ML18031A902
| ML18031A902 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry, 03015165 |
| Issue date: | 10/16/1986 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8610270103 | |
| Download: ML18031A902 (19) | |
See also: IR 05000259/1986026
Text
II TENNESSEE VALLEY AUTHORITY CHATTANOOGA.
TENNESSEE 37401;Qt','f pp P l~R7 5N 157B Lookout Place IIIT 7 6 S86 U.S.Nuclear Regulatory
Commission
Region II Attn: Dr.J.Nelson Grace, Regional Administrator
101 Marietta Street, NN, Suite 2900 Atlanta, Georgia 30323 Dear, Dr.Grace: BRONNS FERRY NUCLEAR PLANT UNITS 1, 2, ND 3-N-E REGION II INSPECTION
REPORT NOS.50-259/86-26, 50-260/86-2f,-96 86-2 , AND 41-08165-09/86-01
RESPONSE TO VIOLATION o-Enclosed is our response to G.G.Zech's September 16, 1986 letter to S.A.Nhite transmitting
IE Inspection
Report Nos.50-259/86-26, 50-260/86-26, 50-296/86-26, and 41-08165-09/86-01
for our Browns Ferry Nuclear Plant which cited TVA with'ive Severity Level IV Violations.
If you have any questions, please get in touch with M.J.May at t (205)729-3566.To the best of my knowledge, I declare the statements
contained herein are complete and true.Very truly yours, TENNESSEE VA LEY AUTHORITY R.Gridley, D rector Nuclear Safety and Licensing Enclosure cc (Enclosure):
Mr.James Taylor, Director Office of Inspection
and Enforcement
U.S.Nuclear Regulatory
Commission
Hashington, D.C.20555 Mr.G.G.Zech Director, TVA Projects U.S.Nuclear Regulatory
Commission
Region II 101 Marietta Street, NH, Suite 2900 Atlanta, Georgia 30323 8610270103
861016 PDR ADOCK 05000259 PDR An Equal Opportunity
Employer~P 0/
RESPONSE NRC INSPECTION
REPORT NOS.50-259/86-26, 50-260/86-26, AND 50-296/86-26
G.G.ZECH'S LETTER TO S.A.NHITE DATED SEPTEMBER 16, 1986 Violation A 10 CFR 20.311(d)(1)
requires that any generating
licensee who transfers radioactive
waste to a land disposal facility shall prepare all wastes so that the waste meets the waste characteristic
requirements
of 10 CFR 61.56.10 CFR 61.56(a)(3)
requires that solid waste containing
liquid shall contain as little free standing and noncorrosive
liquid as is reasonably
achievable, but in no case shall the liquid exceed one percent of the volume.Contrary to the above, on April 2, 1986, the licensee failed to prepare radioactive
waste Shipment Number 0386-048-S
so that it met the free standing liquid limit, in that the dewatered resins in a high integrity container was found upon its arrival of the Chem-Nuclear
Systems,'nc.
operated disposal site near Barnwell, South Carolina, to contain 21 gallons of free standing liquid, which was in excess of the one percent volume limit of 12.7 gallons.This is a Severity Level IV violation (Supplement
V).1.Admission or Denial of the Alle ed Violation Browns Ferry Nuclear Plant<BFN)admits the violation with one correction.
Barnwell's
license allows them to receive up to 12.25 gallons of free liquid (water)in a Chem-Nuclear
System, Inc.(CNSI), Model 195, high integrity container (HIC)with an internal capacity of 164 cubic feet.2.Reasons for the Violation The root cause or this violation is that the dewatering
time (two hour')specified in Operating Instruction
<OI)77 is too short to account for all the variability
that exists in the process of dewatering
spent resin.This dewatering
time was established
in Special Test 8318 by testing one CNSI 195 HIC.On return to BFN, the ,<IC in'violation
'was filled with water and dewatered in accordance
with OI-77.A large quantity of resin was observed in dewatering
lines while dewatering
was taking place, indicating
bypass leakage through the internal filters and/or a defect in the internal plumbing.Preferential
channelling
of water to one location in the HIC was also observed from the top of the container.
