IR 05000259/1992013
| ML18036A736 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 04/30/1992 |
| From: | Bryan Parker, Potter J, Testa E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18036A735 | List: |
| References | |
| 50-259-92-13, 50-260-92-13, 50-296-92-13, NUDOCS 9206020139 | |
| Download: ML18036A736 (20) | |
Text
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UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323 NY 0 4igsz Report Nos.:
50-259/92-13, 50-260/92-13, and 50-296/92-13 Licensee:
Tennessee Valley Authority 6N 38A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Docket Nos.:
50-259, 50-260, License Nos.:
DPR-33, DPR-52, and 50-296 and DPR-68 Facility Name:
Browns Ferry 1, 2, and
Inspection Conducted:
March 30-April 3, 1992 Xnspectors:
E.
D. Testa I
te Signed te Signed a e Signed Approved by:
gee J
P.
Pot r, Chief Facilitie Radiation Protection Section Emergency Preparedness and Radiological Protection Branch Division of Radiation Safety and Safeguards SUMMARY Scope:
This routine unannounced inspection was conducted in the area of occupational radiation safety and included an examination of:
audits and appraisals, planning and preparation, training and qualifications, external exposure control, internal exposure control, control of radioactive materials and contamination, surveys and monitoring, and maintaining occupational exposures ALMM. Xn addition, Information Notices and licensee response to previously identified inspection findings were reviewed.
9206020139 92080+
PDR ADOCK 05000259
Results:
In the area inspected, no violations or deviations were identified.
Based on interviews with licensee management, supervision, personnel from station departments, and records review, the inspector found that the radiation protection program continued to satisfactorily protect the health and safety of the workers and the public.
The computer-based Radiation Exposure System was fully operational in Units 2 and 3 and continued to evolve.
Contaminated square footage was near the goal of two percent and exposure goals remained challenging yet realistic.
Other program areas, including personnel contamination and radiological awareness reports, were maintained within specified goals and the ALARA program continued to move forward with initiatives in many areas including dose reduction and AIdQ& awareness training.
Inspector Followup Item (IFI) 91-35-01, concerning the reliable operation of newly installed continuous air monitors, was closed during the inspection (Paragraph 6).
REPORT DETAILS Persons Contacted Licensee Employees
- R. Beck, Unit 3 Radcon Manager
- S. Bugg, Manager, Radwaste
- R. Coleman, Acting Radiological Protection Supervisor J.
Corey, Manager, Radiological Controls
- C. Crane, Manager, Maintenance
- E. Mastich, Manager, Field Operations
- J. McDaniel, QA Evaluator
- G. Pierce, Manager, Regulatory Licensing
- W. Pierce, Health Physicist
- Radwaste
- J. Sabados, Manager, Chemistry and Environmental
- P. Salas, Manager, Compliance/Licensing
- J. Scalice, Plant Manager
- K. Schaus, QA Audit Specialist
- M. Snodgrass, QA Audit Specialist
- J. Swindell, Restart Operations
- J. Wallace, Compliance
- J. Wolcott, Nuclear Engineer Operations Support Other licensee employees contacted during the inspection included technicians, maintenance personnel, and administrative personnel.
Nuclear Regulatory Commission
- R. Bernhard, Project Manager
- E. Christnot, Resident Inspector
- J. Potter, Chief, Facilities Radiation Protection Section
- Attended exit meeting Organization, Management Controls and Planning and Preparation (83750)
The inspector reviewed changes made to the licensee's organization, staffing levels and lines of authority as they related to radiation protection, and verified that the changes had not adversely affected the licensee's ability to control radiation exposures or radioactivity.
The Manager of Radiological Control, oversees a staff of 180 managers, supervisors and technicians, including 55 who are dedicated solely to Unit 3 Radcon.
The inspector attended plant management and Radcon staff meetings and noted that good communication existed between the various departments.
The status of issues pertinent to Radcon was reviewed on a daily basis and upper management was kept informed of current problems and trend At the time of inspection, Unit 1 was in layup, Unit 2 was at 100 percent power, and preparations for Unit 3 restart continued.
No violations or deviations were identified.
3.
