ML20248C112

Forwards Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $87,500 from Insp on 890506-0605

ML20248C112
Person / Time
Site:	Sequoyah
Issue date:	09/22/1989
From:	Crutchfield D Office of Nuclear Reactor Regulation
To:	Kingsley O TENNESSEE VALLEY AUTHORITY
Shared Package
ML20248C116	List: ML20248C112 ML20248C119
References
EA-89-152, NUDOCS 8910030371
Download: ML20248C112 (6)

Text

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"["N% UNITED STATES

['i w ~j,:p 7n NUCLEAR REGULATORY Ct.JMISSION WASHINGTON, D. C. 20555

% September 22, 1989 Docket Nos. 50-327 and 50-328 License Nos. DPR-77 and DPR-79 EA 89-152 Mr. Oliver D. Kingsley, Jr.

Senior Vice President, Nuclear Power Tennessee Valley Authority 6N 38A Lookout Place 1101 Market Street Chattanooga, Tennessee 37402-2801

SUBJECT:

NOTICE OF VIOLATION AND PROPOSED If1 POSITION OF CIVIL PENALTY - $87,500 I

(NRC INSPECTION REPORT NOS. 50-327/89-15 AFD 50-328/89-15) l This refers to the Nuclear Regulatory Commission (NRC) inspection conducted by K. Jenison at the Sequoyah facility from May 6 - June 5,1989. The inspectior, included a review of the licensed activities associated with (1) changing the Baron Injection Tank (BIT) from continuous recirculation to periodic recircu-lation and thereby placing it in a configuration that is outside the description in the FSAR, (2) placing the Residual Heat Removal (RHR) system in an unar,alyzed condition as reported in LER 89-11, and (3) repositioning of the source range /

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intermediate range (SR/IR) detectors without resetting the intermediate range high flux bistables resultino in the trip functions being inoperable. The report documenting this inspection was sent to you by letter dated June 26, 1989.

As a result of this inspection, significant failures to comply with NRC regula-tory requirements were identified, and accordingly, NRC cor.; erns relative to the inspection findings were discussed in an Enforcement Conference held on June 29, 1989. The letter summarizing this Conference was sent to yeu on July 13, 1989.

The violations described.in the enclosed Notice of Violation and Preposed Imposition of Civil Penalty, when viewed collectively, raise e significant safety concern regarding your control of licensed activities. Each event was j preceeded by the failure to perform an adequate safety review of the planned .

activity The failure to implement or adhere to your safety review program requirements also resulted in subsequent failures to comply with various (

Technical Specification (TS) action statements.

Violation I.A occurred while in Mode 3, on April 6,1989, whcn Unit 2 BIT recirculation was stopped and the recirculation valves shut to stop backleakage from the Reactor Coolant System, which was causing dilution of the BIT and the l Beric Acid Tanks. This evolution was not performed with the benefit of en j

approved procedure. Consequently, no safety evaluation was performed to determine '

if the new system lineup required a change to the technical specifications or involved an unreviewed safet; question. Taking the BIT out of recirculation made it inoperable and placed the system outside the description in the FSAR, which {

l requires BIT recirculation to prevent cold spots and stratification witrin the 8910030371

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i Tennessee Valley Authority September 22, 1989 tank during normal operation, and to detect any large scale leakage within the tank by a flow indicator and alarm. Your operations staff failed to properly evaluate the BIT condition for compliance with the Technical Specification Limiting Conditions for Operability (LCO) action statement during the period of time it was not in recirculation with the low flow alarm annunciated. The fundamental method used to assure compliance with the LC0 volume requirements is the lack of this alarm with the BIT in recirc.ulation. We are concerned that your cperations management condoned the performance of an evolution without an approved procedure notwithstanding a control room alarm for which the abnormal operating procedure was not followed. This sends the wrong message to your operators regarding procedure compliance. Your management initially considered the BIT to be operable and the BIT was placed back in recirculation only after the NRC expressed concern regarding this issue.