The HIC was dewatered again after 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, and six gallons of free liquid were recovered in 15 minutes.Dewatering
was continued and an additional
5.5 gallons of free liquid were recovered.
Nhen dewatering
was terminated
after two hours, water was still being collected from the, HIC.
0 0
The HIC was desludged and inspected by filling with water and sparging air back through the filters.Leaks were found in the joints between filter holders and pipes on al.l levels.Also, a bad joint was found in the piping leading to level 2 of the filters.It is apparent that during the bulk dewatering
process, water is not uniformly removed from the resin cake.Water is selectively
removed from the regions nearest the filters until air voids are formed which cause a sharp drop in vacuum efficiency, effectively
terminating
the dewatering
process.This is enhanced by the presence of leaking filters or broken vacuum piping.In time, water will percolate from the remaining super saturated zones to the depleted zones.When this occurs, water can again be collected through these filters.The HIC vendor recognized
this problem with bulk dewatering
much earlier.CNSI's procedure calls for three eight-hour
dewatering.times separated by two 16-hour reset periods where water is allowed to percolate into the depleted zones'orrective
Ste s Which Have Been Taken and Results Achieved BFN has adopted the CNSI procedure for dewatering
HICs (three eight-hour
dewatering
periods separated by two 16-hour rest periods).This includes installation
of two new dewatering
stations that are capable of meeting all the criteria in the CNSI procedure.
BFN also provides two additi'onal
hours of final dewatering
of each HIC, using a larger capacity vacuum system to further ensure that sufficient
dewatering
occurs.To date, four HICs tested have.successfully
passed an in-house, seven-day dewatering
test, and all HICs tested at the burial site in Barnwell, South Carolina, have successfully
passed the puncture/drainage
test.BFN has developed and implemented
a periodic testing and preventive
maintenance
program to ensure satisfactory
performance
of all dewatering
equipment.
BFN's plant instructions
have been revised to include a visual inspection
of the internals of each HIC immediately
before use to verify that there are no missing or broken components
that could iead to inadequate
dewatering
of the resin.Corrective
Ste s Which Will Be Taken to Avoid Further Violations
All corrective
steps have been implemented.
Date When Full Com li nce Will Be Achieved BFN is in full compliance.
Violation B 10 CFR 71.5(a)requires that each licensee who transports
licensed material outside of the confines of its plant or other place of use, shall comply with the applicable
requirements
of the regulations
appropriate
to the mode of transport of DOT in 49 CFR Parts 170 through 189.49 CFR 172.203(d)(l)
requires that the description
of radioactive
materials on a shipping paper must include the name of each radionuclide
in the radioactive
material and the activity in each package of the shipment.Contrary to the above, on June 13, 1984, the licensee failed to properly describe the radioactive
material on the shipping paper for a calibration
block sent to the licensee's
Power Operations
Training Center (POTC)under shipment number 2618 in that the activity and identification
of the nuclides listed on the shipping paper were not accurate.This is a Severity Level IV violation.(Supplement
V).l.Admission or Denial of the Alle ed Violation TVA admits the violation as stated.2.Reasons for the Violation An error was made in the calculations
used to determine the activity of the calibration
block.The activity was estimated by use of a computer program designed for determining
the activity of large radwaste boxes...This resulted in an over conservative
estimate of the activity associated
with the calibration
block, The computer program also automatically
entered scaling factor data for hard to measure isotopes which were not known to be presents Personnel who utilized the computer program were not aware of the need nor had the ability to change the program to obtain a more accurate list of nuclides and activity estimate.3.Corrective
Ste s Which Have Been Taken and Results Achieved Since the violation, the complet programming
capabilities
for the radwaste organization
has expanded significantly.
More accurate estimates can be made for the activity associated
with all types of radioactive
shipments.
