IR 05000259/1981006
| ML18025B541 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 03/30/1981 |
| From: | Cantrell F, Chase J, Sullivan R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18025B539 | List: |
| References | |
| 50-259-81-06, 50-259-81-6, 50-260-81-06, 50-260-81-6, 50-296-81-06, 50-296-81-6, NUDOCS 8106170037 | |
| Download: ML18025B541 (27) | |
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p UNITEDSTATES NUCLEAR REGULATORY COMMISSION REGION I I 101 MARIETTAST., N.W., SUITE 3100 ATLANTA,GEORGIA 30303 Report Nos. 50-259/81-06,. 50-260/81-06 and 50-296/81-06 Licen see:
Tennessee Val 1 ey Authority 500A'hestnut; Street:
Chattanooga; TN'7401 Facility Name:
Browns Ferry Nuclear Plant Docket Nos. 50-259, 50-260 and 50-296 License Nos. DPR-33, DPR-52 and DPR-68 Inspection at Browns Ferry site near Athens, Alabama Inspectors:
R. F.
S ll van Date Signed J.
M. Chase t
Approved by:
F.
. Cantrell, Se SUMMARY Inspection on February 1-25, 1981 Areas Inspected hief, RRPI Branch
/
Date Signed P3'
ate igned This routine inspection involved 130, resident inspector-hours in the, areas of operational safety, reportable occurrences, plant physical protection, reactor.
trips, surveillance. testing,. circular review, and fuel receipt and inspection.
Results Of the seven areas inspected,.
no violatioh or deviations were identified in six areas, one. violation was found, in one area.
(Violation Failure to maintain secondary containment intergrity,. paragraph 5.c.).
DETAILS Persons Contacted.
Licen see Emp.l oyees, I
H. L Abercrombie, Plant Superintendent J.
L. Harness,. Assistant. Plant Superintendent (Maintenance)
J.
Bynum,, Assistant: Plant Superintendent (Operations)
J.
B. Studdard, Operations Supervisor R. Hunkapillar, Assistant Operations Supervisor J. A. Teague,. Maintenance Supervisor, Electrical M. A. Haney, Maintenance Supervisor, Mechanical J.
R. Pittman, Maintenance Supervisor, Instruments R. G. Metke,. Results Section Supervisor R. T. Smith,*/A Supervisor
.J.
E. Swindell, Outage Director B. Howard, Plant Health Physicist R. E. Jackson, Chief, Public Safety R. Cole," gA Site Representative Office of Power T. Chinn, Compliance Staff Supervisor Other licensee employees:
contacted
.included licensed senior reactor operators and reactor operators, auxiliary operators, craftsmen, techni-cians, public safety officers, gA personnel and engineering personnel.
Management Interviews Management interviews were. conducted. on February 6,
13 and 20, 1981 with the Power-Plant Superintendent:
and/or his Assistant. Superintendents and other selected members of'is staff.
The inspector-summarized the scope and findings of-'heir inspection activities.
The licensee was informed of one apparent violation as discussed in paragraph S.c.
Subsequent.
to the exit interview, F.
S.
Cantrell discussed with J..
G.
Dewease, H.
L. Abercrombie, and J.
L. Harness by telephone the need to implement corrective-actions to prevent recurrence of this type violation.
Licensee Action on Previous-Inspection Findings.
Not inspected during this report period.
Unresolved I'tems There-were-no, new-unresolved items identified during this report period.
Operational Safety.
a..The inspectors kept informed on a. daily basis of the overall plant status. and any significant safety matters related to plant operation i
Daily dicussions were held each morning with plant management and various members of the plant operating staff.
The inspectors made. frequent visits to the-control'oom such that each was visited. at least daily when an inspector was on site:.
Observations included.'nstrument readings.,
setpoints and recordings; status of operating. systems',- status and alignments of emergency standby systems; purpose of temporary tags on equipment controls-and switches; annuni-cator alarms; adherence to procedures; adherence to limiting conditions for operations; temporary alterations in effect; daily journals and data sheet entries; and control room manning.
