IR 05000259/1991022
| ML18036A317 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 07/16/1991 |
| From: | Hughey C, Potter J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18036A316 | List: |
| References | |
| 50-259-91-22, 50-260-91-22, 50-296-91-22, NUDOCS 9108120030 | |
| Download: ML18036A317 (14) | |
Text
gp,S BKGyc Wp0 Cy
C Op pN
+rt*W+
UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323 JUL 12 Nl Report Nos.:
50-259/91-22, 50-260/91-22 and 50-296/91-22 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 u t
ne 10-14, 1991
/
Inspecto C.
. Hugh /
D te S3.gned Approved by:
f/
J.P'ot
, Chief D t 3.gned F ilitie Radiation Protection Section Radiological Protection and Emergency Preparedness Branch Division of Radiation Safety and Safeguards SUMMARY Scope:.
This routine, unannounced inspection of the radiation protection program was conducted in the areas, of internal,,and external exposure control, audits and appraisals, contamination control and organization.
Results:
The fiscal year 1991 collective exposure goal was significantly below fiscal year 1990 actual collective exposure.
Plant management also indicated a high probability that fiscal year 1991 actual exposures would be much less than estimates.
The threshold for reporting radiological incidents appeared adequate for identifying problem areas.
Contaminated square footage had been maintained at or below the 1991 goal of 5 percent due to aggressive decontamination and painting efforts (Paragraph 2).
A recent audit of portions of the radiological control program
~
~
was indepth, well planned and thorough (Paragraph 3).
9108120030 910717 PDR ADOCK 05000259
'DR
Methodologies for determining extremity and internal exposure were reviewed (Paragraphs 4 and 5).
Proper posting and control of radiation, high radiation and contamination areas was observed during plant tours (Paragraph 6a).
One non-cited violation was identified for failing to survey a tool prior to removal from the radiologically controlled area (Paragraph 6b).
Many initiatives had been implemented or were planned for implementation in order to reduce collective dose (Paragraph 7).
Staffing levels'for the radiological control program appeared
.adequate to support current and future projected workloads (Paragragh 8).
REPORT DETAILS 1.
Persons Contacted Licensee Employees R. Beck, Unit 3 Radiological Control Manager S.
Bugg, Radwaste Program Manager R.
Coleman, Radiological Protection Program Manager
- J. Corey, Site Radiological Control Manager B. Howard, Health Physicist E. Mastich, Health Physics Field Operations Program Manager F. Spivey, Unit, 3 Radcon Support Coordinator
- J. Wallace, Compliance Licensing Engineer
- O. Zeringue, Vice President, Operations Other licensee employees contacted during this inspection included craftsmen, engineers, operators, security force members, technicians, and administrative personnel.
Nuclear Regulatory Commission
- C. Casto, Section Chief
- E. Christnot, Resident Inspector K. Ivey, Resident Inspector
- C. Patterson, Senior Resident Inspector
- J. Potter, Section Chief
- Attended Exit Interview 2 ~
Exposure Goals, Personnel Contamination Events, Radiological Incident Reports, and Contaminated Square Footage (83750)
CFR 20.1(c) states that persons engaged in activities under licenses issued by the NRC should make every reasonable effort to maintain radiation exposures as low as is reasonably achievable.
a.
Exposure goals The inspector reviewed the status of fiscal year 1991 site collective doses and discussed past, current and future trends with radiation protection management.
The fiscal year (FY) 1991 exposure goal (October-September)
was 650 person-rem.
This was significantly below the fiscal year 1990 actual collective exposure of 1213 person-rem.
A significant amount of this potential decrease was attributable to the decreased amount of maintenance and modification activities on
Unit 2.
As of June 11, 1991, actual collective exposure was 358 person-rem, which was 55 percent of the goal with 70 percent of the fiscal year completed.
The FY 91 goal had been last revised in May 1991.
As a result, Unit 3 had been assigned 213 person-rem'for anticipated modification/maintenance work in that unit.
The overall site goal of 650 person-rem did not change as a result of this revision because of decreased dose projections by other plant groups.
Radiation protection management indicated a high probability that FY 91 actual exposures could be well below the goal.
