IR 05000259/1986010

Insp Repts 50-259/86-10,50-260/86-10 & 50-296/86-10 on 860408.Violation Noted:Failure to Follow Radiation Control Procedures

ML20205M159
Person / Time
Site:	Browns Ferry
Issue date:	04/02/1986
From:	Cooper W, Hosey C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20205M125	List: IR 05000259/1986010 ML20205M121 ML20205M133
References
50-259-86-10, 50-260-86-10, 50-296-86-10, NUDOCS 8604150112
Download: ML20205M159 (6)

Text

r O

UNITED STATES

[P #f og*o NUCLEAR REGULATORY COMMISSION

"

y" p REGloN il

' _j to1 MARIETTA STREET, *'- 2 ATLANTA, GEORGI A 30323

'+9 9

APR 0 81986'

Report Nos.: 50-259/86-10, 50-260/86-10, and 50-296/86-10 Licensee: Tennessee Valley Authority 6N38 A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 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 3 Inspection Co ducted: March 10-2 , 1986 Inspector: h/Nuhs~ M y' . J-M-8(o W. T. Cooper Date Signed

.

/

Approved b : r Iu ///2/t(,

C, M Wrs'feff Se Wion Chief Date Signed ivision of Radiation Safety and Safeguards SUMMARY Scope: This routine, unannounced inspection involved 22 inspector-hours on site in the areas of organization and management of the health physics program, training and qualifications of the facility staff, external exposure control and personal dosimetry, internal exposure control, and 10 CFR 61 waste classification and characterizatio I Results: One violation for failure to follow procedure I

!

i

W J

!

i h

G

,

l

,

_ _ _ - - - - . _

E

.- --

.

fi s

REPORT DETAILS Persons Contacted Licensee Employees

• L. Lewis, Plant Manager

• C. Mims, Superintendent, Technical Services

• Crowson, Supervisor, Health Physics

• C. Willard, Compliance Engineer

• Mastich, Acting Health Physics Supervisor, Outage Unit

• Witt, Acting Radwasto Section Supervisor

• H. Albright, Health Physics Section, Supervisor, Plant Lab J. M. Corey, Technical Section Supervisor R. D. Colvett, Health Physicist, Dosimetry Section Other licensee employees contacted included four technicians, two security force members, and five office personne . Exit Interview The inspection scope and findings were summarized on March 12, 1986; with those persons indicated in paragraph 1 above. The inspector discussed the licensee's health physics organization and management program, 10 CFR 61 waste classification and characterization, and internal and external exposure control programs with licensee management. The inspector also discussed in detail two apparent violations of NRC requirement.s: failure to evaluate the radiation hazards present prior to entry into the Unit 2 condenser bay on September 27,1985 (Paragraph 8), and failure to follow access procedures for the plant regulated area (Paragraph 4). Licensee management requested that both apparent violations ~ be considered licensee identified. The inspector stated that credit for licensee identification would be determined after review by the Regional Office staff. The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspectio . Licensee Action on Previous Enforcement Matters This subject was not addressed in the inspectio . Organization and Management Controls (83722)

The licensee was required by Technical Specification (TS) 6.1 to implement the plant organization specified in Figure 6.1-2. The responsibilities, authorities, and other management controls were further outlined in Chapters 12 and 13 of the FSAR. TS 6.2 specified the members of the Nuclear Safety Review Board (NSRB) and outlined its functions and authoritie Regulatory Guide 8.8 specified certain functions and responsibilities to be I

_ - _ _ - - - - - _- - _ _ _ - - - - _ _ _ ----__-__ _ _ _ _ _ _ - _ _ _ _

_ _ - - - - - _ _

O

.

