IR 05000259/1989052
| ML18033B112 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 12/12/1989 |
| From: | Collins T, Potter J, Shortridge R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18033B111 | List: |
| References | |
| 50-259-89-52, 50-260-89-52, 50-296-89-52, NUDOCS 9001110117 | |
| Download: ML18033B112 (17) | |
Text
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UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323 OEC.~ 6 19~,
Report Nos.:
50-259/89-52, 50-260/89-52, and 50-296/89-52 Licensee:
Tennessee Valley Authority 6N 38A 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
Inspection Con t
.
November 13-17, 1989 Inspecto s:.R.C sns B
o r.
g Approved by:
.
P.
otter, ief Facilities Radiation Protection Section Emergency Preparedness and Radiological.
Protection Branch Division of Radiation Safety and Safequards D
ned
/i j'
t S gned e ~d" S'aned SUMMARY Scope:
This routine, unannounced inspection was conducted in the areas o
organization and management controls in radiation protection and radwaste; staffing; radiation safety training and qualifications of the Radiological Control Group; external occupational exposure control; internal exposure control and assessment; control of radioactive materials; maintaining occupational exposures as low as reasonably achievable (ALARA); solid wastes; transportation; special nuclear material (SNM) control; and previously identified inspection findings.
Results:
The licensee's radiation protection program continues to be effective in protecting the health and safety of workers.
The licensee's ALARA measures and initiatives appeared to be generally effective for reducing personnel exposures; however, the inspectors found that the licensee did not always review radiological survey results in a timely manner to evaluate radiological
hazards present.
In addition, the licensee will review the controls established for maintaining positive access.
control to areas where high radiation areas greater tha'n 1,000 millirem per hour for those areas where dose rates can increase over a short period of time.
These two issues will be tracked as inspector followup items (IFIs).
Also, the inspectors reviewed the licensee's controls for SNH and found that previous physical inventories had not identified SNM stored in the Radwaste Evaporator Building.
This issue will be tracked as an unresolved item (URI) pending additional review.
Licensee management representatives acknowledged the inspectors findings and stated that these issues would be reviewed and evaluated for appropriate adequate controls to protect the health and safety of plant workers.
In the areas inspected, violations or deviations were not identifie REPORT DETAILS Persons Contacted Licensee Employees:
R. Albright, Radiological Health Manager J. Baxter,.Licensina Enaineer G. Buaa, Radwaste Group Nanaaer P. Byrd, Radcon Shift Supervisor G. Campbell, Plant Manager
J. Corey, Radiological Control Superintendent M. Hazel, Padcon Shift Supervisor
- F. Kelly, PAS/BFNP
- J. 'Lewis, Technical Support Supervisor E. Mastich, Field Operations Supervisor/Radcon
- R. Miller, guality Assurance Evaluator J. Milnor, Radcon Shift Supervisor P. Salas, Compliance Supervisor W. Simpkins, Dosimetry Supervisor
- J. Swindell, Plant Support Superintendent W. Thomison, Technical Support Superintendent
- F. Tsakeres, Radiation Protection Nanaaer Other licensee employees contacted durina this inspection included-enaineers, operators, technicians, security personnel, and administrative personnel.
Nuclear Reaulatory Commission W. Bearden, Resident Inspector D. Carpenter, Site Manager E. Christnot, Resident Inspector K. Ivey, Resident Inspector
- C. Patterson, Restart Coordinator
- Attended exit interview Occupational Exposure During Extended Outaaes (83750)
Oraanization and Management Controls The licensee was in the process of reoraanizina the Radioloaical Control (Radcon)
group to support one operatina unit and two units in wet lay-up.
The Radcon qroup was staffed with 201 technicians, engineers, and supervisory personnel.
Included in the total staff were 73 ANSI-18. 1 (dated March 1971) qualified health physics (HP)
field operations technicians.
The inspectors were informed by licensee management that the reoraanization was in the proposal stages and that reconfiguring of the qroup was expected to result in
a reduction in the Radcon staff.