This inspection activity also included numerous informal discussions with operators and their supervisors.
General plant tours were conducted on at least a weekly basis.
Portions of the turbine building, each reactor building and outside-areas were visited.
Observations included valve positions and system alignment; snubber and hanger conditions; instrument readings; housekeeping; radiation area controls; tag controls on equipment; work activities in progress; vital area controls; personnel badging, personnel search and escort; and vehicle search and escort.
Informal discussions were held with selected plant personnel in their functional areas during these tours.
b.
During this, report period the inspectors observed the preparation for shipment of low.specific. activity. (LSA) waste-for transfer to Barnwell, South Carolina.
This inspection consisted of a review of the previous shipment: papers,, discussions on calculations of activity, in the ship-ment, observation of radiation surveys of the shipment and loading of the, waste on-to the transport vehicle.
The inspectors, had the following-comments with respects to the pre.
paration of. the shipment of LSA material.
1,.
Ih some cases, the references to
CFR made by Radiological Control 'nstruction (RCI)-5, Shipment of Radioactive Material Excluding Fuel, did not reflect. the proper sections of 49 CFR.
The. licensee stated that RCI-5 would be reviewed and submitted to~
the. Plant Operating, Review Committee (PORC) by March 24, 1981..
2.
While. observing the loading, of LSA materials, the inspectors noted that. personnel involved in the loading went from a regulated area (where the drums. were. stored) to a clean area.(where the transport vehicle was parked) without, frisking personnel as. required by RCI.-1 ~
Licensee stated that the regulated area would be extended to include the: transport vehicle during loading operations.
C.
.
On February 25, 1981 at 1030 a.m.
an inspector noted that secondary containment boundary door ¹228 was propped open for painting.
(See
sketch of reactor building door arrangement, page 7).
The inspector was concerned that secondary containment could be jeopardized in that equipment airlock door ¹229 was being opened to receive a shipment of new fuel and to remove the empty fuel storage crates.
With doors ¹228 and ¹229 open, at the same time; a; path to the outside environment. would exi st-.
The. inspector reviewed.'ecurity logs, fuel receipt logs, unit operator logs and, conducted personnel interviews and determined that doors ¹228 and ¹229 were open simultaneously between 7:40 a.m.
and 8:40 a.m.
on February 25',
and secondary containment was violated for approximately one hour.
Door ¹232, a personnel access door (not identified as a
secondary containment boundary door) was verified to have been used for personnel passage on three occasions during the one hour period.
Interviews with plant workers indicate that personnel access door ¹232.
could have been used up to ten times for passage during the one hour time= frame.
Inaddition,door ¹232. was noted to be open 4 to 6 inches.
This condition appears to be caused by a faulty door closer, in that an ex,.tra effort is required to close this door, otherwise the door will be left ajar.
The licensee was informed that the above conditions were an apparent violation'f technical spe'cification 3.7.C.1 which requires that secondary containment to be maintained at all times.
(259, 260, and 296/81-06-01).
On February 25, unit 1 was operating at power, units
and 3 were. in a hot shutdown condition.
A similar item was brought to the licensee-attention in inspection report 50-259, 260, and 296/81;03.
The licensee, took immediate. co'rrection action to restore secondary containment by shutting door ¹228 and padlocking door ¹23Z.
Additional.
administrative controls were imposed on February 26 in that a door watch would be-posted during the. time: that equipment airlock doors are opened and the utilization of the hold order tag system to ensure equipment air lock dqors remain shut when not required to be opened.
Door Alarm and Interlock Features An apparent design problem exists concerning the interlock operation of the equipment airlock doors leading to the. equipment airlock areas.
Door ¹226 (inner pneumatic.'ealed motor-operated door)
and door ¹229 (outer pneumatic. sealed motor-operated door) are interlocked to, allow the opening of only one door at a time.
Door ¹228 and ¹230 are inter-locked to all'ow-only one door to be. opened at a time.
Door. ¹228 and
¹230 are alarmed in the control room and will alarm" if-both doors become open't same. time.
