ML20080C695

Responds to NRC Re Weaknesses & Inspector Followup Items Noted in Insp Repts 50-327/94-30 & 50-328/94-30.Check Valve Program Procedure & Other Program Procedures Transferred to Technical Support Reviewed

ML20080C695
Person / Time
Site:	Sequoyah
Issue date:	12/13/1994
From:	Adney R TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9412190219
Download: ML20080C695 (5)

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TemesseEva5Ey' Authority PosiOft;ce Dom 2060.'$odsrossy Yement,ee 9379 7' " ' t t ' '

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.,,g, December 13, 1994 t

U.S. Nuclear Regulatory Commission ATTNs Document Control Desk Washington, D.C. 20555 i

centlemen:

In the Matter of ) Docket Nos. 50-327 Tennessee Valley Authority ) 50-328 SEQUOYAH NUCLEAR PLANT ($QN) - INSPECTION REPORT NOS. 50-327, 328/94 RESPONSE TO WEAKNESSES - INSPECTOR FOLLOW-UP ITEMS (1FIs) 50-327, 328/94-30-01, AND -02 Enclosed is TVA's reply to R. V. Crlenjak's letter to Oliver D. Kingsley, Jr.,.

dated Octob3r 14, 1994, which transmitted the subject inspection report.

Mr. Crlenjak's letter requested a written response addressing two weaknesses that vere identified in the inspection report as IFIs. The first weakness is associated with implementation deficiencies in the check valve program. The second weakness involves inadequate preventive maintenance performance on remote valve operators.

If you have any questions concerning this submittal, please telephone R. H. Shell at (615) 843-7170.

Sincerely,

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R. . Adney Site Vice President Enclosure cca See page 2 9412190219 941213 }1 PDR ADOCK 05000327 '

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v Mr.:D.:E.1LaBarge, Project Manager 2

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j . U.S.. Nuclear Regulatory. commission

' 5 {. 'One White. Flint, North' 11555 Rockville Pike Rockville,. Maryland 20852-2739 ,

-4 NRC Resident Inspector Sequoyah Iluelear Plant 2600 Igou Ferry Road / . .

Soddy-Daisy,~ Tennessee 37379-3624 L Regional Administrator U.S. Nuclear Regulatory Commission Region II- I 101 Marietta' Street, NW,. Suite 2900 Atlanta,' Georgia 30323-2711 i

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• ENCLOSURE REPLY TO WEAKNESSES NRC INSPECTION REPORT NOS. 50-327, 328/94-30 R. V..CRLENJAK'S LETTER TO OLIVER D. KINGSLEY, JR.

DATED OCTOBER 14, 1994-Inspector Follow-uo Item 50-327. 328/94-30-01 "The check valve program was not being performed in accordance with the program guidelines. Specified periodic reports had not been issued. A check valve computer database was not updated as intended. Further, information in the database as to flow disturbances that might effect check valve performance was incorrect. (Section 2.b)"

Cause for the Weakness The cause for the failure to issue quarterly reports was the Technical Support check valve coordinator's failure to review the procedure for new administrative requirements. The check valve program procedure (Site Standard Practice (SSP) 8.53, " Check Valve Program") was developed by the Technical Programs organization. The requirement for check valve program quarterly reports was proceduralized with the intent of keeping management appraised of program performance. After procedure development, program ownership and responsibility for continued-implementation was transferred to the Technical Support organization check valve coordinator. The check valve coordinator had previous technical responsibility for the program and did not realize that the new procedure contained this change in administrative requirements. As a result, the check valve quarterly performance report was not developed.

A review of the condition determined that the lack of quarterly reports did not result in an adverse condition. Failures associated with check valves have been identified, evaluated, and trended through the corrective action program.

The check valve coordinator did not maintain an electronic (computer) database because of higher work priorities and equipment availability.

However, the check valve coordinator did maintain a check valve database by manually marking changes and program updates on a computer printout from the last available electronic version. Under this method, the data was reviewed for identification of adverse trends.

The check valve coordinator believed that the flow' disturbance data reflected the plant installed condition. Upon further review, it was determinad that the Flow Disturbance field contained a mix of information including vendor information and estimated plant configuration. The information was intended to be approximate and was only one of several data fields established for Jnitial development of the program. The check valve coordinator now recognizes ' sture of the data in the Flow Disturbance field and has concluded that to. condition has not affected check valve maintenance, trending, or identification of potential failure or degradation. Based on program evolution, maintenanco of the Flow Disturbance field is not considered necessary.

