IR 05000259/1987034
| ML20236B546 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 10/07/1987 |
| From: | Weddington R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20236B486 | List: |
| References | |
| 50-259-87-34, 50-260-87-34, 50-296-87-34, NUDOCS 8710260233 | |
| Download: ML20236B546 (10) | |
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.: UNITED STATES -
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',. NUCLEAR REGULATORY COMMISSION
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REGION il
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101 MARIETTA STREET,N.W.
- 2 ATL ANTA, GEORGI A 30323 s
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OCT 161987h i
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n Report Nos.: 50-259/87-34,:50-260/87-34 and 50-296/87-34-q
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o Licensee: l Tennessee Valley Authority'
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6N 38A' Lookout Place
1101 Market Street
Chattanooga', TN. 37402-2801 I
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Docket Nos:.50-259, 50-260, 50-296 License lNos:
DPR-33, OPR-52, DPR-68 Facility Name: Browns -Ferry.1, 2, and 3
Inspection Conducted:~.Se tember 21-25,.1987'
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Inspector:
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R. E. Wedd1rrgton.
Date Signed Accompanying Personnel:
M. T. Lauer Approved by:
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/d!") (7M C. M. Hbs@9, Secti on Chief
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Date Sigried.
j Division of Radiation Safety and' Safeguards l
SUMMARY
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Scope: This was a routine, unannounced, onsite health physics' inspection in the areas of:
organization and management controls, training and qualifications, external and internal exposure control,. dosimetry, facilities and. equipment, solid wastes, transportation of ~ radioactive material Jand followup on IE Information Notices.
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Results: One violation' was identified for failure to comply-with.the license'
condition of a radioactive waste disposal site.
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8710260233 e71016 I
DR ADOCK 0500
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d REPORT DETAILS 1.
Persons Contacted Licensee Employees
- J. G. Walker, Plant Manager
- J. D. Martin, Assistant to Plant Manager
- P. Carier, Compliance Manager
- D. C. Smith, Chemistry Supervisor
- J. M. Corey, Radcon Supervisor
- F. S. Tsakeres, Radcon Supervisor
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- H. M. Crowson, Radcon Supervisor l
- D. S. Hixson, Radwaste Supervisor
- D. C. Mims, Superintendent, Technical Services
- C. S. Hseich, Licensing - Compliance
- J. Olson, Unit 1 and Unit 3 Supervisor
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- L. W. Ivey, Licensing - Compliance l
- C. T. Dexter, Training Instructor
- W. D. Dawson, Operations Training
- H. W. Deason, Engineering and Technical Training
- *R. H. Albright, Radeon Supervisor
- A. W. Sorrell, Site Radcon Supervisor
- R. McKeon, Unit 2 Superintendent
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- L. J. Riales, Corporate Radwaste Supervisor
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- C. Beasley, Information Services
- R. M. Tuttle, Site Security Manager
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- J. Shaw, Shift Technical Advisor Supervisor
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l E. G. Pugh, Engineering and Technical Training
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B. Brooks, Training Supervisor L. J. Politte, Corporate Radeon R. Weeden, Site Radiological Assessor J. Barker, Manager, Radiological Controls, TVA Other licensee employees contacted included technicians, ' security force members, and office personnel.
Nuclear Regulatory Commission
- G. L. Paulk, Senior Resident Inspector
- C. A. Patterson, Resident Inspector
- C. Brooks, Resident Inspector
- E. Christnot, Resident Inspector
- Attended exit interview
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2.
Exit Interview The inspection scope and findings were summarized on September 25, 1987, with those persons indicated in. Paragraph 1 above.
The following issues were discussed in detail:
(1) An_ apparent violation for failure to comply with the license conditions of a disposal site.(Paragraph 8), (2) A licensee identified violation concerning the-failure to adequately 3erform alpha radioactive evaluations (Paragraph 9) and (3) The qualificat'ons of a newly appointed supervisor in the Radcon group (Paragraph 4).
