ML18036B295

Responds to Violations Noted in Insp Repts 50-259/93-07, 50-260/93-07 & 50-296/93-07.Corrective Actions:Radiological Awareness Rept Initiated & Incident Incorporated Into Initial Radcon Category II General Employee Training

ML18036B295
Person / Time
Site:	Browns Ferry
Issue date:	05/17/1993
From:	Zeringue O TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9305250211
Download: ML18036B295 (10)

Text

ACCELERATED DOCMCENT DISTRIBUTION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)ACCESSION NBR:9305250211 DOC.DATE: 93/05/17 NOTARIZED:

NO DOCKET¹"ACII':50-259 Browns Ferry Nuclear Power Station, Unit 1, Tennessee 05000259 50-260 Browns Ferry Nuclear Power Station, Unit 2, Tennessee 05000260 50-296 Browns Ferry Nuclear Power Station, Unit 3, Tennessee 05000296 AUTH.NAME AUTHOR AFFILIATION R ZERINGUE,O.J.

Tennessee Valley Authority RECIP.NAME RECIPIENT AFFILIATION I Document Control Branch (Document Control Desk)

SUBJECT:

Responds to violations noted in Insp Repts 50-259/93-07, 50-260/93-07

&50-296/93-07.Corrective actions:radiological awareness rept initiated&incident incorporated into initial Radcon Category II General Employee Training.DISTRIBUTION CODE: IE01D COPIES RECEIVED:LTR

/ENCL/SIZE: TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES: D D RECIPIENT ID CODE/NAME PD2-4-PD WILLIAMSiJ.

INTERNAL: ACRS AEOD/DSP/TPAB t DEDRO NRR/DRCH/HHFB NRR/DRSS/PEPB NRR/PMAS/ILPB2 O REG FILE 02 RGN2 FILE 01 EXTERNAL EG&G/BRYCE 9 J~H~NSIC COPIES LTTR ENCL 1 1 1 1 2 2 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 RECIPIENT ID CODE/NAME ROSS,T.AEOD/DEIB AEOD/TTC NRR/DORS/OEAB NRR/DRIL/RPEB NRR/PMAS/ILPBl NUDOCS-ABSTRACT OGC/HDS3 RES MORISSEAU,D NRC PDR COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 D D NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTETH CONTACI'HE DOCUMENT CONTROL DESK, ROOM PI-37 (EXI'.504-2065)TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!D TOTAL NUMBER OF COPIES REQUIRED: LTTR 24 ENCL 24 Tennessee Vatley Authority, Post Office Box 2000, Decatur, Alabama 36609 2000 O.J."Ike" Zeringue Vice President, Browns Ferry Nuclear Pfant NN 17 Ir93 U.S.Nuclear Regulatory Commission ATTN: Document Control Desk washington, D.C.20555 Gentlemen:

In the Matter of Tennessee Valley Authority Docket Nos.50-259 50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN)-NRC INSPECTION REPORT 50-259, 50-260, 296/93-07 REPLY TO NOTICE OF VIOLATION (NOV)-RADIATION PROTECTION PROCEDURES The subject NRC inspection report identified a violation involving three examples of failures to comply with radiation protection procedures.

The enclosure to this letter provides TVA's"Reply to the Notice of Violation" (10 CFR 2.201).If you have any questions regarding this reply, please telephone Pedro Salas at (205)729-2636.Sincerely, Mi/(A Enclosure cc: See page 2 OAAAgg 93052502ii 930517 PDR.ADQCK 05000259 8 PDR U.S.Nuclear Regulatory Commission NN i'7 1993 Enclosure cc (Enclosure):

NRC Resident Inspector Browns Ferry Nuclear Plant Route 12, Box 637 Athens, Alabama 35611 Mr.Thierry M.Ross, Project Manager U.S.Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 U.S.Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323

/

EHCLOSURE Tennessee Valley Authority Browns Ferry Nuclear Plant (BFN)Reply to Notice of Violation (HOV)Inspection Report Number-2.2 2 RESTA OF VIOLATIO"During the Nuclear Regulatory Commission (NRC)inspection conducted on February 18-March 19, 1992,[sic]a violation of NRC requirements was identified.

In accordance with the"General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the violation is listed below: TS 6.8.1.l.a requires that written procedures shall be established, implemented and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February, 1978.Regulatory Guide 1.33 requires radiation protection procedures covering access control to radiation areas including a radiation work permit (RWP)system.Radiological Control Instruction, RCI-9, Radiation Work Permits, section 6.5.1, holds the individual worker responsible to ensure the correct RWP for the job is used, and section 6.5.3.requires individuals using a RWP comply with all of the dressout requirements of the RWP as well as the verbal instructions given by radiological control personnel so far as those instructions pertain to radiological matters.Contrary to the above, on February 25, 1993, these requirements were not met for the following examples: l.One worker working with a fuel support piece lifting tool on the refuel floor was not wearing a faceshield.

The worker was determined to not be"signed on" to the applicable RWP, that required a faceshield as directed by radiological controls personnel.

t 2.An individual removed anti-contamination clothing (hood and surgeons cap)out of sequence while still within the contamination zone and prior to reaching the designated location for undressing.