In discussions
.with licensee representatives, the inspectors determined that the current ratio of plant wor'kers to ANSI-N18.1 qualified technicians (job coverage, technicians)
was 30 to 1.
This ratio has increased from 12.7 since September 1988. 'he inspectors discussed the issue of available HP coverage with the Radiological Protection Manager (RPM)
and was informed that this issue was being evaluated.
The RPM stated that currently the large disparity in workers to HP technicians was not posing a
probl.em because the majority of jobs were not in radiologically controlled areas (RCA) of the plant.
To support this the RPM's data showed that the ratio of non-radiation work permit (RWP) hours to,RWP hours was 6 to l.
Also, that Radcon projections showed that the total plant staff would decline as Unit 2 startup was approached in late spring of 1990, to the extent that the worker to HP technician ratio would be reduced to 7 to 1.
The licensee's staffing study showed that this would be slightly less than the industry average of worker to HP technician ratio of 9 to 1.
Several key management"changes have been effected by the licensee in the past year.
The newly appointed Vice President of Nuclear Power has taken the initiative to standardize the HP RWP system among plants and to reduce the contaminated area of the RCA at Browns Ferry.
The HP Technical Supervisor replaced the Radcon Superintendent who was assigned as Mainten'ance Superintendent.
The Radcon Superintendent reorganized the Radcon qroup into three special disciplines; field operations, dosimetry, and instruments/respiratory protection, with each section having defined responsibilities and a
specific training program.
The Radcon Superintendent stated that Radcon currently did not utilize contract personnel and anticipated that they would only need contractor support for large outages.
Additionally, the Radwaste Organization and Management Controls were reviewed by the inspectors.
The licensee had recently reorganized the Water and Waste Group that reported to Plant Operations and presently the Radwaste Group reports directly to the Radiological Control Superintendent.
This change was expected by the licensee to enhance the controls in radioactive waste management.
The inspectors discussed the staffina levels separately with the Radwaste Group Manager and determined that presently the Radwaste Group has five Radwaste Supervisors, three Radwaste Shift Foremen and 51 decontamination personnel.
This group is responsible for the following activities:
Radwaste Packaging Radwaste Shippinq Laundry/Trash Processing Radwaste Minimization Program Equipment Decontamination Area Decontamination
The inspectors concluded that this group appears to have sufficient staff to support routine and start-up operations.
No violations or deviations were identified.
Training The inspectors reviewed the licensee's program for continuing training for Radcon Personnel, interviewed training instructors, and observed classroom and mock-up training.
The inspectors reviewed the continuing training curriculum for the fourth quarter of 1989 through the third quarter of 1991,,and noted that the curriculum contained topics that were designed to update qualified HP technicians on changes in plant and in the nuclear industry.
Examples of evolving changes in plant included - topics on pending plant modificatio'ns, procedure changes, and startup issues.
To provide training on industry wide changes'nd problems relating to HP, industry events training sessions were scheduled in each of the quarters.
The curriculum also contained topics on Mitigating Core Damage, Biological Effects, Personnel Monitoring, BWR Systems, Radiation Detection Theory and individualized instruction.
Licensee representatives stated that to improve performance, training for HP technicians had been increased from 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> annually to 80-90 hours annually.
The inspectors attended two classroom lectures, a lecture on radioactive decay mechanisms and the second on annual qualification for respiratory protection devices.
The attendees for the 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> radiation theory course included HP technicians, dosimetry, and radwaste personnel.
The attendees for the
hour respiratory protection qualification course consisted of plant workers from various disciplines.
The inspectors observed that the instructors for each of the lectures were effective in their presentation, that class participation and response, as well as trainina aids used, were good.
A review of the lesson plans,and tests showed that the test adequately measured the learning ob'ectives for the courses.
For the qualified radiation worker, the licensee provides advanced training in operating radiological techniques.
