IR 05000259/1978022
| ML18024A569 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 10/27/1978 |
| From: | Gibson A, Jackson L, Troup G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18024A564 | List: |
| References | |
| 50-259-78-22, 50-260-78-25, 50-296-78-21, NUDOCS 7812060033 | |
| Download: ML18024A569 (11) | |
Text
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+p*y4 UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30303 Report Nos.:
50-259/78-22, 50-260/78-25 and 50-296/78-21 Docket Nos ~
50-259, 50-260 and 50-296 License Nos.:
DPR-33, DPR-52 and DPR-68 Licensee:
Tennessee Valley Authority 830 Power Building Chattanooga~
Tennessee 37401 Facility Name:
Browns Ferry Nuclear PLant Units 1~ 2, and
Inspection at:
Browns Ferry Site, Athens, Alabama Inspection conducted:
September 11-14~
19?8 Inspectors:
G. L. Troup L. L. Jackson Reviewe by:
A. F.
G on, Chief Radiati Support Section Fuel Facility and Materials Safety Branch
~/~s Date Inspection Summar Inspection on September 11-14 1978 (Report Nos. 50-259/78-22 50-260/78-25 and 50-296/78-21)
Areas Inspected:
Routine, unannounced inspection of radiation pro-tection and radioactive waste management programs including gaseous effluent Limits, sampling and monitoring; gaseous effluent records; waste disposaL reports, testing of air cleaning systems; health physics practices for the Unit 3 refueling outage, including advanced planning, training, exposure controL, respiratory protection and posting and control; and folLowup on previously identified items.
The
. inspection involved 59 inspector-hours on site by two NRC inspectors.
Results:
Of the six areas inspected, no items of noncompliance or deviations were identified in five areas; one apparent item of noncompliance was identified in one area Cinfraction - surveilLance testing of air cleaning systems (259/78-22-01; 260/78-25-01; 296/
78-21-01) 3.
t 812060 QQ
RII Rpt. Nos. 50-259/78-22, 50-260/78-25 and 50-296/78-21 DETAILS I Prepared by:
G. L. Troup, Ra iation Specialist Radiation Support Section Fuel Facility and Materials Safety anch aP
.
L. L.
k n, Radiation Specialist Radiat'
Support Section Fuel Facility and Materials Safety Branch Dates of Inspection:
September 11-14, 1978
"RV Vr Date Revie ed:
. F.
on, Chief Radiat Support Section Fuel Facility and Materials Safety Branch Date All information in Details I applies equally to Units 1, 2, and 3, except where information is identified with a specific unit.
1.
Individuals Contacted Division of Power Production - Browns Fer Nuclear Plant-J.
G. Dewease, Plant Superintendent H. I. Abercrombie, Assistant Plant Superintendent
- J. L. Harness, equality Assurance Supervisor
- R. G. Metke, Results Supervisor
- S.
G. Bugg, Plant Health Physicist W.
C. Thomison, Chemical Engineer A. L. Clements, Jr.,
Chemical Engineer A.
W. Sorrell, Health Physicist Office of Power - ualit Assurance and Audit Staff-R. Cole, equality Assurance Site Representative Office of Power - Division of Power Production
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+J. A. Coffey, Assistant Chief, Nuclear Generation Branch
RII Rpt. Nos. 50-259/78-22, 50-260/78-25 and 50-296/78-21 I-2
+(Contacted by telephone on September 20, 1978.)
The inspectors also talked with and interviewed other licensee employees, including health physics, chemistry and engineering technicians.
-Denotes those present at the exit interview.
2.'icensee Action on Previous Ins ection Findin s
(Open) Noncompliance (77-23-01) Radiation Protection Training.
The corrective actions relating to evaluation of the training are incomplete.
The licensee has not established a method of evaluating comprehension of the training as required by plant procedure.
This item remains open.
(Open) Noncompliance (78-02-01) Respiratory Protection Program.