The licensee acknowledged the inspection findings and stated that they believed the new supervisor met ANSI Qualification requirements.
The licensee did not identify as proprietary any of the materials provided to or reviewed by the-inspector during this inspection.
In a telephone conversation on September 28, 1987,.between the inspector-and the licensee's Site Radcon Manager, the licensee committed to establish a development plan for the newly appointed supervisor.
3.
Organization and Management Controls (83722)
Technical Specification (TS) 6.1.8 describes the licensee's radiation protection organization.
The inspector reviewed the organization and i
staffing of the licensee's radiological control (radcon) and radwaste.
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Licensee representatives stated that due to TVA policy changes, 45 contract health physics (HP) technicians recently left.the organization resulting in an increase in overtime hours for the remaining 100 technicians.
Seventeen HP technician trainees will be ANSI qualified in approximately five months.
Licensee representatives were unsure how much of the remaining staffing shortage will be filled through recruitment.
One radwaste engineering supervisor position within the Solid Waste Unit was currently vacant.
The licensee indicated that because of radwaste personnel cross training, this vacancy was not adversely impacting day to day radwaste operations.
No violations or deviation were identified.
4.
Training and Qualification (83723)
a.
Qualifications TS 6.1.E requires that the qualifications of the Browns Ferry Nuclear Plant management and operating staff meet the minimum acceptable levels as described in ANSI-N18.1.
Within the radcon group, the position of Radiological Protection Supervisor, Technical Section had recently been filled.
The inspector reviewed the position description, the qualifications of the individual who filled the-position, and numerous documents which discuss the applicability of the individual's em31oyment history to the position,s experience requirements.
The inspector determined that the individual did not meet ANSI-N18.1, Paragraph 4.3.2 requirements for a supervisor not requiring NRC license in that the individuals ten year employment
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history did not include four years of experience in the craft or-discipline he. now supervises.
In-response to the inspector's-observation, the licensee indicated that it would.be more appropriate to characterize the position of Radcon Technical Supervisor as Staff i
$pecialist described in Paragraph 4.6.2 of ANSI-N18.1 for which less i
defined experience levels are stated.
ANSI-N18.1.also states that j
one of the responsibilities of a Staff Specialist is to supervise.
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The inspector indicated to the licensee that the absence of any commercial nuclear power plant experience would appear to affect the
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individuals ability to adequately fulfill many of the responsibilities delineated in the position description which _
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included conducting field investigations of radiological. incidents, performing periodic ' assessments of the radiological control program and development of radiological controls program policies.
The inspector also stated that this individual may require additional indoctrination or training to enable him to. fulfill all of these responsibilities.
The licensee agreed that additional training may be required to enable him to be fully effective in his.new position.
This was identified as an inspector followup item and' will be reviewed during subsequent inspections (IFI 50-259/260/296/87-34-01).
No violations or deviations were identified.
b.
Training 10 CFR 19.12 describes instruction the licensee is required to give to individuals working in or frequenting any portion of.a restricted area.
The inspector reviewed lesson plans for Level. I (restricted area access) and Level II (RWP access) General Employee Training (GET).
Through discussions with licensee representatives it was determined that the GET program had recently been ' modified to separate and intensify the respiratory protection information taught during GET.
This effort included separate lectures, tests, and practical factors covering supplied air / air purifying devices and the self-contained breathing apparatuses.
Licensee representatives stated that they are currently sending HP technicians to an operating BWR nuclear power plant in the region to maintain the technician's working knowledge of an operating plant as it relates to HP. coverage.
Groups of two were sent for eight weeks of field work acting in a contract HP technician capacity.
It was indicated that this program is ongoing with 16 individuals having completed the eight week rotation to date.
No violations or deviations were identified.
5.
External Occupation Exposure Control and Dosimetry (83724)
a.
Surveys 10 CFR 20.201(b) requires that each licensee shall make or. cause to be made such surveys as may be necessay for the licensee to comply
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with the regulations in 10 CFR 20 and are reasonable ' under the circumstances to evaluate the extent of. radiation hazards that may be present.