assigned to the Radiation Protection Manager and radiation protection responsibilities to be assigned to line managemen The inspector reviewed recent changes to the plant organization, to determine their effect on plant radiological controls, by examining the resulting changes to administrative procedures and position descriptions and discussing the changes with selected members of the plant staf The inspector reviewed the licensee's program for self-identification of weaknesses related to radiation protection and control of radioactive material. The licensee tracked radiological incident reports (RIRs) and the corrective actions recommended and taken using the plant computer syste The status of any RIR, corrective action, etc., may be reviewed at any time using this syste No violations or deviations were identifie . Training and Qualifications (83723)

During the review of the licensee's RIR system, the inspector noted that RIRs were being written for entries made by licensee employees when general employee radiation protection training (GET) had expired. RIRs were also being written for entries made by licensee employees with expired whole body count qualifications into areas controlled by a radiation work permit (RWP).

The inspectoy discussed area access controls and employee qualifications with a licensee representativ The licensee representative stated that the plant security force had monitored entry requirements such as current whole body counts, medical qualifications and training. When any of the requirements expired, the security force would remove the employee's security badge from service and deny the employee access to the plant protected area until the qualifications were me The security force discontinued the practice of removing security badges in September 198 The HP group did not have another system in place to ensure unqualified  ;

personnel were not allowed onsite and into the regulated areas of the plan ;

Licensee TS 6.3 required that detailed radiation control procedures be '

prepared, approved, and adhered t Plant Procedure BF RCI-8, Radiobioassay Program, required a current whole body count prior to a contamination zone entr Plant procedure BF RCI-9, RWPs,.. required general employee level II 1 training to be current prior to entry on a RW RIRs written by the  !

licensee between September 1, 1985 and February 28, 1986, indicated that j 40 licensee personnel entered- RWP areas and 19 personnel entered contamination zones and did not meet the procedural requirements for entry into those areas. The failure to adhere to radiation control procedures was identified as an apparent violation of TS 6.3 (50-259, 260, 296/86-10-01).

i Licensee Audits and Surveillances (83722, 83723, 83724, 83725, 83726, 83728, l 84722, and 86721)

The inspector reviewed audits of the licensee's program to maintain exposures as low as reasonably achievable ( ALARA), radiological control l l

l

_ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ __ - -_ --- ___ _ _-_ __ _ _ _ _ i

, - _ _ . . . .

programs, RIR program, the training program for HP technicians, radwaste, chemistry and transportation conducted in 1985 and 1986. The audits were conducted using staff with technical backgrounds in radiological controls, were thorough in depth and scope and the audit findings were well documente No violations or deviations were identifie . External Occupational Dose Control and Personal Dosimetry (83524)

The inspector discussed the licensee external dosimetry program with licensee representative The inspector also discussed assignment of dose from beta radiation to the lens of the eye and the licensee's dose assessments based upon the data contained on RWP time sheets with licensee renresentatives. RWP time sheets were routinely collected every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and routine or standing RWP time sheets were collected each 7 days.

l Information obtained from the RWP time sheets was entered into the plant computer system for use in radiological safety evaluations, dose assessment and tracking, ALARA and administrative documentatio The inspector discussed the licensee's NVLAP accreditation program with licensee representatives and reviewed the results of the NVLAP proficiency test dated September 4, 1985. The test indicated that the licensee passed all categories I through VII, inclusive. A licensee representative stated that the NVL6P certification was issued to the Muscle Shoals Laboratory and each licensee site was considered a satellite dosimetry sectio When thermoluminescent dosimeter (TLD) data was generated by the facility, the health physics dose tracking (HPDT) computer transmitted that information to Muscle Shoals where it was evaluate No violations or deviations were identifie . Internal Exposure Control and Assessment (83525)

