ML20086B865

Forwards Response to NRC Re Violations Noted in Insp Repts 50-327/95-13 & 50-328/95-13.Corrective Actions: Mgt Has Placed Addl Emphasis on Arrow-Hart Condition

ML20086B865
Person / Time
Site:	Sequoyah
Issue date:	06/29/1995
From:	Adney R TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9507060134
Download: ML20086B865 (4)

Text

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Hl4 tennm.see va% Aswry vos on c e ao, un uoy.ca.r.y Towsste 37379 June 29, 1995 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) - NRC INSPECTION REPORT NOS. 50-327, 328/95 REPLY TO NOTICE OF VIOLATION (NOV) 327,328/95-13-01 Enclosed is TVA's reply to Charles A. Casto's letter to O.D. Kingsley, Jr., dated June 2, 1995, which transmitted the subject NOV. The NOV pertains to ineffective corrective actions taken relative to a degraded hardware condition.

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

Sincerely, P

R. J. 'dney SQN Site Vice Preside Enclosure cc: See page 2 0C~~7?

Y 9507060134 950629 n

PDR ADOCK 05000327 Q PDR

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. g U.S. Nuclear Regulatory Commission Page 2 .;

June 29,.1995 I E

cc (Enclosure): l Mr. D. E. LaBarge, 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 i

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REPLY TO NOTICE OF VIOLATIONS NRC INSPECTION REPORT NOS. 50-327, 328/95-13 CHARLES A. CASTO'S LETTER TO OLIVER D. KINGSLEY, JR.

DATED JUNE 2,1995 Violation 327,328/95-13-01 "10 CFR 50, Appendix B, Criterion XVI, Corrective Action, requires that measures shall be established to assure that conditions adverse to quality are promptly identified and corrected.

" Contrary to the above, on March 15,1995, measures established as corrective action to ensure safety related motor-op'erated valve operability were inadequate in that Standing Order 94-121 issued as corrective action for PER 940856 expired and compensatory measures prescribed by the standing order were not performed. Subsequent failures of safety-related motor-operated valves occurred due to non-performance of the compensatory measures."

"This is a Severity Level IV viola' ion (Supplement 1)."

Reason for the Violation The root cause of the violation was inadequate management attention to the implementation of the standing order associated with Arrow-Hart contactors. One of the corrective actions taken under Problem Evaluation Report (PER) SQ940856PER was to establish administrative controls on the operation of Arrow-Hart contactors. This involved the use of Operations' standing order process to notify Maintenance personnel for the performance of electrical resistance measurements after the actuation of safety-related equipment containing an Arrow-Hart contactor. When the standing order was issued, no special management emphasis was placed on the standing order, and specific implementation guidance was not provided. A review of the operational failures of safety-related motor-operated valves subsequent to the establishment of the standing order determined that the requirements contained in the standing order had not always been implemented. Interviews with Operations personnel determined that the methodology for implementing the standing order was inconsistent. Over time, adherence to the standing order's requirements tapered off. ,

l Contributing to the condition was that when Stsding Order 94-121 was revised on April 12, 1995, the revised standing order may not have been reviewed by Operations personnel after being placed in the standing order book. The revised standing order was placed towards the back of the book, under its original number. Operations personnel indicated that they reviewed i the standing orders in the front of the book, which had not previously been reviewed. As a result, the revised standing order for Arrow-Hart contactors may not have received the attention necessary for proper implementation.

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d Corrective Steps That Have Been Taken and the Results Achieved Menagement has placed additional emphasis on the Arrow-Han condition. A new standing order was issued on April 18,1995, providing implementation methodology. This standing order requires the placement of a sticker on each main control room handswitch upon manipulation of a valve. The sticker is removed once the valve manipulation is cross-checked against the listing of Arrow Hart operated valves and logged. A log book for each unit containing a listing of Arrow-Hart operated valves that are safety-related or imponant to operation with space on the log sheets to document the component manipulated, the notification to maintenance, and the completion of contact resistance measurement was placed in the main control room. A letter was issued to licensed operators to reemphasize the requirements contained in the new standing order. In addition, Operations' management verbally communicated with each operating crew the established operability basis for motor-operated valves with Arrow-Hart contactors. The degraded Arrow-Hart contactor condition is being carried on the shin turnover package to provide continual management reinforcement of the condition and the actions required to ensure the operability of the associated equipment.

This change in implementation methodology has resulted in consistent implementation of the standing order by the operating crews. To resolve continuing concerns with Arrow-Hart contactors, an aggressive replacement program for these contactors is being implemented.

Operations management has been counselled concerning the necessity of maintaining current, accurate standing orders.

Further, management has stopped the practice of revising standing orders. If changes other than a date extension need to be made to a standing order, a new standing order is to be issued.

Corrective Steps That will be Taken to Avoid Further Violations Shin operations supervisors have reviewed and discussed with Operations personnel cach standing order contained in the standing order book to ensure proper standing order understanding.

Date When Full Compliance will be Achieved TVA is in full compliance based on the corrective actions taken relative to the identified violation.

Commitments None.