Door ¹232'as no interlocks or alarms; Door
¹229 is not interlocked to door ¹228 such that both could be opened at same time. and with access thru door ¹232, secondary containment would be. violated.
,In addition, door ¹230A, 230 and ¹226 could be open at the same time as no interlock exists between these two doors.
The licensee indicate that a review would be conducted to determined what
design changes may be required.
The inspectors will continue to follow the progress in this area.
6.,
Reportabl e. Occurances The below listed: licensee event. reports (LERs) were reviewed.to determine if the information pro'vided'met NRC: reporting requirements.
The determination included, adequacy of event description and'orrective action taken or planned; existence of potential generic: problems and the relative safety significance of each event.
Additional inplant reviews and'iscussion with plant personnel as appropriate were conducted for the reports indicated by an asterisk.
LER No
"259/7935 Rev 2
- 259/8063
"259/8078 259/8091 Rev 1,
"259/8092
.259/8102*
"259/8105 260/8002
"260/8059
"260/8102.
260/8103
~260/8104 260/8105
"296/8060.
= ~296/8061.
296/8101 Date 2/12/81 9/16/81 11/10/80 2/1'3/81 1/26/81 2/5/81 2/9/81 2/12/81.
1/26/81 1/29/81, 1/12/81 1/28/81 2/6'/81.
1/27/81 1/26/81 1/28/81 Event Motor Pinion Gear installed Backwards
.CAM inoperable LHGR exceeded H2 monitor inoperable SBGT train C inoperable Smoke detector inoperable, PH from. pond discharge exceeded'9.0 Flow control valve would not shut Drywell equipment flow system inoperable:-
SDIV rod block setting above that required, Core spray pump discharge switch set to high 4'eactor water. level switches were found set out..of tech spec limits; CMFLPD exceeded limits:
17 HCU level'witches would not operate SLC pump discharge relief valve inoperable Smoke detection inoperable
296/8102 1/30/81 Excessive flow check valves would not seat 296/8103
"296/8104
"296/8106 1/30/81 Sampling of fuel pool not performed 2/3'/81.
3A diesel generator tripped 2/12/81.
Containment HZ'nalyzer inoperable 7.
Within the. areas inspected no violation or deviations were identified.
Circular Review
~,
Licensee action on Circular 80-08, Boiling Water Reactor (BWR) Technical Specification Inconsistancy Reactor Protection System (RPS).
Time Response, was reviewed to determine if the licensee evaluation and action was appropriate to satisfy the concerns described in the circulars.
The review consisted of a review of records, procedures and discussions with plant personnel.
As maintained in Inspection Report 50-259/80-34, a disparity existed between the FSAR and technical specification as. to the time response required.
A further evaluation by the inspector show that no disparity existed.
IE Circular 80-08 is considered closed.
Within the'areas inspected no violations or deviation were identified.
Reactor Trips The inspectors reviewed activities. associated. with the below listed reactor trips during-this report period;.
The review included determination of cause, safety significance,.
performance.
of personnel and.
systems,.
and.
corrective action.
The. inspectors examined instrument. recordings, computer printouts, operations journal entries, scram reports and. had discussions with operations,.
maintenance and'ngineering support personnel as appro-priate.
On February 3,
1981, Uhit 3 tripped -at 8:59 a.m.
from full power during performances of'a surveillance test on low reactor water level switches.
A by-pass switch had not been placed in test position.
The'ormal feeder breaker to. the B recirculation pump MG set opened and the alternate feeder breaker closed. which resulted, in a; flow. dip and rapid flow recovery.
This produced'.
power spike and a high flux trip of the APRMs.
Adherence to step-by-step.
instructions was stressed; No main steam relief valves actuated, nor. were: any emergency core cooling system initiated.
Systems
~
performed, as. desi gned.
On February 7,
1981.,
Unit'
was manually tripped at'2:51 a.m.
from 38K power on. a pl'armed shutdown to repair one of the equipment drain sump pumps in the drywell. All systems performed as designed.
