IR 05000259/1995065
| ML18038B588 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 12/19/1995 |
| From: | Decker T, Wade Loo NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18038B587 | List: |
| References | |
| 50-259-95-65, 50-260-95-65, 50-296-95-65, NUDOCS 9512270095 | |
| Download: ML18038B588 (16) | |
Text
~gS RECT
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UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W., SUITE 2900 ATLANTA,GEORGIA 303234199 Report Nos.:
50-259/95-65, 50-260/95-65, and 50-296/95-65 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 Nose1 DPR-33, DPR 52, and DPR-68 Facility Name:
Browns Ferry 1, 2 and
Inspection Conducted:
November 28 - December 1,
1995 Inspector:
~
~~~
Z W. T.
Loo C/5 D
e igned Approved by:
T.
R. Decker, Acting Chief Plant Support Branch Division of Reactor Safety D
e igned SUMMARY Scope:
This special, announced inspection reviewed area radiation levels for those areas of the plant that would be affected by the restart of Unit 3.
In addition, other health physics activities were reviewed to include internal exposure controls, and control of radioactive materials and contamination, surveys, and monitoring.
Also, the inspector reviewed those activities associated with a recent high radiation area incident.
Results:
Based on interviews with licensee personnel, records review, and direct observations of area radiation levels for various areas, associated with the restart of Unit 3, the inspector found no abnormal area radiation levels not otherwise observed by the licensee as public health risks to radiation workers.
The inspector determined that for those areas where area radiation levels exceeded background or licensee procedural limits, the licensee had adequately posted and secured the areas in accordance with licensee procedural and NRC regulatory requirements.
In addition, one Non-Cited Violation was identified regarding a recent high radiation area incident in which four individuals entered a high radiation area on a radiation work permit that did not allow them access to that area.
9512270095 951220 PDR ADQCK 05000259
PDR Enclosure
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REPORT DETAILS Persons Contacted 2.
Licensee Employees
- R. Coleman, Hanager, Radiation Protection, RadCon J.
Corey, Hanager, Radiological Control and Chemistry C. Crane, Assistant Plant Hanager
- J. Dollar, Outage
- D. Hill, Operations
- G. Little, Superintendent, Operations
- D. Hatherly, Operations
- G. Preston, Plant Hanager
- R. Rogers, 'Haintenance
- P. Salas, Hanager, Licensing R. Simpkins, Supervisor, RP, RadCon
- J. Wa11ace, Compliance Engineer, Licensing
- S. Wetzel, Acting Hanager, Compliance, Licensing
- R. White, Hanager, Fire Protection, Operations Other licensee employees contacted during the inspection included technicians, maintenance personnel, and administrative personnel.
Nuclear Regulatory Commission H. Horgan, Resident Inspector J.
Hunday, Resident Inspector R. Husser, Resident Inspector
- L. Wert, Senior Resident Inspector
- Attended December I, 1995, Exit Heeting Abbreviations and Acronyms used throughout this report are defined in the last paragraph.
External Exposure Control (83729)
This area was reviewed to followup on a recent incident that involved workers entering a
HRA on an RWP that did not allow them access to the area.
TS 6.8. 1 requires, in part, that written procedures be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, titled "guality Assurance Program Requirements (Operations),"
Rev.
2, dated February 1978.
Paragraph 7.e(l)
of Appendix A to Regulatory Guide 1.33 states that the licensee should have written radiation protection procedures for access control to radiation areas including a Radiation Work Permit System.
RCI-9 titled
"Radiation Work Permits,"
Rev.
32, dated November 14, 1995, describes the requirements for RWPs and the administrative procedures for requesting, obtaining and using them.
Item 6.7.3 states, in part, that individuals using a
RWP shall comply with all of the requirements of the RWP.
Item No. I of Section VI, titled "Additional Special Instructions/
n Enclosure
ik'O
Requirements,"
to BFN Radiation Work Permit ID No. 95-0-00022 00 00, states that "...No entry into C-Zones, High Rad, or Airborne Areas on this Subtask..."
The inspector reviewed the circumstances and followup actions for the following self-identified event involving workers entering a
HRA on an RWP that did not allow them access to the area.
