ML20235M844

Responds to NRC Re Insp Repts 50-259/87-28, 50-260/87-28 & 50-296/87-28 Which Requested Supplemental Response to Violation 3 Noted in Insp Repts 50-259/84-12, 50-260/84-12 & 50-296/84-12

ML20235M844
Person / Time
Site:	Browns Ferry
Issue date:	09/28/1987
From:	Gridley R TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
NUDOCS 8710060306
Download: ML20235M844 (5)

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.b TENNESSEE VALLEY AUTHORITY CH ATTANOOGA. TENNESSEE 37401 SN 157B Lookout Place SEP 281987 U.S. Nuclear Regulatory Commission i ATTN: Document Control Desk- '

Washington, D.C. 20555 Gentlemen:

In the Mstter of ) Docket Nos. 50-259 Tennessee Valley Authority ) 50-260

) 50-296 BROWNS FERRY NUCLEAR PLANT (BFN) UNITS 1, 2, AND 3 - NRC-0IE INSPECTION REPORT NOS. 50-259/84-12, 50-260/84-12, 50-296/84-12 SUPPLEMENTAL RESPONSE Enclosed is TVA's reply to G. G. Zech's August 14, 1987 letter to S. A. White, which transmitted IE Inspection Report Nos. 50-259/87-28, 50-260/87-28, and 50-296/87-28. This report' requested TVA to provide additional information i regarding our previous corrective action to Violation 3. Inspection Report Nos. 50-259/84-12, 50-260/84-12, 50-296/84-12, which related to radiation exposure reporting for termination employees.

This supplemental response provides additional steps which have been taken or planned to correct the violation. Enclosure 1 contains TVA's response and an updated schedule for achieving full compliance. A list of commitments is provided in enclosure 2. We do not recognize any other items described herein as commitments. An extension of this supplemental response submittal due date to September 28, 1987, was agreed in a conference with Al Ignatonis of your staff on September 10, 1987.

Please refer any questions to H. 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

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R. Gridley, D rector l Division of Nuclear Licensing and l Regulatory Affairs 4 Enclosures cc: See page 2 8710060306 870928 g> /

gDR ADOCK 0500 9 An Equal Opportunity Employer

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U.S. Nuclear Regulatory Commission cc (Enclosures):

Mr. G. G. Zech, Assistant Director Regional Inspections Division of TVA Projects Office of Special Projects j U.S. Nuclear Regulatory Commission .

Region II 101 Marietta St., NW, Suite 2900 Atlanta, Georgia 30323 Mr. J. A. Zwolinski, Assistant Director for Projects j Division of TVA' Projects Office of Special Projects U.S. Nuclear Pegulatory Commission 4350 East West Highway EWW 322 Bethesda, Maryland 20814 Browns Ferry Resident Inspector Browns Ferry Nuclear Plant P.O. Box 311 Athens, Alabama 35611 1

ENCLOSURE 1  !

SUPPLEMENTAL RESPONSE ~

NRC INSPECTION REPORT NOS.

50-259/84 12, 50-260/84-1.2, 50-296/84-12 LETTER FROM R. C. LEWIS TO H. G. PARRIS DATED MAY 2, 1984 Excerpt from Inspection Report 87-28 The inspector reviewed the licensee's response of June 4, 1984 to violation-50-259, 50-260, 50-296/84-12-03. The. response stated that the licensee would be in full compliance with the termination exposure reporting requirements by January 1, 1985. The inspector reviewed a termination exposure report dated

. June 24, 1987, that.had been sent to one of the resident inspectors. The report contained information back to 1985, but did not include exposure 1 information for the nine months in 1984 that the inspector had been assigned 1 to the site. Licensee representatives stated that the current computer program used to generate termination reports would not-list exposure .

information for contractors which was received before 1985. The inspector stated that 10 CFR 20.408(b) and 10 CFR 20.409(b) require that NRC and the individual be given reports upon termination of the individual's radiation exposure incurred during the period of employment or work assignment in the licensee's facility. The licensee, therefore, was not in full compliance with termination radiation exposure reporting requirements for contractor personnel in that exposures received before 1985 were not reported to these persons upon termination.