Within the areas. inspected no violations or deviations were identifie.
Plant Physical Protection During the cour se. of routine inspection activities, the-inspectors made observations of'certain plant physical protection activities. These included'ersonnel'adging, personnel search and escort,. vehicle search and escort, communications.and.vital area. access control.
No violations or devi'ations.were. identified within the areas inspected.
10.
Surveillance. Instruction During this report period, the inspectors observed the conduct of Surveil-lance Instruction (SI) 4.9..A. 1, Diesel Generator Monthly Operability Check on diesel genrator B. for Unit 1 and 2.
During the conduct of this SI, the inspector observed for compliance to procedure steps and ensured that the requirements of the Technical Specifications were met.
No violations or deviations were identified in th'e areas inspected.
11.
Fuel Receipt and Inspection On'ebruary 23, 1981, the inspector observed various steps in the handling of new fuel which included, the unloading of shipping containers, serial number verification,. radiation checks,, visual inspection and measurements, channeling: and storage; The. inspection. also consisted of verification of fuel inspector qua/ifications, adherence to procedure and maintenance of records.
The following records were, examined:
a.
Fuel Assembly T'ransfer Forms
'.
Fuel Inspection Check Sheets c.
Material and Equipment, Check Lists d.
Channel Inspection Check Sheets e.
Fuel Inspection Certificates In the above'reas, no violations or deviations, were identifie SKETCH Door Arrangement Reactor Building/Equipment Access Lock References; 47W200-P FSAR Fig 1.6.6 Unit
Reactor Building Secondary Containmeng Accesq poors Ipterlocked, Control Room Indication Equipment Access Outer Airlock Door 231 Equipment Access Inner Airlock Outside Environment Bool 229 Door 226 Door 232 Door 225 Poor 230A Door 230 Door 228 Door 224 Actual Conditions; Door 229
& 226 Interloched Door 230A& 229 Alarm 8 Security Secondary Alarm Statiop Door 230
& 228 Interlocked, Alarm, Indication Control Room Door 232 No Interlock, go Alarm Door 230A Padlocked Elevator Door 10 Unit 2 Reactor BuIldipg
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UNITEO STATES NUCLEAR REGULATORY COMMISS(ON
- REGION.II.
101 MARIETTAST., N:W., SUITE 3'l00 ATLANTA,GEORGIA 30303 MAR 6 lgsl Tennessee Valley Authority, ATTN:
H. G. Parris Manager of Power 500A Chestnut Street Tower II Chattanooga, TN 37401 Gentlemen:
Subject:
Report Nos. 50-259/81-5, 50-260/81-5 and 50-296/81-5 This refers to the special safety inspection conducted by G.
L. Troup of this office on February 9"13, 1981, of activities authorized by NRC Operating License Nos.
DPR-33, DPR-52 and DPR-68 for the Browns Ferry facility.
Our preliminary findings were discussed with J.
L. Harness at the conclusion of the inspection.
Areas examined during the inspection and our findings are discussed in the enclosed inspection report.
tltithin these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations by the inspector.
During the inspection, it was found that certain activities under your license t
appear to violate NRC requirements'his item and references to pertinent requirements are listed in the Notice of Violation enclosed herewith as Appen-dix A.
Elements to be included in your response are delineated in Appendix A.
In accordance with Section 2.790 of the NRC "Rules of Practice," Part', Title 10, Code of Federal Regulations, a copy of this letter and the enclosed inspec-tion report will be.placed in the NRC Public Document Room. If thi s report con-tains any information that you believe to be proprietary, it is necessary that
,. you make a written application wi,thin, 20 days to this office to withhold such information fr'om public disclosure.
Any such application must include the basis
.for.claiming,.that the,,information,is.,proprietary,.and.
the proprietary information.
should be contained in a separate part of the document.
If we do not hear from you in this regard within the specified period, the report will be placed in the Public Document, Room.
Should you have any questions concerning this letter, we will be glad to discuss them with you.
ng rec r
Di'vision of Resident and Reactor Project Inspection
Enclosures:
See Page
V
e Tennessee. Valley Authority" Enclosures:.
