ML18026B030

Forwards post-accident Sampling Status in Response to Gc Lainas to Hg Parris,Per 840509 Meeting.Nrc Evaluations of Walk Through of Current Procedures Concluded Facility Adequate & Meets NRC Requirements

ML18026B030
Person / Time
Site:	Browns Ferry
Issue date:	06/06/1984
From:	Mills L TENNESSEE VALLEY AUTHORITY
To:	Harold Denton Office of Nuclear Reactor Regulation
References
TASK-2.B.3, TASK-TM NUDOCS 8406120325
Download: ML18026B030 (17)

Text

REGULATORY FORMATION DISTRIBUTION SY

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AOCESSION NBR:8006120325 DOC ~ DATEt Bll/06/06 NOTARXZEDt YES DOCKET'.

FACIL:50 259 Browns Fer ry Nuclear Power Stations Uni.t 1< Tennessee 05000259 50 260 Browns Ferry Nuclear Power Stationi Unit 2i Tennessee 05000260 50-296 Browns Ferry Nuclear Power Stationi Uni,t 3~

Tennessee 05000296 AUTH'AME AUTHOR AFFILIATION HILLStL ~ Me Tennessee Valley Authority RECIP ~ NAHE RECIPIENT AFFILIATION DENTONiH ~ RE Office of Nuclear Reactor Regulationp Director

SUBJECT:

Forwards post accident sampling status in response to GC Lainas 800501 ltr to KG Parrisgper 840509. meeting,NRC evaluations of walk through of current procedures concluded facility adequate L meets NRC requirements, DISTRIBUTION CODE ~

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TENNESSEE VALLEYAUTHORITY CHATTANOOGA. TENNESSEE 37401 400 Chestnut Street Tower II June 6,

1984 Mr. Harold RE Denton, Director Office of Nuclear Reactor Regulation U.ST Nuclear Regulatory Commission Washington, D ~ C ~ 20555

Dear Mr. Denton:

In the Matter of the Tennessee Valley Authority Docket Nos. 50-259 50-260 50-296 In response to G.

C. Lainas'etter to H. G. Parris, we are providing the enclosed information regarding the Browns Ferry interim Post-Accident Sampling Faoility (PASF).

This letter was the subject of a May 9, 1984 meeting between TVA and representatives of yout staff and Region II

'ur response regarding the permanent PASF will be provided as requested by August 6, 1984.

Very truly yours, Subscrib d ppd sworn to efore me t s ~

day o TENNESSEE VALLEY AUTHORITY

Mills, anager Nuclear Licensing 1984.

Notary Public My Commission Expires Enclosure cc (Enclosure):

U.S. Nuclear Regulatory Commission Region II ATTN:

James PE O'Reilly, Regional Administrator 101 Marietta Street.,

NW, Suite 2900 Atlanta, Georgia 30303 Mr.

RE J ~ Clark Browns Ferr y Project Manager U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue

Bethesda, Maryland 20814 840bi20325 840bOb PDR ADOCK 05000259 P

PDR An Equal Opportunity Employer

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Y TO MAY 1, 1984 NRC LETTER DING POST-ACCIDENT SAMPLING STATUS OF BROWNS FERRY NUCLEAR PLANT UNITS 1, 2, AND 3

'l'his information is submitted in support of a reply to the May 1, 1984,NRC letter from G. 'C. Lainas, Office of Nuclear Reactor Regulation (ONRR), to TVA regarding the current status of Browns Ferry post-accident sampling facility (PASF)'.

Item 1:

Desi n and 0 erational Review TVA's design and operational review resulted in the orginal versions of present procedures under which.interim post-accident sampling and analysis of reactor water 'and drywell atmosphere samples would be conducted and werc originally prepared. in response to NRC TMI-2 lessons-,learned guidelines (NUREG-0578).

During this pe'riod, there was much confusion and uncertainty on the part of both licensees and the NRC as to what constituted'cceptable approaches to meeting thc interim post-accident sampling and analysis needs.

