ML20133N005

Revises Response to NRC Re Violations Noted in Insp Repts 50-327/85-15 & 50-328/85-15.Corrective Actions: Lower Limit of Detection for Effluent Releases Reevaluated for All Gamma Spectrometry Sys & Tech Specs Revised

ML20133N005
Person / Time
Site:	Sequoyah
Issue date:	07/31/1985
From:	Domer J TENNESSEE VALLEY AUTHORITY
To:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
NUDOCS 8508130345
Download: ML20133N005 (2)

Text

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4s TENNESSEE VALLEY AUTHORITY

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CH ATTANOOGA, TENNESSEE 37401 400 Chestnut Street Tower II co July 31, 1985 O c--

U.S. Nuclear Regulatory Commission a Region II c.n ATTN: Dr. J. Nelson Grace, Regional Administrator 101 Marietta Street, NW, Suite 2900 >

Atlanta, Georgia 30323 co

Dear Dr. Grace:

SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 - NRC-OIE REGION II INSPECTION REPORT 50-327/85-15 AND 50-328/85 REVISED RESPONSE TO VIOLATION Enclosed is our revised response to D. M. Verrelli's April 30, 1985 letter to H. G. Parris transmitting IE Inspection Report Nos. 50-327/85-15 and 50-328/85-15 for oar Sequoyah Nuclear Plant which cited TVA with one Severity Level V Violation. The revised response is being submitted as a result of additional discussions with NRC-Region II representatives and as documented in the July 1, 1985 letter from D. M. Verrelli to H. G. Parris.

If you have any questions, please get in touch with R. E. Alsup at FTS 858-2725.

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

Very truly yours, TENNESSEE VALLEY AUTHORITY J. A. Dom lef Nuclear Licensing Branch Enclostare cc: Mr. James Taylor, Director (Enclosure)

Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C. 20555 8508130345 050731 PDR O

ADOCK 05000327 PDR

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An Equal Opportunity Employer [6

l REVISED RESPONSE - NRC-0IE INSPECTION REPORT NOS. I 50-327/85-15 AND 50-328/85-15 D. M. VERRELLI'S LETTER TO H. G. PARRIS DATED JULY 1, 1985 Items 50-327/85-15-02 and 50-328/85-15-02 Technical Specification Table 4.11-2 requires - the analysis of Xe-138 in gaseous waste samples at a Lower Limit of Detection (LLD) of 1E-04 microcuries per cc. -

Contrary to the above, during the period June through December 1984, there were numerous examples of failure to achieve the required LLD for Xc-138 due to excessive decay time between sampling and analysis. ' -

This is a Severity Level V violation (Supplement IV).

1. Admission or Denial of the Alleged Violation

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TVA admits the violation occurred as stated.

N 2. Reason for Violation The violation occurred due to Sequoyah Nuclear Plant (SQN) personnel misinterpreting a previous NRC inspection report that indicated we were

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in compliance with the intent of the LLD requirement. The inspection was conducted on February 19 - 22, 1980, by L. L. Jackson of the Region II staff and included a review of SQN's effluent release program (Report No. 50-327/80-08 AND 50-328/80-05) . The inspection indicated that the RETS sensitivity limits are not rigid limits for all samples. However, in accordance with our telephone conversation with Dan Montgomery, we agree that during the period identified in the violation there were 10 samples of the waste gas decay tanks that did not meet this LLD require-ment while 36 samples were within limits.

3. Corrective Steps Taken and Results Achieved The LLDs for ef fluent releases, liquid and gaseous, have been reeval-uated for all three of SQN's gamma spectrometry systems. The Technical Instruction TI-12, " Radiological Analytical Methods," which describes counting methods, i.e., volumes, efficiency files, counting times, etc.,

has been revised to reflect minimum time periods between sample collection and counting times in order to meet Technical Specification LLD require-ments in Table 4.11-2. If these times cannot be met, analysts have been instructed to resample.

4. Corrective Steps Taken to Avoid Future Violations i

See item 3 for details.

5. Date When Full Compliance Will Be Achieved t

The plant is in full compliance.

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