IR 05000327/1980008
| ML19323B308 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 03/20/1980 |
| From: | Gibson A, Lacey L, Jonathon Puckett NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19323B302 | List: |
| References | |
| 50-327-80-08, 50-327-80-8, 50-328-80-05, 50-328-80-5, NUDOCS 8005120222 | |
| Download: ML19323B308 (7) | |
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UNITED STATES e
NUCLEAR REGULATORY COMMISSION Q
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101 MARIETTA ST N.W., SUITE 3100
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Report Nos. 50-327/80-08 and 50-328/80-05 Licensee: Tennessee Valley Authority 500A Chestnut Street Chattanooga, TN 37401 Facility Name:
Sequoyah 1 and 2 Docket Nos.
50-327 and 50-328 License Nos.
CPPR-72 and CPPR-73 Inspection at Sequo 3fi3 Site near Chattanooga, Tennessee
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Inspectors:,1. L. Jacl@on Dafe Sfgned
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Approved by:
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AbIo OMR!80 A. F Gibson, Section Chief, FF&MS Branch Dat'e Signed SU3 DIARY Inspection on February 19-22, 1980.
Areas Inspected This routine, announced inspection involved 108 inspector-hours on site in the areas of the health physics organization and capabilities, effluent control procedures, preoperational testing of radwaste systems and radiation monitoring systems and followup on inspector identified items of concern.
Results of the four areas inspected, no items of noncompliance or deviations were identified.
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DETAILS
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1.
Persons Contacted Licensee Employees
- J. M. Ballentine, Plant Superintendent
- W. F. Popp, Assistant Plant Superintendent
- D. L. McCloud, Quality Assurance Supervisor
- R. J. Kitts, Health Physics Supervisor J. T. Dills, Jr., Chemical Engineer
- W. J. Classen, Office of Power, QA Coordinator
- L. L. Clements, Training Supervisor
- R. N. Russell, Supervisor, Preop Test Section
- E. A. Condon, Preop Test Supervisor
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- W. M. Halley, Nuclear Engineer, Preop Test Section
- J. McGrif f, Maintenance Supervisor, I and C
- W. H. Kinsey, Jr., Results Supervisor
R. J. Prince, Assistant Health Physics Supervisor U.S.N.R.C. Regional Management
- J. P. Stohr, Chief, Fuel Facility and Materials Safety Branch
- A. F. Gibson, Chief, Radiation Support Section, Fuel Facility and Materials Safety Branch NRC Resident Inspector
- W.
T. Cottle
- Attended exit interview 2.
Exit Interview The inspection scope and findings were summarized on February 22, 1980 with those persons indicated in Paragraph 1 above.
3.
Licensee Action on Previous Inspection Findings
i Not inspected.
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4.
Unresolved Items Unresolved items were not identified during this inspection.
S.
Health Physics Staff Qualifications An inspector reviewed the health physics staff organization, individual resumes, training and qualification records and interviewed the Health Physics Supervisor. The Health Physics Supervisor is the Radiation
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Protection Manager and meets the qualifications for this position as speci-fied in Regulatory Guide 1.8, Personnel Selection and Training. There are 18 individuals who meet the requirements for a technician in a r,esponsible position as stated in ANSI 18.1-1971, Selection and Training of Nu~ clear Power Plant Personnel.
(These 18 individuals also meet the requirements for a technician as stated in the proposed ANSI /ANS 3.1-1978 which is a revision to ANSI 18.1-1971.) Eleven individuals are classified as trainees.
The qualifications of the current staff meet the requirements stated in Section 6.3 of the proposed Technical Specifications.
6.
Plant Health Physics Organization An inspector compared the current plant health physics organizatien to a.
the orEanization shown in Figure 13.1-4, of the FSAR. The current organization is larger and includes more levels of supervision than the organization described in the FSAR. The inspector discussed the organization with the Health Physics Supervisor and determined that the current organization is an improvement over the organization shown in Figure 13.1-4 of the FSAR.
It was determined that the current health physics organization had been incorporated into the radiologi-cal emergency planning and should improve the emergency response of the health physics organization.
b.
The plant health physics organization appears to have adequate tech-nical backup, primarily from the Radiological Hygiene Branch which is a corporate level organization based in Muscle Shoals, Alabama.
Operational backup support can also be obtained from the Radiological Hygiete Branch for emergency operatious, however, there is no formal training program for of fsite management and technical personnel on the plant specific details of the Sequoyah facility.
This concern is not limited to the health physics area, but extends to the whole offsite organization and was identified as an open item (50-327/80-03-08) in Inspection Report No. 50-327/80-3 for an inspection conducted in January, 1980. Training of the offsite health physics organization in plant specific details, although desirable, is not a regulatory require-ment at this time. The inspector had no further questions in this area.
7.
