IR 05000259/1995055
| ML18038B533 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 10/18/1995 |
| From: | Barr K, Wade Loo NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18038B532 | List: |
| References | |
| 50-259-95-55, 50-260-95-55, 50-296-95-55, NUDOCS 9511140249 | |
| Download: ML18038B533 (24) | |
Text
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~o UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W., SUITE 2900 ATlANTA,GEORGIA 303234199 Report Nos.:
50-259/95-55, 50-260/95-55, and 50-296/95-55 Licensee:
Tennessee Valley Authority 6N 38A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Docket Nos.:
50-259, 50-260, and 50-296 Facility Name:
Browns Ferry 1, 2 and
Inspection Conducted:
September 25-29, 1995 License Nos.:
DPR-33, DPR 52, and DPR-68 Inspector: ~
'
W. T.
Loo
,I Approved by:
K./P.
,
)ef Plant Support Branch Division of Reactor Safety D te igned
/0 /FQI Da e igned SUMMARY Scope:
This special, announced
.inspection reviewed Area Radiation Monitoring System operations associated with Unit 3 restart to include a review of the licensee's Continuous Air Particulate Monitors and the status of a specific NUREG-0737 Three Mile Island Action Item.
In addition, issues associated with the Radiological Control Unit 3 Restart Punch List were reviewed.
Results:
Based on interviews with-licensee personnel, records review, and observations of specific Area Radiation Monitoring Systems, the inspector found that the licensee adequately completed the installation, calibration and testing of Unit 3 continuous air particulate monitors.
Furthermore, based on those discussions, reviews and observations the inspector determined that the licensee had completed activities to meet the criteria specified for the installation, calibration and testing for Three Mile Island Action Item II..F. 1.2.c (Containment High Range Monitors).
Also, the inspector determined that the licensee completed work activities associated with the Radiological Control Unit 3 Restart Punch List and found those actions to be adequate.
.In addition, one Inspector Followup Item was identified regarding the licensee's Final Safety Analysis Report describing the number of 95iii40249 95iOi8 PDR ADQCK 05000259
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continuous air particulate, monitors associated with Units 1 and 3 that could warn of abnormal'adiation conditions that may be present and sample the air for airborne particulates.
Also, a previous inspection finding was closed'ased on information gathered during the inspectio.)gi
REPORT DETAILS Persons Contacted Licensee Employees D. Burrell, Lead Electrical Engineer, Nuclear Engineering
- R. Coleman, Radiation Protection Manager, RadCon
- J. Corey, Radiological Control and Chemistry Manager
- C. Crane, Assistant Plant Manager
- T. Dexter, Training Manager
- R. Gilbert, Operations R. Givens, Systems Engineer, Technical Support
- R. Greenman, Restart Readiness Manager
- H. Hill, Maintenance Manager
- D. Lambert, Technical Support
- G. Preston, Plant Manager
"P. Salas, Licensing Manager R. Simpkins, Radiation Protection Supervisor, RadCon F. Spivey, ALARA Supervisor, RadCon
- J. Wallace, Compliance Engineer, Licensing
- S. Wetzel, Acting Compliance Manager, Licensing
- J. White, Outage Manager
- H. Williams, Engineering and Material Manager Other licensee employees contacted during the inspection included technicians, maintenance personnel and administrative personnel.
Nuclear Regulatory Commission
- G. HacDonald, Reactor Inspector J.
Hunday, Resident I'nspector
- R. Husser, Resident Inspector
- L. Wert, Senior Resident Inspector
- G. Wiseman, Reactor Inspector
"Attended September 29, 1995, Exit Meeting Abbreviations and Acronyms used throughout this report are defined in the last paragraph.
Radiation Monitoring Systems (83729)
Section 7.13, titled "Area Radiation Monitoring System" of the Browns Ferry Nuclear Plant FSAR, Amendment No.
12, provides the ARMS design bases, descriptions, inspection and test requirements, sy'tem characteristics, and monitoring and power supply design'onditions.
Through discussions with licensee representatives and a review of applicable records, the inspector determined that the licensee'had completed the installation, testing and calibration for eight of the nine CANs associated with U3 Reactor and Turbine Buildings.
The inspector conducted a tour of the U3 Reactor and Turbine Building and
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observed that the CANs had been installed in various locations of the buildings to monitor for radioactive airborne particulates.
