ML18031B040
| 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.