ML20137S917
| ML20137S917 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 03/14/1997 |
| From: | Jaudon J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Kingsley O TENNESSEE VALLEY AUTHORITY |
| Shared Package | |
| ML20137S922 | List: |
| References | |
| EA-97-092, EA-97-269, EA-97-92, NUDOCS 9704150280 | |
| Download: ML20137S917 (4) | |
Text
_ _ _ _ . _ - .
March 14,1997 EA 97-092 Tennessee Valley Authority ATTN: Mr. Oliver D. Kingsley, Jr.
President, TVA Nuclear and Chief Nuclear Officer
' 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801
SUBJECT:
NOTICE OF VIOLATION (NRC OFFICE OF INVESTIGATIONS REPORT NO. 2-06-009)
Dear Mr. Kingsley:
This refers to an investigation completed on January 24,1997, by the NRC Office of Investigations (01) regarding the alleged falsification of fire watch joumals at the Sequoyah Nuclear Plant. The results of the 01 investigation findings were summarized in an exit meeting conducted with your staff by telephone on March 13,1997. The enclosed Ol investigation synopsis presents the results of the investigation.
The Ol investigation substantiated that two fire watch personnel failed to patrol their assigned areas but documented their fire watch sheets and joumals as though these areas had been patrolled. The evidence reviewed did not substantiate that their actions were intentional or willful, and no further action will be taken by the NRC against these two employees in consideration of the action you have taken. This notwithstanding, the unacceptable performance of these employees resulted in the failure to meet the hourly fire watch requirements of the Technical Specifications for degraded or inoperable fire protection components.
Based on the results of the 01 investigation, the NRC has determined that a violation of NRC requirements occurred. The violation is cited in the enclosed Notice of Violation (Notice) and involves the failure to maintain complete and accurate records of fire watches. The violation is of concem because NRC relies on complete and accurate documentation to ensure compliance with regulatory requirements. In addition, the violation indicates less than fully effective management oversight which (1) permitted poor documentation by fire watch personnel, (2) permitted discontinuance of the bar code recording system in November 1995, which had provided an additional system of checks and balances without total reliance on human performance, and (3) failed to provide adequate supervision and training for fire watch patrol personnel.
Furthermore, for many years TVA has relied heavily on the use of fire watch patrols for degraded or inoperable fire protection components at Sequoyah. At page 5 of your letter to the NRC, dated December 19,1996, which responded to our Notice of Violation and Proposed imposition of Civil Penalty issued on November 19,1996, (EA 96-260), TVA took 9704150280 970314 PDR ADOCK 05000327 {
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TVA 2 exception to NRC's position that reliance on fire watch patrols for degraded fire protection i components presented a challenge to the fire protection defense in-depth concept. Your :
letter stated that fire watch patrols restore the margin of safety which is lost when fire protection systems are degraded and that a fire watch patrolis an acceptable substitute as opposed to an additional level of mechanical protection. Furthermore, your letter stated that linking the use of fire watch patrols to any resulting increased vulnerability to potential fire ;
exposure or fire damage is unwarranted. The Ol investigation of the circumstances associated with these missed fire watch patrols demonstrates that a fire watch patrol does not always provide a level of equivalent protection.
NRC recognizes that TVA's audit program identified the fire watch discrepancies and that the discrepancies were reported to the NRC in Licensee Event Report (LER) No. 50-327/96-01.
However, questions remain regarding the corrective actions discussed in the LER. As part of the corrective action, the LER stated that an altemative methodology to assist in the prompt
- identification of missed fire watches was being considered for use at Sequoyah; however we understand that the altemative program has not yet been fully implemented. In this regard, we request that your response address the status of your actions in this area and the basis for your decision to discontinue use of the bar code system. You should also provide information that explains how you are now ensuring fire watch patrols are completing required checks and accurately documenting their activity.
I You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. The NRC will use your response, in part, to determine whether further enforcement action is necessary to ensure compliance with regulatory requirements.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter, its enclosures, and your response will be placed in the NRC Public Document Room (PDR). ,
l Sincerely, )
Original signed by Johns P. Jaudon l Johns P. Jaudon, Director Division of Reactor Safety Docket Nos.: 50-327, and 50-328 License Nos: DPR-77 and DRP-79
Enclosures:
- 2. Ol Synopsis cc w/encis: (See page 3)
^
TVA 3 cc w/encis:
O, J. Zeringue; Senior Vice President Pedro Salas, Manager
- Nuclear Operations Licensing and Industry Affairs
' Tennessee Valley Authority Tennessee Valley Authority 6A Lookout Place 4J Blue Ridge 1101 Market Street 1101 Market Street Chattanooga, TN 37402-2801 Chattanooga, TN 37402-2801 Jack A. Bailey, Vice President Ralph H. Shell, Manager Engineering & Technical Services Licensing and Industry Affairs
-Tennessee Valley Authority Sequoyah Nuclear Plant 6A Lookout Place P. O. Box 2000 1101 Market Street Soddy-Daisy, TN 37379 Chattanooga, TN 37402-2801 J. T. Herron, Plant Manager R.J.Adney Sequoyah Nuclear Plant Site Vice President Tennessee Valley Authority Sequoyah Nuclear Plant P. O. Box 2000 Tennessee Valley Authority Soddy Daisy, TN 37379 P. O. Box 2000 Soddy-Daisy, TN 37379 - (cc w/encls cont'd - See page 4)
General Counsel -
Tennessee Valley Authority ET 10H 400 West Summit Hill Drive ' '
Knoxville, TN 37902 Raul R. Baron, General Manager Nuclear Assurance and Licensing Tennessee Valley Authority 4J Blue Ridge 1101 Market Street Chattanooga, TN 37402-2801
TVA 4 (ce w/encls cont'd)
Michael H. Moble). Director Division of Radiological Health-3rd Floor, L and C Annex
. 401 Church Street Nashville, TN 37243-1532 County Executive Hamilton County Courthouse Chattanooga, TN 37402 Distribution w/encis:
. J. R. Johnson, Rll M. S. Lesser, Ril S. E. Sparks, Rll F. J. Hebdon, NRR
. R. W. Heman, NRR W. H. Miller, Ril H. L. Whitener, Ril C. F. Smith, Ril E. D. Testa, Ril D.' H. Thompson, Ril J. H. Moorman, Ril .
P. E. Fredrickson, Rll J. Lieberman, OE B. Uryc, Rll PUBLIC j NRC Resident inspector U. S. Nuclear Regulatory Commission 2600 Igou Ferry Soddy-Daisy, TN 37379 NRC Resident inspector U. S. Nuclear Regulatory Commission 1260 Nuclear Plant Road Spring City, TN 37381 orrier nos m r / nos, pit non,pir ricsmt l sica,arunE
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