1.
Appendix A, Notice of Violation 2.
Inspection Report Nos. 50-259/81-5, 50-260/81-5 and 50-296/81-5 MAR 6 198l,
REGION I I 101 MARIETTAST.. N:W., SUITE'3100 '
ATLANTA,GEORGIA 30303 Report Nos.
50-259/81-15, 50-260/81-5 and 50-296/81-5 Licensee:
Tennessee Valley Authority 500A Chestnut Street Chattanooga, TN 37401 Facility Name:
Browns Ferry Docket Nos.
50-259, 50-260 and 50-296 License Nos.
OPR-33, OPR-52 and DPR-68 Inspection at Browns Ferry Nuclear Plant near. Athens, Alabama, Inspector:
G. L. Troup,
)gf Approved by: ~
VY,'.
M. Hos y, cting Chi f,. Facilities Radiation Pl Date Signed Date'S>ghed
Protec ion Section, Te hnical Inspection Branch Division of Engineering and Technical Inspection SUMMARY Inspection on February 9"13, 1981 Areas Inspected This special, unannounced inspection'nvolved 33 ins*pector-hours on site in the
'
.aI.eas,. of.radiation: protection:.including..evaluation., of personnel doses, author.-.
ized doses, dosimetry and reports relating to-an apparent overexposure of a
worker.
Results Of the four areas inspected, no violations of NRC requirements or deviations were identified in three areas; one violation was found in one area (failure to retain exposure data in accordance with 10 CFR 20. 102.}.
DETAILS Pesons Contacted Licensee Employees Browns Ferry Nuclear Plant J. L. Harness, Assistant Plant Superintendent
"D. C. Cummins, Assistant Health Physics Supervisor
"R. T. Smith, guality Assurance Supervisor
"T. L. Chinn, Compliance Supervisor
"E. M. Cargill, Assistant Radiation Control Supervisor (Outage)
"W. Simpkins, Health Physics Engineer Radiological Hygiene Branch, Division of Occupational. Health and Safety S. G. Bugg, Super visor, Radiation Exposure Management Group Nuclear Power Division, Office of Power J.
W. Hufham, Assistant to the Director Other licensee employees contacted included 2 construction craftsmen,
technicians, 2 security force members and 3 office personnel.
NRC Resident Inspector
- R. F. Sullivan J.
W. Chase 8 ~
~
"Attended exit interv'iew
'.'xit Interview The inspection scope and findings were summarized on February 13, 1981 with those persons indicated in paragraph 1 above.
The inspector reviewed the results of his investigation of.the apparent overexposure and stated that his investigation indicated that the individual had not received a dose to his body of the magnitude indicated by the TLD.
This was the same conclu-sion which the licensee had reached.
Regarding the violation concerning retention of exposure forms (paragraph 6),
the inspector stated that the principal concern dealt with the large numbers of records which are pro-cessed during outages and the need to implement controls to assure that they
.are handled and.fi1,ed properly,, not just; the: specifics of. one particular
.
record.
These comments were acknowledged by'r.
Harness.'Licensee Action on Previous Inspection Findings I
Not inspecte.;
4.
Unresolved Items
\\
Unresolved items were not identified during this inspection.
5.
Description of Event a.
On January 6,
1981, the.'TVA Radiation Exposure Management Group reported that the thermoluminescent dosimeter badge (TLO) issued to an outage worker (individual A) for the month of December, 1980 indicated a
dose of 2.818 rems.
When this dose was added to the dose previously received by the individual during the fourth calendar quarter, the total dose for the quarter was 3.429 Rems;
CFR 20. 101 (b) specifies a maximum dose during a calendar quarter of 3 Rems.
Both individuals were outage workers working in the same work crew.
No other workers on the crew received a dose for the month of December greater than 600 millirems as measured by TLO.
The doses for the two individuals as measured by self-reading dosimeters were 804 millirems ms, respectively.
C.
and 786 millire 6... Evaluation of, Doses b.
