ML18036A290

Provides Response to 910611 Ltr Re Violation Noted in Insp Repts 50-259/91-18,50-260/91-18 & 50-296/91-18.Corrective Actions:Unannounced Quarterly Visits to All Util Collection Facilities Will Be Made for 1 Yr from Ltr Date

ML18036A290
Person / Time
Site:	Browns Ferry
Issue date:	07/11/1991
From:	Medford M TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9107170244
Download: ML18036A290 (11)

Text

ACCELERATED DISTRIBUTION DEMONSTPATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

CESSION NBR:9107170244 DOC.DATE: 91/07/11 NOTARIZED: NO DOCKET g FACIL:50-259 Browns Ferry Nuclear Power Station, Unit 1, Tennessee 05000259 50-260 Browns Ferry Nuclear Power Station, Unit 2, Tennessee 05000260 50-296 Browns Ferry Nuclear Power Station, Unit 3, Tennessee 05000296 AUTH. NAME AUTHOR AFFILIATION MEDFORD,M. Tennessee Valley Authority RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Provides response to 910611 ltr re violation noted in Insp Repts 50-259/91-18,50-260/91-18 & 50-296/91-18.Corrective D actions:unannounced quarterly visits will continue for period of yr from date of ltr.

DISTRIBUTION CODE: A022D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: Fitness for Duty Program: Blind Performance Test/Other NOTES RECIPIENT COPIES RECIPIENT COPIES D ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL KREBS,M. 1 1 HEBDON,F 1 1 ROSS,T. 1 1 WILLIAMS,J. 1 1 INTERNAL: ACRS 1 1 Rg/JURIS. RSGB 1 1 NUDOCS-ABSTRACT 1 1 G FILE Ol 1 1 RGN2 . 02 1 1 RNAL: NRC PDR 1 1 NSIC 1 1 D

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D NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTEI CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

AL NUMBER OF COPIES REQUIRED: LTTR 11 ENCL 11

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Tennessee Vailey Authority, 1101 Market Street. Chattanooga. Tennessee 37402 Mark O. Medford Vice President, Nuciear Assurance, Licensing and Fuets JUL 1 1 I91 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Gentlemen:

In the matter of Tennessee Valley Authority FITNESS FOR DUTY PROGRAM NRC INSPECTION REPORT NOS. 50-259/91-18, 50-260/91-18, AND 50-296/91-18 REPLY TO A NOTICE OF VIOLATION Enclosed is TVA's response to a notice of violation by letter from B. A. Wilson to D. A. Nauman dated June 11, 1991. The violation consisted of two incidents within the medical collection facility at Browns Ferry Nuclear Plant. As stated in Enclosure 1, TVA admits the violation. TVA's commitment is provided in Enclosure 2.

If you have any questions, please telephone Charles R. Davis at (615) 751-7509, Very truly yours, TENNESSEE VALLEY AUTHORITY 7I(J'ark 0 Medfo Enclosures cc: See page 2 9i07i70244 9107ii PDR, FiOOCK 05000259

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.2 U.S. Nuclear Regulatory Commission JUL i 1 $ 91 Enclosures cc (Enclosures):

Ms. S. C. Black, Deputy Director Project Directorate II-4 U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike, Rockville, Maryland 20852 NRC Resident Inspector Browns Ferry Nuclear Plant Route 12, Box 637 Athens, Alabama 35609-2000 Mr. Thierry M. Ross, Project Manager U.S. Nuclear Regulatory Cormnlssion One White Flint, North 11555 Rockville Pike Rockvi.lie, Maryland 20852 Mr. B. A. Wilson, Project Chief U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323

II II II

Enclosure 1 Response to NRC Inspection Report Nos. 50-259/91-18, 50-260/91-18, 50-296/91-18 Bruce A. Wilson's letter to D. A. Nauman dated June ll, 1991 Restatement of Violation:

