ML18025B647
| ML18025B647 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 09/04/1981 |
| From: | Mills L TENNESSEE VALLEY AUTHORITY |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML18025B646 | List: |
| References | |
| NUDOCS 8109240551 | |
| Download: ML18025B647 (8) | |
Text
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e TENNESSEE VALLEYEAUT'AOglT-'g CHATTANOOGA. TENNESSEE 3740'tte Qg ~
t00 Chestnut Street Tpr~r II ggu 8 pt September 4,
1981 Mr. James P. O'Reilly, Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Region II - Suite 3100 101 Marietta Street Atlanta, Georgia 30303
Dear Mr. O'Reilly:
This is in response to your August 7, 1981 letter to H. G. Parris, Report Nos. 50-259/81-17,
-260/81-17, and -296/81-17, concerning activities at the Browns Ferry Nuclear Plant which appeared to violate NRC requirements.
Enclosed is our response to Appendix A, Notice of Violation, If you have any questions, please call Jim Domer at"FTS 857-2014.
To the best of my knowledge, I declare the statements contained herein are complete and true.
Very truly yours, TENNESSEE VALLEY AUTHORITY
. M. Mil s, Ma ager Nuclear Regulation and Safety Enclosure 8109240551 810915 PDR ADOCK 05000259 I
8 PDR'n Equal Opportunity Employer
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ENCLOSURE
RESPONSE
NRC INSPECTION REPORT NOS.
50-259/81-17, 50-260/8-1-17, AND 50-296/81-17 J.
P. O'REILLX'S LETTER TO H. G.
PARRIS DATED AUGUST 7, 1981 Item A
10 CFR 20. 104 (a) states that no licensee shall possess, use or transfer licensed material in such a manner as to cause any individual within a restricted area who is under 18 years of age to receive in any period of one calendar quarter, from radioactive material and other sources of radiation in the. licensee's possession, a whole body dose in excess of 125 millirems.
Contrary to the above, an individual under 18 years of age received a
whole body dose for the second calendar quarter in excess of 125 millirems in that, on June 6 and 7,
- 1981, the individual received a whole body dose of 736 millirems while working in the unit 1 reactor cavity.
This individual would not have been 18 years of age until June 23, 1981.
This is a Severity Level III Violation (Supplement IV).
1.
Admission or Denial of the Alleged Violation TVA admits the violation occurred as stated.
2.
Reasons for the Violation if Admitted The minor had been informed by his supervisor (a non-TVA employee) to record his age as 18 years on Form NRC-4 equivalent for employment purposes.
His supervisor's position was that he was following past practices used by other contractors in the construction industry to show an individual's age as 18 if his birthday falls within the current month.
This individual listed his age as 18 on the form.
Although he had recorded his date of birth accurately, the discrepancy between his indicated age and his actual age was not detected.
3 ~
Corrective Ste s Which Have Been Taken and Results Achieved a.
A memorandum was sent to the health physics staff emphasizing the need for review of, and specific points to review. for occupational radiation dose histories before processing, as well as a review of Federal and TVA administrative occupational radiation dose limits for personnel 18 years of age and younger.
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b.
Onsite contractors were asked to verify that their personneL were 18 years of age or older.
c.
The individual under 18 years of age related in the violation was removed from the site on June 8, 1981.
No other minors were identified, and no recurrence of this violation has occurred.
4.
Corrective Stens Hhich Mill Be Taken to Avoid Further Violations I
A change to the onsite dose tracking computer program has been requested.
The change involves the input of the individual's date of birth, a routine to calculate the age in accordance with 10CFR20, input of allowable dose Limit, and a'esponse to the data processor if quarterly dose limits in excess of 0. 125 rem for individuals Less than 18 years of age and 1.25 rems for individuals 18 years of age have been applied.
5.
Date Mhen Full Compliance MiLL Be Achieved The action described in paragraph four will be completed by January 1,
1982.
Item B
Technical Specification 6.3.A requires that detailed written radiation control procedures be pi epared, approved and adhered to.
One such procedure is Radiological Control Instruction 2.
Section XI of this instruction states that no individual less than 19 years of age shalL be authorized to receive a quarterly whole body dose of 3.0 rems.
Contrary to the above, a
17 year old worker, on June 8,
- 1981, was authorized to receive a whole body dose of 3 r ems.
This is a Severity Level V Violation (Supplement IV).
1.
Admission or Denial of the Alle ed Violation TVA admits the violation occurred as stated.
2.
Reason for the Violation if Admitted The violation was due to an oversight by one individual.
The occurrence is considered to be an isolated case since an investigation revealed no similar situations.
This one oversight is not considered an indication of general weakness of the overall dose control program.
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3.
Corrective Steps iJhich Have Been Taken and Results Achieved A memorandum was sent to the health physics staff emphasizing the following:
a.
Verification that age and birth dates are in agreement on dose history forms.
b.
Dose history forms are complete, clearly written, and signed.
c.
Federal and TVA administrative occupational radiation dose limits for personrel 18 years of age and younger.
Corrective Ste s Mhich [Jill Be Taken to Avoid Further Violations A change to the onsite dose tracking computer program has been requested.
The change involves the input of the individual's date of birth and a routine to calculate the age in accordance with
- 10CFR20, input of allowable dose limit, and a response to the data processor if quarterly dose limits in excess of 0. 125 rem for individuals less than 18 years of age and 1.25 rems for individuals 18 years of age have been applied.
5.
Date
'Ahen Full Compliance 1Jill Be Achieved The action described in paragraph four will be completed by January 1,
1982.
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