During tours of the facility, the inspector reviewed l
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Radiation Work Permits (RWP) posted at work areas.
The licensee i
indicated that the survey maps associated with RWPs are located at the RWP issuance station and easily accessible to the worker for his review.
Du ring tours of the plant, the inspector performed
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independent radiation surveys and noted no inconsistencies with
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licensee survey results.
j No violations or deviations were identified.
b.
Processing Dosimeters The inspector reviewed the licensee's methodology for TLD processing.
Currently, all TLDs, approximately 5000 for the current calendar quarter were read onsite.
The raw data was then electronically transferred to a licensee offsite facility where the data was processed with algorithms after which the resulting exposure data was transmitted to both the site and to the licensee's corporate office.
The licensee indicated that in the event that the site was unable to electronically transfer raw data to the offsite facility, the data could be hand carried to the offsite facility or calculated onsite by hand. The inspector reviewed a " watch list" which was produced twice daily and contained pertinent exposure and training data for all individuals granted access to the site. This data included quarterly exposure limits, quarter-to-date exposure totals, Maximum Permissible
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Concentration (MPC) hour totals, and complete training status.
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Abnormal pocket dosimeter reading investigations for the third l
quarter were reviewed by the inspector with no inadequacies I
identified.
The licensee indicated that no TLD/ Pocket Chamber l
Discrepancy Reports were generated during the third quarter.
After
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reviewing the action limits that require the generation of such l
reports, the inspector noted that the action limits appeared to
result in few evaluations being performed since the licensee read j
TLDs when the cumulative pocket dosimeter reading approached 500 millirem and one of the criteria for performing the evaluation was that the exposure exceed 500 millirem. Licensee representatives stated that they would reevaluate the criteria.
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Cumulative Exposure Totals Licensee representatives stated that the person-rem exposure total thru September 13,1987, was 868.8 person-rem which was 58.4 percent of the goal for 1987.
d.
Personnel Contamination Event On September 8, 1987, an individual became contaminated with a radioactive particle which resulted in an extremity exposure of l
2.073 rem to the foot. The NRC limit for such exposures is 18.75 rem
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The inspector reviewed the Personnel Contamination Report (PCR) for this event which indicated that the particle was located inside of the individual's shoe which prevented easy detection.
The individual had been released from the regulated area on several occasions after setting off the hand and foot monitor.
On each occasion health physics was unable' to find any contamination on his shoe.
The last time a check was made the inside l
of his shoe was checked and contamination 'up.to 2400 counts per minute was detected with a frisker.
Review of the gamma spectroscopy-results indicate a cumulative -activity of approximately
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0.011 microcuries of Cobalt-60 (95%) and Zinc-65.(5%). The' licensee determined that the individual had probably picked up the particle in a dressing area and that it had been in his shoe for approximately 26.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />.
After review of the above data, the chronology of
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events, statements by individuals involved, and the licensees proposed corrective actions, which included training HP technicians on particle detection and control and revising their pro;.edure for such events, the inspector determined that the. licensee's actions-were acceptable.
No violations or deviations were identified.
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Facilities and Equipment (83727)
During plant tours, the inspector examined calibration and response check stickers on radiation protection instruments in use by licensee personnel.
Flow rate meters on continuous air samplers in use throughout the plant were observed to be above the 30 liters per minute minimum as required by the licensee's procedures.
The inspector toured the issue station for respirators, pocket chamber (PC) dosimeters, alarming dosimeters, and radiation detection instruments.
Most of the equipment was bar coded i
which allowed for rapid and accurate data input into the. computerized tracking system. This tracking system maintained real time personnel data-on current PC readings, qualification status for specific types of respirators, respirator assignments, and radiation detection equipment assignments.
The computerized system also tracked data on specific instruments such as recalibration due dates and preventative maintenance requirements.
Licensee representatives stated that they will soon begin using newly acquired, state of the art, whole body (WB) friskers at the exit from the regulated area.