On November 20, 1995, the licensee informed the NRC Region II office of the incident and discussed the preliminary findings of their investigation.
On November 17, 1995, at approximately 0510 hours0.0059 days <br />0.142 hours <br />8.43254e-4 weeks <br />1.94055e-4 months <br /> RadCon personnel identified a localized radioactive Hot Spot under the hotwell of the U3
"A" Condenser.
Dose rates were found to be approximately 50,000 mrem/
hour on contact and 5,000 mrem/hour at 30 centimeters.
Upon identification of those radiation dose rates RadCon personnel posted the area with HRA signs.
The licensee had constructed a cage around the U3 Condenser area from wire screen and tube-lock scaffolding along with four gates to permit access to the area.
RadCon personnel secured the four gates with plastic tie-wraps in order to make the HRA inaccessible.
Later that day at approximately 1445 hours0.0167 days <br />0.401 hours <br />0.00239 weeks <br />5.498225e-4 months <br />, a
RadCon representative was conducting tours of the facility and found three of the four gates in the U3 Condenser area to be unsecured.
RadCon resecured the three gates with plastic tie-wraps and verified that area radiation dose rates were greater than 1,000 mrem/hour.
During the onsite inspection, the available records and procedures that were applicable to the HRA incident were reviewed and discussed with cognizant licensee representatives.
Details of the incident as reported by the licensee were verified by the inspector.
In addition, PER No.
BFPER951741, Level B, Rev.
0, was initiated to investigate the circumstances surrounding the HRA incident.
During the investigation, the licensee determined that a laborer crew consisting of four men had been assigned to cleanup the U3 Condenser area.
The laborer crew went to the RadCon control point and was instructed to use RWP No. 95-0-00022 00 00 to conduct their cleanup of the U3 condenser area.
While cleaning in the U3 Condenser area the crew noticed the wire screen cage and the HRA posting.
The crew foreman exited the area and called the RadCon control point to discuss the requirements for entering the caged area directly under the condenser.
The foreman stated that the HPT informed him that if the crew was on RWP No. 95-0-00022 00 00 and were wearing DADs that they could continue to cleanup the condenser area.
The foreman returned to the U3 Condenser area and instructed the crew to enter the caged area to continue cleaning up under the condenser.
The crew stated that the two gates they had entered and exited were not secured in any,fashion.
They did state that they felt resistance when pulling on the gates but believed the hinges on the gates were sticking.
At no time did the crew observe any plastic tie-wraps on or near the gates.
Through discussions with the HPT, the licensee determined that when the HPT was contacted by the crew foreman, it was his understanding that the crew wanted to cleanup the area near the condenser.
The HPT did not recall the foreman indicating that he and his crew were going to conduct cleanup activities inside the secured caged HRA.
Enclosure
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Through further investigation, the licensee determined that one of the four laborers had entered on the wrong RWP, No. 95-3-22621 00 00.
The worker had previously been on that RWP conducting similar work activities associated with System 68 maintenance, Recirculation.
In addition, the licensee found four of the plastic tie-wraps that had been used to secure, two of the three unsecured gates and noted that they were stripped.
Based on discussions with licensee representatives and a review of various records, the inspector verified that upon identification of the unsecured HRA gates, corrective actions were taken by the licensee to secure the gates, make necessary gate repairs and identify other HRA gates for control.
Furthermore, the inspector independently verified that the licensee had made repairs to the gates and tube-lock scaffolding to secure them from unauthorized entry.
The licensee had removed the plastic tie-wraps and had the gates secured with either chains and a padlock or bolted the gates closed with scaffold clamps until padlocks had been procured by the licensee to replace the clamps.
In addition, the inspector noted that the licensee had replaced the HRA signs with new distinctly different kinds of signs that were clearly labeled as
"Locked High Radiation Area" rather than "High Radiation Area."
At the time of the onsite inspection, the inspector informed licensee representatives that workers entering the HRA on an RWP that did not allow them access to the area would be identified as an apparent violation of TS 6.8. 1.
Upon further NRC review, it was determined that the issue was a
violation of TS 6.8. 1.
However, because adequate immediate corrective actions to prevent recurrence were taken, this licensee-identified violation would not be cited because criteria specified in Section VII.B of the NRC Enforcement Policy were satisfied.
