ML19350E901

Forwards Response to NRC 810225 Ltr Re Violations Noted in IE Insp Repts 50-259/80-36,50-260/80-30 & 50-296/80-30. Corrective Actions:Certificate of Compliance Revised to Reflect Proper Wording as Expressed in Original SER

ML19350E901
Person / Time
Site:	Browns Ferry
Issue date:	03/27/1981
From:	Mills L TENNESSEE VALLEY AUTHORITY
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML19350E895	List: ML19350E901 ML19350E909
References
NUDOCS 8106230634
Download: ML19350E901 (9)

Text

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q) 400 Chestnut Street Tower II March 27,1981 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 303G3

Dear W. O'Reilly:

This is in response to your Febmt.ry 25,1981, letter to H. G. Parris, Report Nos. 50-259/80-36, -260/80-30, and -29 5/80-30, concerning a special appraisal of the health physics program at the Browns Ferry Nuclear Plant. Enclosed b our response to Appendix B Notice of Violat an. If you have tg questions, please call Jim Domer at FTS 857-20 14 .

To the best of my knowledge, I declare the statements contained herein are complete and true.

Very truly yours, JENNESSEE VALL$Y AUEORITY

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.'C./. M. Mills, Manager Nuclear Regulation and Safety Enclosure 81062 Bob 3Y t

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.e ENCLOSURE RE3PONSE TO IE INSPECTION REPORT. NOS. .

50-259/80-36, 50-250/30-30, 50-296/80-30

- APPENDIX B NOTICE OF VIOLATION (HEALTH PHYSICS APPRAISAL)

BROWNS FERRY NUCLEAR PLANT (DQCKET NOS. 50-259,~50-260, 50-296)

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,- Violation- ,.

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A. 10 CFR 71.12, requires .that persons' delivering.,11cen' sed material to a carrier for tran' sport. iri a . package fon which a certificate of

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.' compliance has' been issued. . comply'.with the terms. and conditi'ons' of

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the license, certificate,' or other approval. .

ic7trary to.the ab'ove,'the terms and conditions.of, Certificate of' Comp.iance 6568, R'evision 0 w're e noC met in that Ion August 14,~1980' ~

t a'nd August.18, 1980 shipments of radioactive material were made where the weight of the' liner and contents exceeded.the weight restrictions,.(10,000 pounds) specified.- - -

This is a . Severity. Level IV -Violation '(Supp'lement V).

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1. Admission or Denial of the Alleged Violation TVA. agrees' to the all'eged violation.

2. Reasons for'the Vio'ation l if Admitted The ' safety analysis report for the LL-60-150 cask was submitt'ed by TVA to 'NRC for' approval in 1970. ' This document indicated that '

.the weight of the liner and contents would be 12,500 p.ounds. The wording issued for the weight limit on the cask's Certificate of. Compliance' 6568, Revisio,n 0, was interpreted by plant employees to apply only.to the keight of the liner's contents. .

.3 Corrective Steps.Which Have Been Taken and Results Achieved When the discrepancy concerning _the weight' of the liner's contents

was brought to our attention, NRC was inmediately requested to i revise the certificate to reflect the proper wording as expressed in the original SAR. On October 24, 1980, revision 2 of the certi-l ficate of compliance was issued by NRC stating that the weight of j the liner and contents be limited to 12,500 pounds.

Shipping was ceased until the revision to 'the certificate of compliance was issued by NRC. This brought the shipments into j compliance with both the certificate and'the original SAR.

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4.- Corrective Steps Which Will Be Taken' to Avoid Further Violation Further violations will be avo$ded by adherende to the' re' vised

. certificate of compliance and .the Radioactive Materials Shipment .

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Manual.' -

3. Date When' Full. Compliance Will Be Achieved -

. ' Full compliance was achieved ' on. Novembe' '

r 14, 1980, . with issuance of the revision to.the Ra'dioactive Materials Shipment Manua1.

. Violation .

B '. Technical Specification 6.3.B requires that kritten radiation control procedures shall be reviewed by the Plant Ope. rations Review -

Committee (PORC) and appro' v ed by, the plant superintendent prior to

. . implementation. ,

Contrary to tha above,' radiation control procedures were.in use +

which had not been reviewed by.PORC and approved by the' plant superintendant, in that Health Physics Section Instruction Letters, which contained detailed radiological control instructions, had not been reviewed'by'PORC and appro03d by the plant superintendent.

This is a Severity. Level V Violation (Supplement IV)..

1. Admission or Denial of the Alleged Violation TVA denies the alleged violation. Section' Instruction. Letters '

(SIL's) have traditionally been used by TVA for plant sections to issue instructions of an administrative nature, or con 5'erning responsibilities, methods, or procedures to be .followed by members of the section in areas where PORC' review and plant superintendent approval are' not 'rvquired. .This is defined in N-OQAM, Part III, i Section 1.1. TVA has reviewed the Health Physics Se'etion Instruction Letters specifically cited by NRC inspectors and does

. not agree that these contai.n information which should be in radio- ,

' logical control instructions. TVA will' review the remainde' r of ths '

section instruction letters to ensure none contain~ instructions

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- which appropriately belong in PORC-reviewed,~ plant superintendent-

appcoved radiologica'l control instructions. Our review will be completed - by May 1, 1981.

