ML20033D326

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Responds to NRC Re Findings Noted in IE Emergency Preparedness Appraisal Repts 50-327/81-20 & 50-328/81-24. Corrective Actions:Personnel Decontamination Room Unlocked, Calibr Procedure Modified & Emergency Procedures Developed
ML20033D326
Person / Time
Site: Sequoyah  Tennessee Valley Authority icon.png
Issue date: 10/30/1981
From: Wisenburg M
TENNESSEE VALLEY AUTHORITY
To: James O'Reilly
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20033D316 List:
References
NUDOCS 8112070532
Download: ML20033D326 (5)


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TENNESSEE VALLEY AUTHORITY USNRC REGION *"

cnamNOOGA. TENNESSEE 37401 A Q.y 400 Chestnut Street Tower II fil NOV 3 A5 3'

October 30, 198 T Mr. James P. O' Reil'y, Director Office of Inspection and Enforcement.

U.S. Nuclear Regulatory Commission Region II - Suite 3100 101 Marietta Street Atlanta, Georgia 30303

Dear Mr. O'Reilly:

SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 - NRC-0IE REGION II EMERGENCY PREPAREDNESS APPRAISAL 327/81-20,50-328/81 SUPPLEMENTAL REP"0NSE The tubject appraisal dated August 20, 1981 cited TVA with one Severity Level IV Violation and four deficiencies. TVA submitted the response to these items on September 24, 1981. Enclosed is our supplemental response which addresses the NRC's additional concerns as listed in attachment 2 of the inspection report. This matter was discuased with G. R. Jenkins of your office on October 8,1981.

If you havo 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 complet,e and true.

Very truly yours, TENNESSEE VALLEY AUTHORITY

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M. R. Wis nburg P

NuclearEnhineer Enclosure cc:

Mr. Victor Stello, Director (Enclosure)

Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, DC 20555 0$0bbhy PDR An Ecual Opportunity Employer

5-ENCLOSURE SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 RESPONSE TO ADDITIONAL CONCERNS Finding: 81-20-04/81-24-04 The auditor informed the licensee that due to the proximity and capability of the training center laboratory facility, it should be considered for use during an emergency and that the REP and IPD be changed accordingly.

Response

TVA agrees sith this finding and is evaluating the need for an alternate laboratory.

Finding: 81-20-05/81-24-05 The auditors pointed out that anyone requiring personnel decontamination should have immediate access, to the decon room and the policy of maintaining the doors to these rooms locked should be reviewed and revised as necessary so that decontamination of individuals can be completed as rapidly as possible.

Response

TVA agrees with this finding. The program as stated in the audit fir, ding is acceptable; however, the door to the personnel decontaminatia?

room will be unlocked by October 30, 1981.

Finding: 81-20-06/81-24-06 Review the calibration and calculational methods for use of the MS-2 and sodium iodide emergency sample counter with consideration given to the effect of high external background radiation, -the effect of high levels of radionuclides in the sample and the effect of self-shielding of the radionuclide of interest in the charcoal or silver zeolite cartridges.

Response

TVA agrees with this finding. The calibration procedure for the sodium iodida detectors will be reviewed and modified as necessary to incorporate geometry and'self-absorption factors. The possibility

- of providing further detector shielding to reduce background interference shall be considered.. This review and modification will be completed '

_.lDY December 31, _1.981.

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. c Finding: 81-20-07/81-24-07 Consider a system for assuring that the appropriate NaI detector and the MS-2 with which it was calibrated are transported to the health physics van.

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Response

TVA agrees with this finding. The detectors and analyzers will be marked so as to ensure proper matching of components by December 31, 1981.

Finding: 81-20-08/81-24-08 Revise procedures and instructions to health physics personnel to assure that necessary keys are available for vehicles and sampling stations.

Response

TVA agrees with this finding. Sequoyah Implementing Procedure IP-17 was revised July 30, 1981 to include, in one package, all keys to vehicles and environment 1 sampling stations.

Finding: 81-20-09/81-24-09 Provide procedures and instructions to emergency response teams on the use of silver zeolite cartridges.

Response

TVA agrees with this finding. Sampling procedures are being revised to provide instructions to field monitoring and plant personnel regarding the use of silver zeolite cartridges. Thie item will be completed by October 30, 1981.

Finding: 81-20-11/81-24-11 i

Clarify procedures SQN IP-17 and MSECC IP-6 to assure appropriate monitoring and sampling equipment is provided to both plant emergency teams and offsite emergency teare.

Hesponse:

TVA agrees with this finding. - Additional equipment will be purchased.

or identified for use by plant and offsite emergency teams' to ensure that appropriate instrumentation is available and its use will not ; detract from normal plant instrument inventory. An additional vehicle.will be -

dedicated to the plant health physics staff-for emergency use.

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Finding: 81-20-13/81-24-13 Provide emergency procedures and instructions for health physics personnel defining methods, equipment, communications and radiation protection guidance for emergency onsite (out-of-plant) radiological surveys.

Response

TVA agrees with this finding. Emergency procedures are being developed and implemented for health physics personnel to define methods, equipment, communications, and radiation protection guidance for emergency onsite (out-of-plant) radiological surveys.

Finding: 81-20-14/81-24-14 Provide emergency procedures and instructions for health physics personnel defining methods, equipment, communications, rt lation protection and dose control guidance for emergency inplant surveys.

Response

TVA agrees with this finding. A procedure addressing the finding has been drafted and is presently in routing for review and comment.

This item should be completed by December 31, 1981.

Finding: 81-20-15/81-24-15 The implementing procedures should be clarified to indicate where personnel shall be decontaminated and what nonstandard decontamination techniques may be necessary for specific levels-and types of contamination.

Response

TVA agrees with this finding. Sequoyah Nuclear Plant Health Physics Section Instruction Letter Number 10, Personnel Decontamination and Confiscation of Contaminated Articles, describes the procedures for personnel decontamination. Several decontamination' techniques are outlined:in this procedure.

Implementing Procedure 14, Health Physics Procedure, will.

also be revised to indicate the location of the decontamination facilities.

Finding: 81-20-16/81-24-16 Procedures should specify. how the documentation control is to work.

The responsibility 'for each-review and the means of assuring.that each is done on schedule should be specified.

Response

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TVA Jagrees with this finding. - REPP-5 (which was not available.in -

final form 'during the audit) adequately covers document control' for the radiological emergency plan ud implementing procedures document. -

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Finding: 81-20-17/81-24-17 The REP is not clear that areas other than the plan itself will be audited.- The REP should be revised accordingly.

Response

TVA does not agree with this finding. The quality assurance (QA) and audit. programs are defined by TVA-TR 75-1 and the Radiological Hygiene Branch QA manual. These documents provide for the audit of both the REP and

. IPD. No fitrther clarification of this part is deemed necessary in the REP.

Finding: 81-20-18/81-24-18 Designate an individual onsite who has overall responsibility for coordinating drills and exercises required by the REP and applicable criteria.

Response

TVA does not agree with this finding. All exercises and drills are tracked by the Radiological Emergency Preparedness and Protection Group. The responsible organization, as defined in the REP, coordinates the drill or exercise with the designated site REP coordinator as necessary, i

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