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05000327/FIN-2015004-0131 December 2015 23:59:59SequoyahNRC identifiedFailure to Recognize and Submit for Approval a Reduction in Effectiveness of the Emergency PlanThe inspectors identified a Severity Level IV Non-cited Violation (NCV) of Title 10 of the Code of Federal Regulations, Part 50.54(q), for changes to the licensees radiological emergency plan, effective December 18, 2014, that reduced the effectiveness of the plan and therefore, should have received NRC approval prior to making the change. Specifically, the effectiveness of TVAs Radiological Emergency Plan (Generic Part), Revision 104, was reduced by the inadvertent removal of the offsite telephone communications description for the Health Physics Network and Emergency Notification System communication tools, as well as the monthly testing of those devices. The licensees failure to recognize that Revision 104 reduced the effectiveness of the emergency plan was a performance deficiency. The licensee entered this issue into their corrective action program (CAP) as Condition Report (CR) 1093684 This finding is more than minor because it brings into question the thoroughness of the licensees review process when making changes to the emergency plan and adversely affects the procedure quality attribute of the emergency preparedness cornerstone objective. This finding is a violation of NRC requirements and because it has the potential for impacting the NRCs ability to perform its regulatory function, traditional enforcement is applicable in accordance with IMC 0612, Appendix B. This finding is determined to be a Severity Level IV violation in accordance with Section 6.6.d.1 of the Enforcement Policy because it involves the licensees ability to meet or implement a regulatory requirement not related to assessment or notification such that the effectiveness of the emergency plan is reduced.
05000327/FIN-2012005-0631 December 2012 23:59:59SequoyahNRC identifiedFailure to Submit a Technical Specifications Required ReportThe NRC identified a Severity Level IV non-cited violation of 10 CFR 50.36(c)(5) for failure to submit the Technical Specification (TS) required U1R18 Steam Generator report within 180 days after the initial entry into Mode 4 following completion of an inspection performed in accordance with the Specification 6.8.4.k, Steam Generator (SG) Program. The licensee entered this into their CAP as PER 648658 and as a corrective action submitted the report on December 17th 2012 to the NRC. The inspectors concluded that the failure of the licensee to submit a TS required report was a performance deficiency. The inspectors evaluated this performance deficiency using the traditional enforcement process because the failure to submit a required report affected the NRCs ability to perform its regulatory function. Consistent with the guidance in Section 2.2.2 and Section 6.9.d of the NRC Enforcement Policy, the inspectors concluded the finding was a Severity Level IV violation because the licensee failed to make a TS required report that resulted in no or relatively inappreciable potential safety consequences. In accordance with section 07.03.c of NRC Inspection Manual Chapter 0612 cross-cutting aspects are not assigned to traditional enforcement violations.
05000327/FIN-2012003-0330 June 2012 23:59:59SequoyahLicensee-identifiedLicensee-Identified ViolationThe violation referenced in Section 4OA5.2 was identified by the licensee and meets the criteria of Section 2.3.2.b of the NRC Enforcement Policy for characterization as a Non- Cited Violation. This issue is in the licensees CAP as PER 452027, MPC Forced Helium Dehydration Calculation Methodology. This is a Severity Level IV violation and is being treated as a non-cited violation (NCV), consistent with Section 2.3.2.b of the NRC Enforcement Policy; specifically, the violation was identified by the licensee, the issue was placed into the licensees CAP, the violation was not repetitive as a result of inadequate corrective action, and the violation was not willful. Documents reviewed are listed in the Attachment.
