ML20196L575

Responds to NRC Re Notice of Violation & Proposed Imposition of Civil Penalty.Corrective Actions: Controls Established to Limit Interchanging Operators from Cold Shutdown Unit to Operating Unit

ML20196L575
Person / Time
Site:	Sequoyah
Issue date:	07/05/1988
From:	Gridley R TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NUDOCS 8807080016
Download: ML20196L575 (13)

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TENNESSEE VALLEY ' AUTHORITY CH ATTANOOGA. T ENNESSFE 37401 SN 1578 Lookout Place JUL 051988 Olrector, Office of Enforcement U.S. Nuclear Regulatory Commission ATIN: . Document Control Desk Washington, D.C. 20555 Gentlemen:

In the Matter of ) Docket No. 50-328 Tennessee Valley Authority )

SEQUOYAH NUCLEAR PLANT (SQN) UNIT 2 - NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY (NRC INSPECTION REPORT NO. 50-328/88-20) -

RESPONSE TO NOTICE OF VIOLATION Enclosed is TVA's response to S. D. Ebneter's letter to S. A. White dated June 3 1988, that transmitted two notices of violation and proposed imposition of civil penalty and two violations not assessed a civil penalty (NRC Inspection Report No. 50-328/88-20).

Enclosure 1 provides TVA's response to the notices of violation assessed a "

civil penalty. Enclosure 2 provides TVA's response to notices of violation not assessed a civil penalty. Sumnary statements of commitments contained in this submittal are provided in enclosure 3.

I Fees in response to the civil penalty of $50,000 are being wired to NRC, I attention Director, Office of Enforcement.

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.If you have any questions, please telephone me at (615) 751-2729.

Very truly yours, l TENNESSEE V LLEY AUTHORITY R. rid ey, O ector -

Nuclear Licensing and Regulatory Affairs Enclosures cc: See page 2 l

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8807080016 880705 PDR ADOCK 05000328 Q PDC m An Equal opportunity Employer

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i U.S. Nuclear Regulatory Commission JUL 051988 cc (Enclosures):

Mr. F. R. McCoy, Assistant Director for Inspection Programs TVA Projects Division U.S. Nuclear Regulatory Commission Region II 101 Harletta Street, NH, Suite 2900 Atlanta, Georgia 30323 Ms. S. C. Black, Assistant Director for Projects TVA Projects Division U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Sequoyah Resident Inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy Daisy, Tennessee 37379

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. ENCLOSURE 1 RESPCNSE TO NRC INSPECTION REPORT NUMBER 50-328/88-20 REPLY TO A NOTICE OF VIOLATJ0N

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PROPOSE 0 CIVIL PENALTY S. D. EBNETER'S LETTER TO S. A. WHITE DATED JUNE 3, 1988 Violation 50-328/88-20.I.A "I. Violations Assessed a Civil Penalty A. Technical Specification 3.5.2 requires for MODES 1, 2, and 3, a minimum of two independent emergency core cooling system (ECCS) subsystems shall be operable with each subsystem comprised of, among otner equipmert, one operable centrifugal charging pump.

Technical Specification 3.0.3, which contains the ACTION requirements when two ECCS subsystems are inoperable, requires, in part, that within one hour, action shall be initiated to place the unit in a MODE in which the Specification does not apply.

Contrary to the above, on March 9, 1988, with the unit in MODE 3, two ECCS subsystems were inoperable for one hour and twenty-four minutes and action was not initiated to place the unit in a MODE in which the Specification does not apply. Both centrifugal charging pumps were in the pull-to-lock position and would not have operated automatically upon receipt of a safety injection signal."

Admission or Denial of the Alleged Violation TVA admits the violation subject to the following corrections and clarification. During the I hour 24 minutes in question, the handswitch (HS) for the 28-8 centrifugal :harging pump (CCP) was not in the pull-to-lock (PTL) position. Maintenance had previously been completed on the 28-8 pump, and the pump had been returned to service and was in service providing charging flow and RCP seal flow. However, the postmaintenance test (PMT) had rot yet been completed; and therefore the 28-B pump was not technically declared operable at that time. The 28-B CCP would have operated automatically upon receiving a safety injection signal. The 2A-A CCP HS was in the PTL position as discussed below.

