IR 05000327/1986054

Insp Repts 50-327/86-54 & 50-328/86-54 on 861006-10.Addl Example of Violation Noted in Insp Repts 50-327/86-46 & 50-328/86-46 Re Failure to Wear Protective Hoods as Required by Radiation Work Permit Identified

ML20215F163
Person / Time
Site:	Sequoyah
Issue date:	11/13/1986
From:	Hosey C, Weddington R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20215F155	List: IR 05000327/1986054 ML20215F152
References
50-327-86-54, 50-328-86-54, IEIN-86-023, IEIN-86-046, IEIN-86-23, IEIN-86-46, NUDOCS 8612230288
Download: ML20215F163 (9)

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DEC 18 1986 Report Nos.: 50-327/86-54 and 50-328/86-54 Licensee: Tennessee Valley Authority 6N38 A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Docket Nos.: 50-327 and 50-328 License Nos.: DPR-77 and DPR-79 Facility Name: Sequoyah 1 and 2 Inspection Conducted: October 6-10, 1986 Inspector: (tlo/ dig R.E.Weddingtonf Date Signed Accompanying Personnel: C. H. Bassett Approved by: k%

C. M. Hos@, Sectihn Chief l/[/ 3/8b Date Signed Division of Radiation Safety and Safeguards SUMMARY Scope: This was a special announced inspection in the areas of: previous enforcement matters, health physics restart i ssues, control of radioactive material, external exposure control, internal exposure control, solid wastes and followup on previous inspector identified item Results: An additional example of an apparent violation described in Inspection

Report No. 50-327, 328/86-46' forl failure to properly wear protective hoods as required by the radiation work permit was identifie n ..

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REPORT DETAILS

- Persons Contacted Licensee Employees

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• H. L. Abercrombie, Site Director

• P. R. Wallace, Plant Manager

• R. J. Prince, Site Radiological Control Superintendent

• J. Blankenship, Information Services Manager

• D. C. Craven, Quality Assurance Manager

• C. Stehle, Project Manager

• L. M. Nobles, Plant Superintendent

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• C. G. Hudson, Chief, Radiation Health

• F. W. Reiman, Radiological Accessor

• J. M. Qualls, Radwaste Section Supervisor

• B. Schofield, Licensing Engineer Other licensee employees contacted included technicians, security force members, and office personne NRC Resident Inspectors

• K. A. Jenison, Senior Resident Inspector

• P. Harmon, Resident Inspector

• D. P. Loveless, Resident Inspector

• Attended exit interview Exit Interview The inspection scope and findings were summarized on October 10, 1986, with those persons indicated in Paragraph 1 above. The following issues were discussed in detail: (1) the two Health Physics (HP) restart issues: review of the HP staff reorganization and review of the ALARA program (Paragraph 13); (2) an additional example of an apparent violation for failure to adhere to procedures requiring proper use of protective clothing hoods (Paragraph 6); licensee response to personnel contamination events which occurred in July and August,1986 (Paragraph 8); the July 1986, preparation and shipment of high activity irradiated core components for disposal (Paragraph 10); and a commitment to perform an evaluation of the laundry contamination monitor (Paragraph 8). The licensee acknowledged the inspection findings and took no exception The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspection.

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3. . Licensee Action on Previous Enforcement Matters (92702)

(Closed) Violation (50-327/86-04-01 and 50-328/86-04-01), Failure to comply with the Itcense conditions of an Agreement State licensee in regard to the accessibility of cask rigging gear. The inspector reviewed the licensee's responses dated April 30, 1986, and July 3, 1986, and verified that the corrective action specified in the responses had been take (Closed) Violation (50-327/86-04-03 and 50-328/86-04-03), Failure to maintain written procedures regarding respiratory protective equipment issuance records. The inspector reviewed the licensee's responses of April 30, 1986, and July 3,1986, and verified that the corrective action specified in the responses had been take (Closed) Violation (50-327/86-36-01 and 50-328/86-36-01), Failure to perform radiation level measurements on the surfaces of exclusive use transport vehicles. The inspector reviewed the licensee's response dated August 22, 1986, and verified that the corrective action specified in the response had been take (0 pen) Violation (50-327/86-04-02 and 50-328/86-04-02), Failure to use bioassay results to evaluate the regulatory significance of an internal exposure. In a supplemental response to this violation dated July 3, 1986, the licensee stated that the computer codes used by the Tennessee Valley Authority (TVA) to assess uptakes of radioactive materials had been modified to include the calculation of "MPC-hour equivalents" for acute exposure When the inspector attempted to confirm that this action had been taken, no one at the Sequoyah facility could verify that the computer codes had been modified. On the last day of the inspection the inspector learned from TVA corporate representatives that the codes haa not been modified as previously reported. A supplemental response was requested of the licensee. This item will remain open pending review of the licensee's supplemental respons . Organization and Management Controls (83722)

