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{{Adams | |||
| number = ML20154C302 | |||
| issue date = 08/31/1988 | |||
| title = Ack Receipt of 871106 & 880513 Responses to 871012 Notice of Violation from Insp Repts 50-327/87-56 & 50-328/87-56. Suggests Changes to Section 11.2 of FSAR to Eliminate Contradictions | |||
| author name = Richardson S | |||
| author affiliation = NRC OFFICE OF SPECIAL PROJECTS | |||
| addressee name = White S | |||
| addressee affiliation = TENNESSEE VALLEY AUTHORITY | |||
| docket = 05000327, 05000328 | |||
| license number = | |||
| contact person = | |||
| document report number = NUDOCS 8809140312 | |||
| document type = CORRESPONDENCE-LETTERS, NRC TO UTILITY, OUTGOING CORRESPONDENCE | |||
| page count = 5 | |||
}} | |||
See also: [[see also::IR 05000327/1987056]] | |||
=Text= | |||
{{#Wiki_filter:, | |||
0fhC]Gl | |||
, | |||
. | |||
, | |||
MOfU | |||
Tjnnessee Valley Authority | |||
LATTN: Mr. S. A. White | |||
Senior Vice President. | |||
Nuclear Power | |||
6N 38A Lookout Place | |||
1101 Market Street | |||
Chattanooga, TN 37402-2801 | |||
Gentlemen: | |||
SUBJECT: NRC INSPECTION REPORT N05. 50-327/87-56 AND 50-328/87-56 | |||
Thank you for your responsas of November 6,1987, and May 13, 1988, to our | |||
Notice of Violation, issued on October 12, 1987, concerning activities | |||
conducted at your Sequoyah facility. | |||
Af ter careful consideration of the bases of your denial of Violation B, we have | |||
determined, for the reasons presented in the enclosure to this letter, that the | |||
violation occurred as stated in the Notice of Violation. You should note that | |||
the NRC agrees with the goal of the change implemented, that of reducing | |||
radioactive materials in your effluents. However, we did note that the process | |||
followed in making the change did not include a review under 10 CFR 50.59, as | |||
was required, since the change resulted in an operation different from that | |||
described in the Final Safety Analysis Report (FSAR). Therefore, in accordance | |||
with 10 CFR 2.201(a), please submit to this office within 30 days of the date | |||
of this letter, a written statement describing steps which have been taken to | |||
correct the violation and the results achieved, corrective stcps which will be | |||
utilized to avoid further violations, ano the date when full compliance will be | |||
achieved. Additionally, you should consider taking action to revise | |||
Section 11.2 of your FSAR to eliminate any contradictory statements in this | |||
area. | |||
The responses directed by this are not subject to the clearance procedures of | |||
the Office of Management and Budget as required by the Paperwork Reduction Act | |||
of 1980, PL 96-511. | |||
We appreciate your cooperation in this matter. | |||
Sincerely, | |||
Steven D. Richardson, Director | |||
TVA Projects Division | |||
Office of Special Projects | |||
inclosure: (See page 2) | |||
0009140312 000031 | |||
PDR ADOCK 05000327 | |||
O PNU , | |||
a I | |||
_ _ _ _lL | |||
_ ____ ___'L | |||
' | |||
- | |||
Tennessee Valley Authority 2 | |||
Enclosure: | |||
Evaluations and Conclusions | |||
cc w/ encl: | |||
gl.LaPoint,ActingSiteDirector | |||
Sequoyah Nuclear Plant | |||
uP. A. Kirkebo, Vice President, | |||
Nuclear Engineering | |||
M L. Gridley, Director | |||
Nuclear Safety and Licensing | |||
t#. R. Harding, Site Licensing | |||
Manager | |||
LIVA Representative, Rockville Office | |||
bec w/ encl: | |||
J N. Grace, R!l | |||
4 G. Partlow, OSP | |||
t Black, OSP | |||
8. D. Liaw, OSP | |||
K. P. Barr, OSP/RIl | |||
W. S. Little, OSP/Rll | |||
F. R. McCoy, OSP/RII | |||
J. B. Brady, OSP/RIl | |||
(J. Rutberg, OGC | |||
1 | |||
NRC Resident Inspector | |||
DRS, Technical Assistant | |||
Document Control Desk | |||
State of Tennessee | |||
Ril Ril - Ril 4 R1 , Rll RI) R1 /hsli | |||
RW d i ton C DCo qs J S r fBrady FF y GJei ns L pI l f | |||
~}/ /88 8/ /6/88 7/ /t q 2; | |||
'f/)(/88 "}//88 7/9/88 /p/88 | |||
%* | |||
. | |||
y | |||
.. . 4 | |||
. ' | |||
, | |||
l | |||
* | |||
- | |||
. l | |||
i | |||
