ML20214H382
| ML20214H382 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 05/15/1987 |
| From: | Domer J TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8705270366 | |
| Download: ML20214H382 (6) | |
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TENNESSEE VALLEY AUTHORITY-CHATTANOOGA. TENNESSEE 37401 SN 157B Lookout Place-MAY 151987 U.S.-Nuclear Regulatory Coemission ATTN: Document Control Desk Washington, D.C.
20555 Gentlemen:
In the Matter of
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Docket Nos. 50-327 Tennessee Valley Authority
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50-328 SEQUOYAH NUCLEAR PLANT (SQN) UNITS 1 AND.2 - NRC. INSPECTION REPORT NOS.
50-327/87-08 AND'50-328/87 RESPONSE TO VIOLATION NOS.~50-327
-328/87-08-03 AND DEVIATION NOS. 50-327, -328/87-08-01 Enclomed is'our response to Gary G. Zech's April 10, 1987 letter to g
S. A. White which transmitted the subject Notices of Violation and i
Deviation. Enclosures 1 and 2 provide our responses-to the Notices ~of
. Violation and Deviation, respectively.. Enclosure 3 contains the list of comunitments contained in enclosures 1 and 2.
We do not recognize any other items described herein as comunitments.
If you have any questions, please call N. R. Harding at (615) 870-6422.
To the best of my knowledge, I declare the statements contained herein are complete and true.
Vary truly yours, TENNESSEE VALLEY AUTHORITY
>J.A.Domer,~AssistantDirector
- P!/L Nuclear Safety and Licensing Enclosures cc:
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, U.S. Nuclear Regulatory Commission MAY 151987 cc (Enclosures):
Mr. G. G. Zech. Assistant Director for Inspection Programs Division of TVA Projects Office of Special Projects U.S. Nuclear. Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Mr. J. A. Zwolinski,-Assistant Director for Projects Division of TVA Projects office of special Projects U.S. Nuclear Regulatory Commission 4350 East West Highway.
EWW 322 Bethesda, Maryland 20814 Sequoyah Resident Inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy Daisy, Tennessee 37379 I
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ENCLOSURE 1 RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT NOS. 50-327/87-08 AND 50-328/87-08 GARY G. ZECH'S LETTER TO S. A. WHITE DATED APRIL 10, 1987 Violation 50-327. 328/87-08-03 Technical Specification 6.11 requires that procedures for personnel radiation protection be prepared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained..and adhered to for all operations involving personnel radiation exposure. Sequoyah Nuclear Plant Radiological Control Instruction RCI-1, Radiological Hygiene Program, implements these requirements. RCI-l states that employees are responsible for properly monitoring themselves prior to leaving radiologically controlled areas (RCAs).
Contrary to the above, approximately six workers were observed improperly monitoring themselves as they exited the RCA.
The workers did not frisk gloves that were used to handle items that had potential external contamination.
The gloves were removed from the RCA and used to perform work tasks outside the RCA.
This is a severity level V violation (Supplement I).
1.
Admission or Denial of the Alleged Violation TVA admits the violation as stated.
2.
Reasons for the Violation The personnel exiting the RCA complied with the specific requirements of RCI-l in that they performed the required hand and foot frisk. However, the extension of this requirement to their gloves was not interpreted as being required. Therefore, a lack of specific guidance in RCI-1 and a lack of clear understanding of the individuals conjunctively contributed to this violation.
3.
Corrective Stros Which Have Been Taken and The Results Achieved Personnel of the affected sections have been provided further guidance by the Modifications Group managers on the requirements and importance of frisking themselves and their personal effects upon exiting the RCA.
In addition, in conjunction with the Power Operations Training Center, a one-day Radiation Worker Refresher course is currently being conducted for selected permanent sito employees to resolve those problems. This course provides guidance for frisking items leaving the RCA and emphasizes the importance of frisking.
4.
