ML20072G876
| ML20072G876 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 04/25/1983 |
| From: | Kammer D TENNESSEE VALLEY AUTHORITY |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20072G860 | List: |
| References | |
| NUDOCS 8306290203 | |
| Download: ML20072G876 (5) | |
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TENNESSEE VALLEY AUTHORITY tl UIRC TV N
,,..., g ;cpTT ANOOG A. TENNESSEE 374ol 400 Chestnut Street Tower II 03 APR 28 P3 15 April 25, 1983 U.S. Nuclear Regulatory Commission Region II ATTN: James P. O'Reilly, Regional Administrator 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30303
Dear Mr. O'Reilly:
Enclosed is our response to R. C. Lewis' March 21, 1983 letter to H. G. Parris transmitting Inspection Report Nos. 50-259/83-03,
-260/83-03, -296/83-03 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 two-day extension on the submittal of this response f
was discussed with Ross Butcher of your staff on April 20, 1983 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, TENNE 3SEE VALLEY AUTHORITY i
DS W D. S. Kammer Nuclear Engineer Enclosure i
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An Equal Opportunity Employer
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RESPONSE - NRC INSPECTION REPORT HOS.
50-259/83-03, 50-260/83-03, AND 50-296/83-03 R. C. LEWIS' LETTER TO H. G. PARRIS DATED MARCH 21, 1983 Appendix A Item A - (259, 260, 296/83-03-02) 10 CFR 20.201(b) requires each licensee to aske or cause to be made such surveys as (1) may be necessary for the licensee to comply with the regulations of this part, and (2) are reasonable under the circumstances to evaluate the extent of the radiation hazards that may be present. Survey means an evaluation of the radiation hazards incident to the use, release, disposal, or presence of radioactive materials or other sources of radiation under a specific set of conditions.
Contrary to the above, the licensee has failed to perform an evaluation of the radiation hazards to personnel indicated by significantly different personnel exposure results from the TLD and pocket dosimeter devices.
This is a Severity Level IV Violation (Supplement IV).
1.
Admission or Denial of the Alleked Violation TVA denies the violation as stated.
The exposure control and reporting practice cited in item 8 of the details of the report does not constitute a violation of the survey requirements as-promulgated in Title 10 Code of Federal Regulations, Part 20, section 20.201.
Reasons for the Denial 2.
Section 20.201, " Survey" states that licensees must make or cause to be made such surveys to evaluate radiation hazards as may be necessary to. comply with the regulations of Part 20, " Standards for Protection Against Radiation." TVA complies fully with this regulation. Before any work is conducted in a regulated area, extensive surveys are conducted to clearly define the radiological conditions in the work area. The contact and general area dose rates are measured; smear samples are taken to determine the surface contamination levels; air samples are collected to determine the air activity; and personnel are required to wear dosimetry and are issued Personnel dosimetry consists of direct protective equipment as necessary.
reading dosimeters (DRD) and thermoluminescent dosimeters (TLD). Consistent with established industry practices, DRDs are used to control personnel While exposures while the TLDs are used to measure personnel exposures.
DRDs provide personnel with a convenient means of monitoring their exposure to X-ray and gamma ray radiation, the inherent perfornance deficiencies of these devices, i.e., erroneous readings from drift, charging, geotropism, j
and physical shocks, make them unsuitable for measuring personnel exposures j
for the permanent official record. Moreover, these devices cannot meet the rigorous requirements for personnel dosimetry developed by the Health g e pum W he eb A-
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Physics Society Standards Committee, adopted by the ANSI, and endorsed by NRC.
Conversely, the TLD badge used by TVA was tested in accordance with the ANSI standard during NRC's Personnal Dosimetry Testing Program and found to be adequate for monitoring radiation fields normally found in buclear power plants. Hence, by using the TLD badge readings for the official record, TVA is assessing external radiation doses in accordance with the most recent MRC requirements <
While' it is not a violation to not investigate all differences between TLD and DRD readings, it is acknowledged by TVA as a good practice. This fact is documented by the request by the BFN Health Physics Section in November.
1981 for an independent TVA review of the program, identification of causes of discrepancies, and recommendations to reduce the problem. In March 1982, this independent review was completed. Two basic problems were revealed:
an inadec,vate computer routirie and limit check report that compared TLD and DRD data and the physical inaccuracies of'DRDs. From March 1982 through January 1983, new software for the new health physics dose tracking (HPDT) system was prepared. The HPDT system;was implemented in January 1983.
