ML20071L832

Responds to NRC Re Violations Noted in IE Insp Repts 50-259/82-44,50-260/82-44 & 50-296/82-44.Corrective Actions:Interim Criteria for Removal of Waste Oil & Miscellaneous Wastes from Regulated Areas Developed

ML20071L832
Person / Time
Site:	Browns Ferry
Issue date:	04/01/1983
From:	Mills L TENNESSEE VALLEY AUTHORITY
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20071L806	List: ML20071L832
References
NUDOCS 8305270660
Download: ML20071L832 (5)

Text

O TENNESgEpVALLEY AUTHORITY 40 awe'shniiT"d@!e Yl$fe5 YI" a3 ne s AI C April 1, 1983 U.S. Nuclear Regulatory Commission Region II ATTN: James P. O'Reilly, Regional Administrator 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30303

Dear Mr. O'Reilly:

Enclosed is our response to your February 25, 1983 letter to H. G. Parris transmitting Inspection Report Nos. 50-259/82-44,

-260/82-44, -296/82-44 regarding activities at our Browns Ferry Nuclear Plant which appeared to have been in violation of NRC regulations. We have enclosed our response to Appendix A, Notice of Violation. A four-day extension on the submittal of this response was discussed with and granted by NRC Inspector Ross Butcher on March 29, 1983 If you have any questions, please call Jim Domer at FTS 858-2725.

The actions detailed in the enclosed response reflect our continuing commitment to a well-controlled, technically qualified waste disposal program. TVA will continue to improve the program whenever possible and to work with NRC to resolve any problems encountered.

To the best of my knowledge, I declare the statements contained herein are complete and true.

Very truly yours, TENNESSEE VALLEY AUTHORITY L. M. Mills, anager Nuclear Licensing Enclosure B3 h0gO G

An Equal Opportunity Employer

RESPONSE - NRC INSPECTION REPORT NOS.

50-259/82 44, 50-260/82 P', AUD 50-296/82 44 J. P. O'REILLY'S LETTER TO H. G. PARRIS DATED FEBRUAEY 25, 1983

. Appendix A Item A - (259, 260, 296/82 44-01) 10 CFR 20.301. requires that no licensee dispose of licensed material except: (a) by transfer to an authorized recipient as provided in Parts 30, 40, 70, or 72 of Title 10 to the Code of Federal Regulations; (b) as authorized pursuant to 10 CFR 20.302; or (c) as provided in 10 CFR 20.303 (disposed of by release into sanitary systems); or 10 CFR 20.106 (radioactivity in effluents to unrestricted areas).

Contrary to the above, between December 15, 1980 and Novenber 16, 1982, the licensee transferred licensed material to unauthorized recipients and disposed of licensed material by means not provided for in the Code of Federal Regulations. A total of 995 microcuries uns disposed of or transferred improperly according to licensee records.

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

1. Admission or Denial of the Alleted Violation TVA admits the violation occurred as. stated.

2. Reasons for the Violation if Admitted Browns Ferry Technical Specification,- Section-3 8 covers-the- _'

controlled releases of radioactive liquids and gases and restricts these releases to the limits specified in 10 CFR Part 20. The specific' limits ^11sted' address' activity' concentrations of gases and- --

liquids in breathing air and drinking water respectively. Powever,

'10 CFR Part 20 does not specify release limits for waste oil and other miscellaneous vastes that might contain low concentrations of activity. In the absence of specific release criteria for the release of waste, Browns Ferry used the limits specified in Appendix B, Table II, Column 2, for drinking water. These limits were first used at Browns Ferry in 1973 and were based on perceived conservative assunptions and compliance with applicable regulations Because the limit for drinking water was applied to materials not intended for human consunption, it was assumed that this practice was conservative and posed no danger to the health and safety of the public.

- ~ . . . - . - - . ., ..

The Appendix B limits were used for the release of debris deposited by river water flowing into condenser water boxes. Since the water boxes are located in a regulated area, the material must be surveyed for activity prior to release. The waste oil release also came from equipment located within a regulated area.