Violation I.B concerns your placing the plant in a second unanalyzed condition.

IE Information Notice 87-01, RHR Valve Misalignment Causes Degradation of ECCS in PWRs, was issued on January 6,1987 to forward information that the licensing bases for the Westinghouse ECCS analysis assumed that all four RCS cold legs were supplied water from at least one RHR pump. Several plants had been perform-ing operability tests of the low-pressure ECCS that isolated the RHR crossover line, resulting in a RHR lineup that would only inject water into two cold legs.

Your early 1987 review of this information determined that your RHR surveillance instructions did not place Sequoyah in such a configuration. However, from May 1987 through December 12, 1988, several RHR surveillance instructions were subsequently revised to place the RHR in such a lineup. Your procedure review process failed to identify substantial technical errors in the proposed procedure revisions, which were subsequently used to perform surveillance on 26 separate occasions from March 22, 1988 through April 20, 1989. Violation II concerns your inadequate corrective action once your Shift Operations Supervisor identi-fied this deficiency. Consequently, one of the deficient procedures was performed on two more occasions. This performance is clearly unacceptable.

Violation I.C concerns the inoperable Intermediate Range (IR) High Flux trip function during reactor startup. On May 5,1989, your Shift Operations Super-visor discovered that the Unit 2 IR High Flux trip bistables, which are set to trip at 25% power, were not tripped wr.ile the reactor power was at 73% power.

Your review of this event, revealed that the storage baskets housing the source dnd intermediate range detectors hdd been permanently repositioned to reduce random electrical noise spiking that had occurred intermittently on the SR channels. The screening review that preceded the change in the detector poshn did not identify that moving the basket would also affect the IR channels and that relocation of the storage basket would result in a change to the IR high Flux trip setpoint es described in the FSAR. Although the screening review as prepared administratively required a safety evaluation, neither the  ;

preparer nor the reviewers recognized the requirement when reviewing the l screening review form and therefore did not perform a safety evaluation. We l

' are concerned that, although your operations staff was aware that detector movement was necessary to allow access for maintenance, your programs did not require operations to be informed of the permanent repositioning of the detectors. In addition, we are concerned that the operations staff seemed unawere of how the source range noise problem was resolved prior to declaring

i Tennessee Valley Authority September 22, 1989 the channels operable after completion of the maintenance activities. As a result, during four plant startups from April 13, 1989 to April 25, 1989,.the IR High Flux trip functions were inoperable without compliance with Technical Specifications action requirements.

We are concerned about the broad breakdown of checks and balances that allowed these three events to occur. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," .10 CFR Part 2, (1989)

(Enforcement Policy), the violations described in the enclosed Notice have been categorized in the aggregate as a Severity Level III problem. The base civil penalty for a Severity Level III problem is $50,000. To emphasize the importance of conducting licensed activities in a manner which ensures that proper safety reviews are performed prior to implementation, that procedures are adequately maintained and followed, and that Technical Specifications are complied with, I have been authorized, after consultation with the Director, Office of Enforcement, and the Deputy Executive Director for Nuclear Materials Safety, Safeguards, and Operations Supp' ort to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty in the amount of $87,500 for the violations described in the enclosed Notice. The escalation and mitigation factors in the Enforcement Policy were considered and are discussed below.

No escalation or mitigation is warranted for identification and reporting. The NRC identified the inoperable BIT condition (violation I.A) and your shift supervisors identified the RHR procedure deficiencies and IR trip functions l

' (violations I.B and C) after each condition had been present for a prolonged period of time. While the individuals who identified the deficiencies are to be commended, your system should have identified these deficiencies earlier.

No mitigation is warranted for your corrective action. Though you are now in the process of conducting an extensive overhaul of your 10 CFR 50.59 review program, this corrective action did not include a plan for addressing previous reviews. This is significant because two of the three events occurred as a result of inadequate reviews conducted between three months and two years ago.

