ML20058H479
| ML20058H479 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 07/16/1982 |
| From: | Kammer D TENNESSEE VALLEY AUTHORITY |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20058H439 | List: |
| References | |
| NUDOCS 8208030592 | |
| Download: ML20058H479 (4) | |
Text
,__
TENNESSEE VALLEY AUTHORITY
) g p p q, S, CHATTANOOGA, TENNESSEE 374o1
,;73, M 0d Chestnut Street Tower II 1
32 JUL 20 A8.l0 July 16, 1982 U.S. Nuclear Regulatory Commission Region II ATTN: James P. O'Reilly, Regional Administrator 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303
Dear Mr. O'Reilly:
Enclosed is our response to R. C. Lewis' June 9, 1982 letter to H. G. Parris transmitting Inspection Report Nos. 50-259/82-14,
-260/82-14, -296/82-14 regarding activities at our Browns Ferry Nuclear Plant which appeared to have been in violation of NRC regulations. We have enclosed our response to Appendix A, Notice of Violation. A seven-day extension was granted by Ross Butcher on July 7, 1982. If you have any questions, please call Jim Domer at FTS 858-2725.
To the best of my knowledge, I declare the statements contained herein are complete and true.
Very truly yours, TENNESSEE VALLEY AUTHORITY p s y===n D. S. Kammer Nuclear Engineer Enclosure 8208030592 820726 PDR ADOCK 05000259 0
ppg An Equal Opportunity Employer
/
ENCLOSURE
'~
RESPONSE - NRC INSPECTION REPORT NOS.
50-259/82-14, 50-260/82-14, AND 50-296/82-14 H. C. LEWIS' LETTER TO H. G. PARRIS DATED JUNE 9, 1982 Appendix A (259, 260, 296/82-14-01) 10 CFR 20.201(b),- Surveys, requires-that each licensee make or cause to be made such surveys as may be necessary for him to comply with the regulations in this part.
10 CFR 20.203(c)(1), High Radiation Areas, requires that each high radiation arca shall be conspicuously por ted with a sign or signs bearing the radiation caution symbol and the words " Caution High Radiation Area." Technical Specification 6.0.D.2 requires that each high radiation area in which the intensity of radiation is greater than 1000 mrem / hour shall be barricaded and conspicuously posted as a high radiation area and entrance thereto shall be controlled by requiring issuance of a Special Work Permit. Technical Specification 6.0.D.2 further requires locked doors to be provided to prevent unauthorized entry into such areas.
Contrary to the above, during the period from approximtely 11:15 p.m. on April 25, 1982, to approximately 8:30 a.m. on April 26, 1982, the licensee violated the requirements of 10 CFR 20 and Technical Specifications in that:
1.
The licensee failed to make a radiation survey as required by 10 CFR 201(b) to determine that a high radiation area with radiation levels over 1000 mrem /hr existed in the fuel pool domineralizer cell on the 580 elevation after removal of the shield plugs. Consequently, the licensee failed to post the area as a high radiation area as required by 10 CPR 20.203(c)(1) and failed to barricade or provide locked doors as required by Technical Specification 6.0.D.2.
2.
The licensee failed to issue a Special Work Permit for removal of domineralizer cell shield plugs which provided access to a high radiation area where radiation levels exceeded 1000 mrom/hr.
This is a Severity Level IV Violation (Supplement IV).
1.
Admisnion or Denial of the Alleand Violation TVA admits the violation occurred as stated but we believe the following mitigating circumstances should be related.
The incident occurred when a leak developed in a filter located on elevation 580 of the radwaste building.
The Icak resulted in a radioactive spill affecting major portions of the 565 elevation of the radwaste building. Operations personnel immediately notified health physics (HP) who isolated this floor. To verify the leak had been isolated, two operations employees removed a shield plug, which is located on olevation 580 of the radwaste building, and then notified HP.
s
'llP isolated the area with the rope barriers and radiation and contamination area signs and returned to the more pressing problem of containing the spill.
A special work permit is required in advance of the work whero an employee may receive radiation exposuro l'n excess of certain limits in given time periods, in an area having airborne radioactivity greator than specified limits, where contamination exceeds limiting j
values, or when radiation or contamination hazards for a particular job are unknown. -
~
Surveys are required by 10CFR20.201(b) to comply with the regulations
]
and are reasonable under the circumstances to evaluate the extent of j
radiation hazards that may be present.