A series of five courses are presented in a laboratory se'tting that provides indepth instruction in dose reduction techniques, RWP and radcon survey map interpretation, decontamination, contamination work area techniques, and use of containment devices.
Students are required to plan and perform work, filled with anomalies, on a realistic piping system mock-up during the demonstration phase of the 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> course.
To pass the course, the student must perform the operations without prompting from the instructor.
Jf prompting is required, the student is given remedial instruction and a
second chance.
If prompting is again required the student is failed.
The instructor stated that the course challenges the student's diagnostic abilities and has resulted in improved work performance in-plant.
Prior to leaving the training
facility, the instructor had brief discussions with the Accreditation Manager and Training Manager.
The inspectors discussed key factors in the accredited training program with the managers and noted that the program and training facility appear to be effective in preparing licensee personnel for radiological operations in-plant.
No violations or deviations were identified.
.
c ~
External Exposure Control and Personnel Dosimetry
CFR 20.101(b)
specifies the permissible radiation dose to the whole body to be entered on a
NRC Form 4 or equivalent record prior to allowing the individual to exceed the limits of 10 CFR 20.101(a).
The inspector reviewed selected occupational exposure histories for individuals who exceeded the'alues in
CFR 20. 101(a).
The exposure histories were being completed and maintained as required by
CFR 20.102.
The inspectors discussed the external exposure control system with a licensee management representative.
The licensee's current method for controlling external exposure control for personnel is by a
computerized Health Physics Dose Tracking System (HPDT).
The system provides real time dose tracking for all personnel who enter the RCA.
The inspector reviewed HPDT data and concluded that the system does update personnel exposures on a daily basis and also includes other beneficial information, such as medical examination dates, respiratory fit test dates, respiratory training dates, and allowable personnel dose for the quarter.
A licensee management representative stated that there have been no administrative overexposures for +he period of January 1989 to October 1989.
The inspectors reviewed selected active RWPs for appropriateness of the radiation protection requirements based on work scope, location and conditions.
During tours of the RCA the inspector observed the adherence of plant workers to RWP requirements and discussed the RVP requirements with plant workers and Radiation Control Technicians at the job site.
The inspector concluded that the RWPs reviewed specified adequate controls and that workers were aware of these controls.
No violations or deviations were identified.
d.
Internal Exposure Control
CFR 20.103(a)
establishes the limits for exposure of individuals to concentrations of radioactive materials in restricted areas, and requires measurements of airborne concentrations of radioactive materials in restricted areas and appropriate bioassays to detect and assess individual intakes of radioactivit The inspectors reviewed selected results of bioassays (whole body counts)
and the licensee's assessment of individuals with intakes of radioactive material that were performed during the period of January-October 1989.
The inspectors determined by review that no individual intakes had exceeded one percent of a maximum permissible organ burden (MPOB).
CFR 20. 103(b)
requires the licensee to use process or other engineering controls to the extent practicable, tn limit concentrations of radioactive material in air to levels below that specified in Part 20, Appendix B, Table 1,
Column 1,
so that concentrations when averaged over the number of hours in any week during which individuals are in the area, are less than 25 percent of the specified concentrations.
During tours of the RCA, the inspectors observed the use of process and engineered controls to limit airborne radioactivity concentrations in the plant.
The inspectors discussed these controls with a
Radiation Control Technician and Radiation Control Foreman.
The inspector also reviewed air sample survey results of selected areas within the RCA, for the period of October 1989, and determined that airborne concentrations were well below the limits specified in
CFR 20, Appendix B, Table-l, Column 1.
No violations or deviations were identified.
Special Nuclear Material Control The inspectors toured the Radwaste Evaporator Building to observe the licensee's storage of high level radioactive waste on both the 548 foot elevation and 565 foot elevation. 'he inspectors discussed the storage of radioactive waste with licensee representatives and were informed that radioactive waste greater than 1,000 millirem per hour was stored in the 565 foot elevation.
