IR 05000259/1990021
| ML18033B428 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 06/28/1990 |
| From: | Hughey C, Potter J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18033B427 | List: |
| References | |
| 50-259-90-21, 50-260-90-21, 50-296-90-21, NUDOCS 9007170078 | |
| Download: ML18033B428 (19) | |
Text
~P,R REGIj~
UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W, ATLANTA,G EO R G IA 30323 gg~
P. 199~
Report Nos.: 50-259/90-21, 50-260/90-21, and 50-296/90-21 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
Inspector:
C.
Approved by:
Inspection Conducted:
June 18-22, 1990 Facilities Radiation Protection Section Emergency Preparedness and Radiological Protection Branch Division of Radiation Safety and Safeguards Dat Sig Da e
gned SUMMARY Scope:
The routine, unannounced inspection was conducted in the areas of radiation protection, internal exposure control, external exposure control and ALARA.
Results:
In the areas inspected, violations or deviations were not identified.
An Inspector Followup Item concerning the timely review of radiological survey results was closed (Paragraph 2).
An Inspector Followup Item concerning Unit 2 fuel pool heat exchanger dose rates was closed (Paragraph 2).
The whole body counting quality control program was adequate in ensuring accurate counting results (Paragraph 3).
The drywell air sampling program was adequate in determining any airborne l
radioactive hazards in the 'area (Paragraph 3).
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The ALARA/Radwaste reduction program appeared to be very effective and was considered to be a licensee strength (Paragraph 4).
Personnel contaminations, radiological incidents and plant contaminated square footage appeared to be trending downward, however, the original person-rem goals for 1990 had been exceeded (Paragraph 4).
REPORT DETAILS 1.
Persons Contacted
Licensee Employees
- R. Albright, Radiological Health Supervisor D. Bohlender, Health Physicist
- S. Bugg, Radwaste Manager
- R. Coleman, Radiological Protection Supervisor J.
Corey, Radiological Control Manager C. Dexter, Training Manager S.
Howard, Health Physicist
- E. Mastich, Health Physics Field Operations Supervisor
- L. Myers, Plant Manager
- J. Wallace, Compliance Licensing Engineer Other licensee employees contacted during this inspection included craftsmen, engineers, operators, security force members, technicians, and administrative personnel.
NRC Resident Inspectors
- D. Carpenter, Site Manager
- K. Ivey, RI
'Attended exit intervi ew 2.
Licensee Action on Previous Inspection Findings (92701)
(Closed)
Inspector Followup Item (IFI) 50-259, 260, 296/89-52-02:
Review of radiological survey results in a timely manner to evaluate radiological hazards present.
During a
previous inspection (89-52, November 13-17, 1989),
an inspector noted during a review of documentation that an event which described several discrepancies with health physics performance did not appear to be resolved.
The event 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 millirem/hour.
A radiation survey performed prior to eddy current testing on October 21, 1989, showed a combined beta/gamma whole body (18") radiation dose of 1,200 millirem/hour. The health physics shift supervisor was not made aware of the increase in dose rates, nor was the RWP updated by the health physics technician until October 22, 1989.
In discussions with health physics personnel, the inspector determined that health physics supervision was not required to review area radiation surveys on any specific frequency or routine basis.
The Radcon superintendent acknowledged the inspector's finding that for a period of time, health physics supervision was not aware
of the radiological conditions in the 2B Fuel Pool Heat Exchanger area and agreed to evaluate requirements for health physics supervisor review of routine daily radiological surveys.
To resolve the, issue, Health Physics Administrative Section Instruction Letter No.
5 was revised (Revision 2, January 25, 1990)
to require the health physics field operations on-shift supervisor to 1)
review any survey data generated on the prior shift before accepting shift responsibility, 2) discuss the important aspects of these surveys with off-going shift personnel, and 3)
document this review.
This item is considered closed.
(Closed)
IFI 50-259, 260, 296/89-52-03:
Review and evaluate the controls provided for positive access control for high radiation areas.
In response to a problem regarding long range dose reduction for the Unit 2 Fuel Pool Cooling Heat Exchanger (identified and discussed in Inspection Report No. 88-23) the licensee had performed high volume flushes to attempt to reduce heat exchanger dose rates.
During Inspection Report No. 89-52 (November 13-17, 1989),
the inspectors noted that during eddy current operations in the heat exchanger, the licensee had installed a plexi-glass shield over the head opening to reduce beta radiatian levels from the heat exchanger.