On December ll, 1995, a
telephone call was held between the inspector and licensee representatives to inform the licensee of this decision.
NCV: 50-259, 260 and 296/95-65-01:
Failure of four workers to enter a
HRA on an RWP that did not allow them access to the area.
Based on those discussions and reviews of records, the inspector determined that the licensee's investigation and corrective actions for the HRA incident were adequate to address the concerns associated with the incident.
During a previous NRC onsite inspection, an NCV was identified for two HRA incidents as documented in IR No. 50-259, 50-260 and 50-296/95-33, dated July 6, 1995.
Upon further NRC review it was determined that the root causes for the previous HRA events were due to mechanical failures rather than personnel error, as in this case.
One NCV and no deviations were identified in this area.
Internal Exposure Control (83729)
This area was reviewed to determined the adequacy of the licensee's assessments of individual intakes of RAN and records of internal radiation exposure measurements and assessments.
Enclosure
CFR 20. 1502(b) requires each licensee to monitor the occupational intake of radioactive, material by and assess the committed effective dose equivalent to:
(1) Adults likely to receive, in one year, an intake in excess of 10 percent of the applicable Annual Limit of Intake (ALI) in Table 1,
Columns 1 and 2 of Appendix B. to 10 CFR 20.1001-20.2401; and (2) Minors and declared pregnant women likely to receive, in one year, a
committed effective dose equivalent in excess of 0.05 rem.
CFR 20. 1204 states that for purposes of assessing dose used to determine compliance with occupational dose equivalent limits, the'icensee, when required to monitor internal exposure, shall take suitable and timely measurements of concentrations of radioactive materials in air, quantities of radionuclides in the body, quantities of radionuclides excreted from the body, or combinations of these measurements.
When specific information on the behavior of the material in an individual is known, that information may be used to calculate the CEDE.
The inspector discussed with cognizant licensee representatives the
'rogram for conducting WBCs.
Based on those discussions and a review of WBC procedures and records, the inspector determined that the licensee maintained two locations for conducting WBCs, one area located within the plant and one located at the licensee's training center.
During those discussions with licensee representatives the inspector determined that for RadCon personnel an internal cross-training program had been initiated several years ago to develop and broaden RadCon personnel knowledge in other aspects of the RadCon program.
This included RadCon personnel being cross-trained in WBC.
From a review of various RadCon training records the inspector determined that approximately eight individuals had met the licensee's training procedural requirements for conducting WBCs.
Of those eight individuals several of them had experience conducting WBCs at the licensee's facility for numerous years.
The inspector reviewed various records of WBCs performed by the licensee for the calendar year 1995 to date.
From those reviews of records and discussions with cognizant licensee representatives, the inspector determined that for the calendar year 1995 to date the licensee had conducted WBCs routinely on almost a daily basis.
In addition, the inspector noted that approximately 75 percent of the WBC records indicated a radionuclide standard deviation error of greater than 40 percent.
The inspector discussed this standard deviation error with cognizant l.icensee representatives and determined that this numerical value represented the percent error of radionuclides identified in an individual as compared to the full width half maximum value for the radionuclide standard used at the time of cal:ibration.
Although the percent error appeared to indicate a positive uptake of a particular radionuclide it actually represented the percent error for known or unknown radionuclides versus the radionuclide standard used by the licensee.
On most occasions this percent error represented statistical variations, high background or noise from an individual WBC sample.
Furthermore, the licensee placed in their bioassay program procedures a statement that allowed for this percent error.
At Enclosure
0'1
the time of the onsite inspection no concerns were noted by the inspector based on those reviews of various WBC records and discussions with cognizant licensee representatives.
Based on those discussions, observations and review of various records, the inspector noted that the licensee's program for monitoring and assessing internal exposures was conducted adequately in accordance with NRC regulatory and licensee procedural requirements.
No violations or deviations were identified in this area.
4.
Control of Radioactive Materials and Contamination, Surveys, and Monitoring (83729)
This area was reviewed to determine whether area radiation and removable contamination survey.
and monitoring activities were performed as required, and control of RAHs and contamination met licensee procedural and NRC regulatory requirements.
a.