The corrective actions relating to periodic medical clearances are incomplete in that the program for the annual medical review of users of respiratory protection equipment has not been implemented.
This item remains open.
(Closed)
Noncompliance (78-02-03) Submittal of Semi-annual Effluent Reports.
The subject reports have been submitted as required for the past two intervals.
This item is closed (paragraph 11).
3.
Unresolved Items No new unresolved items were identified during this inspection.
4.
Testin of Air Cleanin S stems a
~
Technical Specifications 4.7.E and 4.7.F specify the surveillance requirements for the Control Room Emergency Ventilation and Primary Containment Purge System, respectively, including in-place testing of HEPA filters and charcoal adsorbers.
Technical Specifications 4 '.E.1 and 4.7.F.1 require that the determination of pressure drop across the filters and adsorbers be performed at least once per operating cycle, not to exceed 18 months.
Technical Specifications 4.7.E.2.a and 4.7.F.2.a require that in-place testing and various other tests shall be performed at least once per operating cycle or once every 18 months, whichever occurs first.
b.
An inspector reviewed the plant records for the testing of the Control Room Emergency Ventilation and Primary Containment Purge
RII Rpt. Nos. 50-259/78-22, 50-260/78-25 and 50"296/78-21 I-3 Systems (plant Surveillance Instructions SI 4.7.E.1 -4.7.E.6 and SI 4.7.F.1-4.7.F.6)
for Units 1, 2, and 3.
Based on this review the inspector determined that some tests for Units 2 and 3 were not performed at the required interval.
For example, the Unit 2 Purge System pressure drop test was performed on an interval of 24 months vice the 18 months of Technical Specification 4.7.F.l and the flow rate test was performed on an interval of 25 months vice the 18 months of Technical Specifications 4.7.F.2.a.
Also, tests of the Unit 3 Purge System and Control Room Emergency Ventilation were performed in April-May, 1976 and had not been subsequently performed at the time of the inspection, an elapsed period of 28-29 months, although the Technical Specifications specify a test period of 18 months.
The inspector informed licensee management that this was considered to be an item of noncompliance against the surveillance requirements of Technical Specifications 4.7.E and 4.7.F; this was acknowledged by licensee management.
(259/78-22-01;260/78-25-01;296/78-21-01).
The inspector also determined from the plant records that test results for pressure drop, filter and charcoal adsorber testing and flow tests met the acceptance criteria of Technical Specifications 3.7.E.2 and 3.7.F.2 when the tests were performed.
c ~
Technical Specification 4.7.B specifies the surveillance requirements for the Standby Gas Treatment System, including in-place testing of HEPA filters and charcoal adsorbers, and various functional tests.
The inspector reviewed the plant records for the testing of the Standby Gas Treatment Systems (plant Surveillance Instructions SI 4.7.B-l - 4.7.B-10) for Units 1,
2 and 3.
Based on this review the inspector determined that the tests were performed as required and the results met the acceptance criteria of Technical Specification 3.7.B.
During the review the inspector noted an apparent discrepancy between the acceptance criteria of SI 4.7.B.10, attachment 1 and the operating parameters of the procedure in that, with more than one train operating, the measured flow is greater than the flow specified in SI 4.7.B.10, attachment 1.
Licensee management representa-tives acknowledged this situation and stated that the procedure would be revised to clarify the acceptance criteria.
(259/78-22-02;260/78-25-02;296/78-21-02).
The inspector had no further questions.
5.
Gaseous Radioactive Waste Releases a.
Technical Specifications section 3.8.B specifies the LCO's for gaseous radioactive waste release rates and monitoring require-ments for various release points.
Technical Specifications
~,
RII Rpt. Nos. 50-259/78-22, 50-260/78-25 and 50-296/78-21 I-4 section 4.8.B and Table 4.8-B specify the surveillance require-ments for implementing the LCO's.
These requirements are imple-mented by plant Surveillance Instructions 4.8.B.1, 4.8.B.2 and 4.8.B.3.
b.