For a period of about 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> on October
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 agreed to evaluate and review the method for positive access controls to this area which approached and possibly exceeded the Technical Specification (TS) limit of 1,000 millirem per hour
.
The heat exchanger had become highly contaminated during the Unit 2 fuel reconstitution.
This process required the mechanical
"scouring" of used fuel assemblies.
During this inspection, the licensee was installing lockable fencing around the.Fuel Pool Cooling Heat Exchangers and pump areas in all three units.
The licensee indicated that this project would be completed by July 16, 1990.
Lead blankets had also been wrapped around the Unit 2 Fuel Pool Cooling Heat Exchanger to help reduce dose rates.
As a long term solution to the problem, funds had been requested for fiscal year 1991 to construct permanent shield walls around all three units'uel pool cooling heat exchangers and to chemically decontaminate the heat exchangers.
The inspector verified that construction of the fencing was proceeding and no posting problems were noted around the Unit 2 heat exchanger and the most recent radiological survey of the area was verified.
This item is considered close.
Internal Exposure Control (83750)
a
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In Vivo and In Vitro Bioassay Program
CFR 20.103(a)(3)
requires, in part, that the licensee, as appropriate, use measurements of radioactivity in the body, measurements of radioactivity excreted from the body, or any combination of such measurements as may be necessary for timely detection and assessment of individual intakes of radioactivity by exposed individuals.
1)
Urinalysis Testing ( In Vitro)
quarterly random radiological urinalysis testing was conducted on selected personnel who had recently conducted work that required respiratory protective equipment.-
During fiscal year (FY) 1990 there had been no notable detectable activity in any of these samples.
2)
Whole Body Counting ( In Vivo)
Whole body counting equipment consisted of 2 Canberra FASTSCAN standup counting systems used for 60 second routine screening counts and one Canberra/Nuclear Data whole body counting chair used for diagnostic counting.
Each standup counter contained two Sodium Iodide crystals (lung/thyroid and lower torso)
and the chair contained two intrinsic germanium detectors (lung and lower torso)
and a sodium iodide crystal (thyroid).
The inspector reviewed the following procedures which described the calibration and operation of the whole body counting equipment and found them to be complete and technically adequate:
Corporate procedure DOS-3, Radiological Technical Support Radiation Dosimetry Procedures Manual, Revision 9,
dated March 8, 1990 HP-DSIL 33, Calibration of Canberra FASTSCAN Whole Body Counter System, Revision 1, dated February 16, 1989 HP-DSIL 34, guality Control Checks for Canberra FASTSCAN System, Revision 4, dated May 6, 1989 HP-DSIL 36, Performing Whole Body Counts on the Canberra FASTSCAN System, Revision 5, dated April 24, 1990 HP-DSIL 37, Calibration of Canberra Diagnostic Whole Body Counter System, Revision 0, dated March 31, 1989 HP-DSIL 38, Performing Whole Body Counts on the Canberra Diagnostic Chair System, Revision 0, April 3, 1989
HP-DSIL 39, Quality Control Checks for Canberra Diagnostic Chair System, Revision 1, dated July 10, 1989 The inspector noted the following observations in the area of quality control:
a)
b)
c)
d)
e)
Calibration rec'ords for FASTSCAN system No.
(completed September 11, 1989)
and system No.
2 (February 27, 1990)
were reviewed.
An "as found" calibration verification was performed on both systems in lieu of a full calibration.
This verification, which was allowed by procedure, included counting a
mixed gamma source (Co-60, Nn-54 and Cs-137)
and verifying that the activity values for each isotope were within the initial calibration acceptance criteria.
FASTSCAN quality control check plots for system no.
1 (March 90 to present and system no.
2 (Yay 90 to present)
were reviewed.
These daily quality control checks (QCC) were performed using a
Europium-152 check source to verify system counting efficiencies at 344 and 1408 keY to within plus or minus three standard deviations of a predetermined mean.
New control charts were prepared semiannually.
QCC checks indicated stable and reliable systems performance.
Performance checks were performed every four hours when the systems were being operated to verify peak resolution at 1408 keY thereby preventing gain shift problems.-
Daily background checks (QEB) were also performed.
A similar qual ity control program was in place for the diagnostic chair when it was in operation.
The chair is operated only on an as needed basis when the standup counters detect internal activity.
Sources used for calibrations and calibration checks were traceable to the National Institute of Standards and Technology (NIST), formerly named the National Bureau of Standards.