The inspector also reviewed the reorganized health physics staffing with the new Radiological Control (Rad Con) Superintendent. The qualification requirements for several positions had been upgraded and more technical positions had been create One supervisory position, Radiological Protection Supervisor, remained to be fille The Radiological Control Superintendent stated that he is still in the prccess of completing the Radiological Controls reorganizatio Some vacancies remain to be filled, the continuance of the present staff in their current positions is still under review and a number of program changes are being considered. The licensee's progress on the reorganization will be reviewed during subsequent inspection No violations or deviations were identifie _

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4 Training and Qualifications (83723)

Technical . Specification 6.3.1 required that the Health Physicist (Rad Con Superintendent) meet or exceed the qualifications of Regulatory Guide 1.8, Personnel Selection and Training, September 1975. Regulatory Guide specified the educational and professional experience requirements of a Radiation Protection Manager (RPM). The inspector reviewed the educational background and professional experience of the newly appointed Rad Con

' Superintendent or RPM. The inspector determined the RPM met or exceeded the minimum experience and training requirement No violations or deviations were identified. External Exposure Control and Dosimetry (83724)

The licensee was required by Technical Specification 6.8.1 to establish, implement and maintain written procedures covering activities referenced in Appendix A of Regulatory Guide 1.33, Quality Assurance Program Requirements (Operations), Revision 2, February 1978. Appendix A of Regulatory Guide 1.33 specified that radiation protection procedures should be written including the radiation work permit (RWP) system governing entrance into radiologically access controlled area During tours of the plant, the inspector reviewed RWPs posted at various work locations, including RWP 86-2638-110 which specified controls for building and removing scaffolding inside a contamination zone of the U-2 pipe cnase on the 690' elevation. The RWP specified the use of personal protective clothing including protective hood The inspector observed four workers inside the contamination zone removing scaffolding. All of the workers were wearing their protective hoods improperly. Three of the workers did not have the hoods fastened under their chins but had the flaps, which should have been used to protect the neck area, flipped back. The fourth worker was wearing the protective hood inside out and also had the flaps flipped back. One of the workers was also observed removing his hood while in the contaminated area and then putting it back on. The Rad Con Shift Supervisor was immediately notified of the proble The NRC Resident Inspectors have noted this type of problem in the pas The Resident Inspector's Report 50-327, 328/86-46 identified an apparent violation for failure to adhere to procedures in that workers were observed not wearing protective hoods properly, contrary to the requirements of the RWP. The aforementioned failure of the four workers removing scaffolding to adhere to the RWP requirements is another example of Violation 50-327, 328/86-46-0 .

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5 Internal Exposure Control and Assessment (83725)

The inspector reviewed the licensee's air sampling program and the criteria used to establish maximum permissible concentration (MPC) controls for radioactive material in ai i Licensee Radiological Control Instruction, RCI-I, Radiological Hygiene Program, Revision 30, July 29,1986, required the 'icensee to sample the airborne activity in restricted areas on a quarMrly basis and perform an analysis to determine what isotopes were present. If the limiting isotope, Sr-90, was not found to be present, an MPC value for gross sample analysis of 3E-9 microcuries per milliliter (pCi/ml) was to be use If Sr-90 was present in the quarterly sample, then a more restrictive MPC value of IE-9 pCi/ml was to be use During the inspection, the inspector was made aware of a TVA Corrective Action Report (CAR), SQ-CAR-36-042 dated August 28, 1986. The CAR indicated that the requirements for performing suitable measurements of airborne concentrations and verifying the presence or absence of Sr-90 had not been met during the period from oune 1983 to June 1986. The licensee performed an investigation and determined that there had, in fact, been no radiochemistry analysis ' performed to verify the absence of the limiting isotope in air from June 1983 to June 1986. Except for an initial sample,

