ML20080H587
| ML20080H587 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 12/21/1983 |
| From: | Mills L TENNESSEE VALLEY AUTHORITY |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20080H564 | List: |
| References | |
| NUDOCS 8402140252 | |
| Download: ML20080H587 (3) | |
Text
_
TENNESSEE VALLEY AUTHORITY 1.
CHATTANOOGAi TENNESSEE 37401 33 0EC 27 A 8 : 5 9 December 21, 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 supplemental response to your November 15, 1983 letter to H. G. Parris regarding item A of Inspection Report Nos, l-850-259/83-12, -260/83-12, -296/83-12. After further evaluation we have concluded the violation occurred as stated. The enclosure provides the details of the violation as required by.10 CFR 2.201.
If you have any questions, please call Jim Domer at FTS 858-2725.
To the'best of my knowledge, I declare the statements contained heroin.are complete and true.
Very truly yours, TENNESSEE VALLEY AUTHORITY L. M. Mills, Manager Nuclear Licensing Enclosure
$9 O
PDR An Equal Opportunity Employer s
e.
ENCLOSURE SECOND SUPPLEMENTAL RESPONSE - NRC INSPECTION REPORT NOS.
50-259/83-12, 50-260/83-12, AND 50-296/83-12 R. C. LEWIS' LETTER TO H. G. PARRIS DATED APRIL 22, 1983 Appendix A Item A (259, 260, 296/83-12-02)
Technical Specification 6.3.D.2 requires that each high radiation area in which the intensity of radiation is greater than 100 mrem /hr but less than 1000 mrem /hr shall be barricaded and conspicuously posted as a high radiation area and entrance thereto shall,pe controlled by requiring issuance of a Special Work Permit. Any individual or group of individuals permitted to enter such areas shall be provided with or accompanied by one or more of the following.
1, A radiation monitoring device which continuously indicates the radiation dose rate in the area.
2.
A radiation monitoring device which continuously 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 areas has been established and personnel have been made-knowledgeable of them.
3 An individual qualified in radiation protection procedures who is equipped 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 March 23 and 24, 1983, personnel were observed on two occasions in licensee-controlled high radiation areas; one on the 546-elevation of the Radioactive Waste Building and one on the 565 elevation of the Unit 1 Reactor Building; without dose rate instruments, without an
~
alarming integrating dose rate radiation monitor and not under the positive control of an individual qualified in radiation protection procedures who is equipped with a dose rate instrument.
Additionally, the high radiation area on the 565 elevation of the Unit 1 Reactor Building.was not barricaded and conspicuously posted in that one side of the high radiation barrier and posting had been partially removed.
This is a Severity Level IV Violation (Supplement IV).
i,.
1
%,.4 4.1 u w.e,._.
m
- (
. 1.
Admission or Denial of the Alleged Violation TVA admits the violation occurred as stated.
2.
Reasons for the Violation if Admitted As noted in previous responses, TVA has verified that:
a.
The workers were issued a dose rate meter.
b.
They were provided a pre-job briefing on the use of the instrument.
They were accompanied to the work area by a qualified health c.
physics technician that resurveyed ~the work area and pointed out high dose rate areas to the workers, d.
The health physics technician returned to the work area while work was in progress to ensure that the workers were properly using the dose rate meter. The health physics technician again ascertained that the workers were fully aware of the area dose rates.
e.
There was no potential for changing dose rates or encountering unknown dose rates.
f.
Positive access control to the area was being provided.
g.
A working dose rate meter was within easy reach of the workers at all times.
In addition, TVA has previously. submitted drawings made by the workers that indicate that the dose rate meter was within the limits of the original high radiation zone. The carpenters were of the opinion that they met the requirements of the special work permit and Technical Specification 6.3.D.1 in that they had a dose rate meter in their possession. The carpenters were evidently mistaken as to actual location of the meter when observed by the NRC inspector.
3 Corrective Steps Which Have Beyn Taken and the Results Achieved Radiological incident repor.ts were issued and employees were instructed to comply with all requirements for a dose rate instrument.
4.
Corrective Steps Which Will Be Taken To Avoid Further Violations This is considered a random event and no recurrence control is required.
5 Date When Full Compliance Will Be Achieved Full compliance was achieved May 1, 1983 m v d&,
a 2g;;
a w=
,