a | |||
ENCLOSURE | |||
Evaluations and Conclusions | |||
Restatement of Violation | |||
10 CFFs 50.59 states that the holder of a license authorizing operation of a | |||
f | |||
utilization facility may make changes in the facility as described in the | |||
. | |||
safety analysis report, without prior Commission approval, unless this proposed | |||
change involves a change in the Technical Specifications incorporated in the | |||
license or an unreviewed safety question. The licensee should maintain records | |||
of changes in the facility which shall include a written safety evaluation | |||
which provides the bases for the determination that the change does not involve | |||
an unreviewed safety question. | |||
Final Safety Analysis Report (FSAR), Chapter 11.2 states that the laundry and | |||
hot shower drain tank is normally sampled and discharged as an effluent, with | |||
the provision for processing the liquid through the condensate demineralizer | |||
waste evaporator (CDWE) if the sample result was above the discharge limit. | |||
Contrary to the above, in May 1967, the licensee failed to perform an adequate | |||
safety avaluation for a change in the laundry and hot shower waste water | |||
process which directed all the waste water to the CDWE causing an increase in | |||
the volume and concentration of contaminants into the COWE. | |||
Licensee Coment | |||
Although FSAR Sections 11.2.3.1 and 11.2.4 allow for direct release from the | |||
laundry and hot shower tanks if sample results are below acceptable limits, | |||
they do not preclude additional processing to further reduce radioactive liquid | |||
effluents to the environment nor does the FSAR limit the volume or | |||
concentration of contaminants placed in the COWE. Moreover, the language in | |||
thece paragraphs should be considered within the overall context of the FSAR | |||
Chapter 11.2, "Liquid Waste Systems." For example. FSAR Subsection 11.2.1, | |||
"Design Objectives," states in part "The Liquid Waste Processing System is | |||
designed to receive, segregate, process, recycle and discharge liquid wastes." | |||
The system design considers potential personnel exposure and assures that | |||
quantities of radioactivity released to the environment are as low as | |||
practicable. | |||
NRC Response | |||
FSAR Section 11.2 goes much further than merely allowing direct discharge from | |||
the laundry and hot shower tanks if sample results are below acceptable limits. | |||
FSAR Section 11.2.3.1 and 11.2.4 both state that the water is processed only if | |||
the activity concentration is too high for direct discharge. FSAR Section | |||
11.2.4 states that normally no treatment is required for removal of | |||
radioactivity. While not precluding additional processing, the FSAR clearly | |||
indicates that such processing only occurs if the activity concentration in the | |||
tanks is above discharge limits, otherwise it is directly discharged. | |||
.- | |||
, | |||
. . | |||
* | |||
, | |||
* | |||
- | |||
. | |||
Enclosure 2 | |||
Therefore, processing would only be infrequently required. In May 1987, the | |||
licensee changed the process so that all of the waste would be processed | |||
through the COWE prior to being sampled for release. This was a change from | |||
how the licensee had handled this waste up to that time and was a change from | |||
the FSAR description of the disposition of this waste. The NRC does not | |||
disagree with the goal of the change, to reduce concentrations of radioactive | |||
material in effluents. The process followed by the licensee in making the | |||
change did not include a review of the change under 10 CFR 50.59, as was | |||
required since the change resulted in operation different from that described | |||
in the FSAR. 10 CFR 50.59(a)(2)(ii) states that a proposed change, test, or | |||
experiment shall be deemed to involve an unreviewed safety question if a | |||
possibility for an accident or malfunction of a different type than any | |||
evaluated previously in the safety analysis report may be created. Since the | |||