05000327/FIN-2012002-0431 March 2012 23:59:59SequoyahNRC identifiedInadequate 10 CFR 50.59 Evaluation for Implementation of Manual Actions to Cool RHR Suction Piping During a Mode 4 Loss of Coolant AccidentThe inspectors identified a Severity Level IV (SL-IV) non-cited violation (NCV) of 10 CFR 50.59, Changes, Tests, and Experiments, for the licensees failure to obtain a license amendment pursuant to 10 CFR 50.90 prior to implementing local operator manual action (OMA) changes to Technical Specifications (TS) Bases 3.5.3 and abnormal operating procedure (AOP)-R.02 that were specified in Engineering Document Change (EDC) 22487. The 10 CFR 50.59 performed to support EDC 22487 was inadequate in that the 50.59 did not identify that prior NRC approval was required for implementation of the changes. Specifically, the licensee revised AOPR. 02, Shutdown LOCA, and TS Bases 3.5.3, ECCS - Shutdown, to include OMAs to cool the residual heat removal (RHR) system suction piping as part of RHR realignment to establish emergency core cooling system (ECCS) flow in the event of a loss-of-coolant-accident (LOCA) while RHR was aligned to the reactor coolant system for shutdown cooling in operational Mode 4. The new OMAs added for cooling the RHR suction piping had, in effect, changed the intent of the note in TS limiting condition for operation 3.5.3, and were beyond the scope of what the NRC had previously reviewed and approved in Technical Specification Change 07-05. The licensee entered this issue into the corrective action program as problem evaluation report 535471. The finding was determined to be more than minor because prior NRC review and approval was required before changing the AOP and the TS Bases to include the OMAs for cooling the RHR suction piping as part of ECCS realignment in the event of a Mode 4 LOCA. The inspectors reviewed this issue, in accordance with Inspection Manual Chapter 0612 and the NRC Enforcement Policy, and determined that traditional enforcement was applicable to this issue because it impacted the ability of the NRC to perform its regulatory oversight function. The inspectors determined that this finding was not suitable for evaluation using the significance determination process, and as such, was evaluated in accordance with the NRC Enforcement Policy. The inspectors determined that this finding was of very low safety significance because, since implementation of EDC 22487, the OMAs to cool the RHR suction piping would not have been required if a LOCA had occurred during the times that RHR shutdown cooling was in service in Mode 4. The finding was reviewed by NRC management and because the violation was determined to be of very low safety significance, was not willful or repetitive, and was entered into the corrective action program, this violation is being treated as a Severity Level IV noncited violation, consistent with the NRC Enforcement Policy. The violation was not screened for associated cross-cutting aspects because it involved traditional enforcement.
05000327/FIN-2011004-0130 September 2011 23:59:59SequoyahNRC identifiedFailure to Report System ActuationThe inspectors identified a non-cited violation of 10 CFR 50.73, Licensee Event Report System, for the licensees failure to report an invalid system actuation. On May 5, 2011, a containment ventilation isolation (CVI) signal was inadvertently generated on Unit 2 while performing surveillance testing. This system actuation was not reported to the NRC as required by 10 CFR 50.73(a)(2)(iv) within 60 days of discovery of the event. This issue was entered into the licensees corrective action program as PER 417453, and was reported to the NRC as EN #47249 on September 8, 2011. This violation was determined to be applicable to traditional enforcement because of its potential to impact the ability of the NRC to perform its regulatory oversight function, and was therefore evaluated in accordance with the NRC Enforcement Policy. This issue was determined to be a Severity Level IV violation in accordance with Section 6.9.d.9 of the NRC Enforcement Policy. No cross-cutting aspect was assigned since traditional enforcement violations for which there are no associated ROP findings are not screened for cross-cutting aspects.
05000327/FIN-2009007-0131 December 2008 23:59:59SequoyahNRC identifiedFalsifying DataDuring an NRC investigation conducted between February 20, 2008 and December 16, 2008, a violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation is listed below: 10 CFR 50.9 (a) requires that information provided to the Commission by a licensee or information required by statute or by the Commissions regulations, orders, or license conditions to be maintained by the licensee shall be complete and accurate in all material respects. Technical Specification 6.8.1 requires procedures described in Appendix A of RG 1.33, Revision 2 to be established, implemented, and maintained. Paragraph 10 of Appendix A of RG 1.33 requires, in part, that chemical control procedures be written to prescribe the limitations on concentrations of agents that may cause corrosive attack or fouling of heat transfer surfaces and specify laboratory instructions and calibration of laboratory equipment. Licensee procedure SPP-5.3, Chemistry Control, Revision 5, implemented this requirement for all TVA nuclear facilities. Step 3.1.3 of procedure SPP-5.3 required Chemistry licensee personnel, including Chemistry Supervisors, to implement chemistry quality assurance and quality control (QA/QC) programs. Appendix D of procedure SPP-5.3 described chemistry quality assurance, quality control and referenced