TVA Response l

1. Corrective Steps Which Have Been Taken and The Results Achieved Nuclear Corporate Office (NCO) Radiological Control (RADCON) has compiled a list of non-TVA personnel currently badged at any TVA nuclear site who have continuous monitoring periods beginning before January 1, 1985. This list is checked before releasing any termination letters. Letters issued to employees on the list have been revised and now include the individual's entire exposure incurred during the period of employment or j work assignment.

l During a preliminary review of the check-in/ checkout process, it was discovered that a potential situation existed for contractor personnel assigned to the corporate offices not to be issued their entire exposure history during the period of employment with TVA. To prevent this occurrence, effective September 18, 1987, TVA NCO Personnel Staff will periodically supply NC0 RADCON a list of every contractor terminating from TVA. NCO RADCON will use this list to ensure compliance with the reporting requirements of 10 CFR 20.408(b) and 409(D).

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2. Corrective Actions Which Will Be Taken To Av61d Further Violations TVA is revising its historical exposure database to ensure that exposure .

information for terminated employees at any TVA site will be listed on the "

termination reports to show total exposure incurred during the work assignment period. This modification is presently scheduled to be completed by October 30', 1987. Until the historical exposure database is revised to correct the problem, TVA will manually extract from the database the individual's exposure to radiation incurred during the period of exposure and provide this information on the termination letter. In addition, the TVA NCO Personnel Staff will implement a check-in/ checkout procedure for employees (TVA and non-TVA) at each TVA site and corporate offices. This procedure will further ensure the timely updating of the

" terminating contractor list" provided periodically by the TVA NCO Personnel' Staff to NCO RADCON. This procedure is presently schedule'd to be completed by March 4,1988.

3. Date When Full Compliance Will Be Achieved  !

Full compliance with the reporting requirements of 10 CFR 20.408(b) and 409(b) has been achieved for TVA contractors effective September 18, 1987.

4. Actions Taken to Correct the Problem of Not Taking Adequate Corrective Actions and Steps Taken to Prevent Recurrence In the latest SALP report on TVA nuclear activities, NRC stated that there were weaknesses evident in TVA's licensing support as indicated by incomplete submittals, repeated request for additional information and supplementary responses to Notices of Violations, and failure to aggressively pursue resolution of pending or unresolved issues.

The original response to violation 50-259,-260,-296/R4-12-03 is an example where licensing failed to aggressively pursue the issue to ensure full compliance. Since that response, a site licensing organization has been established at BFN to quickly address licensing commitments. Each commitment made in a violation response is listed as part of the response. NRC commitments are tracked individually in the Corporate Commitment Tracking System. Organizations implementing commitments and their documented responses are tracked as part of the licensing compliance process. A new commitment tracking procedure requires QA verification or independent verification of commitments made in responses. In addition, NRC identified items are reviewed to determine whether a condition adverse to quality report will be needed.

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ENCLOSURE 2 LIST OF COMMITMENTS 4

1. TVA NCO Personnel Staff will periodically supply NCO RADCON a list of~

every terminating contractor in TVA effective September 18, 1987. NC0 RADCON will use this list to ensure compliance with the reporting

-requirements of 10 CFR 20.408(b) and 409(b).

2. TVA will modify its historical exposure database to ensure that exposure information fot terminated employees at any TVA site will be listed on the termination reports to show total exposure incurred during the work assignment period. This modification is presently scheduled to be completed by October 30, 1987.

3. TVA NCO Personnel Staff will develop and implement a check-in/ checkout procedure for employees.(TVA and non-TVA) at each TVA site and corporate offices. This procedure is presently scheduled to be completed by March 4, 1988.

4. NCO RADCON will use a list of' non-TVA personnel currently badged at each TVA nuclear site, who have continuous monitoring periods beginning before January 1.,'1985, to ensure compliance with 10 CFR 20.408(b) and 409(b), ,

until the database modification necessary to accomplish this is complete. '

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