The licensee was required by 10 CFR 20.103, 20.201(b), 20.401, and 20.405 to control uptakes of radioactive material, assess such uptakes, and keep records of and make reports of such uptakes. FSAR Chapter 12 also includod commitments regarding internal exposure control and assessmen The inspector reviewed the licensee's assessment of an uptake of radioactive material which occurred September 27, 1985. Inspection of the baffle area of the Unit 2 condenser required that a licensee employee crawl through low overhead area Survey data noted on the RWP indicated smearable contamination levels of 3,000 disintegrations per minute per 100 square centimeters. The employee was not accompanied on this inspection by the HP technician, who waited on a platfurm overhead. Upon completion of the inspection when exiting the condenser, the worker was found to have contaminated clothing and shoes. The Health Physics Outage Unit Supervisor interviewed all involved personnel, and reviewed the RWP with the HP covering the job. A survey made two days prior to the entry indicated contamination levels in the false bottom area of the condenser where the

_ _ _ _

_ __ _ _ ___._ _ -- -- -- -- -

..

5 -

-

inspection was conducted of 40 millirad per 100 square centimeters. The entry resulted in the employee having a radioactive material uptake of 46 percent of a maximum permissible organ burden. The licensee's investigation of the incident was thorough and well documente ~.

Corrective actions taken by the licensee include:

The health physics technician responsible for the job coverage was fire All personnel assigned to the outage were briefed on radiological

, conditions inside the condense The shift supervisor and condenser bay lead technicians on all shifts discussed the condensate outage schedule and associated radiological hazard *

All technicians assigned to the condenser bay were instructed to become familiar with the condenser false bottom and hot well are ,

_

This incident was identified as an apparent violation of 10 CFR 20.201(b)

for failure to evaluate the radiation hazards present when the RWP in use for condenser entries was not updated with the most current survey dat ~~

However, 10 CFR 2, Appendix C states that because the NRC encourages and supports licensee initiative for self-identification and correction of  : -

problems, NRC will not generally issue a Notice of Violation for a violation that meets all of the following tests: (1) It was identified by the licensee; (2) It fits in Severity Level IV or V; (3) It was reported, if required; (4) It was corrected within a reasonable time, including measures to prevent recurrence, within a reasonable time; (5) It was not a violation that could reasonably be expected to have been prevented by the licensee's corrective action for a previous violation. The apparent violation stated above meets the criteria for licensee identified, therefore, no Notice of '

Violation will be issue .

~ '

9. Solid Waste (84722)

I 10 CFR 20.311 required a licensee who transfers radioactive waste to a land t disposal facility to prepare all waste so that the waste is classified in '

accordance with 10 CFR 61.55 and meets the waste characteristics

-

.

-

c requirements of 10 CFR 61.56. It further established specific requirements 4 for conducting a quality control program and for maintaining a manifest

tracking system for all shipment .

<

..

The inspector reviewed plant procedures for the packaging, classifying, and tracking of radioactive waste shipped to low-level waste burial facilitie '

The inspector reviewed the methods used by the licensee to assure that waste _'_

was properly classified, met the waste forms and characteristics required by 10 CFR 61 and met the disposal site license conditions and discussed the use of these methods with licensee representative y[ QJ#.

y ..

,e s W

_

g q ggggg, '

S an T_T-1C$ -

,

o

.

No violations or deviations were identifie . Facility Statistics The total exposure during 1985 as measured by TLD was 1159 man-re During 1984, the licensee documented 413 personnel contaminations. During 1985, the licensee documented 168 personnel contaminations which was a decrease of 245%.

During calendar year 1984, the licensee generated 114,057 cubic feet (ft )3 of solid radioactive waste and shipped 129,578 ft3 of. solid waste containing 5881 curies of activity for burial. During calendar year 1985, the licensee generated 80,003 ft3 of solid waste, shipped 82,177 ft3 containing 3079 curies for burial and had 3,100 ft3 of solid radioactive waste stored onsit .

O

_____.___________.________.________._.______________.______________ . _ _ . _ _ . _ _ . _ _ _ _ _ _ _ _ _ . _. _... _ _ _ _ _ _ _ . _ _ _ . _ _ _ . _ _ _ _ . _ _ _ _ _ _ _ _ _ _ . . . _ . - _ _ _ _ _ . . . . _ _ . . _ _