IR 05000327/1989005

Special Team Insp Repts 50-327/89-05 & 50-328/89-05 on 890131-0209.Violations Noted.Major Areas Inspected:Radwaste, Radiological Controls,Corporate QA Audits & Site Chemistry

ML20247F346
Person / Time
Site:	Sequoyah
Issue date:	03/13/1989
From:	Adamovitz S, Marston R, Potter J, Shortridge R, Testa E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20247F334	List: IR 05000327/1989005 ML20247F330 ML20247F340 ML20247F346
References
50-327-89-05, 50-327-89-5, 50-328-89-05, 50-328-89-5, NUDOCS 8904030414
Preceding documents:	ML20247L931 (15 May 1989)
Download: ML20247F346 (23)

Text

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UNITED STATES .

,g ; NUCLEAR REGULATORY COMMISSION .

o '* REGION 11 101 MARIETTA ST., e,,,. ATLANTA, GEORGIA 30323 MAR 161989 Report Nos.: 50-327/89-05 and 50-328/89-05 Licensee: Tennessee Valley Authority i

'6N38 A Lookout Place c 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: January 30-February 3, and February 8-9, 1989 j Inspectors: b 8, E. D. Testa

, ) I////YP Da~te Signed ;

fY S. S. Adamovitz v

] Ph9 tate '51gned

? 3bYP9 R. rston Date Signed W

RF B. Shortri ge

$ $1 D/tvSigned Approved by: J ff J.47. Pottar, Chief D6td Signed .

Facilities Radiation Protection Section l Emergency Preparedness and Radiological  !

Protection Branch Division of Radiation Safety and Safeguards SUMMARY

Scope This was a special, unannounced team assessment / inspection in the areas of Corporate and Site nuclear chemistry, radioactive waste, radiological controls and Corporate Quality Assurance (QA) audits. Unit 1 was operating at 100 percent (%) and Unit 2 was approximately 16 days into a refueling outag Results The licensee's radiological controls program appeared to be sound and improving. The use of remote handling tools for steam generator nozzle dam i installation was a positive step in controlling worker dose as low as

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reasonably achievable (ALARA).

g4030424890316 G ADOCK 05000327 PNU l

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Corporate. QA audits in the areas inspected appeared detailed and complet Positive steps were being implemented to reduce the number of standing general Radiation Work Permits (RWPs). The licensee corporate and site staffs appeared knowledgeable and sensitive to established goal 'Within the areas inspected, one violation was identified for failing to perform an adequatt radiation survey necessary to evaluate the extent of radiation hazards present prior to operator entry (Paragraph 11).

Six inspectnr followup items (IFIs) were identified:

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Worker comfort problems associated with supplied breathing air (Paragraph 9).

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Evaluation of breathing zone air samples versus general air samples for respirators (Paragraph 9).

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Expansion of the identification of specific categories of event root causes tc provide better data for evaluations and analysis (Paragraph 10).

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Unexpected high beta dose rate in the steam generators (Paragraph 12).

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Unexpected high airborne iodine concentrations in the containment (Paragraph 13).

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Labels for clean laundry containers to distinguish them from dirty laundry shipments into and out of the same plant location (Paragraph 14).

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REPORT DETAILS Persons Contacted Licensee Employees

• Aslinger, Assistar.t Site Representative for Employee Concerns

• J. Barker, Manager, Rad Con J. Bates Manager, Corporate Chemistry Support Group

• H. Blair, QA Specialist NQA 3 S. Bradley, Shift Supervisor Radiological Health

• J. Bynum, Vice President Nuclear Power Production

• R. Coleman, Radiological Assessor

1. • M. Cooper, Compliance Licensing Supervisor

• P. Crabtree, Shift Operations Supervisor J. Dills, Quality Assurance Specialist - Corporate

• A. Dyson, QA Evaluator /QSS

• G. Fizer, Chemistry and Environmental Superintendent R. Halton, Assistant Site Representative for Employee Cuncerns