Audits, Appraisals, and Reporting Systems (83750)
a ~
Audits Technical Specification (TS) 6.5.1.6 requires that audits of plant activities be performed under the cognizance of the Plant Operations Review Committee (PORC)
encompassing the conformance of plant operation to provisions contained within the TSs and applicable license conditions at least once per 12 months; and the Process Control Program (PCP)
and implementing procedures at least once per 24 months.
The inspector reviewed the following audits conducted by Nuclear Quality Assurance:
BFA 91111,
"Radiological Control (RADCON)," dated October 25, 1991 o
BFA 91201,
"Radiological Environmental and Effluent Monitoring," dated December 10, 1991 o
BFA 92205,
"Performance, Training, and Qualification,"
dated February 25, 1992 In addition to the audits, the inspector reviewed monitoring reports of activities conducted by the licensee.
These reports were generated by the Browns Ferry Quality Organization and consisted of performance-based
"mini-inspections" of many areas including AIdQ& pre-job briefings, radiological awareness report investigation and followup, and inventory/control of radioactive material.
In general, the audits and monitoring reports were found to be indepth, probing, well-planned and documented.
No significant findings were identified by the licensee but, in many cases, recommendations were made in areas where minor changes or increased management attention was needed.
The inspector also noted that the auditors appeared well-qualified and knowledgeable in the audited areas.
b.
Radiological Awareness Reports (RARs)
The RAR program is implemented under Browns Ferry Procedure RCI-14 which provides guidance on the preparation, use, tracking, and trending of RARs.
Between October 16, 1991, and March 26, 1992, the licensee documented 184 RARs, 177 of which involved personnel failing to enter and/or exit the
RCA via the newly-implemented Radiation Exposure System database (REXS) properly (Paragraph 5).
According to the licensee, the major problem was with the actual input of information and not that individuals walked past the REXS terminals without stopping to sign-in/out.
Additional instruction and reminders were given to employees on how to properly utilize the system and the licensee planned to make REXS more "user-friendly" through some software changes.
The inspector reviewed selected RARs and noted that the number of problems occurring with REXS appeared to be trending down.
In addition, the seven RARs not associated with the REXS issue were reviewed and no problems were identified.
c.
Personnel Contamination Reports (PCRs)
The licensee's goal for personnel contamination was to maintain them at a rate of 1.0 PCR per 10,000 RWP-hours.
Between October 1, 1991, and March 31, 1992, the licensee had 24 PCRs at a rate of 0.9 PCR per 10,000 RWP-hours.
The inspector selectively reviewed the PCRs and no problems were identified.
No violations or deviations were identified.
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4.
Trainin and ualifications (83750)
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CFR 19.12 requires the licensee to instruct all individuals working or frequenting any portions of the restricted areas in the health protection aspects associated with exposure to radioactive material or radiation, in precautions or procedures to minimize exposure, and in the purpose and function of protection devices employed, applicable provisions of the Commission Regulations, individuals responsibilities and the availability of radiation exposure data.
The Radcon Curriculum Review Committee (CRC) periodically reviews training related to radiation protection and tra'cks actions recommended to be taken to improve and enhance the training.
The inspector reviewed minutes from CRC meetings held in October 1991 and January 1992 and no problems were noted.
The inspector discussed training with licensee employees during the inspection and, based on those discussions, it appeared that employees received the required training to adequately perform their assigned duties.
In addition, the inspector reviewed the licensee's ALARA Awareness Training program.
The program consisted of various training modules for planners (HPT179.200 module series)
and crafts, chemistry and engineers (HPT179.300 module series)
.
Each training module focused on a different aspect of ALARA pertinent
e to the worker's job.
The inspector noted the program as a
strength in the licensee's overall program and should significantly contribute to future dose savings.
No violations or deviations were identified.
5.
External Exposure Control (83750)
CFR 20.101 requires 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 1.25 rems to the whole body, head and trunk, active blood forming organs, lens of eyes, or gonads; 18.75 rems to the hands, forearms, feet and ankles; and 7.5 rems to the skin of the whole body.
CFR 20.101(b)(3)
requires the licensee to determine an individual's accumulated occupational dose to the whole body on an NRC Form 4 or equivalent record prior to permitting the individual to exceed the limits of 20.101(a).
CFR 20.202 requires each licensee to supply appropriate personnel monitoring equipment to specific individuals and require the use of such equipment.
