ML20154C302

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

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

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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)

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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

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NRC Resident Inspector

DRS, Technical Assistant

Document Control Desk

State of Tennessee

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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

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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.

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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

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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.