licensee's change to processing the laundry waste streau continuously resulted | |||
in the overflow of waste solidification liners and subsequent exposure of | |||
personnel, a malfunction of a different type than any evaluated previously, | |||
then this change involved an unreviewed safety question and should have been | |||
evaluated by the licensee. FSAR Section 11.2.1 does state that the design of | |||
the liquid waste processing system considers potential personnel exposures. | |||
The effect of processing the laundry waste was inconsistent with this design | |||
objective in that when the licensee attempted to solioify the CDWE bottoms | |||
containing high concentrations of laundry detergents, the liner content | |||
overflowed due to chemical reaction with the solidification agent. The | |||
overflow then hardened and personnel had to chip away the excess material, | |||
which measured up to 3 R/ hour, so that the lid could be placed on the liner. | |||
The change to the routine method of processing the laundry waste should have | |||
received a review under 10 CFR 50.59, and if found appropriate, the change | |||
could then have been implemented. | |||
Licensee Cerment | |||
TVA feels that it was, and still is, our responsibility to keep levels of | |||
radioactive materials in effluents to unrestricted areas as low as reasonably | |||
achievable. The administrative change to process the laundry and hot shewer | |||
drain tanks through the COWE before sampling is not inconsistent with the FSAR | |||
provision of the laundry and hot shower drains as discussed abeve, and TVA does | |||
not agree that this decision constitutes a change to the facility or procedures | |||
as described in the FSAR. Thus, TVA believes a 10 CFR 50.59 safety evaluation | |||
is not required. | |||
NRC Response | |||
The NRC agrees that licensees should make efforts to reduce the activity in | |||
their effluents; however, applicable requirements have to be followed when | |||
changes are made. The licensee acknowledges that they made a change to their | |||
process. The licensee's statement that the change was not inconsistent with | |||
the FSAR is valid when considering the overall goal of reducing waste in | |||
effluents. Nevertheless, the FSAR clearly states that the waste stream is not | |||
normally processed, and the change caused all of the waste to be processed | |||
through the CDWE. This change was a significant change to a system described | |||
in the FSAR, and the adverse chenical reaction which occurred during waste | |||
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ ___ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ | |||
. ... | |||
.- | |||
* | |||
. | |||
, | |||
Enclosure 3 | |||
solidification resulted in unnecessary radiation dose to radwaste operators. | |||
This staff position is consistent with the guidance provided to the licensee in | |||
IE Circular No. 80-18: 10 CFR 50.59, Safety Evaluations for Changes to | |||
Radioactive Waste Treatment Systems which states that for any change in a | |||
facility radioactive waste systern as described in the FSAR, a safety evaluation | |||
is required in accordance with 10 CFR 50.59. | |||
HRC Conclusion | |||
For the above reasons, the NRC staff concludes that the violation occurred as | |||
stated. | |||
}} |
Latest revision as of 02:46, 15 November 2020
ML20154C302 | |
Person / Time | |
---|---|
Site: | Sequoyah ![]() |
Issue date: | 08/31/1988 |
From: | Richardson S NRC OFFICE OF SPECIAL PROJECTS |
To: | White S TENNESSEE VALLEY AUTHORITY |
References | |
NUDOCS 8809140312 | |
Download: ML20154C302 (5) | |
See also: IR 05000327/1987056
Text
,
0fhC]Gl
,
.
,
MOfU
Tjnnessee Valley Authority
LATTN: Mr. S. A. White
Senior Vice President.
Nuclear Power
6N 38A Lookout Place
1101 Market Street
Chattanooga, TN 37402-2801
Gentlemen:
SUBJECT: NRC INSPECTION REPORT N05. 50-327/87-56 AND 50-328/87-56
Thank you for your responsas of November 6,1987, and May 13, 1988, to our
Notice of Violation, issued on October 12, 1987, concerning activities
conducted at your Sequoyah facility.