In October 1991, the licensee began using the REXS and, by January 1992, the system was fully implemented in Units 2 and 3.
REXS tracked the accumulated dose of everyone entering the RCA and complemented the official TLD dose records.
Self -reading dosimeters (SRDs)
were issued, but the licensee had begun the phase-in of digital alarming dosimeters (DADs), which was scheduled to be completed in 1993.
At the time of inspection, DADs were issued only for work in high radiation areas and DAD readings were entered into REXS in lieu of SRD readings.
No exposures in excess of 10 CFR Part 20 limits occurred during the inspection period although there was an incident involving two individuals who exceeded RWP administrative dose limits, prompting an incident investigation.
Incident Investigation No.
II-B-92-015 was reviewed by the inspector and indicated that, during replacement of a resistive temperature device in Unit 2 on February 24, 1992, two workers failed to read their DADs frequently enough throughout the job, and did not hear their alarms due to overlays of protective clothing.
As a result, the
. workers exceeded the RWP dose limit of 150 millirem (mrem) per worker by receiving 367 mrem and 340 mrem respectively.
The workers'LDs were immediately processed and confirmed the DAD readings.
The root cause analysis performed and the licensee's corrective actions to avoid acoustical barriers appeared adequat Between October 1,
1991, and April 3, 1992, 52 whole body dose extensions were granted with the highest being 2.450 rem.
The highest whole body doses received during calendar year 1991 were 1.190 rem for a TVA Browns Ferry employee and 2.127 rem for a non-TVA Browns Perry employee.
CFR 20.408(b)
requires that when an individual terminates employment with the licensee, or an individual assigned to work in a licensee's facility but not employed by the licensee completes the work assignment, the licensee furnish the NRC a report of the individual's exposure to radiation and radioactive material incurred during the period of employment or work assignment, containing information recorded by the licensee pursuant to 10 CFR 20.401(a)
.
CFR 20.401(a)
requires each licensee to maintain records showing the radiation exposure of all individuals for whom personnel monitoring is recpxired under 20.202 of the regulations.
Such records shall be kept on Form NRC-5 or equivalent.
On March 16, 1992, Corporate TVA personnel identified a generic problem with the new REXS database that arose during the conversion from the old radiation exposure monitoring database (REMS) in January 1992.
Apparently, a "glitch" in the conversion software changed individuals'hole body exposure totals in the
,REXS database to a lower number than that shown in REMS.
As a result, exposure reports were found to be erroneous as were termination letters that had been issued since the conversion.
TVA-wide, approximately 2800 exposure reports and 450 termination letters were affected by the problem.
At Browns Ferry, the maximum error noted on a termination letter was 10 mrem.
The maximum exposure error noted for an individual still employed was 121 mrem.
At the time of inspection, the licensee had identified the problem and taken prompt corrective action.
Corrected letters were printed and were being validated line-by-line by TVA Corporate before being issued.
In addition, the affected exposure records of those individuals still employed with the licensee, including the one with the 121 mrem anomaly, were adjusted.
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.
Between October 1,
1991, and March 31, 1992, approximately 3507 whole body counts were performed by the licensee.
None were
found to be positive, all were less than one percent of the Maximum Permissible Organ Burden.
Also, it was noted that less than one percent of the whole body counts were performed (1) due to an incident or, (2)
as followup to an individual who received a medical procedure involving a radioisotope.
The individuals who were administered medical isotopes were restricted from entering the RCA until the medical radioisotopes fell below detectable levels.
CFR 20.103(c)(2)
permits the licensee to maintain and implement a respiratory protection program that includes, at a minimum:
air sampling to identify the hazard; surveys and bioassays to evaluate the actual exposures; written procedures to select, fit, and maintain respirators; written procedures regarding supervision and training of personnel and issuance of records; and determination by a physician prior to the use of respirators, that the individual user is physically able to use respiratory protective equipment.
During tours of the plant, the inspector noted that the storage, labeling, and testing of self-contained breathing apparatus (SCBAs) appeared to be adequate.
In addition, the inspector attempted to obtain a cartridge-type facemask at the HP issue desk and was refused because records indicated that a fit-test had not been completed prior to the request.
