ML19290G634

Responds to NRC 801020 Ltr Re Violations Noted in IE Insp Repts 50-553/80-13 & 50-554/80-13.Corrective Actions:Site Holding Pond Discharge Records Placed in Standardized Format & Spill Prevent Control & Counter Measure Procedure Revised

ML19290G634
Person / Time
Site:	Phipps Bend
Issue date:	11/12/1980
From:	Mills L TENNESSEE VALLEY AUTHORITY
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML19290G633	List: ML19290G634
References
NUDOCS 8012180175
Download: ML19290G634 (3)

Text

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O .; : ' C : :. .. l 400 Chestnut Street Tower II November 12, 1980

                                                                                 ' 'l * &;b } j Mr. James P. O'Reilly, Director.

Office of Inspection and Environment U.S. Nuclear Regulatory Commission Region II - Suite 3100 101 Marietta Street Atlanta, Georgia 30305

Dear Mr. O'Reilly:

Enclosed is our response to J. P. Stohr's October 20, 1980, letter RII:ALC 50-553/80-13 and 50-554/80-13, regarding activities at the Phipps Bend Nuclear Plant which appeared to have been in violation of NRC regulations. We have revi med the subject inspection report and find no proprietary information in the report. If you have any questions regarding this matter, please call Ralph Shell at FTS 857-3331. - Very truly yours, TENNESSEE VALLEY AUTHORITY

                                                                  ')h , MM L. M. Mills, Manager Nuclear Regulation and Safety Enclosure a
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ENCLOSURE RESPONSE TO NRC-0IE LETTER FROM J. PHILIP STOHR TO H. G. PARRIS DATED OCTOBER 20, 1980

REFERENCE:

RII:ALC 50-553/80-13, 50-554/80-13 This report responds to the Notice of Violation described in Appendix A of the OIE inspection report referenced above. This is the final report on the subject noncompliances. Noncomoliance Item - Deficiency 50-533/80-13-01, 50-554/80-13-01 A. As required, in part, by Section 3F3 of the Construction Permits, sufficient records to furnish evidence of compliance with all environmental conditions defined in the permits should be maintained. Contrary to the above, the licensee failed to consistently record and maintain records of the site holding pond discharges to the Holston River during the period May 3, 1979, through August 15, 1980. , This is a deficiency.

Response

1. Corrective Steps Taken and Results Achieved At the. time of the inspection, these records did exist but were being maintained in a disorganized manner. These records have since been placed in a standardized format and filed by date of discharge. They are now easily understandable and retrievable.

2. Corrective Steps Which Will Be Taken to Avoid Further Noncompliance

~ Holding pond discharges have been placed under the direct control of the site Environmental Engineer by lock and key on the chain securing the discharge structure valves. A key will also be maintained by the Construction Engineer. No discharge will be made unless the Environmental Engineer or other delegate of the Construction Engineer (in the absence of the Environmental Engineer) is there to record the event. Records of each discharge will be maintained as described above. 3 Date When Full Co=pliance Was Achieved Full cumpliance was achieved on or by October 31, 1980.

i Noncompliance Item - Deficiency 50-553/80-13-02, 50-554/80-13-02 B. As required by dection 3F3 of the Construction Permits, the licensee shall establish a control program which, in part, shall include written procedures which provide fer implementation of all environmental conditiors. Contrary to the above, the licensee failed to establish, in Field Environment 9rocedure-3 (FEP-3), a procedure which provides the required conditions for assuring implementation of effective control and containment of oil or other hazardous material spills. This is a deficiency.

Response

1. Corrective Steps Taken and Results Achieved Our Spill Prevent Control and Counter Measure Procedure has been revised and is currently in the approval stages. The new revision reflects the required conditions for ensuring implementution of effective control and containment of all hazardous material ,

spills.

2. Corrective Steps Which Will Be Taken to Avoid Further Nonco=plaince The Spill Prevention Control and Counter Measure Procedure will be reviewed on a yearly basis for completeness and accuracy.

3 Date When Full Compliance Will Be Achieved Full compliance will be achieved on or before December 6, 1980. = mh m*}}