This area is a locked high radiation area which requires authorization for access using an approved RWP.
The inspector asked licensee representatives what types of radioactive waste were usually stored in this area.
The licensee explained that Special Nuclear Material (SNM) (ie.,
and Reactor Waste Clean-up (RWCU) resins were the primary radioactive wastes stored in the 565 foot elevation of the Radwaste Evaporator Room.
The inspectors toured this area to observe the controls the licensee had in place to control exposure to personnel handling this material.
The inspector noted that the SNM stored in this area was segregated from the other material for inventory control purposes and that the area appeared to have been recently cleaned out and reorganized.
A licensee representative informed the inspector that on November 4, 1989, i adwaste personnel were performing work in the radwaste evaporator room (565 foot elevation)
high level radioactive waste storage area.
Upon moving drums of radioactive waste, three five (5) gallon buckets were discovered to contain seven lead bricks each brick containing a plugged hole.
The
buckets had radioactive material tags attached identifying the material in the buckets as
"SRM's" and
"IRMs."
Additionally "SNM" was marked on the side of the buckets with a black marker.
Also, a
small bag was found which was labeled as SNM.
Radwaste personnel placed the buckets and the bag in a 55 gallon drum and moved the drum to the other side of the room along with other drums of SNM.
On November 8, 1989, four days later, licensee management was informed of the discovery of the SNM items found in the radwaste evaporator bui ldina.
The licensee immediately notified the Special Nuclear Material Custodian (SNMC).
The SNMC requested that a physical inventory of,the discovered items be performed as soon as possible.
After inventory on November 8, 1989, the items were. identified as
SRMs or IRMs and 2 TIPs in the lead bricks,
SRM or IRM from the small poly baq and
SRH from the large poly bag.
Licensee's procedure TI-14, Special Nuclear Material Inventory, requires that a comparison of inventory results to previous history records be performed.
Results of the licensee's comparison of historical records of SNM inventories:
1.
IRMs 6550068, 6550069, 6550076, 6550078, and 6611917 were all replaced during the Unit 1 Cycle 5 outage and were thought to be stored in Drum 74 in ICA 13.
2.
SRM 6554052 was removed from the Unit 2 reactor on March 13, 1986 and was.thouqht to have been stored in Drum 89-RWD-942 in ICA 13.
. 3.
TIPs 6583856 and 6584283 were removed from the Unit 2 reactor'uring April of 1977 and could not be accounted for and were assumed inadvertently shipped.
4.
SRM F4554 was on record as being in ICA 13 and known to he in a poly baq.
The comparison was completed and the results were as follows:
, 2.
The
IRM/SRMs from the lead bricks were determined to be the IPMs previously thought to be in Drum 74 of item 1 above.
The IRM/SRM from the small poly baq was the SRM previously thought to be in Drum 89-RWD 942 of item 2 above.
3.
4.
The 2 TIPs from the lead bricks were determined to be the TIPs of item 3 above.
SRM F4554 was located where it was known to b.
IRMs (serial numbers 6550079, 6554058, 6554061, 6570927, and 6570955),
which were previously unaccounted for and assumed
'
inadvertently shipped were determined to be in Drum 74.
6.
7.
SRM 6554051 which was previously unaccounted for and assumed inadvertently shipped was determined to be in Drum 89-RWD-942.
The process of determining the identity of all SNM items which have ever been located at BFN and reported to the NRC in a
memo.
dated September 30, 1987, stated that the determination was extremely thorough by the licensee.
No information from this event was cause to suspect that these items were other than those previously identified and reported as unaccounted for.
The event was categorized as an inventory discrepancy in accordance with TI:14, Section 7.8.5.
The inspectors discussed this issue with NRC Regional Management on November 15, 1989, and were informed that a Regional based SNM Specialist would followup on this event during the week of November 27, 1909.
The inspectors informed licensee management'f this discussion and stated that this issue would be tracked as URI 50-259, 260, 296/89-52-01 pending further NRC review.
