ML20084G916

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Responds to NRC Re Violations Noted in IE Insp Repts 50-327/84-04 & 50-328/84-04.Corrective Actions:Health Physicist Reviewed Practice of Assigning Preemployment Dose Limits & Stressed Importance of Accurate Estimates
ML20084G916
Person / Time
Site: Sequoyah  Tennessee Valley Authority icon.png
Issue date: 04/10/1984
From: Mills L
TENNESSEE VALLEY AUTHORITY
To: James O'Reilly
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20084G900 List:
References
NUDOCS 8405070392
Download: ML20084G916 (3)


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TENNESSEE VALLEY AUTHORITY CH ATTANOOGA. TENNESSEE 37401 400 Chestnut Street Tower II APR 12 ajg,. g April 10,1984 l

U.S. Nuclear Regulatory Commission Region II l

Attn Mr. James P. O'Reilly, Regional Administrator i

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 50-327/84-04 AND 50-328/84 RESPONSE 'IO VIOLATION The subject OIE inspection report dated March 12, 1984 from R. C. Lewis to H. G. Parris cited TVA with one Severity Level IV Violation. Enclosed is the response to the item 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 arw complete and true.

Very truly yours, TENNESSEE VALLEY AUTHORITY l

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L. M. Mills, 4anager Nuclear Licensing Enclosure ao (Enclosure):

Mr. Richard C. DeYoung, Director r

Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Records Center l

Institute of Nuclear Power Operations 1100 Circle 75 Parkway, Suite 1500 t

Atlanta, Georgia 30339 l

O!h3$7 PDR 1983-TVA BOTH ANNIVERSARY -

An Equal Opportunity Employer

ENCLOSURE j

i RESPONSE - NRC INSPECTION REPORT NOS.

50-32*//84-04 AND 50-328/84-04 d

R. C. LEWIS'S LETTER TO H. G. PARRIS

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DATED MARCH 12, 1984 1

Item 327, 328/84-04-01 i

i Licensee Technical Specifications state in paragraph 6.11, Radiation

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Protection Program, that procedures for personnel radiation protection j

shall be prepared consistent with the requirements of 10 CFR Part 20 and j

shall be approved, ciaintained and adhered to for all operations involving personnel radiation exposure.

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Licensee procedure SQNP, RCI-14, Radiation Work Permit (RWP) Program, l

1 states in paragraph IIID that if an RWP Timesheet is posted at the area, Health Physics shall meet the requirements prescribed on the permit. RWP l

No. 02-01-00001, issued January 9, 1984, for repair of damaged track in the i

fuel transfer canal states obey all instructions on the RWP and do not exceed 250 mrem per day.

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Contrary to the above, Timesheet No. 005 shows that during the period

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January 9 - 13, 1984, three individuals made four entries into the transfer l

canal in which they received exposures in excess of 250 mrem / day, ranging i

from 400 to 625 mren.

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This is a Severity Level IV Violation (Supplement IV).

1.

Admission or Donial of the Alleged Violation

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j TVA admits the violation occurred as stated.

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2.

Reasons for the Violation if Admitted During the period January 9-13, 1984, three individuals made three entries each into the transfer canal to do repair work associated with 2

the fuel upender. Preplanned dose estimates were developed to limit the applicable workers to 250 mrem per day, and a radiation work permit I

(RWP) was insaed which stated this limit. Contrary to the limit stated on the RWP, four entries resulted in exposures greater. than 250 mrom.

j Constant Health Physics coverage was provided for this work. Although l

Health Physica acknowledged the original dose limit was too low to complete the necessary job (and ensured the applicable workers were not exceeding any regulatory exposure limits), no attempt was made to issue another RWP with a less restrictive dose limit for that job.

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Corrective Steps Which Have Been Taken and the Results Achieved Health Physics has reviewed the practice of assigning prejob dose a.

limits and has stressed the importance of accurate estimates.

b.

An aggressive plant-wide training program was developed which stressed several Health Physics aspects including RWP use and compliance.

4.

Corrective Steps Which Will Be Taken To Avoid Further Violations The use of and compliance with BWPs will be scrutinized by plant a.

management to ensure compliance.

b.

A continuing errort to clarify plant procedures and to increase a worker-level understanding concerning the RWP is ongoing.

5 Date When Full Compliance Will Be Achieved All corrective actions including the plant-wide training program were completed before thrch 1, 1984.

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