Quarterly intercomparison cross-checks were performed by all TYA sites with whole body counting facilities.
This program was administered by the corporate office using blind standards containing Co-60, Cs-137, Mn-54, and I-131.
The first quarter results for 1990 from Browns Ferry indicated that all equipment met the acceptance criteria for bias and precision requirements.
The whole body counting program was considered by the inspector to be adequate in ensuring accurate counting results.
3)
Uptakes of Radioactive Materials Procedure RCI-8, Bioassay Program, Revision 4, dated Yiarch 8, 1990, requires that positiVe bioassay results attributable to internal
contamination greater than one percent maximum permissible organ burden (MPOB)
be investigated to determine the root cause of the uptake and that bioassay results greater than five percent MPOB shall require MPC-hour calculations and entry into individual dose records.
The licensee indicated that there had been no whole body counts indicating activity greater than one percent MPOB so far during FY 1990.
During FY 1989; however, there had been one notable uptake which involved the ingestion of insoluble Co-60 by a
worker on the refueling floor on December 17, 1989.
The inspector reviewed the internal dose assessment package prepared by the licensee.
The initial whole body count indicated 33 nanocuries of Co-60 activities.
The elimination of the activity, which occurred over about three days, was followed by the licensee using whole body In Vivo counting along with In Yitro analyses (fecal samples).
The MPOB was determined to be
percent (lower large intestine)
assuming the chronic retention of Co-60.
The total committed dose assigned was 9 millirem with a calculated 1.25 MPC-hour equivalent exposure.
Unit 2 Drywell Air Sampling
CFR 20. 103(a)(3)
requires, in part, that the licensee use measurements of concentrations of radioactive materials in air for determining and evaluating airborne radioactivity in restricted areas.
CFR 20. 103(c)(2)
requires that when respiratory protective equipment is used to limit the inhalation of airborne radioactive material, licensee must maintain and implement a
respiratory protective program that, in part, includes, as a minimum; air sampling
.
to identify the hazard, proper equipment selection and estimated exposures; surveys and bioassays as appropriate to evaluate actual exposures; written procedures regarding supervision and training of personnel and issuance of records; and determination by a physician prior to use of respirators, and at least every 12 months thereafter, that the individual user is physically able to use the respiratory protective equipment.
Because of the significant amount of work activities ongoing in the Unit 2 drywell during the week of the inspection, the inspector toured the drywell and discussed the air sampling program with licensee personnel.
Three low volume air samplers were continuously operated to assess general particulate and iodine activities.
Periodic grab samples (for noble gas activity) were not required because the unit been shut down for several years and had been defueled.
A large number of high volume air samples were taken daily (about 30)
as work requirements dictated, to update issued radiation work permits (RWPs)
and to determine airborne hazards for new RWPs'.
A review of the air sample results from the week of the inspection
t~
indicated that general airborne radioactivity concentrations in the Unit 2 drywell were well below the requirements for respiratory protection (0.25 MPC).
The inspector observed that on June 18, 1990 only one high volume air sample indicated possible airborne activity greater than 0.25 MPC which was 6.36 MPC.
On June 17, 1990, another air sample indicated an airborne activity of 3. 15 MPC.
These samples were both associated with grinding and rebuilding of residual heat removal valve 74-52 and was documented on RWP No. 2263. This RWP required the use of respiratory protective equipment.
The inspector randomly selected six workers who had signed in on this RWP on June 17 and June 18, 1990, and verified that they had 1) received respiratory protection training, 2)
passed an annual physical examination and, 3) been properly fitted for the appropriate respirator type.
The inspector concluded that the drywell air sampling program was adequate in determining any airborne radioactive hazards, in the area and that respiratory equipment was properly used.
No violations or deviations were identified.
4.
As Low As Is Reasonably Achievable (ALARA) (83750)
CFR 20.1(c)
states, in part, that licensees should make every reasonable effort to maintain radiation exposures as far below the limits specified in Part 20 as is reasonably achievable.
"Operating Philosophy for Maintaining Occupational Radiation Exposures As Low As Is Reasonably Achievable,"
describes to licensees a
general operating philosophy acceptable to the NRC staff as a necessary basis for a program of maintaining occupational exposures ALARA.
a
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ALARA/Radwaste Suggestion Program The inspector discussed the ALARA program with licensee representatives.
and reviewed procedure RCI-16, ALARA/Radwaste Volume Reduction Suggestion Program, Revision 3,
dated August 28, 1989, which described the licensee's program.
