ML20062J924

Responds to NRC Re Violations Noted in IE Insp Repts 50-259/82-15,50-260/82-15 & 50-296/82-15.Corrective Actions:Daily Monitoring & Drainage Program Will Be Continued.Violations Re Items a & B Denied

ML20062J924
Person / Time
Site:	Browns Ferry
Issue date:	07/20/1982
From:	Mills L TENNESSEE VALLEY AUTHORITY
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20062J893	List: IR 05000259/1982015 ML20062J890 ML20062J924 ML20062J981 ML20062K000
References
NUDOCS 8208160502
Download: ML20062J924 (7)

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TENNESSEE VALLEY AUTHORITY

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CHATTANOOGA, TENNESSEE 374ot

' I'I' 'kOb Chestnut Street Tower II 32 JUL 26 P12 30 July 20, 1982 U.S. Nuclear Regulatory Commission Region II ATTN: James P. O'Reilly, Regional Administrator 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303

Dear Mr. O'Reilly:

Enclosed is our response to R. C. Lewis' June 3, 1982 letter to H. G. Parris transmitting Inspection Report Nos. 50-259/82-15,

-260/82-15, -296/82-15 regarding activities at our Browns Ferry Nuclear Plant which appeared to have been in violation of NRC regulations. We have enclosed our response to Appendix A, Notice of Violation. If you have any questions, please call Jim DomeP 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 L. M. Mills,' Manager Nuclear Licensing Enclosure D K offyyO4 An Equal Opportunity Employer

RESPONSE - NRC INSPECTION REPORT NOS.

50-259/82-15, 50-260/82-15, AND 50-296/82-15 R. C. LEWIS' LETTER TO H. G. PARRIS DATED JUNE 3, 1982 Appendix A Item A - (259, 260, 296/82-15-04) 10 CFR 50.59 requires that the licensee maintain records of changes in the facility and that records shall include a written safety evaluation which provide the bases for the determination that the change does not involve an unreviewed safety question.

Contrary to the above, the requirement that a written safety evaluation be 1 made was not met in that the off-gas post-treatment sampling station configuration was modified by the addition of a temporarily installed sample pump without a safety evaluation being performed. The off-gas sampling station is described in figure 7.12-2a of the Final Safety Analysis Report.

This is a Severity Level IV Violation (Supplement I.D 1) and pertains to all three units.

1. Admission or Denial of the Alleged Violation TVA denies the violation.

2. Basis for Denial of the Violation Two offgas sample stations are provided for each unit at Browns Ferry.

FSAR Figure 7.12-2A depicts the offgas sample stations (panel 25-40) for sampling at the discharge of the ateam jet air ejectors (SJAE).

The sample stations (panel 25-259) for sampling after the charcoal absorbers (post-treatment sampling station) are not shown in the FSAR figure. They are referenced only as being similar to panel 25-40.

Panel 25-40, as designed and installed, had both a vacuum pump and a sample pump. Panel 25-259 was originally installed with only the vacuum pump. The vacuum pump evacuates the sample bottles before sampling. The sample pump ensures gas flow to the panel. At panel 25-40 the sample pump is rarely required since sample flow is normally provided by the differential pressure across the SJAE. There is no corresponding differential pressure arrangement available for panel 25-259. Therefore, in order for the sample station to provide representative samples, a sample pump had to be added. Because the sample pump for panel 25-259 was not provided during initial installation it had to be added external to the panel.

A millipore-type sample pump was utilized because it was available and identical pumps were used elsewhere onsite ensuring an adequate supply of spare parts. The pump installation was accomplished by plant chemical engineers and maintenance personnel. The millipore pump has never been fastened to the floor but instead has either been mounted on a board or rested on rubber feet to minimize vibration. This technique of utilizing a millipore-type sample pump to obtain grab faamples is a commonly accepted practice for many other stiples routinely taken.

'a.s practice and the fact that the sample pump for panel 25-40 is physically located remotely from the panel and is shown on FSAR figure 7.12-2a as separate from the panel support the continued use of this pump arrangement. No safety analysis was considered necessary because a sample pump was included in the FSAR figure for panel 25-40. Because panel 25-259 is included in the FSAR only by reference, the exact configuration for installation was not specified. Therefore, the installation of the sample pump is consistent with the guidance presented in the FSAR, and we believe that a written safety evaluation was not necessary in this case.

The sample leak referenced in the inspection report was investigated.

Instead of loose sample line fittings as originally suspected, the leak was caused by an open needle valve on the pump. The valve was adjusted and no leaks have been detected since.

Item B - (260/82-15-06)

Technical Specification 4.8.B.1.a requires that for effluent streams having continuous monitoring capability, the activity and flow rate shall be monitored and recorded to enable release rates of gross radioactivity to be determined on an hourly basis.