Health Physics Survey Instruments An inspector reviewed the types and quantities of survey instruments avail-able. The current inventory of instruments exceeds the types and quantities listed in Table 12.3-1 of the FSAR and appears adequate for both routine and emergency operations. The maximum dose rate that can be measured by
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any of the instruments is 1000 R/hr. The purchase of an instrument capable of reading greater than 1000 R/hr is being considered for possible use during an emergency. During an emergency, such an instrument might be used to determine if life-threatening dose would likely be received in the performance of certain critical operations or life saving activities. The licensee is not required to'have such a capability but it is recommended
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that an instrument capable of measuring at least 5000 R/hr be a part of the plant emergency equipment inventory. The inspector had no further questions in this area.
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8.
Health Physics Procedure Review The Technical Specifications will require that health physics procedures a.
be written, approved, and adhered to.
Certain health physics procedures require review by the Plant Operations Review Committee (PORC).
The category of health physics procedures which require PORC approval' are the Radiological Control Instructions (RCIs) which are written to implement 10CFR20 requirements. An additional category of procedures has been developed to be used as the actual working procedures. These procedures, called Health Physics Section Instruction Letters (HPSILs)
are written to implement the RCIs as well as to provide specific guidance in areas not required to be addressed in the RCIs.
The HPSILs are approved by the Health Physics Supervisor with no PORC review. The inspector informed plant management that HPSILs imple-menting those activities performed to assure compliance with NRC requirements shall be adhered to with the same dedication as if the procedure were a RCI. This position does not apply to those miscel-laneous HPSILs which have nothing to do with activities important to safety.
b.
The RCIs had been reviewed on previous inspections and changes had been made in some RCIs to incorporate previous inspector comments.
During this inspection, an inspector reviewed several HPSILs to ensure that this category of procedures had been written with the same care and attention to technical accuracy as the RCIs. HPSIL-14, which addresses the respiratory protection program and HPSIL-17 which encom-passes response testing of HP survey instruments were reviewed in detail and found to be adequate. Several other HPSILs were reviewed and the inspector found the procedures to be adequate. There were no further questions regarding health physics procedures.
9.
Effluent Control Procedures The draft Radiological Environmental Technical Specifications (RETS)
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specify limits for liquid and gaseous effluent release rates, the release controls to be employed, the samples to be taken before and during releases and the analyses which must be performed on the sam-ples. An inspector reviewed several Surveillance Instructions (sis)
which had been written to ensure compliance with the proposed RETS.
The inspector determined that the requirements in the RETS had been adequately addressed in the sis.
b.
The licensee raised a technical question regarding the reporting of
"less than" numbers in regards to effluent analyses. After returning to the regicnal office, the inspector telephoned an individual in the i
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USNRC's Office of Nuclear Reactor Regulation who is responsible for
developing this portion of RETS. The results of this telephone conver-sation were:
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(1) Whenever a nuclide is detected in an effluent sample, it will be
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reported provided there is a reasonable confidence that the
nuclide is actually present. This applies, even if the measured activity is less than the sensitivity limits stated in the RETS.
(2) Whenever an analysis for a nuclide yields a "less than" number
the "less than" number will not be used in quantifying releases j
(in terms of curies) or calculating doses from the effluents.
l (3) The RETS sensitivity limits (example SE-7 uCi/ml for certain
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nuclides in liquid samples) are not rigid limits for all esmples.
These sensitivity limits are primarily performance specifications for analytir:1 systems and are based on blank samples.
It should be understood, however, that state-of-the-art analytical systems can achieve these sensitivity levels on routine effluent samples i
using reasonable counting times. For the unusual situations where these sensitivities cannot be met, without using unusually large sample geometries and/or excessive counting times, it is
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permissible to exceed the sensitivity limits stated in the RETS.
This information was communicated via telephone to a member of licensee c.
management on February 28, 1980. The inspector discussed with the management representative the desirability of providing administrative controls that ensure appropriate review and approval for accepting analytical results having "less than" values larger than the sensitivity limits in the RETS.
The inspector had no further comments regarding the effluent control procedures.
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10.
Review of Radio Frequency Interference With Radiation Monitors i
The licensee has identified a problem with radio frequency (RF) interference with radiation monitors. The licensee has determined that heliarc welding operations are the source of the RF interference. The problem will be corrected by rerunning the unshielded wiring for certain monitors inside electrical conduit. The licensee does not intend to take this corrective action on all radiation monitors but currently is planning to administratively control heliarc welding and provide direct surveillance over the radiation monitors during welding to specifically identify the increased count rates due to RF interference. The Plant Superintendent stated that the adminis-
trative controls would be evaluated and if they proved to be too difficult or unreliable then the remaining radiation monitoring system wiring would
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be rerun in electrical conduits. This appears to be a satisfactory course
of action. This item will be evaluated on future inspections (50-327/80-08-01).
