ML20117L143

Responds to NRC Re Violations Noted in Insp Repts 50-327/95-18 & 50-328/95-18.Corrective Actions:Counseled Individuals Involved & Will Implement Hardware Mod for Resolution of Degraded Condition

ML20117L143
Person / Time
Site:	Sequoyah
Issue date:	09/04/1996
From:	Adney R TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9609120331
Download: ML20117L143 (4)

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1 Tennessee Valley Authority, Post Office Box 2000, Soddy-Daisy, Tennessee 37379-2000 R J. Adney Site Vice Presdent Sequoyah Nuclear Plant l September 4, 1996 l

l U.S. Nuclear Regulatory Commission ATrN: Document Control Desk i Washington, D.C. 20555 Gentlemen:

In the Matter of ) Docket Nos. 50-327 Tennessee Valley Authority ) 50-328 SEQUOYAH NUCLEAR PLANT (SQN)- NRC INSPECTION REPORT NOS. 50-327, 328/95 REPLY TO NOTICE OF VIOLATION (NOV) 50-327,328/95-18-01 Enclosed is TVA's reply to Jon R. Johnson's letter to O. D. Kingsley, Jr., dated August 6, 1996. Mr. Johnson's letter stated that after careful consideration of the basis for TVA's denial to the violation and the supplement information, the NRC staff concluded that a violation occurred as stated in the NOV. The NOV was provided to TVA by letter from Mark S. Lesser to O. D. Kingsley, Jr., dated October 2,1995. The violation notice was associated with the failure to take prompt corrective action for a condition involving accelerated degradation of emergency core cooling system throttle valves in an accident scenario.

If you have questions regarding this response, please telephone R. II. Shell at (423) 843-7170.

Sincerely, P

R. J. dney Enclosure - '

cc: See page 2 [k] f 1

9609120331 960904 PDR ADOCK 05000327 G PDR wm m

I U.S. Nuclear Regulatory Commission Page 2 September 4, 1996 I

cc (Enclosure): i Mr. R. W. Hernan, Project Manager )

Nuclear Regulatory 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 l

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i ENCLOSURE RESPONSE TO NRC NOTICE OF VIOLATION 50-327,328/95-18-01 INSPECTION REPORT NOS. 50-327,328/95-18 JON R. JOHNSON'S LETTER TO OLIVER D. KINGSLEY, JR.

DATED AUGUST 6,1996 VIOLATION 50-327. 328/95-18-01

'Ihe Notice Of Violation was originally issued by letter from Mark S. Lesser to O. D. Kingsley, Jr., dated October 2,1995. The violation was stated as follows:

"10 CFR 50, Appendix B, Criterion XVI requires, in part, that measures shall be established to ensure that conditions adverse to quality are promptly identified and corrected.

" Contrary to the above, prompt corrective action was not implemented for a condition adverse to quality. Specifically, on July 18,1994, Westinghouse notified the licensee of an adverse condition involving accelerated degradation of Emergency Core Cooling System throttle valves during accident scenarios which could cause premature system pump failure, and actions to correct or compensate for the condition were not implemented until July 17,1995.

"This is a severity level IV violation (Supplement 1)."

BEASON FOR THE VIOLATION The cause of the violation was that TVA did not recognize the subject degraded condition as a condition adverse to quality (CAQ) as specified by 10 CFR 50, Appendix B, Criterion XVI.

TVA believed that since the degraded condition could be easily mitigated by existing plant emergency procedures and was bounded by a Westinghousejustification for continued operation, the subject condition was not a CAQ. As a result, when the Management Review Committee (MRC), which is comprised of pdncipal site managers, determined that an additional action (capture of the issue in a Technical Support Center (TSC) activation procedure) was prudent, the action was considered an enhancement to the plant TSC procedure and not a correctives action. TVA now understands that this was an incorrect decision, and the subject condition is now understood to be a CAQ.

CORRECTIVE ACTIONS THAT HAVE BEEN TAKEN AND RESULTS ACHIEVED The notice of violation (NOV) has been reviewed by the involved individuals for lessons i leamed. Additionally, the MRC has been coached on the NOV and the need to take prompt corrective actions for CAQs. MRC sensitivity to ensuring prompt action has been increased.

l CORRECTIVE ACTIONS THAT WIIL BE TAKEN TO AVOID FUTURE VIOLATIONS No additional actions are necessary relative to the failure to recognize the degraded condition as a CAQ.

A hardware modification for resolution of the degraded condition will be implemented during the Units 1 and 2 Cycle 9 refueling outages.

DATE WHEN FULL COMPLIANCE WIII BE ACHIEVED With respect to the cited violataan, TVA will be in full compliance after completion of the Units I and 2 Cycle 9 refueling outages.

COMMITMENT A hardware modification for resolution of the degraded condition will be implemented during the Units I and 2 Cycle 9 refueling outages.

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