, the chemistry group had not performed any subsequent quarterly analysis for

! Sr-90 because no implementing procedure for the sampling program had ever been establishe After the problem was noted, the licensee took several corrective action Using the scaling factors developed for the facility from analysis by Scientific Applications International, In (SAI) for use in classifying

radioactive wastes pursuant to 10 CFR Part 61, the results of selected elevated 1984 and 1985 air sampling data were analyzed and scaling factors

applied. The results of the analyses of plant stack releases were also reviewed. After applying the scaling factor for Sr-90, it was found that the concentrations were in the range where the isotope could be considered as not being present in accordance with Footnote 5 of 10 CFR 20 Appendix B (i.e., less than ten percent of unrestricted area MPC). The licensee

- therefore determined that no personnel exposure adjustments would be necessary. The licensee implemented procedure changes to cause the required analysis to be performed in the futur CFR 20.103 required the licensee to use suitable measurements of concentrations of radioactive materials in air for detecting and evaluating airborne radioactivity in restricted area Failure of the licensee to

perform the required air sample analysis for Sr-90 would normally be

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considered a violation of 10 CFR 20.103. However, the NRC Enforcement Policy,10 CFR 2, Appendix C,1986, states that a Notice of Violation will generally not be issued for violations, if (1) it was identified by the licensee; (2) it fits in Severity Level IV or V; (3) it was reported, if required; (4) it was or will be corrected, including measures to prevent recurrence, within a reasonable time; and (5) it was not a violation that

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could reasonably be expected to have been prevented by the licensee's corrective actions for a previous violatio It was determined that this apparent violation met the criteria specified in 10 CFR 2, Appendix C and would be considered licensee identified (50-327/328/86-54-01). Control of Radioactive Materials and Contamination, Surveys, and Monitoring (8382G)

The inspector reviewed reports of radiation and contamination surveys posted at selected job site During tours of the facility, the inspector performed independent radiation surveys and noted no inconsistencies with l area posting During a previous inspection, it was observed that a significant quantity of material was apparently being taken into the regulated area which subse-

quently required a survey before being released back to the uncontrolled area. It was also noted that a good deal of health physics technicians'

time was being devoted to such release surveys. The inspector noted that-there was an apparent decrease in the amount of material taken into the regulated area as compared to the previous inspectio The inspector reviewed licensee actions in response to several contamination events which occurred in July and August 1986. On four occasions personnel contaminations occurred, apparently due to high activity particles remaining in laundered protective clothing and subsequently becoming deposited on the individual's skin. In each case, the unplanned exposure to the skin of the individual's whole body was calculated and that dose assigned in the appropriate records. The highest dose received was 4.8222 rem to the skin of a worker's back. As a result of these occurrences the licensee took a number of steps to preclude recurrence: 1) all old, stained, highly contaminated protective clothing was discarded, 2) IE Information Notice No. 86-23: Excessive Skin Exposures Due to Contamination With Hot Particles was re-reviewed, 3) the licensee required that in their laundry facility all contaminated protective clothing be wet-washed instead of being dry cleaned to more completely remove contamination from the fabric, 4) the laundry operators were briefed on the problem and instructed on the correct method to load the laundry into the washing machines and the correct amount of laundry to wash per load, 5) the laundry transfer carts and storage areas were surveyed to find and remove any items with significant residual contamination (among the items found was a shoe cover which measured 1300 mrem / hour on contact) and 6) laundry upgrades are presently being considered including contracting with a vendor to have all the contaminated laundry processed at a separate facility (either onsite or at some other location) and completely redesigning and refurbishing the existing facility in the plan These actions were apparently effective because no other personnel contaminations due to high activity particles in laundered protective clothing have occurre However, after discussing the operation and detection limits of the monitor used to check the laundered protective clothing for excessive contamination with various licensee health physics l

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personnel, the inspector noted a problem with the laundry process that the licensee had not addressed. There was no written procedure indicating the correct method to check the laundry monitor for proper response to a known source. Through discussions with licensee representatives it was noted that several different sources had been used to perform the biweekly response check of the monitor although a uninue source was identified by markings as the one that was to be used for the response check. The lack of a written procedure was acknowledged by the licensee and a licensee representative stated that such a procedure would be writte It was also determined bysthe inspector that the response check did not give an accurate indication of what the monitor would actually detect on cleaned laundry because the source was neld in a stationary position over the detectors for the response check while the laundered protective clothing was moved or pulled rapidly across the detector Plant Procedure RCI-1

