ML20153H506

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Forwards Draft Documentation Re Severity Level III Violation.No Civil Penalty Will Be Assessed Since Util Taking Steps to Ensure Proper Dose Limits Assigned to Workers Under Age of 18
ML20153H506
Person / Time
Site: Browns Ferry, 05000000
Issue date: 08/05/1981
From: James O'Reilly
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To: Thompson D
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20151G218 List:
References
FOIA-88-353 NUDOCS 8809090213
Download: ML20153H506 (6)


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UNITED STATES

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.EMORANDUM FOR:

Dudley Thomoson. Of-vetoe, Enforcement and Ir.vestigation, IE w

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James P. O'Reilly, Dire: tor, Region II LEJECT:

ENFORCEMENT ACT*0N FOR TVA - BROWNS FERRY

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The enclosec draf t document.ation relates to a Sevo*ity Level I:I'Vio'ation for hich we do not propose a civil peralty.

The facts surrounding the case are given in paragrapn 5 of the enclosed Inspwction Report.

The allcwed radiation dose to a minor is one-tenth that permitted to an ei;5 teen year-old.

An employee, lacking 17 days of his eighteenth year, was arpcsed, thria administrative error to 736 mrem vs tne allowed limit of 125 mrem.

In view of the magnitudy of the dose, the proximity of the worker's age to 18 anc the prcrrot ef fective action taken by the licensee, we do not believe that a civil canalty is warranted.

The licensee plans to mt.,dify his computer program to reacout the age in years anc the allowed dose in response to a birthdate input.

Thi:; sn:uld ensaro tnat the proper dose limits are assigned to workers under 18 years of age.

If I do not hear frem you with regard to this matter, the enciesed letter, Inspe:tfon Report and Noti:e of Violation will be mailed to the, lice *nsee on August 10, 1981.

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Enclosures:

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Draft Letter to License

/ attache Notice of Violation 2.

Inspection Report Nos. 50-259/81-17 l

50-260/81-17 and 50-296/81-17 cc:

H. D. Thornburg. SRSI J. H. Sniezek, RRRI J. Brockett, EI Enforcement Coordinators RI, RIII, RIV, RV 03* AC * -

C. E. Ocnvr (242-4191) 1 4

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ORAFT LETTER TO LICENSEE Tennessee Val!ey Authority ATTN: Mr. H. G. Parris Manager of Power 500A Ciestnut Street Tower II Caattanooga, TN 37401 Gentlemen:

Subject:

Report Nos. 50-259/81-17, 50-260/81-17 and 50-296/41-17 This refers to the special safety inspection conducted by Mr. J. R. Wray of this ef fice on June 29 - July 2, 1981, of activities authorized by NRC Operating License Nos. OPR-33, OPR-52 and ODR-68 for the Browns Ferry factitty.

Our ereliminary fir. dings wer e discussed with Mr. H. L. Abercrosoie, Plant Superin-terdent, at the conclusion of the inspection.

Areas examined during the inspection and our findings are discussed in the enclosed inspection report. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations by the inspector.

During the inspection, it was found that certain activities under,your license appear to violat6 NRC requirements.

These items and references to pertinent reautrements are listed in the Notice of Violation enclosed herewj,th as Appen-dix A.

Elements to be included in your response are delineated in Appendix A.

One violation has been categorized as a Severity Level III violation in accord-ance with the Interim Enforcement Policy published in the Federal Register (45 FR 66754) dated October 7,1980. A civil penalty is generally'implisec if a Severity Level III violation has occurred. However, after consideration of this matter and for the reasons stated in paragraph 5 of the inspection report no civil penalty will be issued.

Your written response to the Notice of Viulation, and the results of future inspections will be considered in determining further vnforcemeCaciton.

We have examined actions you have tak,en with regard to previo31y identified enfor:ement ratters and unresolved items.

The status of these items is discussed in the enclosed report.

In accordance with 10 CFR 2.190 of the Commission's regulations, a copy of this letter anc the enclo:ed repcrt will be placed in tne NRC's Public Occument Room.

1 I* tae recort cortains any inferr ation t 4t veu celhve to ov wavrpt frer d'scle-i sure unoer 10 CTR t.5(a)(4), it is r.ecessary that you:

(4) netify this of fice oy telephone within ten days from tne date of thts letter of your intention to file a request for withholding; and (b) submit within twenty-five days from tne date I

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of this letter a written application to this office to withhold such information.

If your receipt of this letter has been delayed such that lesLt_har seven days are available for your review, please notify this office promptly so that a new due date may be established.

