ML20106E137
| ML20106E137 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 09/04/1984 |
| From: | Mills L TENNESSEE VALLEY AUTHORITY |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20106E131 | List: |
| References | |
| NUDOCS 8410290044 | |
| Download: ML20106E137 (4) | |
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LTENNESSEE VAL' LEY AUTHORITY -
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CHATTANOOGA. TENNESSEE 374ot
. 400 Chestnut Street Tower II~
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34 SEP 7 Septgebg,1984
.U.S._ Nuclear Regulatory Commission Region II-Attn:.. Mr. James-P. O'Reilly, Regional. Administrator 101;Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323
Dear Mr. O'Reilly:
. SEQUOYAH NUCLEAR PLANT UNITS 1 - AND 2 - NRC-0IE REGION II INSPECTION REPORT 50-327/84-17 AND 50-328/84 RESPONSE TO VIOLATIONS The subject OIE inspection report dated August 2,1984 from R. C. Lewis' to H. G. Parris cited TVA with two Severity Level IV violations. Enclosed is the response to the items of violation in the subject inspection report.
If you have any questions, please get in touch with R. H. Shell at FTS 858-2688.
To the best of my knowledge, I declare the, statements contained herein are complete and true.
.Very truly yours, TENNESSEE VALLEY AUTHORITY
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L. M. Mills, Nanager-Nuclear Licensing Enclosure cc (Enclosure):
Mr. Richard C. DeYoung, Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C.
20555
-Records Center Institute of Nuclear Power Operations 1100. Circle 75 Parkway, Suite 1500 Atlanta, Georgia 30339 I
I E4 280*d!8E PDR i
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1 An Equal Opportunity Employer I
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ENCLOSURE RESPONSE - NRC INSPECTION REPORT 59-327/84-17 AND 50-328/84-17 R. C. LEWIS' LETTER TO H. G. PARRIS AUGUST 2, 1984 Item 327, 328/84-17-01 Technical Specification 3.6.1.1 requires that primary containment integrity shall be ' maintained in modes 1, 2, 3, and 4.
Surveillance requirement 4.6.1.1.a requires that primary containment integrity shall be demonstrated by verifying that manual valves required to be closed during an accident are closed and secured in their positions.
Contrary to the above, primary containment integrity was not maintained in that on June 7, 1984, valve 1-33-704, containment isolation valve for the -
service air system, was shut but not secured by a locking device. The unit was in mode 3, hot standby.
This is a Severity Level IV violation (Supplement I).
This violation applies to unit 1 only.
1.
Admission or Denial of the Alleged Violation TVA admits the violation occurred as stated.
2.
Reasons for the Violation if Admitted System Operating Instruction (SOI) 88.1 A, " Establishing Containment Integrity," and Surveillance In9truction (SI) 14, " Containment Integrity Verification," were performed on April 9, 1984 and April 5, 1984, respectively, and double-person verified. This inspection was performed as required after a scheduled unit 1 outage.
On April 21, 1984, valves 1-33-704 and 1-33-740 were required to be opened so that service air could be supplied to containment during an unscheduled outage. Upon completion of the outage, the outside containment isolation valve, 1-33-740, was double verified closed since SI-14(A) was required for all containment isolation valves outside containment.
SI-14(B) for containment isolation valves inside containment was not required since it had been performed within 92 days. The Configuration Log, per OSLA58, had logged 1-33-704 as being in the abnormal position-open. The log failed to state that this was a locked closed valve. To proceed to mode 4, the valve. had to be verified returned to its normal position. On May 4,1984, the valve was verified closed but was not checked for being secured. A factor which contributed to missing the requirement for locking the valve was the fact that the chain and lock were missing from the valve.
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CErr:ctiva Stent Which Eava Bacn Tr.ktn and-th6 Reruits Achinvnd a.- The' valve was immediately verified closed and secured with a lock
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L and ~ chain.
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An -inspection was performed per SI-14 to verify containment integrity.. No additional discrepancies were. found.
4.
Corrective Steps Which Will Be Taken to Avoid Further Violations a.
Emphasis will be' made during training on the requirements.to
= maintain containment integrity during modes - 1, 2, 3, and 4.
' Additionally, a. letter will be sent to all shift engineers, ASEs, UOs, AD0s, and A0s stressing this requirement.
- b. 'The configuration logs are _ being revised to. contain two-person verification.
5.
Dates When Full Compliance Will-Be Achieved PullJcompliance was achieved on June 7,1984, when the' valve was locked and secured.
Item 327, 328/84-17 Technical Specification 3.5.2 requires that two independent emergency core cooling system (ECCS) subsystems shall be operable in modes 1, 2, and 3.
Surveillance requirement 4.5.2.c requires that ECCS operability shall be demonstrated by verifying that no loose debris is present in the containment which could be transported to the containment sump and cause
-restriction of the pump suctions during LOCA conditions.
Contrary to the above, ECCS subsystem operability was not maintained in -
that on June 7, 1984, a large plastic bag (approximately 36" x 48") was present in the lower containment-area that could be. transported to the containment sump during LOCA conditions and cause restriction of the pump suc tions. The unit was in mode 3, hot standby.
This 'is a' Severity Lovel IV violation (Supplement I).
This violation applies to unit 1 only.
-1.
Admission or Denial of the Alleged Violation TVA admits the violation occurred as stated.
2.
Reasons for the Violation it. Admitted Personnel working in lower containment between May 8,1984 and June 7, 1984_ failed to remove a plastic bag.
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- 3. ~.Correctiv3 Stros Which ihva B;en Tak n end Reculta - AcNievsd i
e 1 An. investigation was performed to try to locate' the personnel involved
- in this incident.
A' time period from May 8,1984 -(the last performance of SI-187 containment inspectien)'t3 June.7,.1984.was determined to have been the period that. the foreign material was -
.- brought into lower containment. A review of. theiradiation work permits :
(RWPs) and the - AI-8 containment entry checklist ~ resulted in a list ' of all personnel that had ' entered lower containment.. These) personnel were questioned on their reason for entry, what' material was brought in and taken out' by.them, - and what activity they oerformed while ' in
' containment. All personnel made written statements that all. material i
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they.had. taken to lower containment was mmoved and that no loose debris maained. Each peson was also briefed on the requirements in -
AI-8.to inspect the route to and from work areas to ensure that no -
loose debris is present. Even though this investigation did not result
- in-finding the person (s) responsible for leaving the material in lower containment, persor.nel awareness in regard to containment cleanliness y
requirements in modes - 1 through 4 was significantly increased.
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4.
Corrective Steos Which Will Be Taken to Avoio Further Violations -
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A revision to AI-8, " Containment Access," will--be made to clarify and strengthen the signed statement by persunnel on their responsibility to verify the work ' area and reute to the work area is free from debris (/
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~5.
Date When Full Comoliance Will Be Achieved
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Full compliance was achieved on June 7,1984.
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