• R. Hays. Radwaste Processing Coordinator

• LaPoint, Site Director

• M. McMilland, Maintenance / Rad Con Work Coordintor

• J. Patrick, Operations Superintendent

• T. Phifer, Plant Reporting Engineer W. Raines, Chief, Environmental Radiological Monitoring and Instrumentation Branch

• H. Rogers, Plant Support Superintendent

• V. Shankes, Program Manager Chemistry B. Smith, Quality Assurance Auditor

• J. Smith, Plant Reporting Supervisor

• S. Smith, Plant Manager

1. • S. Spencer, Licensing Engineer

• Sullivan, Superintendent, Radiological Controir

• K. Walker, Quality Evaluator

• J. Watts, Quality Evaluator Other licensee employees contacted during this inspection included engineers, operators, mechanics, technicians, and administrative personne Nuclear Regulatory Commission

1. J. Brady, Project Engineer, TVA Projects Division

• P. Harmon, Senior Resident Inspector  ;

l #L. Watson, Section Chief, TVA Projects Division

• Attended exit ir.terview

1. Participated in teleconference briefing on February 9, 1989

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2 Licensee Action on Previous Enforcement Matters

.This subject was not addressed during this inspectio . Radiation Protection, Plant Chemistry, Radwaste and Environmental:

Organization and Management Controls (83522) Water and Waste Processing Group The inspector discussed the organization, responsibilities, and operations of the Water and Waste Processing Group (WWPG) with cognizant licensee representatives, reviewed pertinent documentation, and examined the facilities and equipment used by the Grou The inspector determined that WWPG Supervisory personnel met the qualifications specified in their position description The Manager, Water and Waste Processing, reported to the Plant Operations Superintendent who, in turn, reported to the Plant Manager. The WWPG was divided into five subgroups which:

Managed, directed, and supervised packaging, loading (radwaste only), storage, and shipping of all radioactive materials and radwast Directed development and implementation of the decontamination progra Directed the ir.plementation of radwaste minimization programs and radwaste segregation and storage, and prepared shipping document Provided technical support to other operations and engineering staff Managed the technical and water processing units of the WWP Licensee representatives stated that the current approved level of 69 people in the Group was scheduled to be reduced to 59. A licensee representative stated that the losses would be spread through the Group so as to minimize the reduction-in-force impac The inspector reviewed Standard Practice, SQA129, Site Goals and l

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Objectives, Sequoyah Nuclear Plant, for Fiscal Year (FY) 1988, and reviewed the WWPG Performance Measure / Goal for FY 1989. The Group l goals appeared to implement the Plant goals. Specific goals for WWPG ,

(FY1989)were: )

Ship no more than 8,736 cubic feet (ft3) per unit of Dry Active i Waste (DAW) during the fiscal year.

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Ship no more than 1,300 ft3 per unit of resins, sludges, and evaporator bottoms during the fiscal yea Release an average of less than 550,000 gallons per month of Liquid Radioactive Effluents during the fiscal yea Licensee representatives stated that the Group had identified its most significant problems and had developed corrective actions to solve them. Projected personnel reductions and the current outage made the completion schedule uncertai The inspector toured the accessible parts of the radwaste processing and storage systems, and discussed systems' operation and training with systems' operators and supervisors. The personnel appeared to be knowledgeable on the systems and their operatio The inspector reviewed audits, surveillance, and evaluations of the radwaste program conducted within the past year. The audit program appeared to be thorough and in-depth. Corrective actions, where required, appeared to be appropriate and timely, b. Site Radiologic:1 Controls Group The inspector discussed the organization, responsibil4 cies, and operation of the Radiological Controls Group (Rad Con) with cognizant licensee representatives, reviewed pertinent documentation, and examined the facilities and equipment used by the Grou The inspector determined that Rad Con Supervisory personnel met the qualifications specified in their position descriptions. The Rad Con Supervisor had been at the site in this position sin e June 1988. He had worked in the corporate office and various nucir.ir power plants prior to his current job assignmen The Radiological Controls Superintendent reported to the Plant Manager. The Rad Con group was divided into four subgroups which were called and were responsible for:

Radiological Protection - Technical Support including ALARA Radiological Health - Balance of Plant Field Operations - Shif t Coverage Administration and Health Physics (HP) Information -

Administration and Reports Licensee representatives stated that they were operating at the current approved manpower level of 91 people in group. The group had identified its most significant problems and had developed aggressive action plans to solve the __ - __ - _ - .