Consistent with section 2.790(b)(1), such applica-tion must be accompanied by an affidavit executed by the owner of the information which identifies the document of part therwuf Sougnt to be withheld, and a full statement of the reasons on the basis of which it is claimed that the information shoulc be withneld from public disclosure.

This Section further requires the statement to address with specificity the considerations listed in 10 CFR 2.790-(b)(4).

The informa ien sougnt to be withheld shall be incorporated as far as possible into a separate part of the af ficavit.

If we do not hear from you in this regard within the specified periods noted above, the report WC l be placed in the Public Document Room.

Should you have any questions concerning this letter, we will be glad to discuss them with you.

Sincerely, S

i James P. O'Reilly Director

Enclosures:

1.

Appendis A, Notice of Violation 2.

Inspection Roport Nos. 50-259/81-17 50-260/81-17 and 50-296/81-17 cc w/ encl:

H. J. Green, Director of Nuclear Power H. L. Aborcromote, Plant Superintencent R. E. Rogers, Project Engineer H. N. Culver, Chief, Nuclear Safety Review Staff 4r g!

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Nuclear Safety Information Center Tecnnical Information Center Document Management Branch State of Alanama 1

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APPENDIX A NOTICE OF VIOJATION Tennessee Valley Authority Docket Nos. 50-259, 50-260 3rowns Ferry 1. 2, and 3 and 50-296 License Nos. OPR-33. OPR-52 and DPR-68 As a result of the inspection conducted on June 29 - July 2,1981, and in accord-ance with the Interim Enforewment Policy, 45 FR 66754 (October 7, 1980), the followirg violations were identified.

A.

IC CFR 20.104(a) states that no licensee shall oossess, use or transfer licensed material in such a manner as to cause any individual witnin a restricted area who is under 18 years of age to receive in any period of one calendar quarter, from radioactive material and other sources of radiation in the licensee's possession, a whole body doso in excess of 125 milltrems Contrary to the above, an individual under 18 years of age hefetved a whole bocy dose for the second calendar quarter in excess of 125 millirems in that I

on June 6 and 7,1981, the individual received a whole body dose of 736 millirens while working in the Unit i reactor cavity. This individua) would i

not have been 18 years of age until June 23, 1981.

Tnis is a Severity Level III Violation (Supplement IV).

B.

Technical Specification 6.3.A requires that detailed written radiation l

control procedures be prepared, approved and adhered to. One such procedure is Radiation Control Instruction 2.

Section XI of this instruction states that no individual less than 19 years of age shall be authorized to receive a quarterly whole body dose of 3 rems.

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Contrary to the above, a 17 year old worker, on June 8,1981 was authori:ed a

to receive a whole body dose of 3 rems.

This is a severity Lovel V Violation (Supplement IV).

Dursuant to the provisions of 10 CFR 2.201, you are hereby required to submit to this office within thirty days of the date of this Notice, a written statement or explanation in reply, including: (1) admission or cenial of the alleged viola-tions; (2) *.he reascns for the violations if admitted; (3) the corrective steps which have been taken and the results achieved; (4) corrective steps which will oe taken to avoid further violations; and (5) the date when full compliance will 29 acM evec.

Co%1dv atior e av be given te wxtercing vcu' reesponse time for good a

Uncer the authurity of Saction 162 of the Atomic Energy Act. of cause snown.

1954, as amended, this response shall be submitted under oath or affirmation.

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ATLANTA, CEoNCIA 30M3 Rv, ort No,. 50-259/81-17, 50-200/81-17, and 50-296/81-17 t.i cen s,re :

Tennessee Valley Authority 500A Chestnut Street Chattanooga, TN 37401 Fac!!ity Name:

Erowns Ferry Docket Nos. 50-259, 50-250 & 50-296 License Nos. 0P4-33, OPR-52, OPR-68 Ir.acettion at Browns Ferry Site nuar Decatur, Alabama

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. Wray Approved'y:

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C. M; He'sey.' Acting 5 tion Chier ste 5 fg nad',,

Enginvering Inspectic Branch e

Engineering and Technt al Int.pection Division a

SUMMARY

i inspection on June 29 to July 2,1981 1

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Areas Inspected I

This special unannounced inspectinn involved 28 inspector-hours onsite reviewing the circumstances surrounding the exposure of a m!nor to radiation in excess of l

the whole body regulatory limit and follow-up actions to the Health Physics Aopraisal.

1 Results Of the two areas inspected. no violations cr deviations were identified in one i

j area; two apparent violations =vre found in the remaining area (exceeding quarterly whole body dose limit, paragraph 5.b; and failure to follow procedures,

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