Additionally, all radwaste personnel qualified to complete shipping papers have been trained on how to utilize the computer's
capabilities.
In depth training in proper preparation
of shipping papers is required on an annual basis by radwaste technical personnel.
4.Corrective
Ste s Which Will Be Taken to Avoid Further Violations
The corrective
steps described in item 3 adequately
resolve the problem and have yielded correct calculations.
5.Date When Full Com liance Will Be Achieved Full compliance
has been achieved.
0
Violation C Technical Specification 6.6 requires that records of radioactive
shipments shall be kept in a manner convenient
for review for a period of at least five years.Contrary to the above, the licensee failed to retain records of the following radioactive
material shipments:
1.Transfer of a calibration
block from the Electric Power Research Institute (EPRI)in 1983.2.Transfer of a calibration
block from the licensee's
Power Operations
Training Center on May 29, 1986.This.is a Severity Level IV violation (Supplement
V).l.Admission or Denial of the Alle ed Violation TVA admits to the violation.
2.Reasons for the Violation Inadequate
site procedures
governing receipts of radiological
material shipments and accountability
of records.3.Corrective
Ste s Which Have Been Taken and Results Achieved Radiological
shipment records for EPRI transfer to BFN have been obtained from Mark P.Landow of Battelle and are on file in the Power Stores Section.4.Corrective
Ste s Which Will Be Taken to Avoid Further Violations
The Power Stores Section, Chemistry Group (Radwaste Section), and the Radiological
Controls Group will cmrdinate a revised procedure for the pickup and receipt of radiological
materials to ensure tot>1 accountability
for both material and records.Coordinated
meetings by the aforementioned
groups have resolved the records management
issue, and personnel have been instructed
in proper record retention.
By December 31, 1986 site implementing
procedures
will be in place to change the respcnsibility
for radiological
shipment records management
from Power Stores to the Radwaste Section and identify the site organization
responsible
for the control of receipt of radiological
mater'al shipments.
5.Date When Full Com liance Will Be Achieved TVA will be in full compliance
by December 31, 1986'
Violation D Technical Specification 6.3.D.2 requires that each high radiation area in which the intensity of radiation is greater than 1000 mrem/hr shall have the access to the source and/or area secured by lock(s).In the case of a high radiation area established
for a period of 30 days or less, direct surveillance
to prevent unauthorized
entry may be substituted
for permanent access control.Contrary to the above, on March 28, 1986, the licensee failed to secure access to a high radiation area in the reactor water cleanup (RNCU)heat exchanger room, in which the intensity of radiation was measured to be 2000 mrem/hr at 18 inches immediately
prior to the entry, by lock(s)or direct surveillance
in that the door to the room was left unlocked, open and unattended
upon completion
of the entry.Violation 86-25-09 The following incident was described fn NRC Inspection
Report 86-25: "During this month's report, the"lA" RNCU room door was found unlocked and unattended
at 0040 on July 27, 1986, by TVA personnel.
Although a door watch was stationed, the door watch left the area leaving the room unattended.
Surveys of the area recorded 1000 mrem/hr at-18 inches and 4500 mrem/hr contact readings.The area was left unattended
for 55 minutes.This incident has been identified
as another example of violation 259, 260,.296,/86-26-04
for failure to control access to high radiation areas.(259/260/296/86-25-09)
Failure by licensee management
to effect adequate corrective
actions for the previous violation has led to this additional
example although this item was licensee identified.
TVA is requested to address this example in their response to Violation 86-26-04." This is a Severity Level IV violation (Supplement
IV).l.Admission or Denial of the Alle ed Violation TVA admits to be in violation of procedures
in both incidents.
The incident described in NRC Inspection
Report 86-25, in which on July 27, 1986 the area was left unattended
for 55 minutes, is in violation of Special Test Procedure (ST)86-18, Chemical Decon of Reactor Hater Cleanup Pumps, and involved poor work practices.