3 Corrective Steps t'hich Have Been Taken and the Results Achieved The offsite disposal of waste oil and other miscellaneous wastes was innediately halted. TVA perforned a radiation survey of Petroleum Recyclers Corporation, Inc.'s facility and on the grounds surrounding the plant where debris fron circulating water boxes had been deposited. No radicactivity above background levels nas detected.

An interim criteria (i.e., no detectable activity) for the renoval of waste oil and other miscellaneous vastes from reguinted areas was developed. These criteria were discussed with and agreed to by NPC in a Novenber 24, 1982 conference call.

4 Corrective Stens thich Will De Taken To Avoid Further Violations TVA is reviewing applicable regulations including IE Inforcation Motice No. 83-05 (obtaining Approval for Disposing of very Low-f Level Radioactive Maste - 10 CFR Section 20 302) to ensure the adequacy of our disposal program . A formal request to allow TVA to apply the limits in 10 CFR Part 20, Appendix B, Table II, Column i

2 to liquids, sludge, sand, gravel, and other such materials is also being considered.

5. Date Uhen Full Connliance Will Be Achieved Full compliance was achieved on February 4, 1983, when Technical

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Instruction 38 (procedure co'n'taining.ithe intesim heleass c'r'leria)"

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i was issued.

ItenB-(25C260,"206/82144102)"~~' " ' ' ' ' ^ " " ' " ' ' ' " " " ^

10 C' FR 20'.201 states that as used in the regulations in 10 CFR 20,

" survey" means an evaluation of the radiation hazard incident to the production, use, release, disposal, or presence of radioactive materials or other sources of radiation under a specific set of conditions. khen appropriate, such evaluation includes . . .

measurenents of levels of radiation or concentrations of radioactive material present. Furthermore, each licensee shall make or cause to be made such surveys as: (1) may be necessary for the licensee to comply with the regulations in 10 CFR 20, and (2) are reasonable under the circumstances to evaluate the extent of radiation hazards that nay be present.

a . _ . a . .- . ; -._ .-  : _ ~. .~ - ._ _ - .

Technical Specification 6 3 requires procedures covering radiation control be prepared, approved, and adhered to.

Contrary to the above, Brouns Ferry Procedure RLM 756, Procedure for Sampling Uaste Oil Drums for FPC Fatio Deternination, does not provide an adequate neans of representative waste oil sarpling and therefore fails to provide an adequate evaluation of radiation hazards that may be present.

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

I 1. Admission or Denial of tha Alleged Violation TVA admits the violation occurred as stated.

2. Reasons for the Violation if Admitted Regulatory Guide (RG) 1.E1 (Measuring, Evaluating, and Reporting Radioactivity in Solid Wastes and Releases of Padioactive Materials in Liquid and Gaseous Effluents from Lie.ht-Unter-Cooled Nuclear Power Plants) was used as a basis for establishing Radiochemistry Laboratory !!anual (PLM) procedure 756 (Sampling I?aste Oil Drums for MPC Datio Determination). To comply with the RG 1.21 requirements, RLI! 756 specified that waste oil in a drum be mixed, using a stirring rod (with propellers attached) driven by a variable speed hand-held drill, before collecting a sample. RLI! 756 also provided for compositing sacoles from multiple drums in order to reduce

! denands on laboratory analytical instrumentation.

The analytical-resulta-of-composited-samples-wera not-used as_the_

basis for releases. 'ihen the presence of significant arounts of activity uas detected, uaste oil was released based-on an analysis -

of individual drum sarples. . The procedure was not checked.for i adequacy and sample representativeness on drumi khoim to 'c' o htain' ^

• oil, water, and particulate matter. Such tests were conducted at URC's requ,est and it was, discovered that yepr,esentat,ive samp,les were not being obtained from oil drums containing significant

.quantitles of water.

3 Corrective steps which nave Reen Taken and the Results Achieved RLM 756 for sampling waste oil was revised. Prior to sampling, each drun is now checked for the presence of water. If water is detected, it is renoved from the drum, and the remaining oil is mixed and sampled. Samples from multiple drums are no longer being cocposited.

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!! . Corrective Stens 1.'hich Uill Be Taken To Avoid Further Violations Mone.

5. Date When Full Con:oliance Will Be Achieved Full compliance was achieved on March 15, 1083, when PLM 756 uns revised.

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