Reason for the Violation The immediate causes of the violation were a result of the day-shif t reactor operator (RO) (operator A) not recognizing that placing the CCP HS in the PTL position would result in the CCP being considered inopeiabie. The 28.B CCP, for which maintenance had previously been completed, was placed in service to perform a PMT. The 2A-A CCP HS was placed in the PTL position. The PMT on 28-B was completed I hour and 24 minutes later, and the 2B-B CCP was lef t in service with the 2A-A CCP HS still in the PTL position. Because of the operator's (operator B) interpretation of the switch position and a high level of activity in the Main Control Room (MCR) during the turnover process, the subsequent shift turnover did not identify that the 2A-A pump was inoperable

.as a result of the HS being in the PTL position. Because the turnover process l

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, did not identify the 2A-A CCP as being inoperable,.the HS position was incorrectly logged in the System Status Checklist (Appendix B1) of Administrative Instruction (AI) 5, "Shift Relief and Turnover."

During a nonscheduled shift turnover, a new system status checklist (Appendix B1 of AI-5) was not completed by operhtor C; and the incorrectly posttioned CCP HS was not identified at that time. The incorrectly positioned CCP HS was subsequently identified by an NRC inspector, and the HS was then returned to the A-Auto position. During the initial 1-hour-24-minute period, the 2A-A CCP HS was in the PTL position and the 28-B CCP was technically inoperable because of a PMT being performed. However, the 28-B pump was in service and operating during this period with the HS in the A-Auto position. Subsequent completion of the PMT indicated that, had an accident occurred, the 2B-8 pump would have operated automatically to provide required emergency core cooling.

The root causes of the violation resulted from management not adequately considering the potential effects of temporarily assigning operators to a cold shutdown unit and back to an operating unit (mode 3). Operator A had recently been transferred from unit I to unit 2 before this event. This contributed to the operator not fully refocusing to more restrictive technical specification (TS) requirements, to thinking operability requirements were being met with the CCP HS in the PTL position as previously permitted in cold shutdown for reactivity control considerations, and to automatically placing the nonrunning pump in PTL as required in modes 4 and 5 for cold overpressurization considerations. Also, management direction regarding detail of operator log entries and operator communication were less than fully adequate, thus allowing a misleading log entry on the status of CCP-2A-A that resulted in a failure to communicate abnormal status of safety-related equipment.

In addition to the above, procedural weaknesses contributed to failure to recognize the situation. Al-5 did not adequately address nonscheduled shift turnovers. This resulted in the evening shift relief (operator C) not performing a new, independent Appendix Bl to Al-5. An existing TS interpretation (TSI) concerning the operability of a CCP in the PTL position was not consistent with current plant management philosophy. A discrepancy existed between section B of General Operating Instruction (GOI) 3, "Plant Shutdown from Minimum Load to Cold Shutdown," (precaution for solid water operation) and TS 3.1.2.4 (CCPs needed for reactivity control). G01-3 requires one CCP to be locked out when reactor coolant system (RCS) temperature is less than 350 degrees Fahrenheit, node 4, while TS 3.1.2.4 requires both CCPs to be operable in nodes 1 through 4. These procedural weaknesses partly contributed to operator perception that the 2A-A pump was operable with the HS in PTL and failure to identify and question the abnormal HS position.

L Corrective Steps That Have 8een Taken and Results Achieved i The 28-8 CCP was declared operable following PMT, and limiting condition for operation (LCO) 3.0.3 was exited. The 2A-A CCP HS was placed in the A-Auto position upon identification, therefore exiting LCO 3.5.2.

s TVA has instituted extensive corrective actions to prevent recurrence of this event. These actions include changes to plant procedures, additional administrative controls, increased operator training, and a formal review of TSIs currently in use. The following lists the specific actions completed by TVA to date.

1. Controls have been established to limit interchanging operators from a cold shutdown unit to an operating unit. Approval to interchange must come from the plant manager.

2. AI-6, "Log Entries and Review," (for operator log entries) has been revised to delineate the level of detail for log entries such as specifying switch positions.

3. AI-30, "Nuclear Plant Conduct of Operation," (for operator communication) has been revised to increase the level of communication among operators by specifying interface requirements that must be satisfied during control board manipulations that relate to changing switch positions or taking major equipment out of service.

