ML20070M713
| ML20070M713 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 12/10/1982 |
| From: | Mills L TENNESSEE VALLEY AUTHORITY |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20070M678 | List: |
| References | |
| NUDOCS 8301250308 | |
| Download: ML20070M713 (3) | |
Text
h TENNESSEE VALLEY AUTHORITg g ;;,.;
CHATTANOOGA. TENNESSEE 374ol g
400 Chestnut Street Tower II Dscember 10,, w 17 A9: 59 U.S. Nuclear Regulatory Commission Region II Attn:
Mr. James P. O'Reilly, Regional Administrator 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303
Dear Mr. O'Reilly:
SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 - NRC-0IE REGION II INSPECTION REPORT 50-327/82-24 AND 50-328/82 RESPONSE TO VIOLATION This is f response to D. M. Verrelli's letter to H. G. Parris dated November 4,1982 concerning a routine safety inspection conducted during October 12-15, 1982 at Sequoyah Nuclear Plant.
The subject tion report cited TVA with one Severity Level V Violation.
,aed is our response to the violation.
If you have any questions, please get in touch with R. H. Shell at FTS 858-2688.
To the best of ray knowledge, I declare the statements contained herein are complete and true.
Very truly yours, TENNESSEE VALLEY AUTHORITY
'Y,.h i
L. M. Mills,14anager Nuclear Licensing Enclosure cc:
Mr. Richard C. DeYoung, Director (Enclosure)
Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C.
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' C301250308 830103 PDR ADOCK 05000327 O
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An Equal Opportunity Employer l
e ENCLOSURE SEQUOYAH NUCLEAR PLANT RESPONSE TO VIOLATION
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50-32i/d2-24and50-328/82-25 VIOLATION Technical Specification 6.8.4.b requires that wrf tten procedures shall be established, implemented and maintained by the R2 diological Hygiene Branch covering the Quality Assurance Program and~ enviro,nmental monitoring, using the guidance contained in Regulatory Guide 4.15, December 1977.
Procedure Ho, NR-0PS-FO-NRE-62.3 (Calibration of Radiation Monitors) which implements Technical Specification 6.8.4.b requires calibration of environ-mental radiation monitoring equipment at six (6) month intervals, and posting of calibration stickers on or near the monitor.
Contrary to the above, Procedure No. NR-0PS-FO-NRE-62.3 was not implemented in that:
1.
Background radiation monitors and air monitor, flow meters at all assigned air particulate /radioiodine monitoring stations were not calibrated within the required six (6) month interval in the case _of stations LM-1, LM-2, and PM-1 through PM-8.
2.
Calibration stickers docu.nenting the most repent calibrations were not posted on or near the monitors as required.
This is a Severity Level V Violation (Supplement flV.E).
ADDMISSION OR DENIAL OF THE ALLEGED VIOLATION Monitors LM-1, LM-2, and PM-1 through PM-8 were not caliarated within the required six-month interval; therefore, we admit violation of this requirement. It should be noted that section 2.0 (not section 6.4 as stated in the Report Details) of Natural Resource Operations Procedure No. NR-OPS-FO-NRE-62.3 " requires that radiation monitors shall be calibrated at six-month intervals." Also, in,section 5.d of the Report Details, the inspector reports that the " previous c'alibration of air monitor flow meters and background radiation monitors for stations LM-1 and U1-2 was February 23, 1981, and March 3-9, 1981, in case of air monitoring stations PM-1 through PM-8."
We believe the dates were inadvertently listed in error in the report as the actual dates of the Previous calibrations were as follows:
Station No.
Date.
Station No.
'Date LM-1 23 FEB 82 PM-4 9 MAR 82 LM-2 25 FEB 82 PM-5
~3' MAR.82 PM-1 9 MAR 82 PM-6 3 MAR 82 PM-2 1 MAR 82 PM-7 3 MAR 82 PM-3 9 MAR 82 PM-8 3' MAR 82
r In addition, it was stated that there were no' calibration stickers posted on or near the monitors. The Report Details states that such stickers are required in section 6.9.5,(rather than 6.5) of NR-OPS-FO-NRE-62.3.
There is no requirement in NR-OPS-FO-NRE-62.3 providing for the placement -
of.a calibration sticker ou or near the monitor. The procedure does require the use of a " label" on the panel beside the ~ monitor flowmeter that contains information concerning the air flowmeter setting. This is not considered a calibration record for the monitor; however, provision is made in the procedure for calibration records. ' A calibration record form (attachment 1 of the procedure) is completed during the calibration of each monitor. These forms are maintained by the Field Operations, Eastern Area (F0 EAST) Knoxville office, for the lifetime of the plant and in the FO EAST, Chattanooga field office, for one year (section 8.1 of the procedure). We agree that use of calibration stickers may be appropriate, but we know of no requirement for their use; therefore, we deny this alleged violation.
REASON FOR THE VIOLATION IF ADMITTED The reason for the calibration fr'equency violation was insufficient administrative control on the part of FO EAST.
Calibration of the monitors had been scheduled within the six-month period but was postponed because of other work and inadvertently not rescheduled.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED All monitors v.er_e_ calibrated immediately after the OIE/ inspection.
The following ar~e the' dates on which each monitor was calibrated.
a
Station No.
Date
' Station No.
Date LM-1 15 OCT 82 PM-4
,16 OCT 82 LH-2 15 OCT 82 PM-5 16 OCT 82 PM-1 16 OCT 82 PM-6 15 OCT 82
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FM-2 15 OCT 82 PM-7' 15 0CT 82 PM-3 15 OCT S2
?M-8 i
16 OCT 82
_ CORRECTIVE STEPS WHICH WILL ~BE TAKEN TO AVOID FURTHER VIOIATION An administrative procedure has been implemented in FO EAST which schedules and tracks the calibration of the radiation monitors at Sequoyah. This ' procedure will provide a reminder of the need to recalibrate the monitors, and the ' reminder will not be cancelled until the calibration is co=plete. In addition, as part of TVA's overall control plan, a copy of the calibration record form will be sent to Health Physics Services staff.
DATE KEEN FULL COMPLIANCE WILL BE ACHIEVED TVA was in full compliance on December 2, 1982.
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