This is supported by the fact that although some groups were trending ahead of their individual goals, actual collective exposures in Unit 3 as of June 11, 1991, had been significantly below projected exposures (17 percent of the goal with 70 percent of the fiscal year completed).
This decrease was partly attributable to dose reduction/ALARA initiatives that are discussed in Paragraph 7.
Personnel Contamination Reports (PCRs)
The inspector reviewed personnel contamination report summaries for FY 1991 as compared to FY 1990.
The licensee's FY 1991 Tier 3 goal was less than 85 PCRs.
As of June 11, 1991 there had been 58 actual PCRs.
There had been 94 total PCRs durino FY 1990.
The licensee had recently implemented the use of green scrub modesty undergarments under anti-contamination clothing in an effort to further reduce PCRs.
PCR No.91-030, concerning a small internal exposure, is discussed in detail in Paragraph 4.
PCR No.91-035, concerning an extremity exposure, is discussed in detail in Paragraph 5b..
Radiological Incident Reports (RIRs)
The inspector reviewed RIRs for FY 1991 and selectively reviewed several in detail.
For FY 1991 a Tier 3 goal of less than 70 RIRs had been established by the licensee.
As of June 11, 1991, there had been
documented RIRs.
The threshold for reporting RIRs appeared adequate for identifying problem areas and a
selective review of several RIRs revealed adequate corrective actions.
RIR No.91-013, concerning the failure to properly survey a tool for potential contamination prior to removing it from the RCA is discussed in Paragraph 6 d.
Contaminated Square Footage Contaminated square footage during the current fiscal year had been consistently maintained at or below the FY 91 goal of less than 5 percent.
This was attributable to an aggressive decontamination effort which included the reclamation and painting of many areas in Unit 2 and the common Radwaste facility that had previously been contaminated.
This effort was continuing at the time of the inspection.
The licensee had also'ecently purchased a high pressure water jet system ("wet/vac") to assist in their decontamination efforts.
No violations or deviation were identified.
3.
Audits and Appraisals (83750)
Technical Specification (TS) section 6.5.2.8 requires that audits of unit activities shall be performed under the cognizance the Nuclear Safety Review Board (NSRB)
and that the audits shall encompass, in part, the following: (a) the conformance of plant operation to provisions contained within the Technical Specifications (TSs)
and applicable license conditions at least once per 12 months; and (b) the performance, training and qualifications of the entire plant staff at least once per 12 months.
4 ~
Audit No.
BFA 91103, Internal Exposure Control and Radcon Instrumentation, conducted February
March 5, 1991, was reviewed by the inspector.
In general, this audit was found to be indepth, well planned and thorough, and contained items of substance relating, to the internal dosimetry and radcon instrumentation program.
The responses to the findings identified.in this audit were adequate;
~ i?
'la No violations or deviations were identified.
Internal Exposure Control (83750)
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.
Since the beginning of the calendar year there had been no recorded uptakes greater than 5 percent maximum permissible organ burden (MPOB).
There had been one reported uptake on May 1, 1991; however, that resulted in an internal Cobalt-60 contamination of 2.6 percent MPOB.
This item was tracked as
MPC-hours calculations were based on whole body counting results.
The inspector reviewed the documentation-of the incident investigation and the dose calculation methodology and determined that the exposed worker did not exceed any regulatory limits.
A root cause determination (as specified by procedure RCI-8, Bioassay Program, Revision 5) was completed by the licensee and corrective actions were implemented to attempt to prevent recurrence.
Internal dose from the ingestion was determined in accordance with procedure
%BC-7, Internal Dose Calculations,'evision 3, 5/18/87, which used models described in International Commission on Radiation Protection'(ICRP)
Publication 2.
No violations or deviations were identified.
5.
External Exposure Control (83750)
a ~
b.
Self Reading Pocket Dosimeters
CFR 20.202 requires each licensee to supply appropriate monitoring equipment to specific individuals and requires the use of such equipment.
During a previous inspection in this area (91-05, January 1991) the licensee indicated that self-reading pocket dosimeters (SRDs) would be issued to all personnel entering the radiologically controlled area (RCA) of the plants prior to the loading of fuel in Unit 2.
During the current inspection, the inspectors observed that SRDs were being used by personnel entering the RCA and were generally properly placed and worn.
r Extremity Exposure;.