4. AI-5 has been revised to require the completion of an Appendix B1 l checklist for nonscheduled shift relief.

5. A review of for.nal SQN TSIs has been performed for techni:a1 adequacy and clarity. TSIs needing changes have been corrected.

6. AI-5 has been revised to require the unit supervisor senior reactor operator (SRO) to observe the main control board status for abnormal conditions before assuming shift. A checklist-type guidance is provided, and the review is documented in the unit supervisor log.

7. Senior Office of Nuclear Power tranagement has addressed Operations personnel on the causes, conclusions, and corrective actions for this event.

8. Signs to emphasize plant operating mode have been placed in the MCR and auxiliary instrument room.

9. Training has been completed on procedure changes and TSI changes for unit 2 operators.

10. Scenarios emphasizing the use of TSs have been incorporated into the operator simulator training program. Training sessions with unit 2 licensed operators have been conducted.

11. The requirement in G01-3, to place one CCP HS-in the PTL position below 350 degrees Fahrenhelt, has been revised to pefform the action of PTL upon entry into mode 5. Revision 37 was approved May 13, 1988. .

12. TS 3.5.3, mode 4, and 3.1.2.4, modes 1-4, have been evaluated and determined to be consistent.

Corrective Steps That Will Be Taken to Avoid Further Violations

1. Training for unit 1 operators will be given on procedure changes and TSI changes before unit 1 enters mode 2 as committed to in Licensee Event Report (LER) SQRO-50-328/88010.

2. Scenarios emphasizing the use of TSs have been incorporated into operator simulator training. Training for unit 1 operators will be completed before unit i enters mode 2 as committed to in LER SQRO-50-328/88010.

3. Corresponding changes to the Final Safety Analysis Report, section 5.2.2.4.4, regarding administrative procedures for RCS pressure control during low-temperature operation will be submitted in the next annual update.

Date When Full Compilance Will Be Achieved TVA is in full compliance.

Violation 50-328/88-20.I.8

, "B. 10 CFR 50.72.b.2.111 requires the reporting to the NRC Operations Center via the Emergency Notification System (Red Phone) within four hours of eccurrence, any event or condition that alon! could have prevented the fulfillment of the safety functiu of structures or systems that are needed to shut down the reactor and maintain it in a j safe shutdown condition, remove residual heat, control the release of l

radioactive material, or mitigate the consequences of an accident.

) Contrary to the above, on March 9, 1988, the inoperability of the centrifugal charging pumps was not re,.orted to the NRC Operations Center within the required four hours after it was identified.

! Collectively, those violations have been categorized in the aggregate as a Severt ty Level III problem (Supplement I).

Cumulative Civil Penalty - $50,000 (assessed equally between the violations),"

l Admission or Denial of the /.lleged Violation TVA admits the violation.

Reason for the Violation - ,

On March 9, 1988, at approximately 2000 eastern standard time, the shift operation supervisor (SOS) was made aware of the 2A-A CCP HS having been in the PTL position. The SOS assessed the event along with the shift technical advisor, and a potential reportable occurrence was written. At this time, the SOS did not have positive evidence that the 2A-A CCP was inoperable as a result of being in PTL coincident with the 2B-B CCP undergoing a PMT earlier that day. Following verification the following morning with the operators involved that the 2A-A CCP HS had been in the PTL position coincident with~the PMT on the 28-B CCP and.that this condition had lasted for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 24 minutes, it was concluded that TS LCO 3.0.3 had been inadvertently entered. Because this situation was not recognized at the time, a shutdown had not been initiated within one hour, resulting in an operation prohibited by TSs. This would be reportable to NRC in accordance with 10 CFR 50.73.a.2.1.8 (LER). In an effort to keep NRC apprised of activities at SQN, a conservative application of 10 CFR 50.72 was also applied; and the four hour notification was effected. ,

TVA does not wish to pursue this specific event further; however, in reviewing the overall issue with respect to NRC guidelincs for reporting, it is unclear that the event in itself meets any of the re'luirements of 10 CFR 50.72 rules.

It does, however, meet the requirements of 10 CFR 50.73 for a 30-day LER in accordance with 10 CFR 50.73.a.2.1 as an operation prohibited by the TSs. The event was conservatively reported as a four hour notification under the 10 CFR 50.72.b.2.111 rule. This rule addresses any event or condition that alone could have prevented the fulfillment of safety functions. This rule "

does not require that you assume a failure of the opposite train.

