ML20116D084
| ML20116D084 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 11/03/1992 |
| From: | Joshua Wilson TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9211050172 | |
| Download: ML20116D084 (5) | |
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Trn m vee,A+anme. om on;w snstOaseTen ns:,,3m J L Weon We hMdNd 8'ergrJyah fly 3W Dwil November 3, 1992 U.S. Wucioar Regulatory Coh nission ATTNt Docte e.
Control Desk
- e Washington, D.C. 20555 centlement In the Matter of
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Docket Nos. 50-327 Tennessee Valley Authority
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50-328 SEQUDYAll NUCLEAR P1 ANT 'SQN) - NRC INSPECTION REPORT NOS.30-327, 328/92 kESPONSE TO NOTIr'E OF V101ATION (NOV) 50-327, 328/92-25-01 i contains IVA's response to William E. Cline's letter to M. O. Medford dated October 5, 1972, which transmitted-the subject NOV.
Thit< violation concerned a tailure to follow procedures and control.
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hazardous raaterials that ceulst result in radiological hazards. TVA's response includes actions taken to ensure that chemicals brought into rt.diologically controlled areas are properly controlled and will:not present a bazardous condition to plant personnel or equipment. contains a summary of commitments made in this subiaittal.
1( you have any questions concerning this submittal, please telephone M. A. Cooper at (615) 843-0924.
S.incerely,
. L Wilson Enclosures ce t - See page 2 1
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t U.S. Hunlear Regulatory Conunission Page 2 November 3, 1992 1
cc (Enclosures):
Mr. D.
1.aBarge, Project Msnager tl.S. Nuclect Regulatory Coisoission One White Tlint, North r
11555 Rockv11,1e Pike l
Rockv1110 Pary1cnd 20852 NRC Resident Inspector l
Setptoyah Nuclear P16nt 2600 Igou Ferry P.oad Soddy-Daisy, Tennessee 37379 Hr. B. A._ Wilson, Project Chief U.S. Nuclear Regulatory Conunission Region II 101 Marietta Street, IN, Suite 2900 Atlanta, Georgia 30323 f
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.o ENCLOSURE 1 RESPONSE TO HRC INSPECTION REPORT g
NOS. 50-327/92-25 AND 50-328/92-25 WILLIAM E. CLINE'S LETTER TO MARK 0. MEDFORD 11ATED OCTOBER 5,1992 Violakion_50-327.. 328/32-25 0
"Technicel Specification (TS) 6.8.1 requires written procedures shall be cetablished, imp'emented, and maintained covering the activities referenced in Appendix 'A' of Regulatory culde 1.33, Revision 2. February 1978. Appendix "A" Paragraph 10, of Regulatory Guide 1.33 requires the une of control procedures for chemicals to minimize the risk of radiological hazards.
"Proceduro SSP.7, (sic) Revision 7, Appendix A, '!!ousekeeping Ten orary -
(sic) Equipment Control,' checklist items 9 and 17, require controlling l
flammable combustible material.
"Proundere SSP-13.2, Revision 4,
'Chemient Traffic Control (CTC)
Program,' Paragraph 3.3.6 requires new containers be marked if chemicals are transferred from original contsiners.
" Contrary to the above, the licensee failed to follow administrative procedu.es, 1. that during the weak of August 24-28, 1992, '.he licensee did not inbc ar properly co.itrol numerous containers of hazardous
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materlato whic. could result in radiological hazards.
"This is a Severity Level IV violation (Supplement V)."
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Reason _for_theliolnLion There are three reasons for the violation of falling to follow procedures.
First, craft had been trained 7n general Chemical Traffic Control (CTC) program requirements, but the training had not been craft specific. The craft did not always correlate transferring chemicals..i.e., greases, oils, cleaners, paints, and paint thinners, into unlabeled containers and storing these containers in radiolegically controlled areas (RCAs) with the hazardous matetials and control of hazardous materials that were wentioned in the CTC training.
Therefore, the craft left unlabeled containers and unused chemicals in the RCAs.
Second,'immediate manageacnt, i.e., foremen, general foremen, and engineers, did not enforc0 the CTC program requirements associated with labeling and storage of chemicale.
5 Third, supervisors of sections using chemicals were not performing routine inspections of their work areas to ensure compliance with the CTC program requirements. These routino inspections are requirements in the CTC program procedure Site Standard Practice (SSP) 13.2, " Chemical Iraffic Control (CTC) Program."
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'l Cerre ctiveJiteps_Tha LJiav eJ e en _Taken. pndJe s ul t s_ Achi ev e d j
NitC inspectors reported that unlabeled chemicals and containers were stored in the auxillary buildinF on Elevation 690 on August 24, 1992.
Subsequent inspections on other elevations by Radiological Control personnel revealed additional discrepancies, however, on a much smaller ucale.
The untabelett chemicals and containers were :arried into the RCAs by various site organizations.
Ilowever, most appeared to be. associated with an ongoing painting activity under Modificatione' responsibility..
Modifleations' supervisors proreptly directed that all known cheroicala l
under Modificatiens' control be brought out of the RCA and properly l
labeled or appropriately disposed of.
Radiological Control supervisors and personnel performed similar cleanup and removal of chemicals under-their control. Modifications' craft personnel were immediately retrained on the CTC program requirements as they apply to each craft discipline.
Craft-specific training for CTC controls was also provided for the i
Chemistry, Maintenance, Technical Suppo-t, and Operations sections.
1he foremen and engineers involved in the activities responsible for the i
CTC violations have been counseled for their lack of implementation and enforcer ent of the program requirements.
Section supervisors have begun-performing routine ir.spections of their work areas to ensure that chemicals are prop-rly-controlled.
Corre c11v eE u p s Jha t 31113 e_Tak en_1o_AynidlucLher_ Viola tion s SSP-13.2, " Chemical Traffic Control (CTC) Program." and' SSP-13.3
" Environmental Crap 11ance," will be revised to specifically address disposal of unused material aed used containers with residues. The-revision will also address the removal of unused material and containers from the RCA.
Site Quality uill fuitiate a surveillance activity of the CTC program.
Da t eJhen lulLC ouplianc e..R11 Lb c_Ac hieved TVA is in full compliance.
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i 13401,0 SUITE 2 l
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The Site Quality organiention will initiate a surveillance activity of the Chemical Traffic Control program. This will be accomplished by !Jovember 9,1992.
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Site Standard I'ractice (SSP) 13.2 " Chemical Traf fic Control (CTC)
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f rogrnm," and SSI'-13.3, " Environmental Compliance," will be revised l
to specifically address uisposal of unused material and used containers with residues.
This will be accomplished by March 1, 1993.
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