As with other utilities, TVA lacked internal eiperience in this area, and therefore, relied heavily upon the evaluations tha't rcsultcd from a number of inspections of the Browns Ferry facility by the NRC.,In particular, after NRC's initial site visit and evaluation in February 1980 and NRC's documentation of the results (see reference 7 of appendix),

we felt reasonably

~ comfortable'-with our interim facility.

These plater evaluations were used to

'uide the development of the interim post-accident program and ensure its

'compatibility. with NRC requirements.

The present interim procedures represent several steps of evolution through which these procedures and their related equipment have been upgraded and improved in response to internal (TVA) and NRC reviews.

For example, even before the May '1, 1984 NRC letter was 1

. ~

received, the procedures for sampling of 'the drywell atmosphere were under revision in direct response to the NRC concerns expressed following the October 1983 inspection at Browns Perry.

The procedures in place are specific as to what analyses are to be performed and under what conditions they are to be carried out.

Specifically exempted from iVA pIans for interim post-accident sample reactor 'water analyses arc thc determinations for chloride and boron.

hn upper I imit of 100 R/h is established in the procedures as the maximum exposure rate in which sampling shall be performed.

These procedural restrictions have always been reviewed and evaluated by the

NRC, and each time, until the October 1983 inspection, they were determined to be satisfactory.

'Although no detailed design calculations were documented regarding shielding of sample lines for interim post-accident responses, numerous exchanges bctwccn NUC PR and EN DL'S did take place.

These verbal exchanges centered around design calculations that werc being performed for the shielding of the permanent PASS lines and resulted ip the conclusion that shielding the sample lines as presently installed was not feasible.

This resulted in the establishment of the 100 R/h upper working limit and the adoption of the portable shielding philosophy.'.

The location arid availability of portable shielding committed to interim post-accident utilization has recently been surveyed and documented.

This is in response to the NRC inspection concern expressed during the October 1983 evaluation.

Because the existence and use of portable temporary shields was

'I not adequately addressed in the procedures, there may have been some confusion

'on thc part of the analyst during the, October 1983 inspection and walk-

4 t'hrough.,

Availab shielding is adequate to rende~e existing interim

, procedures workable under all but, the most severe accident conditions.

I In all cases, TVA personnel have received extensive walk-through familiarization with the interim post-accident procedures and equipment.

TVA has subsequently held annual training and walk-throughs on procedures'and equipment.

The attached appendix itemizes all correspondence and documentation related to.

the history of the development;

review, and prior NRC evaluation of the Browns

.Ferry interim post-accident sampling procedures.

'Copies of this information wexe given to NRC representatives in our May 9, 1984 meeting.

Item 2:

Basis for the Determination that the Interim Procedures are Workable and Meet I'nterim Criteria As stated earlier, TVA initially conducted walk-through familiarization of all

,personnel. responsible for performance of the interim post-accident procedures, and has included walk-throughs of the procedures as an integral part of annual

'training/retraining.

Numerous NRC evaluations (scc appendix) have observed these walk-throughs of the current procedures and concluded that they were adequate and met the NRC

.requirements.

As discussed

before, TVA found it necessary to rely on the experience and.,knowledge of the NRC and NRC contract personnel involved in, 1

I these evaluations to supplement the lack of internal experience in these

, 'matters and to provide effective review of TVA procedures.

TVA and Browns.

Ferry have always been responsive to thc comments and concerns of the NRC in

regard to the status of thc interim po'st-accident response capabilities.

Rased on the inspection report from the October 1983 NRC evaluation, the efforts of an on-site consultant experienced in post'-accident systems and procedures were immediately directed to the concerns identified.

This was a

commitment made well in advance of the hlay 1, 1984 NRC letter and was an integral part of thc contract negotiation process with the consultant in January 1984.

As a result of the 'hfay 1, 1984 letter, priority on this project has been upgraded.

,4

APPENDIX I.ist 'of Related Documents and Correspondence.