procedure CHTP-109, Chemistry QA/QC, for the details. Step 4.2.3E of procedure CHTP-109 required that a known control standard check within the same concentration range as the instrument calibration range be performed along with each batch of samples and described a batch as less than or equal to 10 samples in a 12 hour period. Contrary to the above, on January 25, 2008, a Chemistry Shift Supervisor deliberately entered false data into the Chemistry Department internal laboratory statistics database. Specifically, on January 24, 2008, the licensee employee failed to perform the required QA/QC standard check for the evening shift, and the following day entered false data into the database. This information was material to the NRC in that the substance of the information is used to determine compliance with the Technical Specifications. The Chemistry Shift Supervisors deliberate entry of false data into the internal laboratory statistics database caused the licensee (TVA) to be in violation of 10 CFR 50.9 (a). This is a Severity Level IV violation. Pursuant to the provisions of 10 CFR 2.201, TVA is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001 with a copy to the Regional Administrator, Region II, and a copy to the NRC Resident Inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice
05000327/FIN-2008005-0131 December 2008 23:59:59SequoyahNRC identifiedFailure to Notify the Commission Within 30 Days After a Licensed Operator Was Diagnosed With a Permanent Physical Medical ConditionThe NRC identified a non-cited violation (NCV) of 10 CFR 55.25 and 50.74 for failure to notify the Commission within 30 days after a licensed operator developed a permanent change in his physical condition. The licensee entered this finding into their corrective action program as problem evaluation report 158614. This finding was evaluated using the traditional enforcement process because the licensees failure to report the changes in medical condition impacted the Commissions ability to perform its regulatory function associated with operator licensing. Using Supplement I, Reactor Operations, of the NRC Enforcement Policy, this finding was determined to be a Severity Level IV violation because the change in the operators physical condition did not impact his ability to perform licensed duties. The cause of the finding was the licensee failed to understand that all permanent conditions, disabilities, and incapacities must be reported to the NRC for evaluation, regardless of whether the operator had exceeded the specific minimum requirement or the related disqualifying condition threshold in ANSI/ANS-3.4, Medical Certification and Monitoring of Personnel Requiring Operator Licenses for Nuclear Power Plants. (Section 1R11.1
05000327/FIN-2001007-0131 December 2000 23:59:59SequoyahNRC identifiedN/A10 CFR 50.7 prohibits, in part, discrimination by a Commission licensee or a contractor of a Commission licensee against an employee for engaging in certain protected activities. Discrimination includes discharge or other actions relating to the compensation, terms, conditions, and privileges of employment Contrary to the above, on April 19, 2000, the licensee discriminated against a contract security officer as a result of his engaging in protected activity. Specifically, the officers protected activity involved his objection to being instructed not to follow Physical Security Instruction PHYSI-32, Security Instructions for Members of the Security Force, Revision 24, which was part of his assigned responsibilities. The licensee made statements which resulted in the employees belief that his employment was being threatened if he followed certain procedural steps. Subsequently, the contract security officer deliberately did not implement some personal search requirements when a metal detector alarmed during a senior licensee officials entry into the protected area. The intimidation represented a discriminatory action related to the compensation, terms, conditions, and privileges of the contract security officers employment.
05000327/FIN-2001007-0231 December 2000 23:59:59SequoyahNRC identifiedFailure to Search an Individual Prior to Granting Access to the Protected Area in Accordance With Access Control ProceduresSequoyah Physical Security Plan, paragraph 5.3.1, Personal Searches, establishes personal search requirements for individuals entering the protected area. The licensee implements personal search requirements through Sequoyah Nuclear Plant Physical Security Instruction PHYSI-32, Security Instructions for Members of the Security Force PHYSI-32, Rev. 24, Step 3.3.C, required that individuals entering the protected area shall be subjected to a personal search, including processing through the metal detector. If an alarm is received on the metal detector, the individual who caused the alarm shall be asked to ensure that all metal is removed (including shoes) and to process through the metal detector again. Should the individual alarm the detector again, the member of the security force shall physically search the individual. Contrary to the above, on April 19, 2000, the licensee deliberately failed to follow PHYSI-32 during the personal search of an individual entering the protected area. Specifically, a senior licensee official received an alarm from the metal detector while entering into the protected area, and a security officer did not ask him to ensure that all metal, including his shoes, was removed. The contract security officer physically searched the official instead of requesting that he remove his shoes and process through the metal detector again.