An inspector reviewed the various data sheets of the SI's for the following time periods:
streams without continous monitors (SI 4.8.B.1) - May 7-August 27, 1978 weekly isotopic (SI 4.8.B.3) - February 28 - March 28 and June 2 - August 1, 1978 weekly iodine (SI 4.8.B.2) - May 27 - August 1, 1978 weekly particulate (SI 4.8.B.2) - April 29 - June 9,
1978 monthly alpha (SI 4.8.B.2) - April - July, 1978 monthly iodine (SI 4.8.B.2) - April'- July, 1978 quarterly composite, Sr-89, 90 (SI 4.8.B.2) - April-July, 1978 Based on the review of these records, the inspector determined that the analyses required by Technical Specification 4'.B and Table 4.8-B were performed for the required nuclides at the specified frequency.
c ~
The inspector reviewed the two semi-annual effluent reports for calendar year 1977 and performed the necessary calculations on the reported data to verify that, on a quarterly average, the release limits of Technical Specifications 3.8.B.1, 3.8.B.2 and 3.8.B.3 were met.
d.
In conducting this inspection, the inspector verified that the licensee was retaining records of gaseous radioactive waste releases in accordance with Technical Specifications section 6.6.A.9.
The inspector had no further questions'.
Advanced Plannin and Pre aration - Unit 3 Outa e
a.
The licensee has established a policy of following the recommenda-tions in Regulatory Guide 8.8, "Information Relevant to Ensuring that Occupational Radiation Exposures at Nuclear Power Stations will be as low as Reasonably Achievable."
The Regulatory Guide
RII Rpt. Nos. 50-259/78-22, 50-260/78-25 and 50-296/78-21 I-5 states that before entering radiation areas where significant doses could be received, station personnel should have the benefit of preparations and plans that can ensure the exposures are as low as reasonably achievable (ALARA) while the personnel are performing the services.
b.
Advanced planning and preparation for the Unit 3 outage was discussed with the plant Health Physics Supervisor (Plant Health Physicist),
the outage Health Physics Supervisor and an individual assigned to the plant to provide specialized health physics training to employees involved in the outage.
The latter two individuals are members of the Muscle Shoals Office of the Division of Environmental Planning and are temporarily assigned to the plant to support the outage.
An inspector determined that, in general, the recommendations in R.G.8.8 are being followed. It was noted however, that several aspects of the program are being informally conducted and no records of those activities are being retained.
The documentation of certain activities such as special training, and post operation debriefings, was discussed with the HP Supervisor and the Plant Superintendent.
The Plant Superintendent stated that the degree of documentation necessary to support the ALARA program is still under consideration.
c
~
An inspector toured the refueling area with the outage HP Supervisor and observed the implementation of Special Work Permits, routine air sampling and work controls.
There were no further questions in the area of advanced planning and preparation.
7.
~Trainin
CFR 19.12, "Instructions to Workers", requires that all individuals working in or frequenting any portion of a restricted area receive certain instructions and information.
An inspector reviewed the records of several individuals whose names appeared on Special Work Permits.
The records indicated that the required training had been conducted.
8.
E osure Control I
a.
CFR 20.101 (a)
and (b) set forth the permissible doses to individuals working in or frequenting a restricted area.
CFR 20 '02 sets forth requirements, for determining an individual's accumulated dose, which must be met prior to allowing an individual to exceed the dose limits in 10 CFR 20.101(a).
CFR 20.202(a)
prescribes the conditions under which a licensee must supply workers with and require the use of personnel monitoring equipmen RII Rpt. Nos. 50-259/78-22, 50-260/78-25 and 50-296/78-21 I-6 An inspector reviewed personnel monitoring activities related to the Unit 3 outage, reviewed the exposure history records (Form NRC-4) of several individuals and observed the use of Special Work Permits.
The inspector had no further questions in this area.
9.
