ML20112J103
| ML20112J103 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 12/14/1984 |
| From: | Domer J TENNESSEE VALLEY AUTHORITY |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20112J061 | List: |
| References | |
| NUDOCS 8501180170 | |
| Download: ML20112J103 (3) | |
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ag I9 t-December 14, 1984 U.S. Nuclear Regulatory Commission Region II ATTN: James P. O'Reilly, Regional Administrator 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323
Dear Mr. O'Reilly:
Enclosed is our response to D. M. Verrelli's November 2, 1984 letter to H. G. Parris transmitting IE Inspection Report Nos. 50-259/84-44,
-260/84-44, -296/84-44 for our Browns Ferry Nuclear Plant which appeared to have been in violation of NRC regulations. A two-week extension for responding was discussed between Ross Butcher of your staff and Mike Hellams of my staff on November 29, 1984. If you have any questions, please call Dennis McCloud at FTS 858-2725.
To the best of my knowledge, I declare the statements contained herein are complete and true.
Very truly yours, TENNESSEE VALLEY AUTHORITY James A. Domer Nuclear Engineer Enclosure DEM:MLH:SCP cc (Enclesure):
NUC PR ARMS,'1520 CST 2-C l
J. W. Anderson, 255 SPB-K l
E. A. Belvin,'109 MPB-M l
Browns Ferry - NRC Inspectors J. A. Coffey, Browns Ferry l
H. N. Culver, 249A HBB-K l
J. W. Hutton, 1760 CST 2-C
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J. A. Raulston, W10C126 C-K H. S. Sanger, Jr., E11B33 C-K F. 7. Szczepanski, 220 401B-C
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RESPONSE
NRC INSPECTION REPORT NOS.
50-259/84-44, 50-260/84-44,~ AND 50-296 84-44 DAVID M. VERRELLI'S LETTER TO H. G. PARRIS DATED NOVEMBER 2, 1984 The following violations were identified during an inspection conducted on September 26 - October 25, 1984.
The severity level was assigned in accordance with the NRC, Enforcement Policy (10 CFR Part 2, Appendix C).
Item 1 - (50-250/260/206/84-44-09) 10 CFR 50, Appendix B, Criterion V requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, or a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Contrary to the above, the requirement was not met in that Radiological Control Instruction 4 (Periodic Inspection and Maintenance of Radiological Emergency Plan Equipment and Supplies) was deficient and was not being adhered to.
Examples of this are as follows:
1.
Although RCI-4 states that eatergency equipment is located at the Huntsville Hospital, the procedure does not contain an inventory checklist for this location.
2.
Three itens on the Medical Treatment Area Inventory List (Table 6 of RCI-4) have not been available since December 1983 The procedure requires that all deficiencies be corrected as soon as possible.
Contrary to this, a remark on the December 1983 inventory states that the items will not be procured due to non-use. No record could be i
found that the approving authority for the procedure (PORC) concurred with this method of' deficiency correction and no action has been initiated to remove the items from the inventory list.
- 3. - The procedure states that self-contained breatning units shall be inventoried and inspected monthly but ie unclear whether the Table 7 inventory sheet should be completed quarterly or monthly. The Table M
was being completed quarterly and a monthly inspection was being,
@ djlj performed using another procedure unreferenced in RCI-4.
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RCI-4 requires that completed inventories be submitted to the Health l
Physics Supervisor for review. Contrary to'this, the Medical Treatment Area Inventory List for the current quarter (Table 6) was-being
":d mainteined by the nurse about one month after the inventory was[,, &[fl:1
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completed.
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RCI-4 requires that inventory lists be posted on the outside and inside of the emergency equipment storage cabinet:. Out of date revisions of the checklists were posted on three emergency equipment cabinets (Control Rooms, Health Physics Lab, and Lunch Room Hallway locations).
.l 6.
The December 1983 inventory of Health Physics Lab emergency equipment identified a typographical error on the list which has remained i
.. uncorrected through four subsequent revisions on RCI-4.
7 The emergency equipment cabinet locations for the communications room is not as depicted in Figure 2 of RCI-4.
8.
No self-contained breathing units are stored in the Chemistry Lab as required by Table 7 cc RCI-4.
9 Table 8 of RCI-4. references Figure 4 for the location of lunch room hall cabinet medical supplies. There is no Figure 4 included in RCI-4.
This is a Severity Level V violation (Supplement I).
1.
Admission or Denial of the Allested Violation TVA admits the alleged violation as stated.
2.
Reasons for the Violation The proper administrative controls for ensuring the current and correct content of RCI-4 was inadequate.
3 Corrective Steos Which Have Been Taken and Results Achieved Revisions to RCI-4 and IPD-17 have been submitted which will combine all emergency requirments into one procedure. This will eliminate the potential of only one of the procedures being revised when changes occur.
It should be noted that all hospitals and self-contained breathing units were inspected as 1equired.
4.
Corrective Steos Which Will Be Taken To Avoid Further Violations Cognizance over the emergency equipment inspections will be transferred from the Health Physics Section to the REP coordinator to provide a dedicated individual to review the results of emergency equipment inspections in the future.
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5.
Date When Full ComDliance Will Be Achieved 4
l Full compliance will be achieved by January 15, 1985.
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