The individual was removed from the area by radiological control personnel..

3.An individual inside a contaminated zone donned an anti-contamination hood that had been lying within the contamination zone.The individual was removed from the area by radiological control personnel.

This is a Severity Level IV Violation (Supplement IV)"

REPLY TO VIOLATIOH-EXAMPLE 1 Reason for Violation After signing on a RWP to work on the Unit 2 refuel floor, a craft machinist noticed that another worker nearby working in the same contamination zone (C-zone)was having some difficulties with the operation of a clean air valve assembly.The valve was used to actuate the air cylinders on the contaminated fuel support piece lifting tool positioned approximately ten feet away.The individual working on the valve had"signed on" to a different RWP which permitted him to perform work activities on the fuel support tool.He advised the machinist not to approach the tool.The machinist was familiar with the valve assembly and was cognizant of the radiological hazards associated with the tool.The machinist attempted to assist the other worker by showing him the proper ,valve alignment to minimize the other worker's radiation exposure.However, this action was taken without Radcon's knowledge or approval.2.Corrective Steps Taken and Results Achieved After TVA was informed of this event by the NRC inspector, a Radiological Control (Radcon)technician promptly went to the fuel support piece lifting tool work area to investigate.

A radiological awareness report was initiated.

The machinist stated he understood the radiological hazards associated with the tool and did not go near it.The machinist was counselled immediately by Radcon at the step-off pad of the work area.On March 3, 1993, the machinist was counselled again by Maintenance management about this incident and the need to comply with RWP requirements and restrictions.,When the worker exited the C-zone, he was surveyed and found not to be contaminated.

His dosimetry indicated that no measurable radiation exposure was received from the tool.3~Corrective Steps That[have been or]Will Be Taken To Prevent Recurrence TVA has incorporated this incident into the initial Radcon Category II General Employee Training (GET)as lessons learned.Additionally, this incident will also be incorporated into the Radcon GET retraining.

These actions will reemphasize the need to be"signed on" to the correct RWP for the work being performed and to be cognizant of the RWP requirements.

TVA believes these actions, as well as those described above, will serve to minimize further recurrence of this type event.

a.Date When Full Compliance Will Be Achieved Full compliance will be achieved when this incident is incorporated into the Radcon GET retraining.

TVA expects to complete this action by June 15, 1993.REPLY TO VIOLATIO-EXAMPLES 2&Reason for Violation Since the events described in Examples 2 and 3 incidents resulted from the same RWP work activity, TVA is providing a combined response to both of these as a single event.Two craftsmen were signed on an RWP to repair the turbine and associate valves.The work activity.was in a low level radiation and contamination area.During the installation of the upper pressure head on Unit 2 number 1 main steam stop valve, the craftsmen noticed that the screen in the valve needed to be turned so that a slot would line up with a pin on the upper pressure head.This realignment necessitated the craftsmen to lean into the valve housing.Consequently,'the assigned Radcon technician recommended the craftsmen don anti-contamination hoods while straightening the screen.The Radcon technician handed two laundered canvas hoods to an ironworker who was also working in the same C-zone but had not touched any contaminated equipment/components.

The ironworker was instructed to place the.-hoods on the craftsmen's heads.One hood was placed on a craftsman; however, the other hood was placed on a steam line in an area where the contamination levels were minimal.The craftsman with the hood proceeded to straighten the screen.During this activity, his hood shifted and covered his eyes which impeded the individual's ability to perform his job in a safe manner.The individual reacted to his situation by removing the obstructing canvas hood.His surgeon cap was also inadvertently removed during this action.(Note: the removal of protective clothing and equipment is permissible in a C-zone in a situation when they immediately impact worker safety.For example, workers are trained to remove respirator in C-zone in the event of physical or psychological distress.)

The individual proceeded to exit the C-zone.Simultaneously, the Radcon technician observed this activity and directed the individual to exit the area.A few minutes later, the upper pressure head was moved back into place to be set.The second craftsman approaching the valve housing then donned the canvas hood that was laid on the steam line.NRC inspector observed this donning and notified Radcon of the event.The second individual was also directed to exit the C-zone.

2.Corrective Steps Taken and Results Achieved Both individuals exited the C-zone and were surveyed with a personnel contamination monitor.Ho contamination was found.A radiological awareness report was initiated on these two incidents.

Both individuals were counselled by the Maintenance Manager and Radcon Manager to heighten their awareness'of the proper radiological practices.

Additionally, the Radcon technician was also counselled on the need for more effective communications with workers concerning donning/removal of anti-contamination clothing in contaminated areas.3.Corrective Steps That[have been or]Will Be Taken To Prevent Recurrence r TVA has incorporated this event into the initial Radcon Category II GET as lessons learned.Additionally, this event will also be incorporated into the Radcon GET retraining.

These actions will reemphasize the proper method for donning/removal of anti-contamination clothing in a contaminated area.TVA believes that these actions will serve to minimize further recurrence of this type event.4.Date When Full Compliance Will Be Achieved Compliance will be achieved when on these incidents are incorporated into the Radcon GET retraining.

TVA expects to complete this action by June 15, 1993.

Three examples of failing to comply with radiation work permits will be incorporated into the Radcon GET retraining by June 15, 1993.

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