For those CAMs observed the inspector reviewed the calibration records and determined that the CANs had been calibrated and tested by licensee personnel as documented in licensee Work Order Nos. 95-01300-01, 95-01301-'01 and 95-01302-01.
In addition, from those discussions and reviews the inspector determined that the licensee had completed the Phase I and II System Pre-Operability Checklists for U3 System No.
Radiation Monitoring Systems.
Included in those checklists was the completion of work activities associated with the CAMs as discussed below in Paragraph 4.
Through further discussions and reviews the inspector determined that the ninth CAN was a shared CAM between Units 2 and 3 in the U3 control room area.
The inspector was informed by licensee representatives that the licensee utilized this CAN to serve as a backup to the licensee's CREVS for Units 2 and 3.
Because the CAN was utilized as a backup to this system licensee management made a decision approximately two years ago to remove the CAN from the U3 control room area.
In the event the CAM would be needed the licensee could readily retrieve the CAN and have it operational within one work shift or eight hours as described in the licensee's TSs.
At the time of the onsite inspection the CAN was being stored in an area near the control room.
Licensee representatives informed the inspector that the CAN had been used during the previous outage because the CREVS had been taken out of service for preventive maintenance.
Prior to using the CAN during the outage the licensee had the instrument calibrated and tested.
The inspector discussed with cognizant licensee representatives their FSAR commitments with regards to the CANs for Units 1 and 3.
Section 7. 13.5.1, titled "Power Generation Objectives," of the licensee's FSAR states that "...The objective of the Additional ARMS is to provide diversity in radiation detection devices to warn of the abnormal radiation conditions that may be present..."
In addition, Section 7. 13.5.3.1 titled "Air Particulate Monitoring Subsystems,"
states that "...Each of the air particulate monitoring stations samples the air for airborne particulates..."
Based on a review of the licensee's FSAR the inspector noted that this section appeared to apply to seven Ul and nine U3 CAMs.
Through those discussions with licensee representatives the inspector noted that the ninth U3 CAM and seven Ul CAMs did not appear to be able to meet this commitment if they were out of service or in storage.
Through further discussions licensee representatives stated that for the Ul CAHs there was no safety significance involved.since Ul had no fuel; however, the inspector noted that there still were some remains of radioactive material in certain Ul systems that represented a radiological hazard.
Also, licensee representatives stated that the purpose of the ninth U3 CAN was to serve as a backup for the CREVS; however, the inspector noted that the CREVS maintained a radiation detector not capable of monitoring for, airborne radioactive particulates and would not be able to function in the same capacity as a CAN.
Through further discussions and reviews licensee representatives informed the inspector that they were
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discussing the option of removing the ninth CAM altogether.
They stated that if they removed the CAN from the control room area they could readily obtain from RadCon a portable CAH to serve in the same capacity.
As a result of those discussions and reviews of records, the inspector stated that a clarification of the licensee's FSAR commitments for the number of CAMs associated with Units 1 and 3 and their functional status would be reviewed during future inspections as an IFI.
IFI 50-259, 296/95-55-01:
Revi'ew of licensee FSAR commitments for CAHs associated with Units 1 and 3.
No violations or deviations were identified in this area.
TMI Action Plan Item II.F.1.2.c (Containment High Range Monitors)
NUREG-0737, THI Action Plan Item II.F.1.2.c, Attachment 3, titled
"Containment High-Range Radiation Monitor," requires, in part, that the licensee install two containment radiation-level monitors with a maximum range of 10'ads per hour, physically separated, and independent and qualified to function in an accident environment.
NUREG-1435, THI Action Plan Item II.F.l, titled "Accident Monitoring,"
requires, in part, that the licensee have the capability to monitor accident conditions and install accident monitoring instruments to include containment high range monitoring for beta/gamma:
1 to 10'ad/hr, or gamma only:
1 to 10'oentgen per hour.
During discussions with licensee representatives and from a review of applicable records, the inspector determined that the licens'ee had received the other two CHRHs since the last onsite NRC inspection of this area as documented in IR Nos. 50-259, 260 and 296/95-42, dated August 17, 1995.
The inspector reviewed applicable calibration records for the two CHRHs, Serial Nos. 6,583,692 and 6,583,697, and determined that they had been sent to ah outside vendor for testing to ensure that they met the TSs as outlined in the manufacturer's
"Operation and Maintenance Instruction" for Gamma Sensitive Ion Chamber 237X731G010.