The. job of fuel pool domineralizer shield plug removal had been j
performed several times in the past and the radiation exposure hazard vas well known. The dose rato above the floor level where the shield plugs are located was normally 15-20 mrem / hour with no airborne radioactivity or contamination in excess of limits. Under these circumstances a special work permit in advance of the work was not required. Also, since the expected radiation hazard was anticipated 1
fren past experience and there were extenuating circumstances resulting j
from the leak which resulted in a radioactive spill affecting the major portion of the floor area on elevation 565 of the radwaste building, a j
survey was not necessary in the area of the shield plug on elevation 580.
We would like to point out that after the spill had been controlled, a lack of personnel to perform decontamination resulted in a ' decision to isolate the area with rope barriers until the day shift. For an individual to get to the shield plugs, one would have had to cross a rope barrier at the radwaste 565 clavation, which bore' a sign stating
" notify HP prior to entry," dressed out in C-zone clothing, crossed through the contaminated spill, traveled to the 580 radwaste elevation, 4
and then passed through a second HP barriere. Even if an individual had l
accomplished this, the dose rates over the floor were about 15-20 mrem /hr. To access the high-radiation area would have been difficult.
As a minimum, access would have required a ladder which was not available.
The inspection report indicated the TLD badge results for the two operators that pulled the shield plugs to be 435 and 35 mrem, respectively. The record should also show that the TLD badge results f
of each operator were consistent with pocket dosimeter data accumulated before these events and that no measurable dose was determined to be received by the operators during the shield plug removal.
i I
i 1
l I
g
^ -
~
- /e
(
-3
.f g
,- r a
/
,5 s
-s a g.
o 3, 4
~
g 4,^ 9
. /, _
a Reasons for the'o. Ef_olC. ion ir Admitted 2.
i 3
r
,\\
)
,t i
Q,f Pai'{,dre tymake y radiation s,urveyy. post the area as a high-radiation
', area,qar.$,.ty,rpe g apecial work'peOnit was due to pers;cnol error. The ciretmstancos,crett.,ed, by the I.evidp,;e on the floor of tbe radwaste "4
buildipg and the' potential. for spthad of contamination diverted ctt(ntibifund crforti,$4y froi, performing actions taken in normal
.e<
cir; cuds dnces.
lA 7
.f t r r ' h' J d l
,f Corr setive Stdos UbirirHaveTo[n flaken and the Results Achiev
./
.4 s
< /
v v
'3 f,
t e
A r,,, 3Y r
v -- ' i
. f-
)
7 Shield plugs / t,ndd shield biEh-radiation fields have been identified.
a.
wit,b, signs f'eq0irin'g the p'resence of HP for the& renoval.
-g g
+
s..
s e
~
- b. fA 110413p of these'shi, eld pltigs, their locations, and anticipated radiation levels orcount red upon removal has been made available 9
s j,
/
[/,vto the HP (echnicibn staff.
^
f r
i
^,
I t, p y
"The-natp$re of the events hn,been discussed wit /' the HP
,}
2 c.
~ 's
.' t'- 4, a
-, s (1I technici n.ataff..
+
q: f.,
, ' ~, t
>>sr
, e
/
d*,
7" Disciplinary acti d.
against the H.P t' chniaWn for'< allure
.. to perfo:s/::'. esp,on,on was talee*
c a
e o
s -
sibly.
]
.e/,
../
s.
- p. f -
z s
1 f
.s
/
I
' Radiological incipent reports were f;mjiedjagainst appip' able c.
r' (2perations' personnel.,4,[-.'<
M.
l
/~ 'I sQ f
1-y
,f 4.
Corrective Steps Which Will Be Trken Lo Avoid Further 'iiolations
~'
T (i ? !a
,I '
~
{~
This event vilEbh fectored into >the-cuppleracatal training for licensed j
andunlicens/d perat6rs,and HP t icians."
y*
- r c
g-
)
j',' l.5.
Date When Fdl Co,mnliarse Will Be hchieved s
a a
i Full complianae will be achieved by Nove,bar 30, 1982 when all i
supplementaltrainingwillbecomppte.Ml.
/
~
/
t.
n 1
f'
,4+
/ (
t,
/
=,t
,A
- /
v t
a., s n-e Y
,O, y<
d j,
/,;s l'
,fi
- g ** e
/
'k
,a ,
f.
~ (
7
' '} ),'
1 t
l' L,
1;,
/j -
r
\\
4 c.
r y
f
,b l
,]
}
'f
,'o
.e' s
4 f
i 4
p
,. )
?
4" 1
> r s
~
t
,},/
,l L
s 3
+
c l
i e
a s1
, i-
,;y.
3, s,-
t.
~;
r k
f L
y F
f 5
i
,/.
\\
r --
^ ~ ~ ^