ML20247Q469

Expresses Concerns Re Installation of RWCU Sys Sample Panel & Relation of Radioactive Water Flowing Through RWCU Sample Panel to Plant

ML20247Q469
Person / Time
Site:	Browns Ferry
Issue date:	08/08/1989
From:	Buggs E AFFILIATION NOT ASSIGNED
To:	Carr K NRC COMMISSION (OCM)
Shared Package
ML20247Q464	List: ML20247Q460 ML20247Q469
References
NUDOCS 8909280204
Download: ML20247Q469 (2)

Text

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409 Cameron Circle # 2402 Chattanooga, TN 37402 August 8, 1989 Mr. Kenneth M. Carr, Chairman U. S. Nuclear Regulatory Commission Washington, D. C. 20555

Dear Mr. Carr:

This letter is in reference to my letter of July 9, 1989 to you and the NRC reply letter of August 3, 1989 from Mr. B. D. Liaw, Director, TVA Projects Division. As I stated in my letter of July 9, 1989, I have continued to pursue these concerns because I believe TVA Nuclear Power management and the NRC staff have decided to take the the trial and error approach toward safety.

I offer you the following information.

I issued five Condition Adverse to Quality Reports (CAQRs) related to the new sample panels and sample lines being installed at TVA Nuclear Power plants. One CAQR was issued for the sample panel installed at the makeup water treatment plant at Sequoyah Nuclear Plant (SON). The other four CAQRs were issued for two panels and associated lines being installed at Browns Ferry Nuclear Plant (BFN), feedwater-condensate and reactor water cleanup.

I agreed to change the CAQR at SQN to a Problem Reporting Document (PRD) on September 20, 1988. TVA issued a corrective action for the PRD at SQN to be implemented on December 14, 1988. TVA has been unable to implement the corrective action for the PRD at SON. The pressure control valves and instruments will not operate properly as reported by SQN laboratory analyst, laboratory supervisor, system engineer and area operator.

In a letter of July 3, 1989, Mr. Liaw stated that TVA is going to implement corrective action for the four CAQRs(PRDs) at BFN in September 1989. It is meaningless for Mr. Liaw to assure me that the NRC will monitor TVA's implementation of the corrective actions scheduled for September 1989 when the NRC has been unable to determine why TVA has not implemented a corrective action for the PRD at SON scheduled for December 1988.

In my letters of October 14, 1988 and May 8, 1989 to the NRC, I sthted that TVA had not performed engineering design calculations for the sample panels. In a letter of June 15, 1989, Mr. Liaw stated that the area is not part of NRC regulations. He stated that TVA has l

assured the NRC that post-maintenance testing is in progress.

Where is TVA getting a continuous flow of water at 1300 pounds-per-square inch gage (psig) to adequately test the reactor water cleanup panel? Obviously, this panel cannot be adequately tested until the reactor begins operation. Mr. Liaw's statement is consistent with the

" count the bodies" attitude toward safety, wait until something happens.

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In addition, I am sure the design basis of BFN does not include six gallons-per-minute of reactor water flowing continuously to the drain system as my calculations show for the reactor water cleanup panel. The design basis, in particular the reactor water leakage rate, is a part of NRC regulations.

As I stated in my letter of July 9, 1989, the NRC initially ignored the CAQRs included in my letter of October 14, 1988. The four CAQRs at BFN were initially closed after I left TVA with no proposed corrective action. The CAQRs were reevaluated only because of a letter I sent to U. S. Senator Jim Sasser. The NRC took no action to ensure that the CAQRs were evaluated.

In summary, TVA has fabricated and installed three sample panels, and no one at TVA or at a contractor has performed engineering design calculations for the panels. Some of the most deadly radioactive streams at BFN will flow to one of the panels. The NRC staff knows that the engineering design calculations were not performed, but the, NRC staff has accepted the philosophy of TVA to operate the panels to determine if there are problems instead of perfoning engineering calculations. I believe one of the complaints about TVA that caused the shutdown in 1985 was inadequate engineering calculations. It is my observation that some members of TVA and the NRC staff have not learned from the past.

Sincerely yours,

\S/ ($5.

Eugene D. Buggs

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