Corrective Steps Which Will Be Taken To Avoid Further Violations i
RCI-1 will be revised to provide further guidance in the requirements associated with the frisking of personal effects.
5.
Date When Full Compliance Will Be Achieved RCI-1 will be revised by June 15, 1987.
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.o "NCLOSURE 2 RESPONSE TO NOTICE OF DEVIATION NRC INSPECTION REPORT NOS. 50-327/87-08 AND 50-328/87-08 CARY C. ZECH'S LETTER TO S. A. WHITE DAT8D APRIL 10, 1987 Deviat ion 50-327. 328/87-08-01 The Sequoyah nuclear plant Final Safety Analysis Report (FSAR) states that, "all equipment installed to reduce radioactive effluents to the minimum practicable level is maintained in good operating order.... In order to assure that these conditions are met, administrative controls are exercised on overall operation of the system; preventive maintenance is utilized to maintain equipment in peak condition; and experience available from similar plants is used in planning for operation at Sequoyah nuclear plant."
Contrary to the above, the licensee failed to conduct routine preventive maintenance on the condensate demineralizer waste evaporator (CDWE) equipment.
Sequoyah Nuclear _ Plant (SON) Response The cited deviation description in paragraph 3. " Licensee Action on* Previous Inspection Findings, URI 327, 328/86-19-03," of the subject inspection report states, "The inspector was not able to identify any routine preventive maintenance performed on the CDWE system.
." TVA does not deny that routine preventive maintenance (FM) was not performed on CDWE equipment before March 1985. However, several PM instructions have been developed and implemented for CDWE equipment and have been in place and documented as being consistently performed since that time. Therefore, corrective actions regarding this portion of the deviation have previously been addressed.
Further, as stated in revision 1 of the Sequeyah Nuclear Performance Plan,Section II.4.3.2, " Detailed review of the technical specifications and FSAR to ensure that maintenance requirements for PMs are identified has been completed. Resolution of the identified items will be completed prior to restart."
The deviation description in paragraph 3 of the subject inspection report also states, ".
. and there is no objective evidence that industry experience is used in planning for operation of the CDWE."
Per section 11.2.4 of the FSAR, "The operating procedures and administrative controls used at the Sequoyah Nuclear Plant are written uoing as references procedures and controls developed by operational PWR plants which have similar waste management equipment. This insures.
operations utilize the field experience gained by operational plants." These statements address the initial development of procedures for Sequoyah waste management equipment.
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. TVA does not deny that' industry experience in the initial development of
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procedures and administrative controls for waste management equipment is not objectively evident. However, the initial procedure development exhibits vendor and initial design considerations. Further, subsequent procedural revisions show that TVA experience and vendor recommendations / considerations are used in the operation of waste management equipment. A FSAR change will be initiated and processed for inclusion into the April 1988 FSAR update to accurately define the industry experience considerations, including vendor recommendations, which are utilized in operation of SQN waste management equipment.
In addition, it should be noted that the inspection report discussion in
'paragrapra 3 regarding the proposed elimination of the requiremant for PM in section 11.2.4 of the FSAR is not accurate.
Rather, the FSAE change alluded to involves a change in the method described for PM development from ".
. as described in manufacturer's instruction manuals.
." to ".
. as determined to be required'by the plant maintenance organization. This determination will be based on experience, consideration of the equipment's importance to safe operation of the plant, and history of equipment failure.
Equipment specifications such as oil grades, quantities, etc., will be determined from the equipment manufacturer's recommendation or from experience." This change has been incorporated into the FSAR as part of revision 4 submitted'to NRC on April 20, 1987.
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ENCLOSURE 3 LIST OF COMMITMENTS 1.
RCI-1 will be revised by June 15, 1987, to provide further guidance in the requirements associated with the frisking of personal effects.
- 2. 'FSAR section 11.2.4 will be revised in the April 1988 update to accurately define the industry experience considerations, including vendor recommendations,.which are used in operation of waste management equipment.
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