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/1. 15 4 , r; Planned corrections and the' schedule'for corrections.

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$, (After identification of.tho' condition, the, check valve"coordinatorf, "

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W einitiated' Problem Evaluation, Report-(PER)KSQ940772PER to document 5the, t L 02 ' '

,  ; conditionand: develop the appropriate. actions to; resolve the conditionP This corrective: action document'isLtracking actions to completion'for

>~~ a.. * . resolution,'ofithe condition.; '

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lThe checkLvalve program procedure,..as wellTas.other program' procedures:

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that' wore transferred from the Technical.Peograms organisation to- s' <

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2 L' Technical'~supporti have been reviewed,to ensure. program' compliance.

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-The computer'(electronic)' version of the check valve database'will.be-> . 0 '

updated _with current and correct information. This willEbe accomplished  :

in'accordance with overall site priorities. ;In'theLinterim, the information will continue'to.be maintained manually.

Insoector Follow-un Item 50-327. 328/94-30-02 e ~

"The' preventive maintenance.(PM)' performed on three manual reach rodj valves was inadequate the inspectors. concluded based on their review.

' The- maintenance instruction remained open for al'nost' two months after :

completion of all the steps except a final stroking and. adjustment to verify correct closure indication. The maintenance instruction stated if-Operations would not allow the stroking, the reason for the non-stroke 4 was to be. recorded.- The stroking was not performed'and the reason

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recorded was:"cannot stroke per. Ops." On the day the PM was closed-(considered complete) the licensee found that-one of the valves. .

, (2-VLV-72-623) (sic) was open, although'the position' indication indicated closed, and about 60,000 gallons of water'had-leaked to the passive-sump. Proper testing and adjustment would have prevented the leakage.

The inspectors concluded that corrective actions were not completed:

relative to the Performance (sic) Evaluation: Report for the event described above. (section 2.c)"

cause for the Weakness-The cause for the weakness is that.the PM did not contain sufficient guidance to ensure that the valve was stroked after completion of PM work

, and before document closure. This was a' result of the PM containing a ,

provision-to waive the valve stroke. The:PM did not provide guidance toL

inspect the flex shaft-driven remote valve operator concurrent with valve

_ stroking. Therefore, upon completion of the physical work required by .

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the PM, the maintenance crew requested Operations to stroke the valve, as -

required by the procedure. Operations decisned valve stroking as allowed L by the PM because of a need to maintain system configuration. The mechanic documented the fact that operations would not allow valve stroking; however, the underlying cause for not stroking the valve (the l

_ need to maintain system configuration) was not documented.

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", l' . i Additionally,-two otherflroblems were identified ducing review of.the . 'l P? weakness. -It was determined'that Valve 2-72-523 was bii.J!ng and that the J treach. rod valve position %ndication was inadequate. fAs'a result,fthe  ;

m < ,g ' assistant unit, operator that performed the valve manipulation believed j h, the. valve to be-fully' closed when the valve was-actually partially open.

'A work document was immediately issued to' correct the. valve binding issue.

2 Planned corrections and the' schedule for corrections The weakness.will'be resolvec'by the revision of'the appropriate'PMs that; l are associated with' flex shaft-driven resote valve operators to ensure that' valve' stroking is includedLin a postmaintenance test for the PM. *

~This is expected to be completed by-April 28, 1995.

The condition of. inadequate reach rod position indication is'being:

addressed by PER SQ940106PER. As,part of the actions associated with.  !

this=PER,'walkdowns of approximately 300 reach rod. valve operators have:

been performed. ,Tha results of the walkdowns are.being evaluated.. The appropriate corrective' actions will be developed as part of the.PER r

. process. As an' interim action, Operations issued Standing Order No.94-128 instructing operations.personne1~to not use' reach' rod position; .s

. indicators for valve position indication.

commitment-IFI 50-327, 328/94-30-02 The appropriate PMs that are associated with. flex shaft-driven remote' I valve operators will be revised by April.28, 1995, to ensure'that valve ,

stroking is included in alpostmaintenance test for tho'PM.

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