The vendor's
"Test Data Report," dated August 16, 1995, indicated the test results for the following:
Insulation Resistance
- collector to case, high voltage to case and high voltage to collector; Capacitance
- collector to case and high voltage to case; Gamma Sensitivity; and Withstand Voltage.
The inspector reviewed the vendor's test data and determined that the results adequately met the manufacturer's TSs for the two CHRMs.
In addition, the inspector reviewed the vendor's graph depicting Current
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Versus High Voltage for specific gamma field strengths and determined that they adequately met the manufacturer's similar graph for'he ion chambers at a similar gamma flux.
Through further discussions with licensee representatives and a review of applicable records, the inspector determined that the licensee had adequately completed environmental qualification work activities associated with each CHRM as documented in Forms SSP-235 titled
"Environmental gualification Maintenance Work Record,"
dated'eptember 17, 1995, and attached Forms SSP-227 titled "Replacement Eg Whole Device Field Verification Form," dated September 21,'995.
During those discussions and reviews with licensee representatives,
'the inspector determined that the licensee had adequately completed the installation, calibration and functional testing for all four CHRMs as documented in the following Surveillance Instructions:
3-SI-4.2F-19(A), titled "Containment High Range Radiation Monitoring Channel Calibration and Functional Test (3-RM-90-272A)
Division I, Rev.
0, guality Related,"
dated August 28, 1995; 3-SI-4.2F-19(B), titled "Containment High Range Radiation Monitoring Channel Calibration and Functional Test (3-RM-90-273A)
Division I, Rev.
0, guality Related,".dated August 28, 1995; SII-3-RM-90-272B, titled "Containment High Range Radiation Monitoring Channel Calibration and Functional Test, Suppression Chamber Division I (3-RM-90-272B),
Rev.
0, guality Related,"
dated September 8,
1995; and SII-3-RM-90-273B, titled "Containment High Range Radiation Monitoring Channel Calibration and Functional Test, Suppression Chamber Division I (3-RM-90-273B),
Rev.
0, guality Related,"
dated September 8,
1995.
In addition, the inspector accompanied by licensee'epresentatives conducted a tour of those areas within the plant to review the installation and location for three of the four CHRMs.
Also, the inspector observed the graphs and electronic monitor readouts located in the U3 control room for those CHRMs.
Based on those discussions, reviews and observations, the inspector
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determined that the CHRMs had been adequately calibrated, installed and tested to meet those criteria as specified above for monitoring accident conditions from 1 to 10 roentgen per hour, gamma only.
At the time. of the onsite inspection, the inspector informed licensee representatives that TMI Action Plan Item II.F.1.2.c would be considered closed.
No violations or deviations were identified in this are IP IQi Ili
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RadCon U3 Restart Punch List (83729)
Through discussions with licensee representatives and a review of various records available at the time of the onsite inspection, the inspector determined that the licensee had completed those remaining work activities associated with the RadCon U3 Restart Punch List.
During those discussions and reviews the inspector noted that for the two remaining, open items RadCon had direct responsibility for one had been completed as noted below:
Operating Area Dose Rate
-
RCA Boundary
& PCM-1B Impact
. The licensee conducted a review of various RadCon program aspects as they related to the potential radiation increases from the restart of, U3.
The licensee concluded that a potential for an increase of radiation levels could be observed in various areas associated with U3.
This included areas such as the East Access Facility on the 580 foot elevation, U3 East Portal, 'Control Rod Drive Hydraulic Control Unit banks and the southeast quad.
The license determined that the potential increase in radiation levels could affect the PCM-1B and tool monitors in those.areas by increasing their count times..
As a result of this potential for increased radiation levels the licensee was considering an alternate RCA exit arrangement and relocating that exit to the 565 foot level of the East Access Facility or U3 Turbine Building breezeway.
Also, the licensee was going to establish more area TLDs to further define likely area radiation doses to individuals located at work stations outside the RCA boundary in the building.
Furthermore, the licensee was going to check portal monitor response checks throughout U3 power ascension to determine if additional shielding would be required to reduce background area radiation levels affecting the portal monitors.
As discussed in IR Nos. 50-259, 260, 296/95-42, the inspector determined that the item for "Decon All Possible Areas" would be an ongoing issue since it would be an effort by the licensee for conducting decontamination of U3 work areas during recovery, restart,,
and future work activities.