Control of Radioactive Materials and Contamination, Surveys, and Monitoring The inspectors reviewed the HP required reading file to ascertain HP technician participation.
The review showed that the technicians were meeting their required reading assignments.
However, in reviewing the file the inspector noted an event that 'described several discrepancies. with HP performance that did not appear to be resolved.
The evert description stated that upon removal of the head on the 2B Fuel Pool Cooling Heat Exchanger on October 16.
1989, the whole body beta/gamma dose rate was 450 mrem/hr.
A radiation survey performed prior to eddy current testing on October 21, 1989, 'showed a
combined beta/gamma whole body (18") radiation dose rate of 1,200-mrem/hr.
The HP shift supervisor was not made aware.of the increase in dose rates, nor was the RWP updated by the HP technician unti 1 October 22, 1989.
A supervisor review at this time identified an error in the HP technician conversion of the beta component, and it.
was determined that the correct radiation dose rate at 18" from the heat exchanger opening was 950 mrem/hr.
To assure the survey was correct, HP performed another survey that showed an increase in the radiation dose rate to 1,600 mrem/hr.
The HP group took immediate corrective action to lock the containment tent, thereby providing positive access controls to the high radiation area in accordance with technical specifications.
In discussion with HP personnel, the inspectors determined that HP supervision was not required to review area radiation surveys on any specific frequency or routine basis.
The Radcon Superintendent acknowledged the inspectors finding that
for a
period of time, HP supervision, was not aware of the radiological conditions in the 28 Fuel Pool Cooling Heat Exchanger area and agreed to evaluate requirements for HP supervisor review of routine daily radiological surveys.
The inspectors informed licensee management that this issue will be reviewed during a
subsequent inspection and will be tracked by the NRC as an Inspector Follow up Item (IFI) 50-259/89-52-02.
The inspectors discussed high radiation levels associated with the Fuel Pool Cooling Heat Exchanger with HP representatives.
A previous problem was identified by the NRC in Inspection Report No. 88-23 regarding a long range dose reduction pl.an for the heat exchangers.
In response the licensee took the initiative to perform a high volume flush to reduce heat exchanger dose rates, however, during each use the source term is increased.
The inspectors noted that during eddy current operations, the licensee installed a plexi-glass shield over the head opening, held in place by
"C" clamps, to reduce beta radiation levels from the heat exchanger.
For a
period of approximately 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br />
'on October 21 and 22, 1989, it appeared from radiation.surveys that the heat exchanger work area should have been posted as a prohibited high radiation area, and locked.
The licensee ag'reed to 'evaluate and review their current methods for positive access controls to high radiation areas that approach the limit of 1,000 millirem per hour as required hy Technical Specifications.
The inspectors informed licensee management that this issue will be reviewed during a subsequent inspection and will be tracked by the NRC as IFI 50-259/89-52-03.
No violations or deviations were identified.
3.
Followup on Previous Inspector Identified Items (92701)
(Closed) IFI 50-259, 260, and 296/88-23-01:
This item concerned adequate HP technician staffing levels for suppor't of routine and start-up operations.
This item is discussed in Paragraph 2(a) in detail.
This item is considered closed.
4.
Exit Interview The inspection scope and findings were summarized on November 17, 1989, with those persons indicated in Paragraph 1 above.
The inspectors described the areas inspected and discussed in detail the inspection findings.
The licensee was informed of the status of the items in Paragraph 3.
Proprietary information is not contained in this report and no dissenting comments were received from the license Item Number-50-259, 260, 296/89-52-01 50-259, 260, 296/89-52-02 50-259, 260, 296/89-52-03 Description and Reference URI - Adequate inventory controls of Special Nuclear Material (Paragraph 2.e).
IFI - Review of radiological survey results in a timely manner to evaluate radiological hazards present (Paragraph 2.f).
IFI - Review and evaluate the controls provided for positive access'controls for high radiation areas (Paragraph 2.f).
0',