The incident described in NRC Inspection
Report 86-26, in which on March 28, 1986 the intensity of radiation was measured at 2000 mrem/hr with the door unlocked or unattended, is in violation of BFN Radiological
Control instruction (RCI)17, High Radiation Area Door Control.TVA does deny both events were a violation of technical specification (TS)6.3.D.2 as dose rates in the noted areas were less than the TS-6.3.D.2
criteria of greater than 1000 mrem/hr.
NRC Ins ection Re ort 86-25 Surveys of the lA RHCU pump room taken on July 25, 1986 and July 27, 1986 both indicated dose rates of exactly 1000 mrem/hr.Eighteen thermoluminescent
dosimeters
placed in the 1A RHCU pump room on July 28, 1986 confirmed dose rates were below the"greater than 1000 mrem/hr" criteria found in TS-6.3.D.2
for locked/guarded
high radiation areas, with, the maximum reading or 603 mrem/hr.TS-6.3.0.2
requires doors=o be locked when the dose rate in the room is greater than 1000 mrem/hr.Thus, for the lA RHCU pump room, no survey or dosimetry data exists which would require the 1A RHCU pump room to be locked/guarded
in accordance
with the TS requirement.
There is no reason to have expected the dose rates in the 1A RHCU pump room to change during this time period.The appropriate
violation for this incident would have been against ST-86-18, Chemical Decon of Reactor Hater Cleanup Pumps, step 3.2, which required a door watch to be present anytime the RHCU pump room door was open for the pump chemical decontamination
operation.
This violation was identified
by RADCON.NRC Ins ection Re ort 86-26 The unit 2 RHCU heat exchanger room was surveyed on March 25, 1986 and indicated a whole body dose rate of 600 mrem/hr.The March 25, 1986 survey was reviewed and signed off by radiological
control (RADCON)supervisory
personnel and officially
entered in the RADCON data base.Hhere radiological
conditions
are not expected to change, RADCON procedures
allow survey data to be valid for up to seven days.Dose rates were not expected to change'Tn the RHCU heat exchanger room.On'March 28, 1986, while performing
work in the unit-2 RHCU heat exchanger room, a RADCON technician
incorrectly
noted the whole body dose rate as 2000 mrem/hr.The designated
individual
should have liked the door as required by RCI-17, High Radiation Area Door Control.The door was unattended
and'nlocked
for three hours and 35 minutes after the 2000 mrem/hr reading was recorded.The door was locked on March 29, 1986 upon discovery by RADCON.The survey, incorrectly
noting a dose rate of 2000 mrem/hr, had not been reviewed by RADCON supervision.
On March 31, 1986 a RADCON supervisor
and technician
entered the unit 2 RHCU heat exchanger room with rulers and survey meter and confirmed the dose rates to be significantly
less (500 mrem/hr)than the TS limit of Lt h 00D I In summary-.Both incidents were licensee identified.
Neither incident was a violation of technical specification 6.3.D.2, as actual readings did not exceed 1000 mrem/hr.Both incidents were a result of personnel error and involved a failure to.follow procedures.
2.Reasons for the Violation The reason for the door watch leaving his post at the lA RHCU pump'oom on July 27, 1986 (Report No.86-25)is as follows: The door watch did not adhere to BFN procedure ST-86-18 and left the door unguarded just after shift change.The evening shift foreman did not adequately
communicate
to the midnight shift foreman the necessity of ensuring the door was watched continuously.
