ML20078M338

Responds to NRC Re Violations Noted in IE Insp Repts 50-259/83-11,50-260/83-11 & 50-296/83-11.Corrective Actions:Radiochemical Lab Manual Revised to Incorporate Reg Guide 4.15 Interim Guidance

ML20078M338
Person / Time
Site:	Browns Ferry
Issue date:	08/16/1983
From:	Mills L TENNESSEE VALLEY AUTHORITY
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20078M327	List: ML20078M338
References
NUDOCS 8310250138
Download: ML20078M338 (3)

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TENNESSEE VALLEY AUTHORITY CHATTANOOGA. TENNESSEE 37401 1100 Chestnut Street Tower II , y G j)

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$co N*i o August 16, 1983 r,o y U.S. Nuclear Regulatory Commission P

to b3 o,g Region II ** 1~

ATTN: James P. O'Reilly, Regional Administrator C#1 D 101 Marietta Street, NW, Suite 2900 C "

Atlanta, Georgia 30303

Dear Mr. O'Reilly:

Enclosed is a supplemental response to R. C. Lewis' July 26, 1983 letter to H. G. Parris regarding Inspection Report Nos. 50-259/83-11

-260/83-11, -296/83-11 for Browns Ferry Nuclear Plant. The enclosure contains additional information regarding action items in progress at the time of the inspection and details additional plans TVA has for preventing recurrence of findings such as 83-11. On August 15, 1983 Mike Hellums of my staff and Ross Butcher of your staff discussed an extension to August 17, 1983 for submitting this information. If you have any questions, please call Jim Domer at FTS 858-2725.

Very truly yours, TENNESSEE VALLEY AUTHORITY p 5 %~

g L. M. Mills, Manager

/ Nuclear Licensing Enclosure 8310250138 831007 PDR ADOCK 05000259 PDR g

1983-TVA SOTH ANNIVERSARY An Equal Opportunity Employer

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. *2 r4 SUPPLEMENTAL RESPONSE - NRC INSPECTION REPORT NOS.

50-259/83-11, 50-260/83-11, AND 50-296/83-11 259.'260. 296/83-11-02 -

-As requested in a July 15, 1983 teleconference and again in your letter of July 26, 1983, the following additional information, regarding actica items already in progress at the time of the inspection, details additional plans TVA has'for preventing recurrence of findings such as item 83-11-02 (railure to establish and implement calibration procedures).

Radiochemical Laborator'y" Manual (RLM) Section 1500 (Radiochemical Laboratory Quality Control) has been revised to incorporate interim guid;nce on Regulatory Guide 4.15 as well as accomplish imp)ementation of Division Procedure Manual (DPM) N79E2,Section III, (Nuclear Plant Water Quality Manual). In this revision to RLM 1500, more emphasis has been given to the quality control cross-check samples which are provided by the Nuclear Central Office (NCO) Chemical Monitoring Section (CMS). These samples are generally provided approximately every two months and are varied such that most types of analysis routinely performed in the chemistry laboratory are checked within the period of a year. These samples are to be analyzed with a priority

, exceeded only by surveillance instructions and samples related to .

3 operational emergencies. . The results of sample analyses must be'sent back to NCO CMS within two weeks of. sample receipt. NCO CMS will evaluate the sample results for agreement and report their findings to ,

the engineering supervisor at the plant. Disagreement in sample results will require recheck and additional investigation as dictated by the situation. Comparison of radiochemical gamma spectral results

. should be more readily accomplished in the future as both NCO CMS and i

the plant radiochemical laboratories are now using the Nuclear Data 6620 counting system. The ECO CMS will prepare control charts for the cross-check program results and provide these to the plant on an annual basis. .

Also, in RLM 1500 proviaions are made for duplicate and replicate j sample analyses for both radiochemical and nonradiochemical samples.

[ Both the schedule for these analyses'and the analyses results have l been incorporated into the routine laboratory logsheets and will therefore be reviewed by the laboratory supervisor and the unit supervisor on a regular basis. Range charts (R-charts) have also been prepared for tracking the results from the various duplicate / replicate analyses. An R-chart is a plot of samples number versus a range of difference between a set of similar samples on a scale that contains

, the . average difference, R, and an upper control and upper warning limits. These R-charts will be maintained by the plant nuclear chemist and reviewed by the chemical unit supervisor on a routine r -. . - . . - - - . - - - -. _ _ - _ _ - -.- - - - - - - .

7 basis. Any problems noted by the nuclear chemist in the preparation of R-charts will be brought to the attention of the chemical unit supervisor immediately.

At present, these duplicate / replicate sample programs are provided as interts guidance while working toward implementation of Regulatory Guide 4.15. The plant and NCO are resolving problems encountered in changing DPM requirements to comply with Regulatory Guide 4.15. It is expected that the contents of the duplicate / replicate sample program may vary somewhat as DPM requirements are developed.

Further, the RLM 1500 revision includes provisions for gamma spectroscopy system operating instructions, instructions for Ge(Li) detector changeout, and efficiency calibration instructions for both the HP 9830 and ND 6620 based systems. The data sheets associated with these instructions have been revised to require a performer and reviewer signature. The review of this data will be performed by the chemical unit supervisor.

The preceding items provide an indication of some of the changes to RLM Section 1500. This list is by no means complete as the RLM 1500 revision was extensive. This section will continue to change over the next several months as experience is gained working under this revised procedure. ,

Finally, since the inspection, TVA has utilized the expertise of some of its NCO personnel to perform internal audits of the progress made toward correction of deficiencies identified in the inspection. We .

will continue to use these personnel in this manner to provide a general review on a routine basis as well as work in specifically identified problem arca .

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