For those items where RadCon did not have direct responsibility for closure, the final two items had been completed by other organizations as noted below:
Install Gamma TIPS, Traversing Incore Probe The licensee replaced the existing TIP neutron sensitive detectors with gamma sensitive detectors, the existing coaxial drive cable with triaxial drive cable, and the existing flux probing monitor in panel 3-9-13 with a high gain flux probing monitor for use with
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activities on August 8, 1995, as documented in Design Change Notice No.
W17837A and attached Forms SSP-83, titled "Modification Work Completion Statement."
CAN Operability As discussed above in Paragraph 2, the licensee had completed the calibration, installation and testing of the CAMs as documented in Forms SSP-123, titled "Phase I System Pre-Operability Checklist,"
dated August 25, 1995, and SSP-124, titled "Phase II System Pre-Operability Checkl.ist," dated September 22, 1995, to SSP-12.55 titled "U3 System Pre-Operability Checklist," dated August 2, 1995.
The inspector reviewed the applicable documents associated with the closure of the above Punch List items and discussed those items with cognizant licensee representatives.
Through those discussions, reviews and observations of related work activities, the inspector determined" that the licensee adequately conducted reviews and work activities associated with the closure of the remaining Punch List items.
The inspector noted no concerns with those reviews and work activities except for the ongoing activities associated with the decontamination of U3 contaminated areas as discussed above.
The inspector informed licensee representatives that the completion of those items associated with the RadCon U3 Restart Punch List was found to be adequate and appropriate for U3 Restart.
No violations or deviations were identified in this area.
External Exposure Controls (83729)
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Personnel Dosimetry
CFR 20. 1502(a) requires each licensee to monitor occupational exposure to radiation and supply and require the use of individual monitoring devices for:
(1-)
Adults likely to receive, in one year from sources external to the body, a dose in excess of 10 percent of the limits in
CFR 20.1201(a);
(2)
Minors and declared pregnant women likely to receive, in one year for sources. external to the body, a dose in excess of 10 percent of any of the applicable limits of 10 CFR 20. 1207 or
CFR 20.1208; and (3)
Individuals entering a high or very HRA.
The inspector reviewed the licensee's dosimetry program and noted that the licensee had implemented a new program for maintaining TLDs at the licensee's facility as previously discussed and documented in NRC IR Nos. 50-259, 50-260 and 50-296/95-33, dated
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July 6, 1995.
On August 4, 1995, the licensee initiated a new plant security system.
The old security system allowed the employees to leave both their security badge and TLD with security; however, the new system allowed the employees to take home their security badges.
Although employees were a11owed to take home their security badges under the new system they were not allowed to take home their TLDs.
As a result, the licensee installed TLD racks at the two main entrances, east and west sides, to the RCA for employees to store their TLDs when they were not in the RCA.
When the licensee began to implement the new TLD storage system, the licensee identified eight occurrences where individuals had enter the RCA without their TLDs.
On each of those occurrences the licensee initiated a
PER; however, after the identification of an observed trend associated with those PERs the licensee initiated PER No.
BFPER951123 to review the TLD occurrences.
After further review by the licensee several actions were initiated as follows:
A site bulletin was issued to alert personnel of the TLD problem; Additional signs were placed at the RCA entrances to alert and remind personnel to wear their TLD when entering the RCA)
HPTs were placed at the RCA entrances and exits in an effort to stop those who had forgotten to wear their TLD and to identify those who had already entered the RCA without a TLD for proper documentation; and Illuminated beacons were placed at entrances to the 'RCA as a
more prominent reminder to personnel to wear their TLD.
In addition, the licensee would continue to monitor the trends associated with proper wearing of TLDs through the end of November 30, 1995.
Site guality Assurance also agreed to assist RadCon with the monitoring of this issue. by using the inspector-of-the-day program to observe personnel in the plant for proper wearing of TLDs in the RCA.
Also, the licensee had decided to implement a new program of "take home dosimetry" beginning January I, 1996.
Although the PER had not been closed out because of two outstanding items, the inspector determined that the licensee had taken adequate actions to ensure that employees wore their TLDs prior to entering the RCA.
In addition, during tours of the plant, the inspector observed proper use of TLDs and electronic dosimeters by licensee employees and contractors within the RCA.
Radiation Work Permits The inspector reviewed selected RWPs for appropriateness of the radiation protection requirements based on'work scope, location,
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and conditions.
The inspector noted and reviewed survey results for the initiation of various special RWPs as well as the surveys conducted during those job activities and after the work had been completed.