~ t (
g
~
~ k
/
" 14 I
10 CFR 20.101 requires, in part, that no licensee shall possess, use or transfer licensed material in such a
manner as to cause any individual in a restricted area to receive in any period of one calendar quarter a
total occupational dose in excess of 18.75 rems to the hands, forearms, feet and ankles; and 7.5 rems to the skin of the body.
The inspector reviewed the documentation of PCR No.91-035, which involved the exposure of an individual's left foot to contamination lodged inside the shoe.
Assumptions used by the licensee to determine time of exposure appeared reasonable and conservative.
The skin dose calculation, which resulted in a total assigned dose of 4,454 millirem, was verified by the inspector to be in accordance with Procedure RCI-2.1,
P
Dosimetry Implementing Procedure No. 7, "Skin Dose Assessment and Calculation", Revision 5.
Followup surveys of the Unit 3 dressout areas and previous daily surveys of the area had revealed no contamination.
A comparison of the 1990 Annual Radionuclide Trending and Assessment Report against an isotopic analysis of the contamination after it was removed from inside the shoe revealed much different isotopic mixtures.
The licensee concluded that anti-contamination clothing received contaminated from the contract laundry service was the probable cause.
The licensee informally notified the laundry service prior to the end of the inspection.
No violations or deviations were identified.
Surveys, Monitoring, and Control of Radioactive Material and Contamination (83750)
a ~
Plant Tours
CFR 20.303 specifies the posting, labeling and control requirements for radiation areas,
'high radiation areas, airborne radioactivity areas and radioactive material.
During several tours of the Units 1,2 and 3 Reactor Buildings, Auxiliary Buildings, Radwaste Facility and remote radioactive materials storage areas, the inspector observed proper posting and control of radiation, high radiation and contamination areas.
Several independent radiation surveys conducted by the inspector were comparable to licensee survey results.
Selected radiation protection instrumentation was also verified to be within current calibration requirements.
There had been a significant decrease in the amount of radioactive materials and contaminated areas in and around Unit 2 due to the end of modification work on the Unit, especially the area in and around the drywell.
Since Unit 2 was in its restart phase, many areas of the plant that previously had not been posted or were posted as radiation areas were posted as high radiation areas.
The inspector paid special attention to these areas during plant tours to ensure proper posting and to ensure that areas where potential dose rates could exceed 1000 millirem per hour were properly secure b.
Improper Tool Monitoring
CFR 20.201(b) requires each licensee to make'r cause to be made such surveys as (1)
may be necessary for the licensee to comply with the regulations and (2)
are reasonable under the circumstances to evaluate the extent of the radioactive hazards that may be present.
During a review of recent RIRs, the inspector noted that RIR No.91-013 involved the willfulviolation of Radiological Control Procedures.
The report alleged that a plant worker attempted to exit the RCA with a pipe threading tool without having the tool monitored for contamination.
This was in violation of Procedure RCI-1, section 6.10.1.8.
The report also alleged that the worker also failed to obey verbal instructions from the RADCON technician monitoring the RCA entrance/exit
,
area to not remove the tool from the RCA and return it to the turbine building tool room as published in a plant directive.
Procedure RCI-1, section 7, discussed the requirement to obey verbal RADCON instructions.
Prompt corrective actions were initiated by the licensee which included immediate (next day)
suspension of the worker without pay for 5 days.
I Although the RIR states that a willfulviolation of radiological controls occurred, further discussions between the inspector and management revealed that a personality conflict between the Health physics technician and the plant worker had aggravated and escalated the situation into a misunderstanding of proper plant radiological control procedures and that the RIR was improperly described by the technician as a
willfulviolation of radiological control procedures.
The Tool was later confirmed as uncontaminated.
Although the tool was not properly surveyed as required by 10 CFR 20.201(b),
prompt and immediate corrective actions were implemented by the licensee.
Therefore a
Non-Cited Violation (NCV) was identified.
The criteria specified in Section V.G.1 of the NRC Enforcement Policy were satisfied and no response would be required (NCV 50-259, 260, 296/91-22-01).
One NCV was identified.
7.