Such monitors were already in use at the exits from several contaminated areas.
The licensee had conducted field tests to-demonstrate the acceptability of using these. devices rather-than hand held friskers as the primary personnel contamination detection device.
The inspector reviewed the technical. basis and field test results for the adoption of the WB frisker.
This review included an operational test by the inspector using a 7500 dpm Co-60/Cs-137 source and a Technetium-99 frisker check source. The WB frisker alarmed during each test.
No violations or deviations were identified.
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Solid' Wastes (84722)
<1 Through discussions with licensee representatives.it was determined that the scaling factors.used to assure proper waste classification as required by 10 CFR 61.55 were -last updated-in 1984.
The licensee stated that an
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update of these scaling factors would be complete.before startup..
l The inspector. toured the resin dewatering process area, The licensee stated that the current process. requires three 8-hour dewaterings
~i separated by 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> of settling.
However, prior :to startup-the Llicensee
- 3 plans ' to.begin operation of a new rapid dewatering system thereby; decreasing the complete dewatering. process to.12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
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The licensee stated, that an aggressive attempt was being made to reduce
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the generation and current o'nsite inventory of solid waste..In keeping l
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12,070 ft3 in March 1987 to 6;178 ft3 by the' end of August 1987; A-
monthly waste generation goal of 4',700 f t3 had been : set with an actual total during the month of August '1987 of.3,205 ft3.- All of this data included dry active waste, dewatered resin, andL solidified oil. _ The j
inspector reviewed a Radwaste Minimization ' Project Progress Report dated j
September 14, 1987.
This report included completed and ongoing efforts
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such as the formation of a Radwaste Volume. Reduction Committee, comparison
of C-zone RWP entries and the amount of protective clothing waste generated, and the creation of separate tool rooms for the clean area and -
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The inspector indicated to the licensee that this I
program appeared to be an aggressive initiative for decreasing solid waste
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generation of the site.
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btions were identified.
8.
Transportation (86721)
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Transportation Events 10 CFR 30.41(c) requires that before' transferring byproduct material'
to a specific licensee of an Agreement State, the licensee -
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transferring the material shall verify that the transferee's license
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authorizes the receipt. of the type, form, and quantity of. the l
byproduct material to be transferred.
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License Condition 32A of Radioactive Material -License 097, Amendment 41, issued to the low level radioactive waste disposal -
facility operation, Chem-nuclear Systems, Inc. by the State of South Carolina, Department of Health and Environment Control, requires that
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the licensee not receive any liquid radioactive waste regardless of l
the chemical or physical form.
License. Condition 34 of Radioactive Material License 097,.
Amendment 41, requires that the licensee not accept liquid radioactive waste packaged in absorbent materials, or where absorbent i
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l materials have been used to absorb liquids rather than using an approved media to properly solidify the waste.
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On August 5,1987, a licensee radioactive waste shipment arr'ived'at j
the Barnwell, SC disposal site.
The shipment consisted of trash, filters, and mop heads packaged in 55-gallon drums within metal boxes (6 per box).
Some of the drums were randomly selected and checked.
for excessive free liquids by puncturing the drum. A small amount of
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clear liquid (approximately 1 to 2 ounces) was immediately drained
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from one of the drum, followed by a sludge comprised -of absorbent material and water.
After several hours, approximately a pint of.
i liquid and absorbent had drained from the drum.
The licensee was
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notified of the-problem by, the State of South Carolina.
No enforcement action was-taken by the State other than sending a letter j
notifying the licensee of the problem and that the State. license requirements had been violated.
l The licensee conducted an investigation into the excess liquid in the waste drum containing mop heads.
The mops packaged in the drum had been used in contaminated areas of the facility and then taken to a central area in the radwaste building.
The mops were not allowed to dry completely because of the concern that the contamination might become airborne.
The mop heads, along with aosorbent material, were placed in the drums.
