ML20004D097
| ML20004D097 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 05/11/1981 |
| From: | Mills L TENNESSEE VALLEY AUTHORITY |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8106080361 | |
| Download: ML20004D097 (2) | |
Text
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Mr. James O'Reilly, Director Office of I ection and Enforcement U.S. Nuclear Re latory Consnission W
Regica II - Suite ~100
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101 Marietta Street Atlanta, Oeorgia 303
Dear Mr. O'Reilly:
SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 - NRC-OIE RE0 ION II DISPECTION REPORT 50-327/81-12, 50-328/81 REVISED RESPONSE TO VIOLATION The subject inspection report dated March 27, 1981, cited TVA with one Severity Level IV Violation in accordance with 10 CFR 2.201.
A response to the violation was submitted on April 17, 1981. Enclosed is our revised response as requested by D. Quick.
If you have any questions, please get in touch with D. L. Lambert at FTS 857-2581.
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Td the best of :ny knowledge, I declare the statements contained herein arc.
complete and true.
Very truly yours, TENNESSEE VALLEY AUTHORITY L. M. Mills, Manager Nuclear Regulation and Safety Enclosure
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cc:
Mr. Victor Stello, Director (Enclosure V Office of Inspection and Enforcement U.S. Nuclear Regulatory Consnission
'4ashington, DC 20555 g,I4 s
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ENCLOSOURE SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 REVISED RESPONSE TO VIOLATION 50-327/81-12-01 Violation 50-327/81-12-01 Technical Specificat, ion 3.6.1.1 requires that containment integrity shall be =aintained in modes 1, 2, 3, and 4 and that containment penetration isolation be verified periodically. Containment integrity is based in part on 10 CFR 50, Appendix A, Criterion 56, which requires that lines that penetrate containment and are open to the containment atmosphere be isolated by one locked closed valve inside and one locked closed valve outside containment.
Contrary to the above, containment integrity has not been adequately maintained or verified in that, position requirements for the inside containment isolation valve for the service air system, valve 1-33-704, was not included in system operating instruction SOI-88.1, Containment Isolation Integrity. Valve 1-33-704 was normally maintained in the open position; however, the outside containment isolation valve, 1-33-740, was maintained closed and periodically verified to be in the proper position during unit operation.
This is a Severity Level IV Violation (Supplement I.D.3.).
Admission or Denial of the Alleged Violation TVA admits the violation occurred as stated.
Reason for the Violation if Admitted The original design and construction was that valve 1-33-704 was a. check valve. The valve was subsequently replaced with a manually operated valve which should have been nor= ally closed. When this modification was made, drawing 47W846-2 was marked up indicating this change and submitted to drawing control. This was the correct procedure for having the drawing revised to include the modification; however, drawing control incorrectly revised the drawing to show a normally open valve. When' the valve lists in 30I-88.1 and SI-14 were made, this valve was therefore omitted.
Corrective Steps Which Have Been Taken and Results Achieved Upon the discovery that valve 1-33-704 had been incorrectly identified as a nor= ally open manually operated valve, a temporary alteration control form was issued to ensure that this valve was closed and containment integrity maintained.
Corrective Steps Which Will Be Taken to Avoid Further Violations Drawing 47W846-2 is being changed to show valve 1-33-704 as a normally closed manually operated valve. Operating instruction SOI-88.1 and surveillance instruction SI-14 are being. revised to include valve 1 704. Additionally, a drawing review was performed, and comparisons to the valves listed in SOI-88.1 and SI-14 were made. This was done to confirm that there were no other valves incorrectly identified on the drawings and that there were no additional valves incorrectly positioned.
Date When Full Compliance Will Be Achieved We are now in full compliance.