ML18036B295
| 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) | |
See also: IR 05000259/1993007
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.
.i