The licensee did not identify any unusual j
circumstances concerning the processing of this drum such as i
procedure noncompliance or involvement of inexperienced personnel.
The licensee concluded that the mop heads were probably excessively l
wet when placed in the drum.
Licensee representatives stated that they were evaluating means of ensuring that the mop heads were completely dry before being placed in a drum and were developing i
policies that would reduce the number of mops used in the controlled area.
Shipment of the drum of mop heads containing liquid and the use of absorbent material rather than a solidification agent was identified as an apparent violation of 10 CFR 30.41(c)
(50-259/260/296/87-34-02).
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Audits 10 CFR 71.137 requires that the licensee shall. carry ' out a comprehensive system of planned and periodic audits to verify compliance with all aspects of the radioactive waste packaging quality assurance program.
The inspector reviewed records of selected audits performed by the Onsite Quality Surveillance Section in the area of transportation.
No deficient areas were documented in the reports reviewed.
No violations or deviations were identified.
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10CFR71.5(a) requires each licensee who transports licensed material outside of the confines of its plant or other place of use,
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or who delivers 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 Transportation (DOT) in 49 CFR Parts 170 through 189.
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The inspector reviewad selected records of radioactive material shipments performed during 1987.
The iupector verified that the radioactive material manifests, shipment classification, marking, labeling and placarding were consistent with DOT requirements.
No violations or deviations were identified, l
9.
Internal Exposure Control and Assessment (83725)
j The licensee is required by 10 CFR 20.103, 20.201(b), 20.401 and 20.403 to control intakes of radioactive material, assess such intakes and keep records of and make reports of such intakes.
Chapter 12 of the Final i
Safety Analysis Report (FSAR) also includes' commitments regarding internal i
exposure control and assessment.
The inspector reviewed a Condition Adverse to Quality Report (CAQR)
involving internal dose control and assessment during the Unit 2 drywell safe end replacement project from December 1986 to April 1987.
At the initiation of this project, air samples taken were not adequately assessed l
for alpha contamination until several days after the air samples were ta ken.
The licensee indicated that this delay was caused by pre-job assessments and surveys which indicated that no significant airborne alpha contamination was expected during the project and the nonavailability of
sufficient equipment to perform alpha counting.
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Approximately one month into the project, sufficient data was available for the licensee to realize the magnitude of the alpha radiation problem.
An analysis of air samples indicated that the average alpha Maximum Permissible Concentration (MPC) fraction was seven times the beta / gamma MPC fraction on these samples.
The highest single sample was taken following a breach in a glove bag which indicated peak alpha concentrations of 2500 times MPC, Personnel working in the area at the time had been wearing respiratory protection and had left the area immediately.
The licensee established a task force that, with corporate assistance, was asked to evaluate the alpha problem and to recommend corrective actions.
The licensee took effective action to implement appropriate controls for the remainder of the outage.
The highest exposure assigned to any individual who had been working in the areas where airborne alpha radioactivity was present was 10 MPC-hours.
The inspector determined that the failure of the licensee to perform adequate evaluations prior to the work to indicate that an alpha radiation hazard may be present arid failure to promptly count samples for alpha at the beginning of the outage, was an apparent violation of 10 CFR 20.201(b).
However, because the licensee had identified the problem and had initiated corrective actions, the inspector determined
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that the licensee had. met the self-identification' criteria in 10 CFR Part 2,. Appendix C:forL not ' issuing a Notice.of Violation.
The licensee.'s long tenn corrective action will be reviewed.during a-subsequent-inspection (50-259/260/296/87-34-03).
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IEInformationNotice-(IEN)'(92717)
The inspector, determined that the following information. notices had been received. by the licensee ' reviewed for applicability, distributed ;to=
appropriate personnel and that action, 'as ' appropriate, was. taken or scheduled.
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IEN 87-31, Blocking, Bracing, and Securing-of Ra'dioactive Mat'erials Packages in' Transportation IEN 87-37, Control of Hot Particle Contamination at Nuclear Power-Plants'
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