ML20079J825
| ML20079J825 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 09/07/1983 |
| From: | Mills L TENNESSEE VALLEY AUTHORITY |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20079J717 | List: |
| References | |
| NUDOCS 8401240428 | |
| Download: ML20079J825 (4) | |
Text
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.e TENNESSEE VALLEY AUTHORITY U S W' O T
400 Chestnut Street Tower II
, ; f;g September 7,19833 SU 13 A 9 0 5 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 supplemental response as requested in your August 2, 1983 letter to H. G. Parris regarding Inspection Report Nos. 50-259/83-03,
-260/83-03, -296/83-03 Our original response to this inspection report l
was submitted to you on April 25, 1983 An extension to the September 1, 1983 submittal date of this response was discussed with F. S. Cantrell of your staff. 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 L. M. Mills, Marager Nuclear Licensing Enclosure 8401240428 840113 PDR ADOCK 05000259 0
.,83-TVA 5OTH ANNIVERSARY An Equal Opportunity Employer
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SUPPLEMENTAL RESPONSE - NRC INSPECTION REPORT NOS.
50-259/83-03, 50-260/83-03, AND 59-296/83-03 Item A - (259, 260, 296/83-03-02)
We have reviewed th'e requirements of 10 CFR 20.201, and although we concur that the evaluation of TLD versus DRD readings is a good health physics practice, we maintain it is not a violation of 10 CFR 20.
As stated in the previous response, a computer program was being developed (March 1982 to December 1982) to provide reliable data for supporting TLD/DRD comparisons and subsequent investigations. During the period of March 1982 through December 1982, TVA performed monthly comparisons of TLD versus DRD date with the existing computer system.
Since the January 1983 implementation of the new health physico dose tracking system (HPDT), TVA has performed reviews of differences Detween TLD and DRD using the stated criteria (investigation, documentation, and corrective action for individual exposures exceeding 500 millirem per month with a difference greater than 25 percent between the TLD/DRD).
At this time TVA is in full compliance with NRC's interpretation of 10 CFR 20.201.
Item B - (259, 260, 296/83-03-03)
The Tennessee Valley Authority denies that there were two occasions where dose rate instruments were not in use as specified in item B, Appendix A, Notice of Violation. Technical Specification 6.3.D.1 was complied with in one instance (occasion number one).
The NRC inspector's first citing occurred on the morning of January 13, 1983 as he was observing workers inside the unit 2 drywell through the southeast equipment hatch. Engineers were working on special work permit (SWP) 01-2-27225. After watching the engineers for a short period of time, the NRC inspector asked a test engineer if he had a dose rate meter. When he replied "no," the NRC inspector asked the individual adjacent to him if he had a dose rate meter. This engineer also replied "no." This inspector then questioned the drywell health physics technician as to why workers were in the high radiation area without the required dose rate meter. The health physics technician immediately dressed out and entered the drywell to talk with the engineers and to ensure that all workers in the high radiation area had dose rate meters. When the health physics technician arrived at the test engineers, he found that the group of eight workers were in fact in possession of two Eberline R02A dose rate meters.
The two workers whom the NRC inspector had questioned were standing about five feet from the six other engineers who were maintaining the dose rate meters. Later conversation with the first test engineer questioned revealed that he and his co-worker thought that the NRC inspector was asking if they had their own personal dose rate meter. While they did not each have a personal meter, they were well aware that meters were being maintained by their work group. The first test engineer also stated to the
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health physics technician that he and his fellow worker were only about five feet from the group in possession of the required meter when questioned by the NRC inspector.
The eight engineers were standing in an area posted with a sign which stated:
"This location has the lowest dose rate in the general area - 25 mrem per hour." During a prework briefing with the engineers on the date in question, the health physics technician had discussed the drywell dose rates and informed them to remain in the posted low radiation area as much as possible. In addition to a thorough discussion of drywell dose rates, a large map was present near the drywell access which indicated radiation and contamination levels on all elevations of the drywell.
In light of these factors, it was felt that the engineers were fully aware of the dose rates in their work areas. While it is realized by all that it is a legal requirement to have a dose rate meter in any and all high radia-tion areas, it is not considered necessary to be constantly observing the meter readout while standing stationary in an area of known radiation intensity.
Past experience during the previous five months of the refueling outage had shown that the area by the southeast equipment h?tch where the engineers were standing was not subject to significant dose race variations. There-fore, in view of these circumstances, it is the licensee's opinion that through use of the available dose rate meters, the health physics prework briefing, and the information signs posted in the drywell, that the workers were properly cognizant of their work area exposure rate and that this occasion does not constitute a violation of Technical Specification 6.3.D.1.
Attached is a map of the southeast drywell hatch area showing the location of the personnel during the incident in question.
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IlELATI'.'E POSITIONS OF TEST ENGINEERS IN THE UNIT TWO
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DRYWELL 03 JANUARY 13, 1983
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4 CONTAINMENT WALL
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3 NORTH
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25' MREM /HR.
X\\ NRC INSPECTOR ENGINEERS QUESTIONED
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BY NRC INSPECTOR f
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HIGH-RAD AREA
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BOUNDARY:
5 FT.
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ENGINEERS WITH TWO b--
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8 FT.
DOS.E RATE, METERS X X X ')';
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s
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X i
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25 MREM /HR.
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SIGN POSTED
."25 MREM /HR" f
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<a EQUIPMENT HATCH OPENING SHIELD BLOCKS j.FROM EQUIP. HATCH s
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