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' Violation. -

C. Technical. Specification. 6 3.D.1 requires ~ that..each high . radiation area in which-the intensity of radiation is greater than 100 mrem / '

. hour but'less than 1,000 mres/ hour; shall be barricaded and conspicuously pos.ted. as ac high radiation area. ,

Contrary to.the above, high radiation areas w'ere not barricaded

' and/or conspicuous'y posted in.that:' - '

a.

• Access to thelun'it 2 control rod ' drive header piatform, a .

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high radiation area, . located east of the. drywell .on.the 1 565' elevation was not. barricaded on October 21, 1980.

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.b. . Access to th'e unit 2 contr'o1 rod drive platform, .~a high .

radiation area, located west.of' the drywell on the 565' .

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elevation was not barricaded on 0ctober 20, 1980.

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.c. Access ladders to the top cf units 1 and 3.s'hi' eld walls, in .

the vicinity of the high pressure turbines, were not posted as high radiation areas' on Oct,ober 22, 1980. High radiation areas existed on top of the shield walls. ,

. d. A high radiation area l'ocated in the vicinity of a fill line in the radwaste building west truck loading bay was p$sted as ~

a radiation area. -

This is a Severity Level IV Violation (Supplement IV).

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1. . Admission or Denial of the Alleged Violation

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TVA. agrees to.the alleged' violation.

2. Reasons for the Violation if Admitted

a. . Employees working in this ' area negl'ected to replace the metal cover over the ladder upon completion of the work. .

b. Access was controlled by four health physics technicians and one security officer who were within 30 feet of the ladder; however, this does not meet the technical specification wording of " barricaded." Employees involved did not fully understand this subtle difference.

c. These ladders had previously been posted and. barricaded as

'high radiation areas but the signs and barricade were removed by persons unknown. .

d. The in'ident c resulted 'from radioactive materia 1' settlement after a radwaste cask filling operation and after the. radiation survey was performed.

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3. . Corrective ' Steps Which Have' Been Taken and Results Achieved

a. Access to the area was modified by a sheetmetal enclosure wa.

a hinged door secured by a controlled" padlock.

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Refer to ,(a') ~above.':

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The-access' ladders have been barricaded. by addition of a hinged .

cover'and controlled pad' lock. In' addition', signs have been

. reposted. ,

d. The area has been posted and barricaded as'a high radiation area. .

. 4. Corrective S"teps Which Will Be Taken to Avoid Further Nolatiions '

A sign will be perinanently attached to the doors stating that

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the door must 6e locked when. unattended.- , .

. b. Refer to (a) dbove.-

c. No further action other .than that' described under .3 (c) atieve is planned. , ,

d.. A special irstruction has been issued to h,ealth physics employees requiring a survey be performed a sufficient period

. of. time af ter cask filling is completed to allow for satttling

, of radioactive particles.

5 Date When Full Compliance'Will Be Achieved All corrective measures except 4 (a) and 4'(b) are complete. The signs describ'd e by 4 (a)cand 4 (b) will be installed by May 1, 1981.

Violation D.. 10 CFR 20.103(a) requires that for the purposes of determining

. compliance with the requirements of this section, the licensee shall ~

use suitable measurements of conce,ntration of radioactive materials in air for detecting and evaluating airborne radioactivity in restricted areas.

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Contrary to the above. suitable measurements of concentrations of rad'ioactive matt. rials in ai. were not used to detect and evaluate-airborne radioactivity in restricted areas in that.no evaluation

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was performed for an air sample taken inL the vicinity of an

' individual performing a' weld on the tc.7us- en 0ctober 22, 1980 to determine the, adequacy of the respiratory protection-devi'ce. worn.

This is a Severity Level IV Violation (Supplement M IV).

1. AdmissionorDenialof'theAllegedViN1ation T

TVA agrees to the al'leged violation.

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2.' Reasons' for the ' Violation'if Admitted It is not known whether a sainple was not. collected o'r whet'her the ,

sample.and'/or analysis .was, misplaced.

3 Corrective Steps Which Have Bee'n Taken and Results Achieved No c'errective actions for.this particular incident can b'e.taken.

Repeat violations ~of this nature will be' avoided as described below. '

I 4 Corrective Steos Which Will Be'Taken to Avoid Further Violations Corrective action will be taken by continuing to reduce the use of lapel air samplers to a minimum through the increased use of fixed low volume air samplers..

Increas.4 emphasis will be.placed on .the proper use of lapel. air samplers turough the employe'e orientation program and in prework conferences with craftsmen. In addition, all 1.apel air samplers will be logged out and logged in by health physics employees and a notation made when the sample is evaluated...When samples are not returned by craftsmen, a radiological incident report will be comoleted against the individual concerned. ,

5 Date When Full Compliance Will Be Achieved We expect that full . compliance will be achieved by June 1, '1981, when additional fixed low volume air samplers.are received.