Specifically, NUREG-1022, Supplement 1, question 7.8, states that unrelated, independent failures that did not actually occur should not be included in the evaluation if an event or condition is reportable under this rule. During this event, the 28-B CCP was in operation, as was stated earlier, and was always capable of performing its intended safety function. Had an accident occurred during this time, the 28-B CCP would have continued to operate and  ;

perform its emergency core cooling function.  ;.

l' In conclusion, a notification was not made to NRC within four hours of the identification of the 2A-A CCP HS in the PTL position; but it is believed that a conservative interpretation of the reporting requirements was made upon confirmation that TS 3.0.3 had inadvertently been ent; red and confirmation i that the duration resulted in the action of TS 3.0.3 not being compiled with. '

Corrective Steps That Have B?en Taken Immediate corrective actions were effected by making the telephone l; notification. TVA senior management has directed the shift supervisors te i ensure control of shift activities and to become more involved with incidents -

of this nature. The 50Ss are aware of their responsibility to perform ll determinations and notifications in accordance with 10 CFR 50.72.

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TVA management has additionally discussed with the.50Ss the importance of aggressively pursuing resolutions in a timely fashion of incidents involving TSs. TVA management has also directed the SOSs to be conservative during evaluations of events involving TSs and to initiate a notification when situations indicate this action could be required.

Corrective Steps That Will Be Taken to Avoid Further Violations No further action is required.

Date When Full Compliance Will Be Achieved TVA is in full compliance.

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ENCLOSURE 2 RESPONSE TO NRC INSPECTION REPORT NUMBER 50-328/88-20 REPLY TO A NOTICE OF VIOLATION NOT ASSESSED A CIVIL PENALTY S. D. EBNETER'S LETTER TO S. A. WHITE DATED JUNE 3, 1988 Violation 50-328/88-20.II.A "II. Violations Not Assessed a Civil Penalty A. Technical Specification 6.8.1 requires that written procedures be establishe'd, implemented, and maintainee' covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, ,

Revision 2, February 1978. Appendix A o' Regulatory Guide 1.33 requires that procedures be established and implemented to control system operations and administrative acti"ities.

Contrary to the above, the licensee failed to adequately establish and implement procedures in the following instances:

1. On March 5, 1988, a Technical Specification Interpretation was established and used that conflicted with the plant Technical Specifications. Technical Specification Interpretation 8 allowed operation of the facility, with Technical Specification 3.0.5 invoked, with one alternate motor driven auxiliary feedwater train operable and the capability to supply at least three steam generators from the turbine driven 4

auxiliary feedwater pump. In some circumstances, this allowed 3 operation of the facility with flow paths to only three steam generators. However, Technical Specification 3.7.1.2 requires that flow paths to all four steam generators be operable.

2. On March 9, 1988, the improper implementation of the AI-5 Lead Operator Checklist resulted in the improper documentation of the 2A-A CCP control room handswitch position. The checklist Indicated that the handswitch was in the prcper position (i.e. A-Auto), whereas the actual position w. pull-to-lock 3 (PTL).

This is a Severity Level IV violation (supplement I)."

Admission or Denial of the Alleged Violation (example 1)

TVA admits the violation.

Reason for the Violation On March 5,1988, during the performance of Sur..'111ance :nstructior, (SI) 166.8, "Increased Frequency Testing of Category A and 8 Valves," valve 2-LCV-3-175 failed to stroke. 51 14' J reluir.;s that, if the valve exceeds the maximum allowable stroke time u've sh '

he declared inoperable and

! repaired. The valvt should have red insperable end LC0 3.7.1.2

entered; but the operator usad

• the operation of unit 2 without entry into an LCO. Additional' .

~ the valve .o strcka was not  ;

recorded in the 509, UO, or R0 '

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The root cause of this violation was failure to properly implement SI-166.8 is written, failure to record the occurrence in operational logs at the time of the event, and use of an inadequate TSI resulting in failure to enter an LCO, Corrective Steps That Have Been Taken and Results Achieved

1. AI-6 has been revised to delineate the level of detail for log entries.

2. A rev u / of formal SQN TSIs has been performed for technical adequacy arf clarity. TSIs needing changes have been corrected.