As Low As Is Reasonably Achievable (ALARA) (83750)
CFR 20.1(c) states that persons engaged in activities under licenses issued by the NRC should make every
reasonable effort to maintain radiation exposure ALARA.
a ~
ALARA Program Initiatives The inspector reviewed and discussed several ALAEQ, initiatives that had been approved and were being incorporated into site procedures.
Several, but not all, of these initiatives are discussed below:
1 ~
The'Plant Manager had been named as the ALAEQ/Radwaste Committee Chairman to ensure high level direct participation in collective dose control.
2.
Actual versus estimated doses were being provided daily to RWP work supervisors to help control and reduce exposure for jobs in progress.
3 ~
4 ~
Jobs with dose estimates less than 1 person-rem would require a review to be performed by the work supervisor and an ALARA representative when the collective dose reached 75 percent of the estimate.
Jobs with dose estimates greater that 1 person-rem would require an ALARA plan review and also require reviews at 25, 50, and 75 percent of the estimate to determine any needed revisions.
An RWP would be pulled if actual doses exceeded estimates until a new ALARA action plan and revised dose estimates were developed and approved.
RWP work supervisors would be required to notify RADCON within 3 working days after completion of field work associated with a Radiation Work Permit (RWP) to allow the RWP to be closed out so that ALtQQ, reviews can be performed in a timely manner.
For all jobs requiring an AL2QR plan review, a
post-job ALARA evaluation must be completed within 3 days after completion.
b.
Unit 3 Outage ALARA Initiatives In an effort to reduce collective exposures during modification work on Unit 3, the licensee had completed and were planning several projects.
Many of these items were developed as a direct result of "lessons learned" during Unit 2 modifications work.
Several of the more important initiatives are discussed below:
1.
Composite metal scaffolding was being installed in the Reactor Building and wood scaffolding was
removed.
This scaffolding was to, for the most part, remain in place for the entire outage to increase work efficiency and reduce time for scaffolding modifications therefore reduce'xposure time, and decrease the amount of solid radwaste generated since the permanent scaffolding was relatively easy to decontaminate.
During Unit 2 outage, the use of wooden scaffolding that was constantly being removed, replaced or modified creating unnecessary exposure and radwaste.
2.
Installed temporary shielding on the Recirculation, Reactor Water Cleanup and Residual Heat Removal Systems piping.
3 ~
4 ~
5.
6 ~
Completed a wipedown/washdown decontamination of the Unit 3 Reactor Building and drywell area to minimize radiological control requirements during the outage.
Performed detailed composite radiation and contamination surveys of the Reactor building, Turbine building and drywell at the beginning of the outage, and identified and posted hotspots.
Plans and funding had been approved for a chemical decontamination (Low Oxidation Metal Ion) of the Unit 3 Recirculation, Reactor Water.Cleanup RWCU),
Residual Heat Removal and Fuel Pool Cleanup Systems piping around August-September 1991.
Remaining hotspots after the chemical decontamination would be flushed or shielded (Control Rod Drive headers, RWCU heat exchanger drains, RWCU sample lines).
During the Unit 3 outage, the licensee planned to replace all existing control 'rod drives'and blades with new updated BWR-6 models.
This replacement would produce a side benefit of reducing dose rates during the outage.
Future source term reduction could also be realized because the pins and rollers on the replacement control rod blades would not contain cobalt.
No violations or deviations were identified.
8.
Organization and Management Controls (83750)
The Radiological Control Organization at the time of the inspection included approximately 167 people.
About 65 of those people had been assigned specifically to cover Unit 3 outage work and were assigned to a Unit 3 Radcon Mange The remainder were assigned to Unit 2, Unit 1 and plant common areas.
There had been no significant changes in staffing since the last inspection in this area and no significant turnover problems.
There were no vendor technicians on staff. Current staffing levels appeared adequate to support current and future projected workloads.
No violations or deviations were identified.
Exit Interview The inspection scope and results were summarized on June 14, 1991, with those persons indicated in Paragraph 1.
The inspector described the areas inspected and discussed the inspection findings.
Proprietary information is not contained in this report.
One Non-cited Violation was identified.
Item Number Cate or Descri tion Reference 50-259, 260, 296/91-22-01 NCV Failure to survey a tool prior to removal from RCA (Paragraph 6b).