The inspector noted that when the potential for certain conditions to exist, such as airborne.radioactive material, the licensee took adequate precautions for evaluation of work conditions associated with the job activities to include air sampling and appropriate RadCon job coverage.
Based on those reviews the inspector noted that the RWPs were being appropriately initiated and terminated based on the job scope.
For those RWPs reviewed, the inspector noted that the radiological concerns were adequately addressed in that appropriate protective clothing,
.respiratory protection, and dosimetry were required.
The inspector noted that the licensee had initiated several actions to ensure that workers were knowledgeable of RWP requirements because of a previous inspection finding as discussed below in Paragraph 6.
During tours of the plant, the inspector observed the adherence of plant workers to RWP requirements and discussed the RWP requirements with plant workers at the various job locations.
The inspector found those workers to be knowledgeable of the RWP requirements and their responsibilities to comply with those requirements.
Furthermore, the inspector found the licensee's program for RWP implementation to adequately address radiological protection concerns, and to provide for proper control measures.
c.
Posting and Labeling During tours of the plant and various radioactive material storage areas, the inspector noted that the licensee's posting and control of radiation areas, HRAs, airborne radioactivity areas, contamination areas and radioactive material areas were adequate.
Based on those discussions, observations and reviews of various records, the inspector noted that the licensee was adequately labeling, posting, and controlling access to radiation and HRAs and radioactive material to include appropriate RWPs and adequate dosimetry monitoring for radiation exposure.
No violations or deviations were identified in this area.
Followup of Previously Identified Inspection Findings (83729)
(Closed)
VIO 50-260, 296/95-33-04:
Failure to follow procedures for RWP implementation.
In response to the subject violation, the licensee initiated a
PER, No.
'BFPER-950695.
Several corrective actions were taken to. address the violation as follows:
Appropriate corrective actions taken for those individuals involved with the observed violation;
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RadCon provided briefing material to site organization managers to notify workers of the event and re-emphasizing RWP requirements; Nuclear Assurance conducted a field assessment of worker knowledge of RWPs while working in the RCA and identified the same issues associated with the violation; Revision to procedures to. clarify management expectations concerning worker responsibilities of RWP requirements and to require workers to acknowledge that they had reviewed the RWP requirements 'prior to being 'added to the briefing/approval list in
.REXS; and RadCon created a
"RWP and Survey Hap Information Center" at the main entrances to the RCA. to enhance the workers awareness of RWPs and radiological surveys.
During the onsite inspection, the inspector reviewed RWP implementation and conducted tours of the plant to see if workers were knowledgeable
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and adhering to their respective RWP requirements as discussed above in paragraph 5.b.
The inspector informed licensee representatives that this item would be considered closed based on the appropriateness of their corrective actions and those direct observations made by the inspector.
Exit Heeting At the conclusion of the onsite inspection on September 29, 1995, an exit meeting was held with those licensee representatives indicated in Paragraph I of this report.
The inspector summarized the scope and findings of the inspection and indicated that no apparent violations or deviations had been identified.
In addition, the inspector informed licensee representatives that there were no outstanding issues associated with U3 restart for the RadCon area.
Licensee representatives 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.
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Item Number-Status Descri tion and Reference IFI 50-259, 296/95-55-01 Open VIO 50-260, 296/95-33-04 Closed Review of licensee FSAR commitments for CANs associated with Units I and
(Paragraph 2).
Failure to follow procedures for RWP implementation (Paragraph 6).
THI II.F. 1.2. c Closed Calibration, installation and functional testing for CHRHs '(Paragraph 3,).
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Index of Abbreviations and Acronyms Used in this Report ALARA ARM ARMS CAM CHRM CREVS EQ FSAR HRA IFI IR No.
NRC PER PCH RadCon REXS SSP TIPS TMI TS U1 U3 VIO.
As Low As Reasonably Achievable Area Radiation Monitor Area Radiation Monitoring System Continuous Air.Particulate Monitor Containment High Range Monitor Control Room Emergency Venti-lation System Environmental Qualification Final Safety Analysis Report High Radiation Area Inspector Followup Item Inspection Report Number Nuclear Regulatory Commission Problem Evaluation Report Personnel Contamination Monitor Radiological'ontrol Radiation Exposure System Site Standard Practice Tranversing Incore 'Probes Three Mile Island
.
Technical Specification Unit
Unit 3 Violation
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