ML20209A966

Responds to NRC Re Violations Noted in Insp Repts 50-327/86-36 & 50-328/86-36.Corrective Action:Procedure Data Sheet Revised to Include Space for Recording Survey Data for Top Surface of Closed Transport Vehicles

ML20209A966
Person / Time
Site:	Sequoyah
Issue date:	08/22/1986
From:	Domer J TENNESSEE VALLEY AUTHORITY
To:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
NUDOCS 8609080141
Download: ML20209A966 (3)

Text

r- bcD TENNESSEE VALLEY AUTHORITY CHATTANOOGA. TENNESSEE 37401 c~,

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AUG 221986

.2 ru U.S. Nuclear Regulatory Commission .n.

Region II C ATTN: Dr. J. Nelson Grace, Regional Administrator 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323

Dear Dr. Grace:

SEQUOYAH NUCLEAR PLANT UNITC 1 AND 2 - NRC-OIE REGION II INSPECTION REPORT 50-327/86-36 AND 50-328/86 RESPONSE TO VIOLATION Enclosed is our response to Gary G. Zech's July 23, 1986 letter to S. A. White which transmitted Notice of Violation Nos. 50-327/86-36-01 and 50-328/86-36-01 for our Sequoyah Nuclear Plant. Enclosure 1 is our response to the subject violation. We do not recognize any other actions described herein or the subject inspection report as commitmants.

If you have any questions, please get in touch with G. B. Kirk at (615) 870-6549.

To the best of my knowledge, I declare the statements contained herein are complete and true.

Very truly yours, TENNESSEE VALLEY AUTHORITY ffYllk J. 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 8609030141 DR 860822 ADOCg 03000327 PDR, ob An Equal Opportunity Employer l'~

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r T ENCLOSURE RESPONSE - NRC-0IE IPISPECTION REPORT NOS. 50-327/86-36 AND 50-328/86-36 GARY G. ZECH'S LETTER TO S. A. WHITE DATED JULY 23, 1986 Violation 50-327/86-36-01 and 50-328/86-36-01 During the Nuclear Regulatory Commission (NRC) inspection conducted on June 16-20, 1986, a violation of NRC requirements was identified. The violation involved a failure to perform radiation surveys on the top surfaces of radioactive material exclusive use closed transport vehicles. 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, or who delivers licensed material to a carrier for transport, shall comply with the applicable requirements of the regulations appropriate to the mode of transport of the Department of Transportatica (POT) in 49 CFR Parts 170 through 189.

49 CFR 173.475 (i) requires that before each shipment of any radioactive materials package, the shipper shall ensure by examination or appropriate tests that external radiation levels are within the allowable limits.

49 CFR 173.441(b)(2) requires that the radiation levels on packages transported by exclusive use shipment not exceed 200 millirem per hour at any point on the outer surfaces of the vehicle, including the top and underside of the vehicle.

Contrary to the above, on May 2 and June 5, 19ts, the licensee failed to comply with DOT requirements for radioactive material shipments SNP-428 and SNP-430, transferred to the Chem-Nuclear Systems, Inc. low level waste disposal site near Barnwell, S.C. in that, prior to the shipment, no radiation level measurements were performed on the top surfaces of the exclusive use closed transport vehicles.

This is a Severity Level IV violation (Supplement V).

1. Admission or Denial of the Alleged Violation TVA admits the violation occurred as stated.

2. Reason for the Violation The violation occurred due to personnel error resulting in an inadequate procedure. The instruction, Radwaste Handling and Shipping Instruction (RHSI) -2, requiring measurements for top surfaces was incorrectly revised deleting this requirement from the data sheet. Specifically, for -

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shipments SNP-428 and SNP-430, because of the incorrect revision, the data sheets for the health physics portion of the shipments did not have a section for recording radiation level measurements on the top surfaces of the transport vehicles. Further investigation into the violation has verified that the surveys for the top surfaces were performed but'not documented because of tne revised data sheets.

3. Corrective Steps Taken and Results Achieved The procedure data sheet was revised to include space for recording the survey data for the top surface of closed transport vehicles along with identification of the acceptance criteria. These actions were completed prior to the NRC exit for this inspection.

4. Corrective Steps'Taken to Avoid Future Violations The Radwaste Section requested that the Quality Assurance Section perform a review of the RHSIs and provide recommendations for improving the instructions.

5. Date When Full Compliance Will Be Achieved The plant was in full compliance on June 19, 1986 when RHSI-2 was revised.

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