Beginning in January 1983, all significant differences hetween TLDs and DRDs will he investigated and documerted. During the period of March 1982 thrcugh De,emmber 1982, TVA ran a monthly ecmparison of TLD versus DRD data as required by plant procedures.'
During the inspection, the NRC inspector requested a review of ceveral specific discrepancy cases. TVA spent several man-days reviewing these cases and in each TVA thought an adequate explanation had been provided to the inspector.
Item B - (259, 260, 296/83-03-03)
Technical Specification 6.3.D.1 reacires that each high radiation area in
.which the intensity of radiation is greater the.n 100 mrem /hr but less.than 1000 mrem /hr shall be barricaded and conspicuously posted as a high radiation area and entrance thereto shall be controlled by requiring issuance of a Special Work Fermit. Any individual or group of individuals permitted to enter such areas shall be provided with or accompanied by one or more of the followingt A radiation monitoring device which ocntinuously indicates the radiation a.
dose rate in the area.
b.
A radiation monitoring device which contineously integrates the radiation dose rate in the area and alarms when a preset integrated dose is received.
Entry into such areas with this monitoring device may be made after the dose rate level in the area has been establisbed and personnel have been made knowledgeable of them.
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An individual qualified in radiation protection procedures who is equipped c.
with a radiation dose rate monitoring device. This individual shall be responsible for providing positive control over the activities within the area and shall perform periodic radiation surveillance at the frequency specified by the facility Health Physicist in the Special Work Permit.
Contrary to the above, on January. 13, 1983, personnel were observed on two occasions in the Unit 2 drywell, which is a licensee-controlled high radiation area, without dose rate instruments, an alarming integrating dose rate radiation monitor, or under the positive control of an individual qualified in radiation protection procedures who is equipped.with a dose rate instrument.
This is a Severity Level V Violation (Supplement IV).
1.
Admission or Denial of the Alleged _ Violation TVA adnits that on January 13,' 1983 only one incident occurred for the violation as stated (occasion #1).
TVA denies the other occasion (#2) as a violation of Technical Specification 6.3.D.1.
On this occasion, the HRC inspector believed there had been a violation due to a misunderstanding in communications between the inspector and the workers in the unit 2 drywell. When the workers were asked by the inspector if they had a dose rate meter, they responded "No." The workers thought the inspector's question referred to an individual dose rate meter in their personal possesslen. The health physics technicien who entered the drywell after being informed by the NRC inspector of the situation verified.
that the workers were part of a work group that was in possession of an R02A dose rate meter. The group had acquired the dose rate meter before entering the high radiation area as stipulated in the special work permit.
TVA regrets that due to time constraints this confusion was not clarified before the inspector left the site.
2.
Reasons for the Violation if Admitted Occasion #1 The personnel involved had read the requirements of the special work permit and had checked out a dose rate meter. They failed to take the dose rate meter with them when they entered the unit 2 drywell.
3 Corrective Steps Which Have Been Taken and the Results Achieved All Browns Ferry employees have been reminded by memorandum of their responsibilities relating to safe radiological control practices and conpliance with special work permits. Employees have been notified that failure to adhere to safe radiological control practices may result in disciplinary action. Disciplinary action for the workers involved has been taken appropriate to the circumstances.
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Corrective Steps Which Will Be Taken To Avoid Further Violation d
None required.
5.
Date When Full Compliance Will Be Achieved Full compliance was achieved on April 12, 1983, with disciplinary action completed for the individuals involved in the violation.
Item C - (259, 260, 296/83-03-06)
Technical Specification 6.3.A.7 states that detailed radiation control procedures... shall be approved and adhered to.
Radiological Control Instruction I which states in part " contaminated clothing shall be removed prior to exit from the contaminated area."
Contrary to the above, on January 13, 1983, a licensee employee was observed wear'ng protective gloves in an uncontaminated regulated area which he had worn in a contaminated zone in the Unit 1 Reactor Building.
This is a Severity Level V 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 cause of the violation was personnel error. The employee was negligent in the performance of his duties.
3 Corrective Steps Which Have Been Taken and the Results Achieved The employee was given a verbal documented warning and has been scheduled for retraining on RCI-1.
4.
Corrective Steps Which Will Be Taken To Avoid Further Violations Additional retraining in RCI-1 will be given by Health Physics personnel to all laborers in the plant laborer group.
5.
Date When Full Compliance Will Be Achieved Full compliance will be achieved on May 1, 1983, when retraining for the plant laborer group will have been conpleted.
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