The reason for the unit 2 RHCU heat exchanger room door being left open (Report No.86-26)is as follows: The individual
designated
to lock the door failed to perform tne required action upon completion
of the entry.Personnel who entered the room propped the door open and failed to close the door upon exit.1 3.Corrective
Ste s Nhich Have Seen Taken and Results Achieved The below listed actions have been taken to strengthen
the high radiation area door control program and facilitate
adherence to procedures.
a.RCI-17, High Radiation Area Door Control, has been revised to further clarify at what radiation level an area must be locked or guarded.b.Technical Section Instruction
Letter (TSIL)13, Surveillance
of High Radiation Areas, has been revised to require the RADCON technician
to know which areas are potentially
in excess of 1000 mrem/hr before conducting
the routine check of high radiation area doors.It has also been revised to state that when there is a possibility
for excess of 1000 mrem/hr, a RADCON Shift Supervisor
will be immediately
notified, and the door will not be left open and unattended.
c.Report requirement
and actions have been defined when high radiation area doors are found unlocked/unguarded.
d.Personnel serving as door watches for high radiation area doors are required to be trained.e.High radiation area door watches are now maintained
on a log sheet kept by the door watch.The high radiation area door watch responsibility
must be formally transferred
in writing.f.Only RADCON personnel can relieve the last individual
listed on the High Radiation Area Door Natch Log Sheet.Unless received in writing by RADCON, the last name on the High Radiation Area Door latch Log is totally responsible
for access control to the high radiation area.g.Administrative
actions have been taken against the indi.viduals
involved in the two noted events for failure to properly perform assigned duties.
rg
There have been no additional
incidents where a door to an area of greater than 1000 mrem/hr has been left open or unguarded.
4.Corrective
Ste s Hhich Hill Be Taken to Avoid Further Violations
No further action is necessary.
5.Date Hhen Full Compliance
Hill Be Achieved Full compliance
has been achieved.
ENCLOSURE 2 RESPONSE NRC INSPECTION
REPORT NO.41-08165-09/86-01
G.G.2ECH'S LETTER TO S.A.NHITE DATED SEPTEMBER 16, 1986 During the Nuclear Regulatory
Commission (NRC)inspection
conducted on July 21-25, 1986, a violation of NRC requirements
were identified.
The violation involved failures to comply with applicable
NRC and Department
of Transportation (DOT)requirements
concerning
transportation
of radioactive
material.In accordance
with the"General Statement of Policy and Procedure for NRC Enforcement
Actions," 10 CFR Part 2, Appendix C (1985), the violation is listed below: 10 CFR 71.5(a)requires that each licensee who transports
licensed material outside of the confines of its plant or other place of use, shall comply with the applicable
requirements
of the regulations
appropriate
to the mode of transport of DOT in 49 CFR Parts 170 through 189.49 CFR 172.203(d)(1)
requires that the description
of radioactive
materials on a shipping paper must include the name of each radionuclide
in the radioactive
material and the activity in each package of the shipment.Contrary to the above, on May 29, 1986, the licensee failed to properly describe the radioactive
material on the shipping paper for a calibration
block sent from the Power Operations
Training Center (POTC)to the Browns Ferry site under Shipment No.TC-86-22 in that the acti'vi ty and identification
of the nuclides listed on the shipping paper were not accurate.This is a Severity Level IV violation (Supplement
V).l.Admission or Denial of the Alle ed Violation TVA admits the violation.
2.Reasons for the Violation The calibration
block is the only shipment of its type ever received or shipped from POTCH Thus, POTC personnel sought help from the Radwaste Operations
Section in Chattanooga
with'preparation
of the shipment papers.In preparing the isotopic, content, the original shipping content values from BFN to POTC were used, which included transuranic
material which was'actually not present.In the conversion
and calculation
process, milli curies were changed to curi es, but the mill i curi es unit was retained throughout
the calculation.
'herefore, all values are off by a factor of 1000, e.g., 0295 mCi should read.0295Ci and should not have included transuranic
values,
3.Corrective
Ste s Nhich Have Been Taken and Results Achieved All involved personnel have been informed of the errors and are directed to retain their units on conversions.
Also, TVA training personnel have been made cognizant of the errors and directed to stress correct units in training.4.Corrective
Steps Nhich N!11 Be Taken to Avoid Further~liolations
All steps are complete for avoiding further violati,ons.
5.Oate Nhen Full Compliance
Ni 11 Be Achieved Full compliance
has been achieved.10