Af ter careful consideration of the bases of your denial of Violation B, we have
determined, for the reasons presented in the enclosure to this letter, that the
violation occurred as stated in the Notice of Violation. You should note that
the NRC agrees with the goal of the change implemented, that of reducing
radioactive materials in your effluents. However, we did note that the process
followed in making the change did not include a review under 10 CFR 50.59, as
was required, since the change resulted in an operation different from that
described in the Final Safety Analysis Report (FSAR). Therefore, in accordance
with 10 CFR 2.201(a), please submit to this office within 30 days of the date
of this letter, a written statement describing steps which have been taken to
correct the violation and the results achieved, corrective stcps which will be
utilized to avoid further violations, ano the date when full compliance will be
achieved. Additionally, you should consider taking action to revise
Section 11.2 of your FSAR to eliminate any contradictory statements in this
area.
The responses directed by this are not subject to the clearance procedures of
the Office of Management and Budget as required by the Paperwork Reduction Act
of 1980, PL 96-511.
We appreciate your cooperation in this matter.
Sincerely,
Steven D. Richardson, Director
TVA Projects Division
Office of Special Projects
inclosure: (See page 2)
0009140312 000031
PDR ADOCK 05000327
O PNU ,
a I
_ _ _ _lL
_ ____ ___'L
'
-
Tennessee Valley Authority 2
Enclosure:
Evaluations and Conclusions
cc w/ encl:
gl.LaPoint,ActingSiteDirector
Sequoyah Nuclear Plant
uP. A. Kirkebo, Vice President,
Nuclear Engineering
M L. Gridley, Director
Nuclear Safety and Licensing
t#. R. Harding, Site Licensing
Manager
LIVA Representative, Rockville Office
bec w/ encl:
J N. Grace, R!l
4 G. Partlow, OSP
t Black, OSP
8. D. Liaw, OSP
K. P. Barr, OSP/RIl
W. S. Little, OSP/Rll
F. R. McCoy, OSP/RII
J. B. Brady, OSP/RIl
(J. Rutberg, OGC
1
NRC Resident Inspector
DRS, Technical Assistant
Document Control Desk
State of Tennessee
Ril Ril - Ril 4 R1 , Rll RI) R1 /hsli
RW d i ton C DCo qs J S r fBrady FF y GJei ns L pI l f
~}/ /88 8/ /6/88 7/ /t q 2;
'f/)(/88 "}//88 7/9/88 /p/88
%*
.
y
.. . 4
. '
,
l
-
. l
i
a
ENCLOSURE
Evaluations and Conclusions
Restatement of Violation
10 CFFs 50.59 states that the holder of a license authorizing operation of a
f
utilization facility may make changes in the facility as described in the
.
safety analysis report, without prior Commission approval, unless this proposed
change involves a change in the Technical Specifications incorporated in the
license or an unreviewed safety question. The licensee should maintain records
of changes in the facility which shall include a written safety evaluation
which provides the bases for the determination that the change does not involve
an unreviewed safety question.
Final Safety Analysis Report (FSAR), Chapter 11.2 states that the laundry and
hot shower drain tank is normally sampled and discharged as an effluent, with
the provision for processing the liquid through the condensate demineralizer
waste evaporator (CDWE) if the sample result was above the discharge limit.
Contrary to the above, in May 1967, the licensee failed to perform an adequate
safety avaluation for a change in the laundry and hot shower waste water
process which directed all the waste water to the CDWE causing an increase in
the volume and concentration of contaminants into the COWE.
Licensee Coment
Although FSAR Sections 11.2.3.1 and 11.2.4 allow for direct release from the
laundry and hot shower tanks if sample results are below acceptable limits,
they do not preclude additional processing to further reduce radioactive liquid
effluents to the environment nor does the FSAR limit the volume or
concentration of contaminants placed in the COWE. Moreover, the language in
thece paragraphs should be considered within the overall context of the FSAR
Chapter 11.2, "Liquid Waste Systems." For example. FSAR Subsection 11.2.1,
"Design Objectives," states in part "The Liquid Waste Processing System is
designed to receive, segregate, process, recycle and discharge liquid wastes."