3. Scenarios emphasizing the use of TSs have been incorporated into the operator simulator training program.

4. Late entries were written in 505/UO/R0 logs to reflect the findings of valve nonactuation by the previous shifts.

Corrective Action That Will Be Taken to Avoid Further Violations No further corrective action is required.

Date When Full Compliance Hill Be Achieved TVA is in full compliance.

Admission or Denial of the Alleged Violation (example 2)

TVA admits the violation.

Reason for the Violation The HS for 2A-A CCP was placed in the PTL position by the day-shift R0 (operator A) when the 28-B CCP was placed in service to perform a PMT.

Because of the operator's (operator B) interpretation of the switch position and a high level of activity occurring in the MCR during the turnover process, the subsequent shift turnover did not identify that the 2A-A pump was inoperable as a result of the HS being in the PTL position. Bec:Use the turnover process did not identify the 2A-A CCP as being inoperable, the HS position was incorrectly logged in the System Status Checklist (Appendix B1) of AI-S.

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Corrective Steps That Have Been Taken and Results Achieved- >

1. AI-6 (for operator log entries) has been revised to delineate the level of I detall for log entries such as specifying switch positions.  ;

2. . AI-30 (for operator communication) has been revised to increase the level of communication among operators by specifying interface requirements that must be satisfied during control board manipulations that relate to ,

changing switch positions or taking major equipment out of service.  !

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3. AI-5 has been revised to require the unit supervisor SR0 to observe the j main control board status for abnormal conditions before assuming shift.

A checklist-type guidance is providec, and the review is documented in the unit supervisor log.

. Corrective Steps That Will Be Taken to Avoid Further Violations, No #urther action is required.

Date When Full Compliance Will Be Achieved TVA is in full compilance.

Violation S0-328/88-20.11.B "B. TS 4.5.1.1.1.6 requires that each cold leg accumulator be demonstrated l

operable by verifying the boron concentration within six_ hours after i each solution volume increase of greater than or equal to 1 percent of l

the tank volume. '

Contrary to the above, on March 6, 1988, the number 3 cold leg accumulator boron concentration was not verified within six hours after a solution volume increase of greater that I percent of tank I volume due to inleakage.

l This is a Severity Level IV violation (Supplement I)."

! Admission or Dental of the Alleged Violation ,

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! TVA admits the violation.  ;

Reason for the Violation i I i l The root causes of this violation have been determin.J to be that the Operations shift crews did not consider that the RCS leakage into the i accumulator, after draining the accumulator, constituted a filling operation j and that applicable Operations procedures did not alert the op?rator to l

l request a boron concentration sample for such an event, i

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' Corrective Steps That Have Been Taken and Results Achieved Immediate corrective actions were to declare the accumulator inoperablo and to have the Radiochemistry Laboratory verify the boron concentration.

Radiochemistry Laboratory personnel sampled the accumulator; and the results of the sample yielded a boron concentration of 2,085 parts per million, which is within TS limits. The accumulator was then declared operable.

In order to preclude recurrence of the event, System Operating Instruction 63.1, "Emergency Core Cooling System," has been revised to require a boron concentration sample to be taken af ter both filling and draining occur. This will prevent refilling of the accumulator without obtaining the corresponding boron concentration as required by TSs. A training letter has been issued to Operations personnel detalling the subject matter of this incident. This will ensure that operators are aware that inleakage into a tank or accumulator constitutes a refilling operation and that appropriate action must be

. initiated. Additionally, SI-2, "Shif t Log," contains a note that will alert Operations personnel to notify the Radiochemistry Laboratory to perform a boron concentration analysis when cold-leg accumulator volume increases by 1 percent or greater, as recuired by TSs.

Corrective Steps That Hill Be Taken to Avoid Further Violations No further corrective action is required.

Date When Full Compliance Hill Be Achieved TVA-is in full compliance.

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,, Commitments

1. Training for ur. ,c.atorswillbegivenonhrocedurechangesandTSI changes before unit i enters mode 2 as committed to in LER SQRO-50-328/88010.

2. Scenarios emphasizing the use of TSs have been incorporated into operator simulator training. Training for Unit 1 operators will be completed before unit i enters mode 2 as committed to in LER SQR0-50-328/88010.

3. Corresponding changes to the Final Safety Analysis Report, section 5.2.2.4.4, will be submitted in the next. annual update.