IR 05000259/1985042
| ML18029A855 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 08/29/1985 |
| From: | Collins T, Hosey C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18029A854 | List: |
| References | |
| 50-259-85-42, 50-260-85-42, 50-296-85-42, NUDOCS 8509160203 | |
| Download: ML18029A855 (14) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.IN.
ATLANTA,GEORGIA 30323 gS 30 88b Report Nos.:
50-259/85-42, 50-260/85-42, and 50-296/85-42 Licensee:
Tennessee Valley Authority 500A Chestnut Street Chattanooga, TN 37401 Docket Nos.:
50-259, 50-260 and 50-296 License Nos.:
DPR-33, DPR-52, and DPR-68 Facility Name:
Browns Ferry 1, 2, and
Inspection Conducted:
Apuust 12-16, 1989 Inspector:
T.
R. Collins Approved by: sg M.
C.
M. Hosey, Section Chief Division of Radiation Safety and Safeguards Date Si ned Pg gS Date Signed SUMMARY Scope:
This routine, unannounced inspection involved 36 inspector-hours onsite in the areas of organization and management controls, control of radioactive materials and contamination, surveys and monitoring, external occupational dose control and personnel dosimetry, internal exposure control, solid radwaste, shipment of radioactive material, ALARA, audits, IE Information Notices.
Results:
No violations or deviations were identified.
8509g60203 8508~30259 pDR ADOCK 050 pDR
REPORT DETAILS Persons Contacted Licensee Employees
- R. L. Lewis, Plant Manager J.
E. Swindell, Assistant Plant Manager
- A. W. Sorrel, Health Physics Supervisor
- L. J. Politte, Site Services
- D. Mims, Engineering Group Supervisor J.
M. Corey, Health Physics Engineering Unit Supervisor H.
M. Crowson, Health Physics Outage Unit Supervisor
- B. C. Morris, Plant Compliance
"ED G. Balch, Plant Compliance Other licensee employees contacted included technicians, operators, mechanics, security force members,,and office personnel.
NRC Resident Inspectors
- G. L. Paulk, Senior Resident Inspector-
,"C. A. Patterson, Resident Inspector
- C.
R. Brooks, Resident Inspector
- Attended exit interview Exit Interview The inspection scope and findings were summarized on March 1, 1985, with those persons indicated in paragraph 1 above.
The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspection.
Licensee Action on Previous Enforcement Matters (Closed)
Violation (50-259, 260, 296/83-25-01)
Radioactive material not labeled in accordance with 10 CFR 20.203(e)
and (f).
The inspector reviewed and verified the corrective actions as stated in the licensee's letter dated September 9,
1983.
(Closed) Violation (50-259, 260, 296/84-19-01)
Failure to properly brace a
shipment of radioactive material for transport.
The inspector reviewed and verified the corrective actions as stated in the licensee's letter dated July 30, 1984.
(Closed) Violation (50-259, 260, 296/84-37-01)
Failure to follow procedure in the Chemi stry Laboratory while handling sample bottles in the laboratory
fume hood.
The inspector reviewed and.verified the corrective actions as stated in the licensee's letter dated November 1,
1984.
4.
Training and gualifications (83723)
a.
'Basic Radiation Protection Training The licensee was required by
CFR 19. 12 to provide basic radiation protection training to workers.
Regulatory Guides 8.27, 8.29, and 8. 13, outline topics that should be included in such training.
Chapters
and 13 of the FSAR contain further commitments regarding training.
The inspector discussed the initial and refresher general employee radiation protection training (GET) with the Training Super-visor and reviewed lesson plans to determine what changes had been made in GET training and the scope of these changes.
The inspector reviewed the GET training records for selected individuals to determine if records reflected adequate completion of GET initial and refresher training.
Radiation Protection and Chemistry Technician gualification The licensee was required by Technical Specification 6. 1 to qualify radiation protection and chemistry technicians in accordance with ANSI 18. 1.
The inspector discussed with the technicians their training and qualification program.
The inspector discussed, with one radiation protection technician-in-training, the qualification program and assignments to assure that they had not been assigned to work independently and had been qualified for assigned tasks.
The inspector reviewed the program for qualification of contract radiation protection technicians and contract chemistry technicians.
The inspector discussed separately with two contract technicians their previous experience and training to determine if it was comprehensive or if it had been limited to selected tasks.