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specified that the contamination limit for releasing laundered protective clothing for use was that the clothing was not to exceed 0.75 mrad /hr in any 644cm2 (100 in2 ) are A review of the calibration procedure for the laundry monitor, SI-637, Periodic Calibration of Personnel Radiation Monitoring Equipment, March 12, 1986, and a review of the associated technical manual indicated that the monitor was calibrated and set with a count time of one second, a dead time or time between counts of one second and an alarm setting of 0.6 mrem. 1he calibration was also performed with the source held in a stationary positio Because of the calibration and response check technique for the monitor and the method used to pull the laundered clothing across the detectors, it was concluded that the monitor would likely not detect clothing contaminated above the licensee's procedural limit The licensee acknowledged this problem and made a commitment to conduct a test to determine what level of residual contamination could actually be detected with confidence on laundered protective clothing, with considerations being given to how the monitor is actually used. After the test, the licensee was to determine whether or not the detectable level was acceptable and, if not, then also determine what additional actions would be needed to ensure adeouate surveys are performed. This evaluation will be reviewed during subsequent inspections (50-327/86-54-02 and 50-328/86-54-02).

The inspector reviewed the classroom training given to the laundry operators, HP Training Lesson Plan 260, Health Physics for Sequoyah Laundry Personnel - Good Radiological Work Practices, Revision 0, October 24, 198 The entire training, including how to remove laundry from a contamination zone, how to operate a dose rate meter, how to operate the laundry monitor and how to clean and sanitize respiratory devices, was only scheduled to last an hour and there was no practical demonstration or evaluation of the trainees on any of the tasks they were being qualified to perform. The licensee acknowledged the problem of operator training and stated that at least part of the problem was organizational in natur The laundry operators were not in the health physics organization and, therefore, their supervision and training were not under health physics' cognizance and control. The licensee explained that a proposal had been made and was being

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considered to place the operators under operational control of the health physics group as part of the reorganization to remedy the problem. This item will be reviewed during subsequent inspections as part of the licensee's reorganizatio No violations or deviations were identifie . Maintaining Exposures As Low As Reasonably Achievable (ALARA) (83728)

In NRC Inspection Report No. 50-327, 328/86-36, several apparent weaknesses in the licensee's ALARA program were identified. After that report was issued, the TVA Division of Nuclear Quality Assurance performed an audit of the ALARA program and found weaknesses similar to those mentioned in Report No. 86-36. Since these reports were published, a new Rad Con Superintendent has been placed in charge of the health physics organization and the newly created position of Manager of ALARA has been filled from within the grou Although many good ideas and programs have been proposed, no substantive changes have been made. This item will remain open pending review of the actions actually taken to improve the ALARA progra . Solid Wastes (84722)

10 CFR 20.311 specified the manifest requirements for low level radioactive waste and required that all wastes be classified according to the methodology given in 10 CFR Part 6 In July 1986, the licensee prepared and shipped for disposal a large quantity of irradiated hardward including thimble plugs, burnable poison rod assemblies, a cluster control rod assembly, a primary source assembly and guide tube sections. The licensee had contracted with Chem-Nuclear Systems, Inc. (CNSI) to perform the 10 CFR Part 61 waste classification for the item The items were shipped in two separate shipments. The first shipment, No. 434, was made on July 9,1986, and consisted of a 55 SST CNSI liner containing a total activity of 6,250 curies. The radiation level on the liner was 6,300 rem / hour at contact while the radiation level on the shipping cask was 70 mrem /hr at the surface of the cask. The second shipment, No. 435, was made on July 11, 1986, and was made up of three 55 SST CNSI liners with a total combined activity of 4,900 curie The highest radiation level on the three liners was 5,300 rem /hr at contact while the radiation level on the shipping cask was 40 mrem /hr at the cask's surface. Both shipments were classified as Class The inspector reviewed the licensee's shipment documentation and waste classification methodology and determined that it meet the requirements of 10 CFR 20.31 No violations or deviations were identified.

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1 Inspector Follow-Up Item (92701)

(Closed) IFI (50-327/86-46-02 and 50-328/86-46-02), Inadequate cleaning of protective clothing resulting in personnel contaminations. See Paragraph . IE Information Notices (IEN) (92727)

The inspector determined that the following information notice had been received by the licensee, reviewed for applicability, ' distributed to appropriate personnel and that actions, as appropriate, were taken or schedule '

IEN 86-46: Improper Cleaning and Decontamination of Respiratory

Protection Equipmen '

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13. Health Physics Restart Issues l-(0 pen) IFI (50-327/86-36-02 and 50-328/86-36-02), Review reorganized health physics staff (See Paragraph 4).

(0 pen) IFI (50-327-86-36-03 and 50-328/86-35-03), Review licensee's resolution of weakness identified in the ALARA program (See Paragraph 9).

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