The inspector noted this as an indication that the licensee's fit-testing and mask/SCBA issuance procedures worked as designed and prevented the unauthorized issuance and use of respiratory protection equipment.
CFR 20, Appendix A, Footnote (d), requires adequate respirable air of the quality and quantity in accordance with NIOSH/MSHA certification described in 30 CFR Part 11 to be provided for atmosphere-supplying respirators.
CFR 11.121 requires that compressed, gaseous breathing air meets the applicable minimum grade requirements for Type
gaseous air set forth in the Compressed Gas Association (CGA)
Commodity Specification for Air, G-7.1 (Grade D or higher quality).
The inspector noted that the licensee's compressed air system was last tested for quality on December 3,
1991, and was found to meet and even exceed the above standards, being certified as Grade E air.
During the inspection at the request of the inspector, a
SCBA tank was chosen at random and sampled for air quality.
SCBA Tank No. 295-10016 was found to be pressurized to 4400 psi and the air contained within met at least Grade D
quality.
CFR 20.103(b)(1)
requires that the licensee use process or other engineering controls to the extent practicable to limit
concentrations of radioactive materials in the air to levels below those which delimit an airborne radioactivity area as defined in 20.203(d)(1)(ii).
During a tour of the Unit 3 drywell, the inspector noted the licensee's use of HEPA filter banks.
These were used to lessen the potential of airborne radioactivity during a weld-crown reduction effort.
No violations or deviations were identified.
Surveys, Monitoring, and Control of Radioactive Material and Contamination (83750)
CFR 20.201(b)
requires each licensee to make or 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 radioactive hazards that may be present.
The inspector reviewed selected records of radiation and contamination surveys performed during the period of February/March 1992, and no problems were noted.
During tours of the plant, the inspector observed health physics technicians performing radiation and contamination surveys.
The inspector performed independent radiation and loose surface contamination surveys in the clean tool rooms.
No abnormal radiation or contamination levels were found.
CFR 20.203 specifies the posting, labeling and control requirements for radiation areas, high radiation areas, airborne radioactivity areas and radioactive material.
Additional requirements for control of high radiation areas are contained in the plant's Technical Specifications.
During tours of the plant, the inspector noted that the licensee's posting and control of radiation areas, high radiation areas, airborne radioactivity areas, contamination areas, radioactive material areas, and the labeling of radioactive material was adequate.
No violations or deviations were identified.
Program for Maintaining Exposures As Low As Reasonably Achievable
'~un)
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 a low as reasonably achievable.
The recommended elements of an ALARA program are contained in Regulatory Guide 8.8, Information Relevant to Ensuring that
Occupational Radiation Exposure at Nuclear Power Stations will be ALARA, and Regulatory Guide 8.10, Operating Philosophy for Maintaining Occupational Radiation Exposures AZAR..
Regulatory Guides 8.8 and 8.10 provide information relevant to attaining goals and objectives for planning and operating light water reactors and provide general philosophy acceptable to the NRC as a necessary basis for a program of maintaining occupational exposures ALMA.
The inspector reviewed the following licensee ALSGA documents:
BFN - ALARA/Radwaste Committee Meeting Minutes, dated February 13, 1992 o
BFN - AIdQ&/Radwaste Committee Meeting Minutes, dated December 11, 1991 o
BFN - ALARA/Radwaste Committee Meeting Minutes, dated October 24, 1991 o
BFN - AIBA/Radwaste Committee Meeting Minutes, dated September 6,
1991 The inspector found th
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at management was actively involved in meeting parte.czpata.on and attendance.
Topics addressed during the meetings were appropriate and agendas for the meeting had been distributed approximately one week prior to the meeting to ensure adequate preparation.
The inspector noted that the radiation exposure goal from 650 person-rem to 539 person-rem.
Since performance had been good, a more challenging goal was established.
The dose savings realized prior to a Unit 1 walk down, by using chemical decontamination was actively discussed.
The inspector selectively reviewed ALARA post-job evaluation reports and Md&A/Radwaste suggestions and found no problems.
The licensee awarded priority parking spaces for the best ALM&
suggestions.
No violations or deviations were identified.
The inspector selectively reviewed the AIdQK/Radwaste Action Xtem Log and observed that most items appeared to be closed out in a timely manner; however, some improvement in timely action item completion could be realized.