Violation E. 10 CFR 20.203(c.)(3) requires that high radiation area controls be established in sych a way that no individual will be prevented. from leaving a high radiation area.

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Contrary to the ab6ve, high radiation area' controls were not established in such a way that an. individual could leave a.high radiation area in that, .on October $4, 1980, the door'providing access to the unit 1 reactor water clean-up. pump 1B room was. '

secured with a padlock which would prevent an individual from

- leaving the area'if. the padlock wette inadvertently locked.-

- This is' ~a Severity Level IVJViolatiori (Supplement II).

1. Admission or Denial of the Alleged Violation ,

TVA agrees to the alleged' violation.

2. Reasons for-the Vio'lationiif Admitted.' ' 5 The door was ' mistakenly. padlocked closed for radiation control while the original lock was being repaired'.

3 Corrective Steps Which Have Been Taken and Results Achieved .

The padlock was immediately removed. .

II . - Corrective Steps Which Will Be Taken to Avoid Furt!her Violations

' Maintenance employees will be instructed in their safety meetings that hasp locks may not be placed on high' radiation doors.

5 Da'te When Full Complianice Will Be Achieved pull compliance will be achieved by April 15, 1981.

Violation F. Technical Specification 6.3A requires that detailed written radiation control procedures shall be prepared, approved, and adhered to.

Contrary to the above, detailed written radiation control procedures were not prepared, approved, and/or adhered to, in that:

a. On October 21,'1980, three individuals exited from the 577' elevation of the turbine building to the clean area without ,

using the hand and foot monitor and three other individuals l

failed to use'the hand and foot monitor for five seconds as required by Station Procedure RCI-1, Radiation Program, paragraph III.C.1.

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ti. On October 22, 1980, domineralizer filters were moved in the cadwaste building without taking precaution,s to minimize the

. . spread of contamination as required by Station Proce' dure RCI-1,

, . paragraph III.DP . , -

c, .On' October 26, 1980,' an. individual'was observediin a posted

')11gh radiation area without a port'able radiation dose rate measuring instrument' required *by Station Procedure RCI-9, Appendix.A, paragraph'III'.C.3 . ,. ,

d. The ctation does 'not have a, proc'e dure whic'h would require an area radiation l monitor to.be Pemoved from service when the calibration. du.e' date has passed. . An area radiation monitor r,emainedin service on October 22, 1980 monitoring the radiation levels in the radwaste compactor' room although the

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calibration due date had passed.' .

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This is acSe'v erity Level IV Violation -(Supplement' IV) .

1. Admission o'r Denial of .the Alleged Violation-TVA agrees to the' alleged vio'lations specified in'F (a), F (c), and

'F (d). TVA denies the violation specifi'ed'in F (b). There are no specific procedu'res defining actions needed to minimize the spread of contamination during movement of demineralizer filters.

TVA maintains that in' situations similar to the' type described in F (b)~, necessary' precautions are most effect'ively' implemented by a case-by-case decision based on the judgment of the health physics technician iavolved. To date, this. method of minimizing the spread of contamination ha's been effective. The incident cited was an isolated case of precautions'taken not being fully adequate due to the fact,that the particular box chosen to transport the filters was not water-tight. However,_the intent of RCI-1, paragraph III.D, ,

was. met in that precautions were taken to minimize the spread of contamination by isolating the used filters in a box before movement ~.

2. ,Beasons for the Violation if Admitted

a. The violation occurred due to employees ignoring instructions regarding monitoring themselves on exiting a controlled area.

b. Not applicable.

c. The, violation occurred due to employees not following procedures.

d. 'The violation occurred due to procedural deficiency.

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Corrective Steps Which Have 'Been Taken and Results Achieved 3

a. ' Plant management ha's provided'for a letter-regarding personnel monitoring policy'to be posted. periodically.

. b .. *Not applicable. '. -

c. Plant minagement .has ptwovid~ e d TDr a letter to all plant -

' emp'loy'ees ' emphasizing' the need 'to' use' dose rate meters -in high radiation. areas to be' posted periodically.- . Area radiation monitors were in's.talleiin t.he high radiation areas near the CRD headers. A' designated walkway was established and the probe was. located in thec highest dose rate area.in- the travel path. The readout is located such that employees can see a

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' readout during travel across the zone. .

d. The' instrume'nt involved was' immediately repla'ced'.' -In addition a section instruction letter was issued to provide for the removal from service of area radiation monitors when calibration due dates. are passed.

4. Corrective Steps Which Will Be .Taken to Avoid. Further Violhtions

a. Periodic surveys on use of the monitors have ,been' and will -

continue to be performed. Employees identified as failing to use monitors will be disciplined appropriately.

b. No,t applicable.

, c Appropriate disciplinary actions will be taken on individuals violating requirements for using dose rate instruments,

d. No further corrective action is necessary. '

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5. Date When Furi Compliance Will Be Achieved

a. Full compliance has been achieved.

b. Not applicable.

c Full compliance has been achieved..

d. Full compliance was achieved on January 21, 1981, when the revised section instruction letter was issued and fully implemented.

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