U3 Restart Area Radiological Surveys and Instrumentatjon
CFR 20. 1501(a) 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 observed HPTs conduct area radiation and removable contamination surveys associated with U3 Restart activities.
Based on those observations and reviews of records, the inspector found the licensee activities associated with the 55 percent power ascension area radiation surveys to be adequate.
The inspector noted that the HPTs used appropriate area radiation detection survey instruments for conducting the U3 area and penetration surveys.
In addition, the inspector noted that the radiation detection survey instruments had been calibrated and source-checked as required by licensee procedures.
Also, for those areas where known or expected high radiation levels existed, the licensee had adequately posted and secured those areas in accordance with licensee procedural and NRC regulatory requirements..
The inspector observed HPTs conducting the area radiation surveys in accordance with licensee procedural and NRC regulatory requirements.
Furthermore, the inspector conducted various independent area radiation surveys of the U3 Reactor and Turbine buildings and noted no concerns with the observed area radiation survey results.
b.
Radiological Postings and Control of Contamination and Radioactive Material
CFR 20. 1904(a) requires the licensee to ensure that each container of licensed material bears a durable, clearly visible label bearing the radiation symbol and the words "Caution, Radioactive Material," or
"Danger, Radioactive Material."
The label must also provide sufficient information (such as radionuclides present, and the Enclosure
ik'I IO
estimate of the quantity of radioactivity, the kinds of materials and mass enrichment)
to permit individuals handling or using the containers, to take precautions to avoid or minimize exposures.
CFR 20. 1902(e),
requires that.for posting of areas or rooms in
.which licensed material i's used or stored, the licensee shall post each area or room in which there is used or stored an amount of licensed material exceeding 10 times the quantity of such material specified in Appendix C to 20.1001-'20.2401 with a conspicuous sign or signs bearing the words "Caution, Radioactive Material(s)" or "Danger, Radioactive Material(s)."
During tours of various areas within the plant, the inspector observed adequate RAN contamination control and housekeeping practices.
The inspector noted that the licensee's control and labeling of RAN for those areas observed were adequate.
The inspector noted that the licensee's posting and control of radiation areas, HRAs, Locked HRAs, Very HRAs, airborne radioactivity areas, contamination areas, and RAM areas for those areas observed were appropriate.
The inspector noted that all containers of RAN observed were properly labeled in accordance with the radiation hazards present.
All RAN and radiation area signs were conspicuous and legible and maps and labels were clearly visible and informative.
Also, the inspector conducted random
~ independent area radiation surveys and noted no problems with observed area radiation levels.
Based on those discussions, observations and review of various records, the inspector noted that the licensee was adequately conducting area radiation and contamination surveys at the licensee's facility with appropriate radiation detection and measurement survey instruments.
In addition, the inspector noted that for those areas observed that the licensee was adequately labeling, posting and controlling access to radiation and HRAs and RAM.
No,violations or deviations were identified in this area.
5.
Exit Meeting On December I, 1995, an exit meeting was held with those licensee representatives denoted in Paragraph I of this report.
The inspector summarized the scope and findings of the inspection.
At the time of the onsite inspection the inspector informed licensee representatives of an apparent violation of TSs.
Upon further NRC review it was determined that the issue constituted an NCV rather than a cited violation of TSs as discussed in Paragraph 2.
The licensee did not indicate that any of the information provided to the inspector during the onsite inspection was proprietary in nature and no dissenting comments were received from the licensee.
Enclosure
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Item Number Status NCV 50-259, 50-260 Closed and 50-296/95-65-01 Descri tion and Reference Failure of workers to enter a
HRA on an RWP that did not allow them access to the area (Paragraph 2).
6.
Index of Abbreviations Used in this Report CFR DAD HPT:
HRA IR mrem NCV PER RAN-RadCon RCA RCI Rev.
RP RWP TS U3 WBC Code of Federal Regulations Digital Alarming Dosimeter Health Physics Technician High Radiation Area Inspection Report Hilli-Roentgen Equivalent Nan Non-Cited Violation Problem Evaluation Report Radioactive Haterial Radiological Control Radiologically Controlled Area Radiological Control Instruction Revision Radiation Protection Radiation Work Permit Technical Specification Unit 3 Whole Body Count Enclosure
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