ML18030B322

Responds to NRC 860408 Ltr Re Violations Noted in Insp Repts 50-259/86-10,50-260/86-10 & 50-296/86-10.Corrective Actions: Current Health Physics Training Will Be Required for Unescorted Access to Protected Area,Effective on 860526

ML18030B322
Person / Time
Site:	Browns Ferry
Issue date:	05/06/1986
From:	Lambert D TENNESSEE VALLEY AUTHORITY
To:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
NUDOCS 8605200311
Download: ML18030B322 (6)

Text

TENNESSEE VALLEY AUTHORITY CHATTANOOGA. TENNESSEE 37401 5N 118B Lookout Place May 6, 1986 pl U,S. Nuclear Regulatory Commission Region II ATTN: Dr. J. Nelson Gxace, Regional Administrator 101 Marietta Street, NW, Sui.te 2900 Atlanta, Georgia 30323

Dear Dx. Grace:

BROWNS FERRY NUCLEAR PLANT UNITS 1, 2, AND NRC-OIE REGION II INSPECTION REPORT 50-259/86-10, SO-260/86-10, 50-296/86-10 RESPONSE TO VIOLATIONS Enclosed is our x'esponse to J. A. Olshinski.'s April 8, 1986 letter to S. A. White transmitting IE Inspection Report Nos. SO-259/86-10, 50-260/86-10, and 50-296/86-10 for our Browns Ferry Nucleax Plant, which cited TVA wi.th one Severity Level IV Violation.

If you have any questions, please get in touch with R. E. Alsup at FTS 858-2725.

To the best of my knowledge, I declare the statements contained herein are complete and true.

Vex'y truly yours, TENNESSEE VALLEY AUTHORITY pX D. L. Lambext Nuclear Engineer Enclosure cc: Mr. James Taylor, Director (Enclosure)

Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Sb05200311 8b050b PDR ADOCK 05000259 8 PDR An Equal Opportunity Employer

ENCLOSURE

RESPONSE

NRC INSPECTION REPORT NOS.

50 259/86 10 ~ 50 260/86 10 y AND 50 296/86 10 JOHN A. OLSHINSKI'S LETTER TO S. A. WHITE DATED APRIL 8, 1986 Item 1 Technical Specification 6.3 requi.red that detai.led radiation control procedures be prepared, approved, and adhered to.

Plant procedure BF RCI-8, Radiobioassay Program, required a current whole body count prior to entry into a contamination zone.

Plant procedure BF RCI-9, Radiation Work Permits, requi.red current General Employee Level II training prior to entering an area requiring a radiation work permit.

Contrary to the above, during the period September 1, 1985 to February 28, 1986, the li.censee failed to adhere to radiation control pr'ocedures in that:

a. Forty licensee employees entered radiati.on work permi.t areas without the training required by plant procedure RCI-9.

b. Nineteen licensee employees entered contamination zones without current whole body counts as required by plant procedure RCI-8.

This is a Severity Level IV violation (Supplement IV).

1. Admission or Denial of the Alle ed-Findin We admit that the violation occurred as stated. We believe it is important to emphasize that this vt.olation was identi.fied about. three months before the NRC inspecti.on. Each deviation event was formally documented by health physics through theRadiological Incident Report (RIR) system.

2. Reasons for the Violation The completion of all required training and whole body counts is a prerequisite for personnel to obtain a security badge when first reporting to the site. Until September 1985, individual security badges were pulled if the retraining requirements were not kept current. At that time, a decision was made to use the security badge as control of personnel for security reasons only and not. to ensure health physi.cs retraining. This change was made to simplify the security access control system. Thus, individuals were made r'esponsible for maintaining their own retraining requirements. Supervisors were notified of the changes to the security badge program during various plant meetings. Our experience since the change is that the new method has not, been completely sati.sfactory as evidenced by the number of defi.ciencies documented in the RIR system.

It appears that all plant personnel are not aware of health physics training requirements before entry into a radiati.on work permit area or the requirement of current whole body counts before entry into a contamination zone.

3. Corrective Ste s Which'Have Been Taken and Results Achieved Health physics wx'ites RIRs against those individuals who use a Radiological Work Permit (RWP) without having cuxrent health physics training ox whole body counts. Plant management has stressed these requirements during plant meetings and is reviewing completed RIRs.

In addition, effective January 31, 1986, health physics initiated a respirator issue program which has successfully prevented workers with expired health physics training or whole body count from entex'ing a radiation work permit area xequiring respiratory protection.

4. Corrective Ste s Which Will Be Taken to Avoid Further Violations

a. Effective May 26, 1986, current health physics training will be required for unescorted access to the protected area.

b. Plant management will issue a letter to plant employees by May 8, 1986, describing disciplinary action to be taken for entering contamination zones without a current whole body count and for entering a radiation work permit area without current level training.

II

c. The training department will emphasize the following specific issues during, General Employee Training beginning May 14, 1986:

1. Plant procedures require a current whole body count before entry into a contamination zone:"-

2. Plant procedures require current Genexal Employee Level II Health Physics Training before entering an axea requiring a radiation work permit.

3. Attentiveness to all posted areas is essential for all plant employees.

4. Notify health physics full compliance if you are not "positive" that you are in with radiological control procedures.

d. Health physics will contxol the ability of personnel to enter RWP

. areas, including contamination zones, thxough control of the pocket chamber. Personnel must have a pocket chambex in order to sign on an RWP. Only personnel who meet RWP entry xequirements will be issued pocket chambers. Computer software changes will be made to accomplish this action, including pulling the pocket chambex's of individuals with expired whole body counts.

5. Date When Full Co lienee Will Be Achieved Our corrective actions detailed in 4.d. will be in place by June 15, 1986, at which time full compliance will be achieved.