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) | |
Text
TENNESSEE VALLEYAUTHORITY 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 Shipping did 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.