgment _of those expectations.
This action will be completed by September 12, 1997, 2.
It will be determined if other Operations procedures reference the use of pressurizer cold calibrated level and appropriate backfill requirements will be established by September 26, 1997, i
3.
'The pressurizer upper-tap angle root valves will be replaced i
with straight valves.
This action will be completed before restart from the Unit 1 Cycle 9 refueling outage and the Unit 2 Cycle 9 refueling outage.
Violation B None.
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