The system design considers potential personnel exposure and assures that
quantities of radioactivity released to the environment are as low as
practicable.
NRC Response
FSAR Section 11.2 goes much further than merely allowing direct discharge from
the laundry and hot shower tanks if sample results are below acceptable limits.
FSAR Section 11.2.3.1 and 11.2.4 both state that the water is processed only if
the activity concentration is too high for direct discharge. FSAR Section
11.2.4 states that normally no treatment is required for removal of
radioactivity. While not precluding additional processing, the FSAR clearly
indicates that such processing only occurs if the activity concentration in the
tanks is above discharge limits, otherwise it is directly discharged.
.-
,
. .
,
-
.
Enclosure 2
Therefore, processing would only be infrequently required. In May 1987, the
licensee changed the process so that all of the waste would be processed
through the COWE prior to being sampled for release. This was a change from
how the licensee had handled this waste up to that time and was a change from
the FSAR description of the disposition of this waste. The NRC does not
disagree with the goal of the change, to reduce concentrations of radioactive
material in effluents. The process followed by the licensee in making the
change did not include a review of the change under 10 CFR 50.59, as was
required since the change resulted in operation different from that described
in the FSAR. 10 CFR 50.59(a)(2)(ii) states that a proposed change, test, or
experiment shall be deemed to involve an unreviewed safety question if a
possibility for an accident or malfunction of a different type than any
evaluated previously in the safety analysis report may be created. Since the
licensee's change to processing the laundry waste streau continuously resulted
in the overflow of waste solidification liners and subsequent exposure of
personnel, a malfunction of a different type than any evaluated previously,
then this change involved an unreviewed safety question and should have been
evaluated by the licensee. FSAR Section 11.2.1 does state that the design of
the liquid waste processing system considers potential personnel exposures.
The effect of processing the laundry waste was inconsistent with this design
objective in that when the licensee attempted to solioify the CDWE bottoms
containing high concentrations of laundry detergents, the liner content
overflowed due to chemical reaction with the solidification agent. The
overflow then hardened and personnel had to chip away the excess material,
which measured up to 3 R/ hour, so that the lid could be placed on the liner.
The change to the routine method of processing the laundry waste should have
received a review under 10 CFR 50.59, and if found appropriate, the change
could then have been implemented.
Licensee Cerment
TVA feels that it was, and still is, our responsibility to keep levels of
radioactive materials in effluents to unrestricted areas as low as reasonably
achievable. The administrative change to process the laundry and hot shewer
drain tanks through the COWE before sampling is not inconsistent with the FSAR
provision of the laundry and hot shower drains as discussed abeve, and TVA does
not agree that this decision constitutes a change to the facility or procedures
as described in the FSAR. Thus, TVA believes a 10 CFR 50.59 safety evaluation
is not required.
NRC Response
The NRC agrees that licensees should make efforts to reduce the activity in
their effluents; however, applicable requirements have to be followed when
changes are made. The licensee acknowledges that they made a change to their
process. The licensee's statement that the change was not inconsistent with
the FSAR is valid when considering the overall goal of reducing waste in
effluents. Nevertheless, the FSAR clearly states that the waste stream is not
normally processed, and the change caused all of the waste to be processed
through the CDWE. This change was a significant change to a system described
in the FSAR, and the adverse chenical reaction which occurred during waste
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ ___ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _
. ...
.-
.
,
Enclosure 3
solidification resulted in unnecessary radiation dose to radwaste operators.
This staff position is consistent with the guidance provided to the licensee in
IE Circular No. 80-18: 10 CFR 50.59, Safety Evaluations for Changes to
Radioactive Waste Treatment Systems which states that for any change in a
facility radioactive waste systern as described in the FSAR, a safety evaluation
is required in accordance with 10 CFR 50.59.
HRC Conclusion
For the above reasons, the NRC staff concludes that the violation occurred as
stated.