ML20073A366
| ML20073A366 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 03/25/1983 |
| From: | Mills L TENNESSEE VALLEY AUTHORITY |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20073A289 | List: |
| References | |
| NUDOCS 8304110735 | |
| Download: ML20073A366 (3) | |
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.c TENNESSEE VALLEY AUTHORigg prggy ;;
400 Chestnut Street Tower II,7i' M tai UEGE01A CH ATTANOOGA, TENNESSEE 374o1 March 25, 983 g 28 All 05 U.S. Nuclear Regulatory Commission Region II.
Attn: Mr. James P. O'Reilly, Regional Administrator 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30303
Dear Mr. O'Reilly:
SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 - NRC-0IE REGION II INSPECTION REPORT 50-327/83-01.AND 50-328/83 RESPONSE TO VIOLATION The subject OIE inspection report dated February 25, 1983 from R. C. Lewis to H. G. Parris cited TVA with one Severity Level IV Violation.
Enclosed is our response to the subject inspection report.
If you have any questions, please get in touch with R. H. Shell at t
FTS 858-2688.
To the best of my knowledge, I declare the sLatements contained herein are complete and true.
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Very truly yours, TENNESSEE VALLEY AUTHORITY I
L. M. Mills,, nager Nuclear Licensing.
4 Enclosure cc: Mr. Richard C. DeYoung, Director (Enclosure)
Office of Inspection and Enforcement -
U.S. Nuclear Regulatory Coinnission Washington, D.C.
20555 8304110735 830405
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PDR ADOCK 05000327 O
PDR c
An Equal Opportunity Employer
l ENCLOSURE RESPONSE - NRC INSPECTION REPORT NOS.
i 50-327/83-01 AND 50-328/83-01 R. C. LEWIS' LETTER TO H. G. PARRIS DATED FEBRUARY 25, 1983 4
327. 328/83-01-01 Technical Specification 3 3 3 9, Table 3 3-12, 2.a requires that a minimum of one radioactive liquid effluent monitoring instrument shall be operable at all times for-each Essential Raw Cooling Water line with its alarm / trip setpoint set to ensure that the limits of Specification 3 11.1.1 are not exceeded. With no monitors operable, discharges may continue for up to 30 days provided grab 4
samples are analyzed at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> for gross radioactive gamma.
Contrary to the above, the "A" train Essential Raw Cooling Water' effluent monitors were inoperable from December 7,1982 until January 24, 1983 and grab samples were not analyzed once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> for gross radioactive gamma.
Radiation monitors 0-RM-90-133A and 140A were reading approximately 1.0E03 counts per minute (CPM) due to high background radiation from a nearby Refueling Water Storage Tank (RWST) pipe. The background radiation caused the monitors to alarm continously and any radioactivity released through the effluent pathway.
could not cause the monitor to alarm and alert the operators. The monitors were not declared inoperable and-8-hour grab samples were not initiated. This l
violation applies to both Units 1 and 2.
l This is a Severity Level IV Violation (Supplement I).
1.
Admission or Denial of the Alleged Violation TVA admits the violation occurred as stated.
2.
Reasons for the Violation if Admitted On December 7, 1982, the monitor high radiation alarm was received and a grab sampling was initiated. No activity was found;~however, background radiation to the monitor had caused the monitor to stay in high alarm. All-monitor functions were verified to be working properly except that the alarm would.not clear due to the background readings.
The failure to continue the requirements of the action statement-was caused I
by an inadequate surveillance instruction (SI) which did not require the
- absence of alarms to prove operability of the monitor.-
Since the SI did'not rely on the absence of alarms to prove operability and-the monitor responded" to daily channel checks, the monitor was not declared inoperable.
A contributing cause was that the technical specification limiting 1
conditions for operation'(LCO) was interpreted to mean that~a proper monitor
.setpoint was all that was required.
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Corrective Steps Which Have Been Taken and the Results Achieved Upon identification of the occurrence on January 24, 1983, the requirements of the action statement were complied with. An evaluation was made of the nature of the background radiation and the alarm setpoi.nt. The alarm was i
cleared by adjusting the setpoint which includes the13ackground radiation.
4.
Corrective Steps Which Will Be Taken to Avoid Further Violations A review was made of the, technical specification LCO bases and an interpretation has been 'nede to require operations personnel to clear the alarm from the monitor as quickly as possible. Otherwise, the monitor is to be declared inoperable and the action statement complied with. The SI has been revised to reflect these guidelines for verifying operability.
In addition to the instruction revision, a Design Change Request (DCR) has been issued (DCR 1856) to evaluate the possibility of moving the ERCW radiation monitors to an area less susceptible to background radiation.
5 Date When Full Compliance Will Be Achieved 1
Full compliance was achieved on February 9, 1983 I
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