Consequently, your corrective action plan was changed after the NRC identified this weakness. As to Violation I.B prior notice of the RHR lineup concerns were provided to you in IE Information Notice 87-01. The base civil penalty has been increased area by50.59 of 10 CFR 50 percent revi,ews.based on that A proposed notice

$50,000 civil and your penalty poor past EA 88-307) was p(erform issued on February 17, 1989 because your post-trip review process failed to identify that RCS temperature was not being adequately controlled following a reactor trip to ensure adequate end-of-life shutdown margin. This is relevant to the present enforcement action because EA 88-307 identified instances where your programs were not identifying deviations from FSAR assumptions that could subsequently result in operating the plant in an unanalyzed condition. An additional 25 percent escalation is warranted for the multiple examples whereby the plant was operated in an unanalyzed condition (Violations I.A and B).

You are required to respond to this letter and the enclosed Notice and should follow the instructions specified therein when preparing your response. In your response, you should document the specific actions taken and any additional actions you plan to prevent recurrence. After reviewing your response to this Notice, including your proposed corrective actions and the results of future inspections, the NRC will determine whether further NRC enforcement action is necessary to ensure compliance with NRC regulatory requirements.

Tennessee Valley Authority September 22, 1989 In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosure will be placed in the NRC Public Document Room.

The responses directed by this letter and the enc;9sure is not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, Pub. L. No.96-511.

Should you have any questions concerning this letter, please contact us.

Sincerely, ,

L-DennTI'5 h, R. Crutchfie e ill%

d, Asfciate'[frector for Special Projects /

Office of Nuclear Reactor Regulation

Enclosure:

Notice of Violation and Proposed f Imposition of Civil Penalty cc w/ enclosure:

See next page 4

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Tennessee Valley Authority September 22, 1989 cc w/ enclosure:

General Counsel Mr. Kenneth M. Jenison Tennessee Valley Authority Senior Resident Inspector 400 West Summit Hill Drive Sequoyah Nuclear Plant ET 118 33H U.S. Nuclear Regulatory Commission Knoxville, Tennessee 37902 2600 Igou Ferry Road Soddy Daisy, Tennessee 37379 Mr. F. L. Moreadith Vice President, Nuclear Engineering Mr. Michael H. Mobley, Director Tennessee Valley Authority Division of Radiological Health 400 West Sumit Hill Drive T.E.R.R.A. Building, 6th Floor WT 12A 12A 150 9th Avenue North Knoxville, Tennessee 37902' Nashville, Tennessee 37219-5404 Dr. Mark 0. Medford Dr. Henry Myers, Science Advisor Vice President and Nuclear Committee on Interior Technical Director and Insular Affairs Tennessee Valley Authority U.S. House of Representatives 6N 38A Lookout Place Washington, D.C. 20515 Chattanooga, Tennessee 37402-2801 Tennessee Valley Authority Manager Nuclear Licensing Rockville Office and Regulatory Affairs 11921 Rockville Pike Tennessee Valley Authority Suite 402 SN 1578 Lookout Place Rockville, Maryland 20852 Chattanooga, Tennessee 37402-2801 Mr. John L. LaPoint Site Director Sequoyah Nuclear Plant Tennessee Valley Authority P. O. Box 2000 Soddy Daisy, Tennessee 37379 Mr. M. Burzynski -

Site Licensing Manager Sequoyah Nuclear Plant P. O. Box 2000 Soddy Daisy, Tennessee 37379 County Judge Hamilton County Courthouse Chattanooga, Tennessee .37402 Regional Administrator, Region II U.S. Nuclear Regulatory Comission 101 Marietta Street, N.W.

Atlanta, Georgia 30323 t

a l Tennessee Valley Authority September 22, 1989 I Distribution PDR LPDR SECY-CA HThompson, DEDS JTaylor, DEDR JLieberman, OE DCrutchfield, . NRR TMurley, NRR JPartiow, NRR Enforcement Coordinators RI, RII, RIII, RIV, RV FIngram, PA .1 BHayes, 01. -

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