On January 7,
1981 the Radiation Exposure Management Group reported that, the TLO issued to another outage worker (individual 8) indicated a
dose of 2.21 Rems.
The fourth quarter dose for this individual was 2.793 Rems, which is below the regulatory limit.
a.
Following the identification of the apparent overexposure to indivi-dual A, the licensee initiated an investigation to establish the validity of the dose and to identify the cause(s)
of the overexposure.
Incl.uded in this.'investigati.on were:..
...,..
.".,(1) :;.Review. of":dosimeter, logs. (rezera logs),...radiological...incident
.
reports,: and special work permits (SMP's);
(2)
Review of radiation surveys of work areas and conduct of special.
radiation surveys to identify any hot spots or streamers which might have previously not been identified; E
(3)
Calculation of doses based on radiation levels and stay times for each SMP; (4)
Interview with both individuals and the crew foreman; (5)
. Comparison of. doses for both.individuals with the doses of. other
.
w'orkmen'w'ho performed'-'the'same'work at the same time; and (6)
Testing of TLD's for adequate response.
e
Based on this investigation, nothing was identified which indicated that the-doses received by the two: individuals were of. the magnitude measured by the TLO's.
b.
The inspector reviewed the results of the licensee's investigation, independently calculated doses based on the SQP information and compared the doses received by other members of the work crew with the doses for the two individuals for both self reading dosimeters and TLO's.
The inspector also inspected the TLO storage area for possible sources which might have affected the measured doses, and reviewed the records of when radiography was performed in the areas where the individuals worked.
The inspector did not identify any probable cause for the high dose for the two individuals.
C.
The inspector also interviewed the general foreman and individual A by telephone.
Neithe~ individual was able to provide any information not previously provided to the licensee.
Neither individual was able to provide any information which would'xplain the disparity in doses between the workers on the crew and individuals A and B.
7.
Authorized Ooses a.
CFR 20.101(b)(1) permits an individual to receive a whole body dose of 3 rems provided that a
Form NRC-4 has been completed in accordance with section 20. 102, and the accumulated lifetime dose does not exceed 5 (N-18)
rems.
If these actions have not been completed, then the
. permissible dose is 14 rems per calender quarter.
b.
The inspector reviewed the records for individual A and verified that a current Form NRC-4 had been completed by him in September 1980.
The
....inspector'lso-reviewed.,the.
Personnel,.Exposure Computer Printout..-
(issued twice d'aily) and verified that the cumulative lifetime dose and
,...:.::,.:.allowable".lifetime.,dose had:.been:.determined...,.Neither an authorized..,::.....
dose o'f 3 rems nor the assigne'd dose of 3.429 gems would have resulted in the individual exceeding his allowable lifetime dose.
The inspec-tor had no further questions on the authorized dose for individual A.
C.
The inspector also reviewed the dose records for individual B.
How-ever,- the licensee could 'not locate the cut rent Form NRC-4 either in the plant files or in the dosimetry files.
Oiscussions with indi-viduals involved with these records at the plant revealed that the individual had filled out the Form NRC-4 in November 1980.
The indi-viduals involved stated that the individual and his foreman had come to the office together and discussed the need for a current form before it was signed;.:The; inspector..reviewed the Personnel Exposure -Computer Printouts for Nov'ember 26. 'The 'first printout at 8: 14 a.m. 'showed that the individual did not have a current form and his allowable quarterly dose was 1,250 mrems; the second printout at 7: 19 p.m.
showed that the individual had a current form and his allowable quarterly dose was
c
.4, 3,000 mrems.
The individual who does the computer input told the inspector that the data are taken directly off the form. so if the computer base was changed, then the completed 'form was available.
Based on the computer records and discussions with the personnel, the inspector concluded that a
Form NRC-4 had been completed for indivi-dual B but had been lost or misplaced.
Despite an extensive search of the files, the form could not be located.
d.
CFR 20. 102(c)(2) 'requires that the licensee shall retain and pre-serve records used in preparing Form NRC-4.
In that the form could not be located after an extensive search the inspector concluded that it had not been retained.