Res irato Protection Pro ram a
~
CFR 20.103,
"Exposure of Individuals to Concentrations of Radioactive Materials in Air in Restricted Areas," allows licensees to use respiratory protective equipment to limit the inhalation of radioactive material provided that such equipment is used as stipulated in Regulatory Guide 8.15,
"Acceptable Programs for Respiratory Protection."
b.
An inspector reviewed procedure, HP SIL 8, "Respiratory Protection Program" and verified that it contained the proper protection factors for respirators in use, that it specified the type training given to respirator users and that it gave adequate maintenance instructions.
c ~
An inspector reviewed the records of several individuals whose names appeared on Special Work Permits as being fully trained and fitted for respirator use.
All of the individuals had been trained and fitted except for one individual who had received the classroom training but who had not been fitted.
This individual was properly fitted, with a face mask, on his next scheduled work shift.
The individual had not been issued a mask for respiratory protection purposes.
This oversight was apparently caused by a HP Technician using the individual's name instead of his social security account number (SSAN) to verify his training.
Several other individuals with very similar names had completed all of the required training and fitting.
The HP Supervisor stated that he would caution HP Technicians to use an individual's SSAN when checking training records.
The inspector had no further questions on these aspects of the respiratory protection program.
10.
Postin and Control
CFR 19.11, "Posting of Notices to Workers," requires that licensees post certain documents or a notice informing workers where the documents may be examine v e ~
e RII Rpt. Nos. 50-259/78-22, 50-260/78-25 and 50-296/78-21 I-7 An inspector observed that the required form NRC-3 "Notices to Workers" and a letter stating the location of other documents was posted as required.
It was noted that the letter was not current.
A management representative stated that the letter would be updated.
The inspector had no further questions.
11.
Radioactive Effluent Release Re orts a
~
Technical Specification 6.7.3.A requires that the licensee submit a report of radioactive discharges (liquid and gaseous)
and solid waste shipments be submitted to the NRC within 60 days after January 1 and July 1.
The Technical Specifications require that the data shall be submitted in accordance with Regulatory Guide 1.21.
An inspector reviewed the reports for the periods July 1-December 31, 1977 and January 1 - June 30, 1978 and verified that the reports were submitted within the required time period, were in the specified form and contained the specified data.
The inspector discussed the reports with a licensee representative and made several editorial comments which were acknowledged by the licensee representative representative.
The inspector had no further questions.
b.
In RII report nos. 50-259/78-2, 50-260/78-2 and 50-296/78-2, an item of noncompliance was identified as the reports were not submitted within sixty days of the end of the reporting period as required by Technical Specifications 6.7.3.A.
In the response letter dated March 1, 1978 the licensee stated that administrative action would be taken to define responsibilities to assure that the reports are issued on time.
The inspector discussed the administrative actions with a licensee representative and was informed that actions have been taken to control the preparation and submittal of the reports.
As the last two reports have been submitted on time as required, the inspector informed licensee management that he had no further questions and this item was considered closed.
12.
Chan es to Radioactive Waste Control Procedures An inspector reviewed the changes to operating procedures 0/I-66.
Off-Gas System and 0/I-77, Radwaste System, which were made during calendar year 1978 and verified the changes were approved in accordance with Technical Specifications 6.3.B and that the changes were consistent with 10 CFR 20 and the Technical Specification RII Rpt.
Nos. 50-259/78-22, 50-260/78-25 and 50-296/78-21 I-8 The inspector had no further questions.
13.
Exit Interview At the conclusion of the inspection on September 14, 1978 the inspectors met with licensee representatives (denoted in paragraph 1).
The inspectors summarized the scope and findings of the inspection.
Mr. Dewease, Plant Superintendent, acknowledged the item of non-compliance on the testing of air cleaning systems and stated that action would be taken to perform the tests and to correct the master test schedule to correct this problem.
On the previous items of noncompliance, Mr. Dewease informed the inspectors that procedure changes were being reviewed to complete the action on these items.