A part of the ALARA program at Browns Ferry was to solicit suggestions from radiation workers that could help reduce radiation exposures and also reduce the volume of solid radwaste generated.
Suggestions were submitted through the worker's supervisor, who screened the suggestion to pass on to the health physics department ALARA coordinator.
The coordinator would then further review the suggestion, assign a tracking number and, if appropriate, pass, the suggestion along to the site ALARA Review Committee (ARC).
The committee, during monthly meetings, would decide the viability of the suggestion and whether or not significant dose reductions could be realized.
Workers with the best suggestions for that month were rewarded with close-in parking or a free dinne O.
'l
For calendar year 1989, there were 122 suggestions that made it through the initial screening process and were presented to the ARC.
For calendar year 1990, so far, there had been about 50 suggestions passed on to the ARC.
About 30 percent of all these suggestions had resulted in improvements to the ALARA/Radwaste reduction program.
This program appeared to be very effective and was considered by the inspector to be a licensee strength.
b.
Exposure and Contamination Goals 1)
Person-rem As of June 16, 1990, there had been about 798 person-rem expended for FY 1990.
This had well exceeded the original yearly goal of 710 person-rem.
The licensee indicated that this was mainly due to additional required drywell steel and pipe support work ongoing in the Unit 2 drywell that was unanticipated at the time the original goal was estimated.
A revised goal for FY 1990 of 1,055 person-rem had been submitted to upper management for approval at the time of the inspection.
2)
Radiological Incident Reports (RIRs)
The inspector randomly reviewed the documentation of the RIRs so far for FY 1990, and procedure RCI-14, Radiological Incident Determination and Reporting, Revision 12, April 26, 1989, which discussed the identification, determination, and corrective actions associated with
,radiological incidents.
As of June 19, 1989, there had been 41 RIRs.
The. original goal for FY 1990 was 135.
The most serious of these incidents involved an individual who may have intentionally violated radiation control procedures by not carrying proper dosimetry into a high radiation area.
RIRs for the year were well below the goal of 135 therefore a
revised reduced goal for FY 1990 of 100 had been submitted for upper management approval.
3)
Personnel Contamination Reports (PCRs)
As of June 21, 1990, there had been 61 reported PCRs.
The original goal for FY 1990 was 250.
The trigger level for reporting a
personnel contamination was greater than 100 counts per minute (cpm)
surface contamination.
To further reduce PCRs the licensee planned to begin the use of green scrub undergarme'nts within three months.
Because of the low number of PCRs so far for the year a reduced goal of 100 had also been submitted for upper management approva )
Contaminated Square Footage As of May 31, 1990, about 5.8 percent of applicable plant square footage (910,480 square feet)
was considered-contaminated.
This was a considerable reduction over the previous year and was well within the FY 1990 goal of less that 10 percent.
A revised goal of less than 5 percent had been submitted, along with the previously discussed items, to upper management for approval.
The licensee anticipated further reductions as Unit 2 proceeded toward restart and major work was completed.
5)
Drywell Shield Package To reduce dose rates in the Unit 2 drywell the licensee had completed the installation of a shielding package in the drywell which included the placing of large quantities of lead blankets around highly radioactive RCS RHR components.
The licensee noted approximately a
35 percent reduction in general area dose rates after the installation was completed on April 15, 1990.
This shielding was to be removed prior to the Unit startup.
The licensee indicated that an estimated 106 person-rem savings was realized from the shield package installation.
No violations or deviations were identified.
5.
External Exposure Control (83750)
CFR 20.202 requires each licensee to supply appropriate monitoring equipment to specific individuals and requires the use of such equipment.
Periodically, during the week of the inspection, the inspector toured the radiologically controlled area (RCA) including the Unit 2 drywell and observed the proper use and placement of thermolumininescent dosimeters (TLDs) and self-reading pocket dosimeters (SRDs)
by plant workers. At the time of the inspection, SRDs were not required for general entry into the RCA however, they were required when work was being performed under an RWP.
The licensee indicated that this policy would be changed requiring all workers to wear SRDs when entering the RCA at least two weeks prior to Unit 2 startup.
6.
Exit Interview The inspection scope and results were summarized on June 22, 1990, with those persons indicated in Paragraph 1.
The inspectors described the areas inspected and discussed the inspection results.
Proprietary information is not contained in this report.
Dissenting comments were not received from the licensee.
Licensee management was informed that two IFIs discussed in paragraph 2 were closed during this inspection.