During an NRC inspection conducted on April 30 May 3, 1991, a violation of NRC requirements was identified. In accordance with the -"General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1991), the violation is listed below:

10 CFR, Part 26, "Fitness For Duty Programs," Appendix A, Subpart B "Scientific and Technical Requirements,".Paragraph 2.4 specifies:

(e) Access to Authorized Personnel Only, "No unauthorized personnel shall be permitted in any part of the designated collection site where specimens are collected or stored." and (g) Integrity and Identity of Specimens, "The collection site person shall ensure that all personnel belongings such as a purse...

remain... outside of the room in which the... urine sample is collected," and "... the individual shall remain in the presence of the collection site person and shall not have access to any...

faucet... which could be used to adulterate the urine specimen."

"Contrary to the above, on May 2, 1991, the inspectors found the rear door to the designated collection site to be open and unattended thus allowing the potential for unauthorized personnel access during collection and storage of specimens. Additionally, the inspectors noted that individuals do not always remain in the presence of the collection site person, have access to purses left in the hallway, and have access to faucets in two bathrooms at the end of the hallway."

Admission or Denial of the Alle ed Violation:

TVA admits the violation occurred as stated.

Reason for the Violation:

The reason for the violation has been determined to be personnel error.

Collection site personnel were not aware that by opening the Emergency Room door unauthorized personnel could gain access to the Browns Ferry Nuclear Site collection facility.

Because of the close proximity of the bathroom to the collection facility, collection site personnel were not aware that the donor was considered out of their presence and could potentially have access to purses and faucets when walking to the bathroom from the collection room.

A contributing factor to the violation was that during this time the Browns Ferry Nuclear Health Services was in the process of not only performing the daily random testing but were also group testing 0 approximately 160 personnel over a 3-day period. With the large influx of people in the Health Services office, the Emergency Room door was opened to provide additional ventilation to the facility.

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t Corrective Ste Up on s taken and Results Achieved notification that the Emer g enc y Ro om door was open, Site Management instxucted collection site personnel to keep the door closed at all times and restrict access to the collection Eacility to authorized personnel only. Additionally, collection site personnel were instructed to escort donors to the bathroom and instructed on the importance oE ensuring that individuals remain in the presence of the collection site person until the entire collection process is completed.

At the conclusion of the exit meeting held on May 3, 1991, TVA's Manager oE Corporate Clinical Support, Training, and Compliance met. with the Browns Ferry Health Services Staff and discussed the circumstances surrounding the violation and reemphasized the importance of contxolling access to the collection facility and ensuxing that the collection site personnel remain in the presence of the donor. The Manager of Corporate Clinical Support, Training, and Compliance and Clinical Services Manager have since met with TVA's other site collection personnel, reviewed the exit meeting minutes, and reemphasized the importance oE maintaining control of access to the collection facility and remaining in the presence of the donor to ensure there is no access to personal belongings ox faucets.

On June 5, 1991, an alarm was installed on the Emergency Room doox to notiEy Health Services pexsonnel when the door is being used. The coat rack and chairs just outside the collection area have been removed. This is intended to ensure there is no access to pexsonal belongings during the collection process. Since the collection site person escorts the donor, there should be no opportunity for access to personal belongings or the faucets in the bathrooms at the end of the hallway.

Corrective Ste s which will be taken to Avoid Further Violations Unannounced quarterly visits to all TVA collection facilities will be made by the FFD Coordinator and the Health Services Supervisor of Clinical Support, Training and Compliance for the purpose of, ensuring, FFD testing is properly performed. These unannounced quarterly visits will continue for a period of one year from the date oE this letter.

Date Mhen Full Co liance will be Achieved TVA is in full compliance.

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Enclosure 2 TVA'S COMMITMENT Unannounced quarterly visits to all TVA collection facilities will be made by the FFD Coordinator and the Health Services Supervisor of Clinical Support, Training and Compliance, for the purpose of ensuring FFD testing is properly performed. These unannounced quarterly visits will continue for a period of one year from the date of this letter.

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