ML20078S961

Forwards Response Violations Noted in Insp Repts 50-327/94-34 & 50-328/94-34.Corrective Actions:Managerial Requirements & Supervisory Techniques Stressed to Maint Supervision,Including Review of Issue W/Maint Dept Managers

ML20078S961
Person / Time
Site:	Sequoyah
Issue date:	12/22/1994
From:	Adney R TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9412290332
Download: ML20078S961 (5)

Text

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f Tennessee Van ey Aumon!y Post Ort.ce Box 2000. Sod @ Daisv Tennessee 37379

, December 22, 1994 U.S. Nuclear Regulatory Commission -

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) - INSPECTION REPORT NOS. 50-327, 328/94 REPT.Y TO NOTICE OF VIOLATION (NOV) 50-327, 328/94-34-01 Enclosure 1 contains TVA's reply to Mark S. Lesser's letter to Oliver D. Kingsley, Jr., dated November 29, 1994, which transmitted the subject NOV. The violation is associated with the failure to implement procedures and/or have adequate procedures as required by 10 CFR 50, Appendix B, criterion V, which requires, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings such that the activity can be accomplished in accordance with these instructions, procedures, or drawings. During the implementation of a scheduled maintenance activity on the electrical distribution equipment, several delays occurred, resulting in exceeding the Limiting Condition for Operation (LCO) timeframe. Discretionary enforcement of LCO 3.8.2.1.b to exceed the 24-hour action statement was requested and granted. The delays involved the testing of a wrong breaker and incorrect vendor and TVA drawings. A list of commitments is included in Enclosure 2.

If you have any questions concerning this submittal, please telephone

. J. W. Proffitt at (615) 843-6651.

Sincerely, p /'

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Gk R. . Adney Site Vice Presiden Enclosure cc: See page 2 9412290332 941222 PDR ADOCK 05000327 j ll O PDR l

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U.S. Nuclear Regulatory Commission  !

Page 2 l December 22, 1994 ,

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Mr. D. E. LaBarge, Project Manager U.S. Nuclear Regula, tory 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

! 101 Marietta Street, NW, Suite 2900

! Atlanta, Georgia 30323-2711 1

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i ENCLOSURE 1 I

RESPONSE TO NRC INSPECTION REPORT NOS. 50-327, 328/94-34 ,

4 MARK S. LESSER'S LETTER TO OLIVER D. KINGSLEY, JR. l DATED NOVEMBER 29, 1994 Violation 50-327. 328/94-34-01 l

"10 CFR Part 50, Appendix B, Criterion V, requires, in part, that l activities affecting quality shall be prescribed by documented )

i instructions, procedures, or drawings, of a type appropriate to the )

j circumstances and shall be accomplished in accordance with these

+ instructions, procedures, or drawings. l 2 \

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" Contrary to the above on October 1, 1994,

1. An activity affecting quality was not accomplished in accordance with I prescribed instructions in that Work Order 93-08531-00 was'not followed during maintenance and testing of vital inverter 2-I. The rectifier output breaker was initially tested instead of the inverter d

DC input breaker which contributed to the inability to complete the j work within the required technical specification action statement.

2. Instructions, procedures and drawings were inadequate in that TVA

! Drawing 1,2-45N700-1, vendor drawing 014D17734, vendor manual SQN-VTD-S250-0020 and Procedure SOI 0-SO-250-2 incorrectly depicted I

or referred to the AC output switch for vital inverter II-1 as a circuit breaker. This resulted in testing that damaged a replacement

, switch and contributed to the inability to complete the work within j the required technical specification action statement.

i "This is a severity level IV violation (supplement I)."

2 Reason for the Violation i

l This violation is associated with the implementation of scheduled l maintenance activities on plant electrical distribution equipment. The j reason for the violation example associated with the testing of the wrong breaker was determined to be personnel error resulting from inadequate management involvement. The prejob brief performed by the foreman was lacking in sufficient detail for the complexity and urgency of this 4 task. Field supervision of this task was also inadequate. The TVA drawing utilized did not provide sufficient detail in relation to circuit breaker location on the front of the inverter to positively locate the input circuit breaker. Alsc, the labeling nomenclature used to describe the output breaker was not consistent with each of the inverters.

Therefore, the rectifier output breaker was mistakenly tested as the input breaker. The reason for the violation example associated with inadequate drawings was inadequate vendor information. The vendor failed to provide sufficient information to differentiate between the vendor's molded case switches and their molded case circuit breakers.

• Corrective Steos That Have Been Taken and the Results Achieved Managerial requirements and supervisory techniques have been stressed to Maintenance supervision, including a review of this issue with the Maintenance department managers.

Maintenance employees have been cautioned regarding the potential problems associated with the acceptance of inadequate prejob briefings.

Additionally, the appropriate Haintenance employees have been instructed on how to differentiate between the molded case circuit breaker and molded case switch.

Corrective Steos That Will be Taken to Avoid Future Violations The appropriate plant drawings will be revised to identify the location of input and output circuit breakers. Also, the applicable plant and vendor drawings will be revised, as appropriate, to differentiate between the vendor's molded case switch and their molded case circuit breaker.

The system operating instruction 9 for the vital inverters will be revised to use the same nomenclature for components that is actually on the labels.

The nomenclature labeling for the 120-volt alternating current vital inverter output device will be corrected.

Date When Full Comoliance Will be Achieved TVA will be in full compliance at the completion of the corrective actions scheduled to be completed by June 16, 1995.

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ENCLOSURE 2 l

COMMITMENTS I l

1. The appropriate plant drawings will be revised to identify the .

location of input and output circuit breakers. Also, the applicable l plant and vendor drawings will be revised, as appropriate, to differentiate between the vendor's molded case switch and their molded case circuit breaker. These actions will be completed by June 16, 1995.

2. The nomenclature labeling for the 120-volt alternating current vital inverter output device will be corrected by February 10, 1995.

3. The system operating instructions for the vital inverters will be revised by March 10, 1995, to use the same nomenclature for components that is actually on the labels.

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