This is a violation.
(259/81-15-01, 260/296/
81-05"01).
The inspector emphasized to licensee management that care must be exercised to assure that personnel records such as these are properly handled and filed, expecially when during outages when copious amounts. of records are being generated.
This comment was acknowledged by licensee representatives.
8.
Dosimetry a.
During work in the radiation control ar eas, individuals wore both self-reading dosimeters and thermoluminescent dosimeters (TLD's).
t Doses recorded on work permits were based on self-reading dosimeters.
The inspector asked if the dosimeters used by the two individuals had been checked for accuracy, malfunction, etc.
A licensee representative stated. that for much of the work, high range dosimeter s had been issued when entering the area and returned when exiting.
The same dosimeter was not used each time so any discrepancies which might be identified with a papticular dosimeter could not be related to the dose any particular:individual may or may not have received.
'I
b.
The TLD's used by'VA contain two chips'. 'o evaluate the dose, each
- "..::-,.:"-,...chip...i:s,read
.seperately;;... The...'inspector reviewed the strip..chart...,,...,
pr'intout for the energy output ("glow'urves") for the two chips in the TLD worn by individual A., glow curves for other chips and the light response curves for checking the instrument performance.
The relative size of the peaks for the two chips were comparable and were markedly larger than the peaks for other chips.
The shapes of both curves were consistent with the curves for other chips and indicated no anomalies or breaks and the light response curves appeared normal'ased on these records the inspector did not identify any irregulari-ties which would invalidate the dose of 2.818 Rems which was reported for the TLO of individual A.
c.
A,licensee representative, discussed. the checks performed on the TLD, eh>ps, which included checking for a retained dose due to improper preparation and response to a
known dose.
The licensee representative stated that the checks did not indicate the presence of a retained dose and the chip responded properly to the known dose.
The inspector I
'
~
reviewed the data from the exposure of several chips, including the two chips from the TLD issued to individual A, and concluded that the response-to a
known dose was consistent for the chips and did not indicate any anomaly in the performance of the chips.
A licensee representative stated that. based on the checks of the chips, the dose of 2.818 Rems was measured by the chip 'as a true dose but nothing can be concluded concerning 'the dose which the individua.l might have received, because there was no way of determining when or how the dose was received.
9.
Reports a.
CFR 20.405.(a) requires that each licensee shall make a report in writing within 30 days of each exposure of an individual to radiation in excess of the applicable limits in section 20. 101.
On February 4,
1981 the licensee submitted.a written report of the exposure which exceeded the quarterly limit for whole body exposure of 10 CFR 20. 101-(b).
After,reviewing the report the inspector had several questions concerning the actions taken during the investigation by the licensee and the conclusions drawn.
These were discussed with a
licensee representative during the inspection.
The inspector requested that a
supplemental report be submitted to clarify these questions; this was acknowledged by the licensee representative.
A supplemental report was submitted on February 13, 1981.
The inspector had no further questions concerning the report.
b.
CFR 19. 13(d) requires that when a licensee is required pursuant to
CFR 20.405 to report to the Commission any exposure of an indivi-dual. in excess of regulatory limits, the licensee shall also furnish the individual a report on his exposure data.
The inspector reviewed
. the report which was sent,to individual A on February 4, 1981 in ac-cordance'with 10 CFR 19. 13(d); the inspector had no further questions.
~
C
~
10.
Conclusion a.
In the report of the event, the licensee stated
"based on work records and pocket dosimeter data, there is no indication of an exposure of the magnitude indicated by the TLD badges".
This position was substanti-ated by the licensee's investigation and by the inspector's review.
The inspector concluded that the individual did not receive a dose to hfs person of the magnitude on the TLD and that an overexposure had not occurred.
b.
The licensee's report further stated
"since this discrepancy cannot be accounted, for, the.TLD data.,will. be entered into the radiati.on exposure
.
history for these empl'oyees."
'The 'inspector -noted that this was a
conservative approach and concluded that this was an acceptable re-solution of the discrepancy.
'
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