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Leak Testing of the Waste Gas System One of the Short Term Lessons Learned from the Three Mile Island (TMI)
Accident is that the waste gas system should be thoroughly leak tested prior to exceeding very low power levels. An inspector determined that there were no plans to formally leak test the system as a whole prior to full power operation nor were there any plan. to retest the system on a periodic basis. After discussions with the Plant Manager and the Preop Test Section Supervisor concerning the problems caused by the leaks in the waste gas systems at TMI, the Plant Superintendent agreed to conduct a leak test of the waste gas system prior to exceeding five percent power. This item will be reviewed ot future inspections (50-327/80-08-02).
12.
Review of Preoperational Test Results An inspector reviewed completed preoperational test procedures for the radwaste systems and the radiation monitoring systems. The test results indicate that the systems will function as intended.
Some minor deficiencies remain uncorrected, however, the licensee has identified milestones (such as fuel load or initial criticality) by which time certain deficiencies must be corrected before proceeding to the next milestone. The inspector found no problems with the licensees plans for correcting the outstanding deficiencies. The only major test not reviewed were the leak tests on the HEPA and Charcoil filtration systems. These tests will be reviewed on a future inspectica (50-327/80-05-03).
13.
Concerns for Cross Connections in the Ventilation System Prior to this inspection, an inspector from the Reactor Construction and i
Engineering Support (RCES) Branch questioned whether or not common ties in ventilation systems at Sequoyah Nuclear.Dlant (SNP) might allow contamination to spread from one section of the plant to another via the ventilation system.
The RCES inspector had originally raised this question in regards to the Watts Bar Nuclear Plant but extended it to SNP because of the simi-larity of the two plants. During this inspection, ventilation system diagrams were reviewed and portions of the ventilation system were visually inspected. The inspectors did not identify any problem with the design or construction of the systems.
14.
Health Physics Concerns Regarding Pressurizer Access The inspectors inspected the location of valves and instrumentation on a.
the pressurizer and determined that access to the areas requiring maintenance was restricted and would likely result in higher exposures i
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to workers than is desirable.
It was concluded that modifications to the pressurizer shielding prior to startup would not be feasible and exposures would have to be minimized by taking advantage of ext'ensive work planning, training, temporary shielding and consideration as to whether the pressurizer should be filled or drained prior to starting work near it.
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The Health Physics Supervisor informed the inspectors that' pressurizer work would be well planned to offset the undesirable construction of the shielding around the pressurizer, however, this item will remain open pending further study by the NRC (50-327/80-05-04).
15.
Followup of Licensee Identified Item of Noncompliance On February 14, 1980, licensee representatives were utilizing an AmBe neutron source (0.88 Curies) to calibrate the Failed Fuel Detector which is located in its own shielded room. At the conclusion of the calibration, health physics technicians were asked to return the source to its authorized storage location. The health physics technicians proceeded to return the source container to its storage location, but the source was not in the container. The source was left suspended near the Failed Fuel Detector, where it had been used for calibration of the detector. This oversight was not detected until February 16 at 0745 hrs. when a plant operator noticed that the Failed Fuel Detector was registering counts. Health physics personnel were notified and they retrieved the source and placed it in its
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i proper storage location. An investigation by the Assistant Health Physics Supervisor revealed that the room had been locked during the period of time that the source had been unattended.
This was determined by discussions with shift personnel and by reviewing key control logs. The dose rate (neutron and gamma) from the source was determined to be 229 mrem /hr. at contact and 33 mrem /hr. at 18 inches. No measureable unplanned exposures occurred as a result of this incident. The NRC Resident Inspector was notified of this incident by the licensee. Because there were no measured exposures resulting from this incident and the corrective actions taken by the licensee were adequate, no citation will be issued for this licensee identified item.
16.
Access Control For The Incore Detector Tunnel Beneath The Reactor Vessel The tunnel beneath the reactor vessel is an area where extremely high dose rates can occur. Several overexposures have occurred in the tunnel beneath the vessel due to inadequate access controls. The inspectors noted that there were no provisions for locking the access hatch but there were provisions for bolting the access hatch cover in place. Discussions with the Health Physics Supervisor revealed that a design change request has been submitted to provide for the installation of a key lock on the access hatch cover.
In addition, the access hatch cover will be posted as an " Extremely High Radiation Area".
The inspector had no further questions concerning this subject.
17.
U.S. Nuclear Regulatory Commission Region II Management Visit
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The Chief of the Fuel Facility and Materials Safety sranch (FFMS) and the
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Chief of the Radiation Support Section, FFMS Branch, arrived on site on
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2/21/80 and accompanied the inspectors for the remainder of the inspection.
They toured portions of the plant and the environs with the inspectors and
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a licensee representative. They also met key licensee personnel during i
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this visit. The main purpose of this visit was to establish a frame of reference for future decisions regarding the SNP, particularly decisions involving implementation of the Radiological Emergency Plan. They also participated in the inspectors meeting with plant management at the conclusion of the inspection.
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