ML20113F644

Forwards Response to NRC Re Violations Noted in Insp Repts 50-327/96-08 & 50-328/96-08.Corrective Actions: Identified Condition W/H Recombiner Was Corrected

ML20113F644
Person / Time
Site:	Sequoyah
Issue date:	09/18/1996
From:	Adney R TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9609250116
Download: ML20113F644 (4)

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Tennessee Valley Authority, Post Office Box 2000, Soddy-Daisy, Tennessee 37379-2000 l

R.J. Adney ,

Site Vice President  !

Sequoyah Nuclear Plant i

i September 18,1996 I 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 (SON) - NRC INSPECTION REPORT NOS. 50-327, 328/96 REPLY TO NOTICE OF VIOLATION (NOV) 50-327, 328/96-08-02

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Enclosed is TVA's reply to Jon R. Johnson's letter to Oliver D. Kingsley, Jr., dated August 19,1996, which transmitted the subject NOV. The violation is associated with  ;

the f ailure to establish measures to assure that conditions adverse to quality are promptly identified, corrected, and reported to the appropriate levels of management.

The cover letter that transmitted the subject NOV expressed NRC concern over plant l material condition and reliability. TVA shares this concern and is taking actions to improve plant reliability as outlined in our meeting with you on August 8,1996. These actions are resulting in increased reliability (i.e., a decrease in the number of reactor trips) as you noted in the subject letter. TVA will continue to pursue this issue in order to obtain our safety and businese goals relative to increased plant reliability.

The subject cover letter also stated that NRC believes that events at SON are related to j a lack of understanding of complex procedures / processes, inadequate commitment by users to identify and improve deficient procedures / processes, and a tolerance of poor r procedure utilization. TVA agrees that examples of these conditions do occur.

However, TVA management continues to promote an environment where issues are identified and corrected. This is evident by the increase (approximately 200 percent since 1994) in the number of problem evaluation reports (PERs) wrimn over the last year (approximately 3000 PERs). A recent Institute of Nuclear Power Operations evaluation concluded that SON's processes and procedures are consistent with the rest of the industry. Also, personnel knowledge of these processes and procedures is good.

A process improvement initiative is underway which is focused on standardizing

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U.S. Nuclear Regulatory Commission I Page 2  !

September 18,1996  ;

processes across TVA Nuclear (TVAN), providing less complex processes and procedures, and eliminating unnecessary tasks. A benchmarking study was performed as part of this initiative to ensure that TVAN processes and procedures are consistent with other utilities, additional benchmarking will also be performed. The results of this effort will be communicated to NRC during a future NRC/TVA meeting. TVA remains committed to ensuring that processes and procedures are appropriate to successfully  :

perform work at SON. TVA will continue to ensure that worker knowledge and use of  !

procedures / processes is adequate and will continue to correct poor procedures in a l timely manner. Management will continue to emphasize a questioning attitude at all levels of the organization, with specific emphasis at the front line worker level, in order to sustain improved site performance.

The enclosure contains TVA's response to the NOV.

If you have any questions concerning this submittal, please telephone R. H. Shell at  ;

!- (423) 843 7170.  !

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Sincerely, i I

L i R. .Adney Enclosures cc (Enclosures):

Mr. R. W. Hernan, Project Manager Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 2739

( NRC Resident inspector l Sequoyah Nuclear Plant

! 2600 lgou Ferry Road.

I Soddy-Daisy, Tennessee 37379-3624 i'

Regional Administrator U.S. Nuclear Regulatory Commission Region I!

2 101 Marietta Street, NW, Suite 2900

] Atlanta, Georgia 30323 2711 4

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' ENCLOSURE RESPONSE TO NRC INSPECTION REPORT j NOS. 50-327, 328/96-08 '

'JON R. JOHNSON'S LETTER TO OLIVER D. KINGSLEY, JR.

DATED AUGUST 19,1996 VIOLATION 50-327.328/96-08-02 4

"10 CFR 50 Appendix B, Criterion XVI requires, in part, that measures shall be established to assure that conditions adverse to quality such as failures, malfunctions, i' and deficiencies are promptly identified, corrected, and reported to appropriate levels of management. ,

Site Standard Practice (SSP-3.4), Corrective Action, Revision 17, requires that any employee identifying a problem, including adverse conditions, chall promptly notify the i Shift Operations Supervisor if it is recognized that the condition may affect the

- operability of the plant.

" Contrary to the above, On July 12,1996, the licensee's established measures did not assure that a condition adverse to quality was promptly identified, corrected, and reported to appropriate levels l of management. A deficiency identified on July 12, rendered Unit 1 hydrogen recombiner 1B-B inoperable; however, the component was not recognized as being inoperable until July 16,1996.  ;

"This is a Severity Level !V Violation (Supplement 1)."

Reason for the Violation On July 12, Maintenance personnel were performing troubleshooting activities on the 1B-B hydrogen recombiner. It was discovered that there was possibly a broken electrical lead on the power adjustment potentiometer. The potentiometer is used to control the output power to the heaters in the recombiner. The craftsmen did not

- recognize the potentialimpact that the condition could have on the operability of the recombiner. Therefore, the craftsmen did not notify Operations of the condition. The craftsmen were focused on repairing the condition.

, Later that day, the next shift craftsmen were assigned to verify the condition and to I

repair as necessary. After evaluating the condition, it was determined ~that the lead - l l

was broken and that the repair could not be made. During the review with Operations,

a misunderstanding of the condition occurred. The specific details of the operability

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i; were not consistently understood by the personnelinvolved. This was the result of j- ~ inadequate communications and the lack of a questioning attitude by both Maintenance

' and Operations personnel.

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I On July 16, Maintenance personnel returned to Operations for authorization to correct _

the identified condition. At this time, the determination was made that the hydrogen l recombiner was inoperable. The appropriate technical specification action was entered. I An investigation of the condition determined that the reason for the violation was l inadequate work practice and inadequate communications. Personnel failed to verify and validate applicable information.

Corrective Actions That Have Been Taken and the Results Achieved The identified condition with the hydrogen recombiner was corrected, and the hydrogen recombiner was returned to service.

The lessons learned were discussed and emphasized with the appropriate Maintenance personnel in order to ensure that expectations and the importance of evaluating equipment degradation are fully understood, to ensure that a questioning attitude is used, and to communicate operability concerns when appropriate.

I A training letter was issued to the appropriate Operations personnel to emphasize the j lessons learned to ensure that expectations and the importance of evaluating  !

equipment degradation are fully understood, to ensure that a questioning attitude is j used, and to communicate operability concerns when appropriate. '

SON management is continually reinforcing expectations relative to issues such as l proper questioning attitude and the use of Stop, Think, Act, and Review (STAR). In maintenance, for example a different problem evaluation report is reviewed with personnel each week as an example of how maintenance activities could have prevented this type of event. In Operations, stand down meetings are held within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of an event in order to ensure appropriate actions can be reinforced.

The Corrective Steos Taken to Avoid Future Violations No further corrective actions are required.

Date When Full Comoliance Will be Achieved With respect to the violation cited, TVA is in full compliance.

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