Contrary to the above, the requirement that effluent streams having continuous monitoring capability have the activity monitored on an hourly basis was not met in that the inspectors determined that the sampling line for the turbine building exhaust ventilation going to Continuous Air Monitor (CAM) had accumulated water (approximately two cups) obstructing the sample flow. The sample line had been blocked by water accumulation for an undetermined amount of time. The licensee had previously identified that this line has a tendency to accumulate water and had replaced the sample pipe with clear plastic hose to aid in determining water accumulation; however, no specified frequency was established to determine

! moisture buildup.

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This is a Severity Level V Violation (Supplement IV.E.) and is applicable to Unit 2.

1. Admission or Denial of the Alleged Violation TVA admits the violation occurred as stated.

2. Reasons for the Violation if Admitted A temporary support loosened, allowing a low point to form in a plastic sample line. Moisture in the sample line condensed and collected in this low point, eventually blocking sample flow.

3 Corrective Steps Which Have Been Taken and the Results Achieved The condensate was removed and the sample line resupported. The accumulated condensate was counted on a GeLi Counting System. No appreciable activity was found. In addition, a program which daily monitors and removes any accumulated condensate as necessary has been implemented. This inspection is performed in conjunction with the daily background and source checks of all CAMS.

4. Corrective Steps Which Will Be Taken to Avoid Further Violations The daily monitoring and drainage program will be continued as long as necessary.

5 Date When Full Compliance Will be Achieved Full compliance was achieved on May 10, 1982 when the daily monitoring program was implemented.

Item C - (259,260,296/82-15-03, 259,260,296/82-15-02, 260/82-15-05)

Technical Specification 6.3 requires that detailed written procedures shall be adhered to, reviewed by the Plant Operating Review Committee (PORC) and approved by the Plant Superintendent.

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Contrary to the above, the requirement that procedures be adhered to, reviewed by PORC and approved by the Plant Superintendent was not met in that:

1. The procedure used to perform the weekly off-gas post treatment analysis,. required by Technical Specification (TS) 4.8.B.3, Radiochemical Laboratory Manual (RLM) procedure 709B, was not of the current revision.

2. The procedure used to perform the weekly sensor check of waste gas monitors, required by TS 4.8.b 4, RLM procedure 741, was not reviewed by PORC or approved by the Plant Superintendent.

3 The procedure being used for inspection of new fuel, General Operating Instruction (GOI) 100-2, was not of the current revision, in that the data sheet being used to sign off inspection points had been superseded by a later revision.

This is a Severity Level V Violation (Supplement I.E.) and is applicable to all three units.

C-1

1. Admission or Denial of the Alleged Violation TVA admits the violation occurred as stated.

2. Reasons for the Violation if Admitted When procedure revisions are made to the Radiochemical Laboratory Manual (RLM), no one person was designated to verify that the appropriate revision was placed at the various sample locations.

3 Corrective Steps Which Have Been Taken and the Pesults Achieved After the identification of improper dates, an updated revision of the procedures was obtained and used to take the offgas samples.

4. Corrective Steps Which Will Be Taken to Avoid Further Violations A laboratory analyst has been assigned on a rotating basis to handle procedure revis'.ons. One of the assigned duties will be to update all instructions placed at remote locations.

5. Date When Full Compliance Will Be Achieved All corrective actions were completed on June 1, 1982.

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C-2

1. Admission or Denial of the Alleged Violation TVA admits the violation occurred as stated.

2. Reasons for the Violation if Admitted All RLM procedures referenced by surveillance instructions (SI) used to comply with technical specification requirements had previously been incorporated into Technical Instruction (TI) 38 and reviewed by PORC.

RLM 741 was not uniquely referenced in an SI, hence it was not included in TI-38 and reviewed by PORC.

3 Corrective Steps Which Have Been Taken and the Results Achieved SI-2 was revised to reference RLM 741. RLM 741 was then incorporated into TI-38 and reviewed by PORC.

4. Corrective Steps Which Will Be Taken to Avoid Further Violations None required.

5. Date When Full Compliance Will Be Achieved TI-38 changes were PORC-reviewed on May 25, 1982.

C-3

1. Admission or Denial of the Alleged Violation TVA admits the violation occurred as stated.

2. Reasons for the Violation if Admitted The operator in charge used the data sheet that was on hand and failed to check the official procedure to verify that he had the latest revision.

3 Corrective Steps Which Have Been Taken and the Results Achieved Working copies of GOIs 100-2 and 100-3 have been placed on the refuel floor and all revisions are to be placed in these working copies. The event has also been discussed with the operator involved.

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4. Corrective Steps Which Will Be Taken to Avoid Further Violations GOIs 100-2 and 100-3 for the refuel floor have been placed on the document control unit's transmittal distribution list for procedure changes for working copies. The latest revisions will be placed in the working copies by the assigned clerk. The transmittal form used for these changes requires a signoff that the rerised copies have been installed in the appropriate working copy file.

5. Date When Full Compliance Will Be Achieved Full compliance was achieved on June 17, 1982, when working copies of GOIs 100-2 and 100-3 were placed on the refuel floor. These GOIs were added to document control unit's distribution list for working copies on June 15, 1982.

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