The inspector also discussed the training and qualification program the licensee had provided, what limits had been placed on their activities, and controls that should be established for one task they were qualified to perform.
The inspector reviewed the resumes,. training records, and tests for these technicians.
Radiatiou. Protection and Chemistry Foreman gualifications Technical Specification 6. 1 required radiation protection and chemistry supervisory staff have four years experience in their specialty.
The inspector discussed, with one recently appointed supervisor from the radiation protection departments, training and experience and selected duties and responsibilities of the respective positions.
The inspector reviewed the records of these individuals'xperience.
No violations or deviations were identifie +1
5.
Organization and Management Controls (83722)
a.
Organization The licensee was required by Technical Specification 6. 1 to implement the plant organization specified in Table 6. 1-2.
Regulatory Guide 8.8 specifies certain functions and responsibilities to be assigned to the Radiation Protection Manager and radiation protection responsibilities to be assigned to line management.
The inspector discussed with a health physics supervisor, and health physics shi.ft foreman, the type, and degree of interaction between plant groups.
b.
Staffing Technical Specification 6.8 specified minimum plant staffing.
The inspector discussed authorized staffing levels vs.
actual on-board staffing separately with the Health Physics Supervisor.
There has been a high turnover rate in the health physics organization.
During the period June 1984 to August 1985, twenty-four (24) technicians and three supervisors left the plant.
The health physics program has relied heavily on contract health physics technicians who have worked at the plant for a significant period of-time.
No violations or deviations were identified 6.
.Control of Radioactive Materials and Contamination, Surveys, and Monitoring (83726)
The licensee was required by 10 CFR 20.201(b),
20.403, and 20.401 to perform surveys to show compliance with regulatory limits and to maintain records of such surveys.
Technical Specification 6.8 required the licensee to follow written procedures.
Radiological control procedures further outlined survey methods.
a.
Surveys The inspector discussed the radiological controls and monitoring of selected radiation work permits (RWPs)
and surveys with the health physics technician assigned and other workers.
During plant tours, the inspector observed radiation level and contamination survey results outside selected cubicles.
The inspector performed independent radiation level surveys of selected areas and compared them to licensee survey results.
The inspector also noted that the licensee had established goals for reducing the number of contaminated areas in the facilit Frisking During tours of the plant, the inspector observed the exit of w'orkers and movement of material from contamination control to clean areas to determine if proper frisking was performed by workers and that proper direct and removable contamination surveys were performed on materials.
Instrumentation d.
During plant tours, the inspector discussed the use of survey instru-ments by plant staff.
The inspector examined calibration stickers on radiation protection instruments in use by licensee staff and stored in the radiation protection laboratory.
The inspector discussed with radiation protection technicians the methods for doing instrument source checks prior to use.
Release of Materials for Unrestricted Use The inspector discussed with a radiation protection technician, the program for survey-out of items from contaminated areas.
The inspector observed release surveys performed by radiation protection technicians, and documentation of results.
During tours of plant areas, the inspector observed posting of containers and performed independent surveys to determine if containers of radioactive material were properly identified.
No violations or deviations were identified.
External Occupational Dose Control and Personal Dosimetry (83724)
During plant tours, the inspector checked the security of the locks at two locked high radiation areas.
Use of Dosimeters and Controls The l.icensee was required by 10 CFR 20.202, 20.201(b),
20.101, 20.102, 20.403, 20.405, 19. 13, 20.407, and 20.408 to maintain worker's doses below specified levels and keep records of and make reports of doses.
The licensee was required by
CFR 20.203 and Technical Specification 6. 12 to post and control access to plant areas.
During observation of work in the plant, the inspector observed the wearing of thermoluminescent dosimeters (TLDs) and pocket dosimeters by workers.
The inspector determined from discussions with workers that they were aware of their current total exposure and administrative exposure controls.
During plant tours, the inspector observed the posting of areas and made independent measurements of dose to assure proper postin r
b.
Dosimetry Results The inspector reviewed the exposure controls for January 1985 - August 1985.
For four individuals who received greater than 1.25 rems in one quarter, the inspector examined each individual's dosimetry file to determine if NRC Form 4's had been completed.
No violations or deviations were identified.
8.
Internal Exposure Control and Assessment (83725)
The licensee was required by 10 CFR 20. 103 to control uptakes of radioactive material.
a.
Control Measures During plant tours, the inspector observed the use of temporary ventilation systems, containment enclosures, and respirators.
