ML19345H448
| ML19345H448 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 04/24/1981 |
| From: | Mills L TENNESSEE VALLEY AUTHORITY |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML19345H447 | List: |
| References | |
| NUDOCS 8105200315 | |
| Download: ML19345H448 (4) | |
Text
{
) '.
e TENNESSEE VALLEYJ'MCBCTYN ::
CH ATTANOOG A, TEN 1
400 Chestnut Street Tower II 31 APR 28 A B : l' April 24, 1981 Mr. James P. O'Reilly, Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Ca mission Region II - Suite 3100 101 Marietta Street Atlanta, Georgia 30303
Dear Mr. O'Reilly:
SEQUOYAH NUCIEAR PIANT WIT 1 - NBC-OIE REGIN II INSPECTIN REPORP 50-327/81 RESPWSE 'IO VIO[ATICNS
'1he subject inspection report dated A;pil 3,1981 cited TVA with one Severity Level IV and one Severity Level V Violation. Enclosed is our response.
If you have any questions, please get in touch with D. L. Lambert at FIS 857-2581.
To the best of my knowledge, I declare the statements contained herein are emplete and true.
Very truly yours, TDNESSEE VALLEY AUIBORITY
.)
\\
Yf
. M. Mills, Ma.nager Nuclear Regulation and Safety Enclosure cc: Mr. Victor Stello, Director (Enclosure)
Office of Inspection and Enforcement U.S. Nuclear Regulatory Ca mission Washington, DC 20555 81052003/5 An Ecuai 0; portunity Emotoyer
s m
SECUOYAH NUCIER PLANT RESPONSE '1D VICKATIO1S
~
violation 327/81-10-01 Technical Specification 3.11.1.2 requires that when the calculated dose
-frcza the release of radioactive materials in liquid effluents during a calendar quarter exceeds 1.5 mrem to the total body or 5 mren to an organ, a special report shall be subnitted to the Ccanission within 30 days identifying the causes for exceeding the limit and the corrective actions
~
to be taken.
Contrary to the above, a special report was not submitted to the Ccanission within 30 days after it was determined that the dose to an organ due to radioactive materials in liquid effluents during the third quarter of 1980 was 9.1 mren.
his is o Severity Level IV Violation (Supplement I.D.4).
Admission or Denial of the Alleged Violatio_n 2e violation occurred'as stated.
Reasons for the Wlation if Admitted Plant personnel, specifically those responsible for developing and transmitting raw data to the Division of M = tional Health and Safety, were notified verbally in October 1980 that the technical specification limit had been exceeded for the third quarter of 1980. %e responsible plant personnel failed to realize the significance of the verbal report and did not report the connunication to appropriate managerent.
On February 9, 1981, plant supervisory personnel were notified in writing l
by the Division of Occupational Health and Safety that Technical Specification 3.11.1.2 was exceeded for the third and fourth quarters of 1980. We requirement to notify the Ccenission if a quarterly limit is exceeded was not satisfied within the specified 30-day reporting period. A breakdown in inter /intradivisional ccmnunications resulted in the failure to report as required.
Corrective Steps Which Have Been Taken and Results Achieved Following formal receipt of information fecm the Division of Occupational Health and Safety,~an investigation was performed and the resulting findings were assembled as special report 80-8 dated March 6, 1981. We Ccanission was notified verbally concerning the violation before preparation of the special report. W is special report was subnitted within 30 days of official notification of the violation for the third and fourth quarters of 1980.
l
2-Corrective Steps Which Will Be Taken 'Ib Avoid Further Violations During a meeting of the Radiological Assessment Review Counittee on April 8,1981, a firm line of comunication between the operating plant and the Division of Occupational Health and Safety was formulated.
It was agreed that connonications between parties related to technical' specification requirements shall be handled formally (i.e., in writing) between appropriate levels of management. Verbal comunications may continue for informational purposes but must be followed by written verification for prescribed formal reporting action.
It'was further agreed that nonthly dose calculations shall be provided to the operating plant in order to more effectively track the accruement of offsite dose to the most limiting critical organ. his information shall be used to control plant effluents to ensure technical specification quarterly and annual dose limitations are satisfied.
Date When Full CcmpliAnce Will Be Achieved Full compliance was achieved on March 6, 1981, when special report 80-8 g o subnitted.
Violation 327/81-10-02 Technical Specification 6.8.1 requires that written procedures be established, implemented, and maintained covering applicable procedures reccanended in Appendix A, Regulatory Guide 1.33, Rev. 2, February 1978.
Regulatory Guide 1.33 specifies that chemical and radiochemical procedures should be written to specify laboratory instruction and calibration of laboratory equipnent.
Contrary to the above, written procedures were not implemented in that reference checks and background checks were not recorded and compared against acceptance criteria as required by plant procedures TI-12 and TI-49 during the period of September through December 1980.
21s is a Severity Level V Violarion (Supplement I.E).
Admission or Denial of the Alleged violation he violation occurred as stated.
9
- -.. - +
-y.,,
,,..,,. -..-~,
m..
.,ww
.7
-,g-..,~
,.-___y,. _. _
l
_y
. Reasons for the' Violation if Admitted Failure to record required data on the subject data sheet (worksheet 49-F.3-3) was an oversight resulting frcza a ocabination of inattention to procedural detail, inadequate supervisory review, and analyst inexperience. Acceptance criteria had not been established _due to the relative paucity of generated data during the time period noted in the violation; therefore, this absence of acceptance criteria precluded the performance of the required data comparison.
~
Corrective Steos M ich Have Been Taken and Results Achieved Revisions to plant instructions, TI-12 (Radiological Analytical Methods) and TI-49 (Radiological Chemical Laboratory Test RIuipnent Calibration l.
Program), have been initiated to singlify and clarify tie quality control data requirements for radiochemical analytical instrinnents. Appropriate i
acceptance criteria have been incorporated into the applicable instructions. Radiochemical laboratory analysts have been briefed on the deficiencies and shall be required to review the instruction revisions when issued.
Corrective Steps Nhich Will Be Taken to Avoid Marther Violations Corrective actions taken to date are deemed sufficient to minimize j
recurren:e.
Date When Full Capliance Will Be Achieved Full compliance will be achieved by May 15, 1981 when the revised plant l
instructions, TI-12 and TI-49, will be issued and reviewed by radiochemical laboratory analysts.
Additional Ccenents
'Ihere is considerable doubt that the calculated levels of piamscrus 32 l
(P-32) reported in special report 80-8 actually existed. Sequoyah Nuclear l
Plant, being one of the first standardized technical specification plants, is required to meet standards where there is no previous operating experience. 'Ihe level of P-32 released to the environment is one of these requirements. 'Ihe extremely low levels that have measured approach the limits of the equipnent available to detect them. When these low values are multiplied by the large volumes that the su ples reprecent, the-calculated levels beccane significant per the technical specifications.
We know of no other facility required to make this kind of analysis although the specifications are called standardized technical specifications.
._.._,..._.--._._._,s
-, -.. _