Pert'aining to. the Current Status'f the TVA/Browns Ferry Post-Accident Sampl'ing Status

, Reference'13 requests information from TVA concerning the Br'owns Ferry permanent and interim PASF.

The request contains three parts.

Part 1

requests further review of the permanent facility for criteria 1, 2, 10, and,11.

TVA will submit a response by August 6, 1984.

Part 3 requests TVA to review the overall impact if the installation of the permanent system was required by NRC to be complete before startup in cycle 6.

I'he NRC concern over the relative low priority given to the implementation of the permanent system has resulted in increased attention to the adequacy of the interim system as expressed in part 2 of reference 13.

TVA's response (ref. 1) to NUREG-0578 stated our intention of processing, designing, and building an onsite analysis facility.

Reference 2 gave NRC a schedule whereby unit 1 and unit 3 short-term requirements would be complete by December 1979 and unit 2 by March 1980. In reference 3;

'1VA rescheduled the unit 2 date to January 1, 1980 per NRC request.

Xn reference 4 (our original response to NUREG-0737),

TVA committed to installing a complete post-accident, sampling r

~

~

facility.

I In reference 5,

NRC. gave Browns Ferry unit 1 confirmatory orders to implement all 'Category A'essons

learned,

~ In. a reply (ref. 6) to an NRC request for the methods used for implementation of NUREG-0578 short-term requirements, r

TVA stated that duc to the location of the curcnt sampling systems, access is r

limited for severe accident cases.

TVA also related (ref. 6) that procedures werc devised to evaluate the primary coolant system activity depending on'he accessibility of the sampling stations.

NRC made a site inspection on

February 19 and 20, 1980 to inspect compliance with the Category A

requirements.

In a report of the staff evaluation of the February 19 and 20, I

1980 inspection (ref. 7),

NRC concluded that the 'licensee has justified the intent of this item, has implemented interim procedures and has, therefore, complied with the requirements of Post-Accident Sampling.'n rcfercncc 8,

NRC again stated that

'I'MX Action Item II:B.3, Post-Accident

Sampling, Interim System (Category A), had been found acceptable.

In July

1981, NRC made an Emergency Preparedness Appraisal and in their report (ref.

9) stated that interim sampling techniques were acceptable.

NRC did have some concern over shielding and stated this matter should be considered for improvement.

Xn reference 10, TVA stated in their response to the concerns expressed in the Emergency Preparedness Appraisal that we were evaluating the possibility of adding temporary shielding around the existing sample stations.

TVA made an cvalution, discussed the shielding questions with EN DES, as the I

minutes (ref. 11) of the meeting held December 15, 1981," reflect',

and it was II determined that permanent shielding for either the interim or final PASF was not feasible at the existing sample stations.

In an internal Browns Ferry memorandum attached to reference 11, solutions to the NRC concer'n on shielding expressed in the Emergency Preparedness Appraisal were evaluated and

~ the recommendation made that portable lead shields be used as needed for the interim system.

References 0

1.

L. M. Mills to D.

G. Eisenhut dated October 17, 1979 2.

L. M. hIills to H. R. Dcnton dated November 16, 1979 3.

L. M. Mills to '7. A. Ippolito dated December 19, 1979 4.

L. hI. Mills to II. R. Donton dated Dcccmbcr 23, 1980 5.

H.

R. Denton to H. 6. Parris dated January 2, 1980 6.

L. M. Mills to H. R. Denton dated January 17, 1980 7,

T. A. Ippolito to H.

G. Parris dated February 29, 1980 8.

R.

C. Lewis to H.

G. Parris dated August 13, 1981 9,

J.

P. O'Reilly to H.

G. Parris dated November 6, 1981 10, L. M. Mills'o J.

P. O'Reilly dated December 7, 1981 11.

A. M.

Rom to Nuclear Engineering Branch files dated January 7, 1982

'12.

R.

C. Lewis to H. 6. Parris dated January 10, 1984 13.

G.

C. Lainas to II. G. Parris dated hfay 1,,1984

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