The inspector determined that the AIBA program was active, functions well and management commitment to the program was eviden Plant Tours During the inspection, the turbine building, the auxiliary building, Unit 3 drywell, and Cooling Tower 3 were toured.
The inspector noted that a repainting project was in progress in the auxiliary building and, in general, housekeeping was adequate.
Workers all appeared to be wearing appropriate dosimetry and entering/exiting the RCA properly via REXS.
No problems were noted with the licensee's posting and control of radiation areas, high radiation areas, airborne radioactivity areas, contamination areas, radioactive material areas, and the labeling of radioactive material.
The inspector also noted that dose rates were relatively low in the Unit 3 drywell due to the chemical decontamination and other AIdQK steps initiated by the licensee.
This should save a significant amount of dose during the Unit 3 restart effort.
During the inspection, the processing for disposal of decommissioned control rod blades stored in the Unit 2 spent fuel pool was in progress.
The project was performed under Browns Ferry Procedure RWI-116,
"Spent Fuel Pool Cleanout Procedure, Revision 8" and involved crushing and shearing the blades into approximately one foot lengths. After cutting, the pieces were transferred to a HIC liner for disposal.
The crusher/shearer was designed and operated by vendor personnel, with radcon support provided by the licensee.
The inspector observed a full evolution of the work and identified no significant problems.
The inspector raised two questions about the project related to health physics regarding (1) the location of the air sampling equipment in the work area and (2) the quantities of potentially contaminated
"crud" shaken loose from the blades and into the pool water during the crushing and cutting process.
In response to the inspector's questions, the licensee relocated the air sampling equipment closer to the pool's edge in the areas most often occupied by the workers and requested the vendor to develop ways to enhance the vacuum system attached to the crusher/shearer for capturing the released
"crud".
During a tour of the outside radwaste loading and shipping area, the inspector noted gases bubbling in a puddle where the asphalt had subsided and rainwater had collected.
The inspector requested an air sample to ensure that no radioactive material was contained in the gas bubbles and being released.
Radioanalytical results of the air sample indicated that no radioactivity was present in the gas.
The inspector expressed concern about the subsidence in the area and displaced gas percolating through the asphalt paving.
The licensee began an investigation to determine the cause of the subsidence and to formulate a remedy to the problem.
No violations or deviations were identifie.
Information Notices (92701)
The inspector determined that the following Information Notices (IN) had been received by the licensee, reviewed for applicability, distributed to appropriate personnel, and that action, as appropriate was taken or scheduled:
91-10:
Summary of Semiannual Program Performance Reports on Fitness-for-Duty in the Nuclear Industry 91-35:
Labeling Requirements for Transporting Multi-Hazard Radioactive Materials 91-36:
Nuclear Plant Staff Working Hours 91-37:
Compressed Gas Cylinder Missile Hazard 91-39:
Compliance with 10 CFR Part 21,
"Reporting of Defects and Noncompliance" 91-40:
Contamination of a Non-Radioactive System and Resulting Possibility for Unmonitored Uncontrolled Release to the Environment 88-63, High Radiation Hazards from Irradiated Incore, Supp.
2:
Detectors and Cables 91-60:
False Alarms of Alarm Ratemeters Because of Radiofrequency Interference 91-65:
Emergency Access to Low-Level Radioactive Waste Disposal Sites No violations or deviations were identified.
11.
Followup Items (92701)
(Closed) IFI 91-35-01:
Reliable operation of newly installed Continuous Air Monitors (CAMs).
During a previous inspection, the inspector noted that a large number of CAMs were out-of-service awaiting repair for extended periods of time.
During this inspection, the inspector reviewed a program developed by the licensee to promptly identify problems and initiate maintenance for CAMs and no problems were identified.
At the time of inspection, only one CAM was out-of-service.
The inspector informed the licensee that this item would be considered closed based on the identified improvements and continued actions within this program are e 12.
Exit Meeting
At the conclusion of the inspection on April 3, 1992, an exit meeting was held with those licensee representatives indicated in Paragraph 1 of this report.
The inspector summarized the scope and findings of the inspection and indicated that no apparent violations or deviations were identified.
The licensee did not indicate any of the information provided to the inspector during the inspection as proprietary in nature and no dissenting comments were received from the licensee.