ML18031B040

Forwards Response to NRC 861022 Ltr Re Violations Noted in Insp Repts 50-259/86-29,50-260/86-29 & 50-296/86-29. Corrective Actions:Radwaste Section Supervisor Temporarily Relieved from Duties & Placed in 4-month Training Program

ML18031B040
Person / Time
Site:	Browns Ferry
Issue date:	11/21/1986
From:	Domer J TENNESSEE VALLEY AUTHORITY
To:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
NUDOCS 8612030714
Download: ML18031B040 (6)

See also: IR 05000259/1986029

Text

TENNESSEE VALLEY AUTHORITY CHATTANOOGA.

TENNESSEE 37401 5N 157B Lookout Place NOV 21 686 U.S.Nuclear Regulatory

Commission

Region II Attn: Dr.J.Nelson Grace, Regional Administrator

101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Dear Dr.Grace: BROWNS FERRY NUCLEAR PLANT UNITS 3-NRC-OIE REGION II INSPECTION

REPORT 50-259/86-29, 50-260/86-29, 50-296/86-29

-RESPONSE TO VIOLATION Enclosed is our response to Dr.Grace's October 22, 1986 letter to S.A.White transmitting

IE Inspection

Report Nos.50-259/86-29, 50-260/86-29, and 50-296/86-29

for our Browns Ferry Nuclear Plant which cited TVA with one Severity Level IV Violati.on.

If you have any questions, please get in touch with M.J.May at (205)729-3566.To the best of my knowledge, I declare the statements

contained herein are complete and true.Very truly yours, TENNESSEE VALLEY AUTHORITY A.Domer, Assistant Director Nuclear Safety and Licensing Enclosure cc (Enclosure):

Mr.James Taylor, Director Office of Inspection

and Enforcement

U.S, Nuclear Regulatory

Commission

Washington, D.C.20555 Mr.G.G.Zech, Director U.S.Nuclear Regulatory

Commission

Region II 101 Marietta Street, NW Atlanta, Georgi,a 30323 8612080714

861121 PDR ADOCK 05000259 8 PDR An Equal Opportunity

Employer l)h

RESPONSE NRC INSPECTION

REPORT NOS.50-259/86-29, 50-260/86-29, AND 50-296/86-29

DR.J.NELSON GRACE'S LETTER TO S.A.WHITE DATED OCTOBER 22, 1986 Item 1 During the Nuclear Regulatory

Commission (NRC)inspection

conducted on September 8-12, 1986, a violation of NRC requirements

was identified.

The violation involved two examples of noncompliance

with transportation

regulations:

failure to require an authorized

person to sign a radioactive

material shipping manifest and failure to perform internal contamination

surveys of a shipping container classified

as Department

of Transportation (DOT)"empty." In accordance

with the"General Statement of Policy and Procedure for NRC Enforcement

Actions," 10 CFR Part 2, Appendix C (1986), the violation is listed below: 10 CFR 71.5(a)requires that each licensee, who transports

licensed material outside the confines of its plant, or other place of use, shall comply with the applicable

requirements

of the Department

of Transportation (DOT)regulations

in 49 CFR Parts 170 through 189.49 CFR 172.204(a)

requires each licensee to certify that the material to be transported

is properly classified, described, packaged, marked, labeled and in proper condition for transportation

according to the applicable

regulations

of the DOT.49 CFR 172.204(d)

requires that the certification

be legibly signed by a principal, officer, partner or employee of the shipper.49 CFR 173.427(c)

states that a package, which previously

contained radioactive

material and has been emptied, is excepted from certain requirements

provided that the internal contamination

of the package does not exceed 100 times, the limits in 49 CFR-173.443(a).

r.r Contrary to the above, the licensee failed to comply with the applicable

requirements

of the DOT for offsite radioactive

material shipments in that: l.On August 20, 1986, an individual

other than an authorized

employee of the shipper signed the shipping manifest certification

statement for Shipment Number S56-9570.2.On August 20, 1986, the licensee failed to perform contamination

surveys on the inside surfaces of an empty wooden box within Shipment Number S56-9570 to demonstrate

that the internal contamination

levels met, the limits for an empty container.

This is a Severity Level IV violation (Supplement

V).

~~~1.Admission or Denial of the Alle ed Violation TVA admits the violation.

2.Reasons for the Violation TVA policies governing the shipment of radioactive

waste are contained in a document entitled,"Radioactive

Material Shipment Manual (RMSM)." The RMSM incorrectly

stated that sites could allow vendors to ship their contaminated

equipment offsite.We, therefore, did not verify that London Nuclear was licensed to ship radioactive

material.As a consequence, we permitted a London Nuclear representative

to sign as shipper on the August 20, 1986 shipment.London Nuclear's contaminated

equipment was not received onsite by the Radwaste Section personnel.

Later, when the equipment was being prepared for offsite shipment, it was believed the box had been delivered empty and had not been opened.Browns Ferry Nuclear Plant (BFN)radioactive

material shipment checklists

in TI-77, Radwaste Packaging and Shippingdid not contain specific requirements

for internal surveys of empty containers.

Therefore, the proper surveys required for an empty package were not performed.

3.Corrective

Ste s Which Have Been Taken and Results Achieved The RMSM has been revised to state'Chat

verification

of the vendor's license must, take place before the vendor will be allowed to sign as the shipper.If the vendor does not have a license to possess radioactive

material at BFN, we will act as the shipper.Radwaste Controller

personnel have been made aware of this revision.The radioactive

waste and radioactive

material checkoff sheets in TI-77 were revised to include checkoffs for Radcon personnel to verify that proper surveys are done for radioactive

empty packages.A checkoff was included in the Radwaste Controller

Section to verify that the surveys are completed and that the proper empty package certification

is forwarded with the package.Personnel have been trained in the use of the revised checkoff sheets.4.Corrective

Ste s Which Will Be Taken to Avoid Further Violations

Corrective

actions have been taken to avoid similar violations

as stated in item 3 above.5.Date When Full Co liance Will Be Achieved Full compliance

has been achieved.

Further Actions to I rove the Pro ram: Your October 22, 1986 letter addressed concerns about the violations, experienced

in the transportation

of radioactive

materials.

The letter requested that we describe actions taken to prevent further violations

in this area.We reviewed the past violations

and are taking the following actions to strengthen

the radioactive

material transportation

program.Our initial action for this concern has been to temporarily

relieve the Radwaste Section Supervisor

of his duties and place him in a four-month

training program.In order to strengthen

his training and broaden his experience, he will devote this four-month

period to attending applicable

industry training courses, visiting other utilities, and learning the various , phases of the in-plant program through Mirect observation

of packaging, loading, and shipping activities.

While the Radwaste Section Supervisor

is in training, we have placed another individual

in.the Radwaste Section Supervisor

position.This individual

is familiar with radioactive

material transportation

programs at other utilities, burial site criteria, and has a regulatory

background

in DOT requirements

contained in 49 CFR.While in this position, this individual

will review the present program for needed improvements.

An additional

individual

will also be assigned to the Radwaste Section for approximately

four months, he has extensive experience

in the transportation

of radioactive

materials, and he will participate

in this program review.This program review will cover procedures, organizational

structure, job functions, staffing, and training and experience

requirements

for various positions in the section.It should be complete by February 6, 1987 and corrective

actions will be taken as warranted by the findings of program review.