The inspector discussed the use of this equipment with radiation protection personnel.
b.
Respiratory Maintenance and Issue The inspector observed the cleaning and maintenance of respirators with.
staff members assigned the task.
The inspector discussed with health physics personnel the method used to ensure only qualified personnel used respirators.
No violations or deviations were identified 9.
Maintaining Occupational Doses As Low As Reasonably Achievable (ALARA)
(83728)
CFR 20. 1(c) specifies that licensees should implement programs to keep workers'oses ALARA.
FSAR Chapter 12 also contains licensee commitments regarding worker ALARA actions.
'a
Worker and Supervisor Actions The inspector discussed dose control measures with ten workers on the job and two maintenance and two operations supervisors to determine their degree of involvement in dose reductions The inspector discussed with the supervi'sors their actions to reduce individual and collective doses, concentrating particularly on staff members with highest doses.
The inspector also discussed these actions to set dose goals for tasks, methods used to reduce doses, and techniques used to monitor performance against goal V,
b.
ALARA Procedure Changes The inspector reviewed recent changes to administrative procedures that implemented the elements of ALARA.
The inspector discussed these changes with the Health Physics Supervisor and the ALARA Engineer.
c.
ALARA Reviews The inspector reviewed the ALARA review documentation for activities during 1984 and 1985, and discussed resulting actions with a
Modifications Manager and the ALARA engineer.
d.
ALARA Reports The inspector reviewed the ALARA outage reports for specific jobs during the 1985 outage and the 1985 ALARA summary report and discussed the results with the Health Physics Supervisor.
The total cumulative TLD dose for 1985 was 715 man-rem with a projection of 1463 man-rem for 1985.
e.
ALARA Program Support The inspector reviewed the minutes
.of the previous ALARA committee meetings for 1984 and 1985 and di.scussed ALARA projects with the ALARA.-
engineer and the Health Physics unit supervisors.
During the course of these meetings, ALARA engineering reviews, other outage exposure issues that substantially affected the modifications organization were discussed.
No violations or deviations were identified.
10.
Audits The inspector reviewed audits of the radiation protection operations during 1984 and 1985; the respo'nses to these audits; and the status of selected corrective actions resulting from the audits.
Corrective actions for the audit findings appeared to be appropriate.
No violations or deviations were identified.
ll.
Transportation of Radioactive Material (86721)
CFR 71.5 requires that licensees who transport licensed material outside the confines of its plant or other place of use, or who deliver 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 Transportatioq in 49 CFR Parts 170 through 189.
CFR 71.91 specifies records that the licensee is required to maintain for each non-exempt shipment of radioactive material.
The inspector reviewed selected records of radioactive waste shipments made during the period of
August 1985 and verified that the licensee had maintained the records required by 10 CFR 71.91.
The inspector observed the performance of radiological surveys and the loading of a waste shipment, consisting of dewatered resin on August 13, 1985.
The inspector performed independent radiation surveys and verified that the radiation levels were within the limits specified in 49 CFR.
The inspector also reviewed the appropriate records for the shipment and discussed the shipment with licensee representatives.
The inspector reviewed plant procedures for the preparation, documentation, and shipment of radioactive material and verified that the procedures was consistent with regulations.
No violations or deviations were identified.
12.
Solid Waste (84722)
CFR 20.311 requires a licensee who transfers radioactive waste to a land disposal facility to prepare all waste so that the waste is classified in accordance with 10 CFR 61.55 and meets the waste characteristic requirements of
CFR 61.56.
It further establishes specific requirements for conducting a quality control program and for maintaining a manifest tracking system for all shipments.
The inspector reviewed the methods used by the licensee to assure that waste was properly classified, met the waste forms and characteristics required by
CFR 61 and met the disposal site license conditions and discussed the use of these methods with licensee representatives.
The inspector reviewed selected manifests prepared for waste shipments made during the period August 1985 to verify that a tracking system was being used to insure that shipments arrived at the intended destination without undue delay.
No violations or deviations were identified.
13.
IE Information Notices The following IE Information Notices were reviewed to ensure their receipt and review by -appropriate licensee management:
IN-84-75, Defective Detector Tubes Model No.
71623 for Analog Tel etector Model 6112B IN-85-46, Clarification of Several Aspects of Removable Radio-active Surface Contamination Limits for Transport Packages IN-85-48, Respirator Users Notice, Defective Self-Contained Breathing Apparatus Air Cylinders