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c. Site Chemistry Department l

The Chemistry Department was managed b.v a Chemistry and Environmental Superintendent who reported directly to the Plant Manage The department was divided into four sections which included Environmental, Chemistry Control, Technical Support, and Process Control. Staffing for the department totalled 48 personnel including supervisors and staff. Ten additional positions, which were to be divided among the various sections, had been cancelled due to TVA's reduction-in-forcc plan The inspector reviewed a series of position descriptions which defined the minimum qualifications, responsibilities, and primary functions of each position in the department. Minimum qualifications for chemistry supervisory personnel generally required a bachelor's degree in an associated engineering or scientific discipline and four years related experience. A review of individual resumes showed that the related work experience for the superintendent and the four section supervisors totaled 83 year In general, the licensee appeared to have a dedicated, knowledgeable staff concerning chemistry matter Additionally, the technical support staff was available to assist in the resolution of special problems and to evaluate data concerning plant parameters. The chemistry staff had been reduced by the reduction-in-force cuts; however, current staffing was considered adequate to maintain the regular program but not to accomplish planned long-term goals. The department had issued a " Chemistry Improvement Program," and the assigned due dates were based upon the additional ten staff positions which had been eliminated. The current level of staff was considered insufficient to achieve the original due dates and, at the time of this inspection, the licensee had not rescheduled the dates based on the reduced staff. The chemistry count room had seven analysts to maintain 24-hour coverage and this resulted in the back shift being manned by a single individual. The count room had arranged for a temporary assignment of two Watts Bar technicians to alleviate the I aNitional work loads caused by outage sampling. The count room supervisor also explained that, if required, low level activity samples could be sent to the Training Center for analysis should the count room became too backlogge Chemistry management exhibited a positive attitude toward identifying and correcting program weaknesses. Chemistry program improvements and goals for the FY 1989 had been documented in the plan " Chemistry Goals and Performance Indicators for Fiscal Year 1989." This plan covered management improvement, quality performance, program improvements, and safe and efficient operatio Management improvements included additional training and timely performance appraisals. Quality performance goals involved conducting chemistry operations in such a manner as to minimize the number of INP0 findings or NRC violations, to quickly address any problem areas,

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and to evaluate causes of recurring problems. To assist in problem }

identification, the chemistry department had initiated a " Chemistry i Group Observation Program." These observations would serve as an additional, informal audit progra The department had also established an observation schedule. The schedule covered selected l plant systems for sampling and analysis, instrument calibrations, onsite chemical controls, and Post Accident Sampling System (PASS)

operatio Other general program improvements detailed in the " Chemistry Goals and Performance Indicators" included incorporating the use of the Nuclear Data Microvax system for gamme spectroscopy, effluent management, and chemistry database management; establishing a chemistry control program to monitor and trend plant parameters; providing technical expertise to eval" ate and implement chemical treatments of various plant systems; ar.d improving control of the facility's solid waste disposa The chemistry department had also identified a series of long-term goals which were summarized in the "Sequoyah Chemistry Improvement Program." The Improvement Program identified eight areas which included standards development, online instrumentation upgrade, QA/QC program development, procedures upgrade, Microvax program development, chemical traffic control program, training upgrade, and equipment deficiency corrections. Generally, the goals established by this program were broader based than the specific improvements identified in the " Chemistry Goals and Performance Indicators for Fiscal Year 1989," and some due dates extended beyond the current fiscal yea Chemistry management indicated that the due dates for the Improvement Program were based upon the additional ten positions which had subsequently been eliminate Based upon the reduced staff, reevaluation of the due dates would be necessary and some program improvements would be necessarily postponed or eliminated. However, the licensee management also indicated that the program in.provements identified in the " Chemistry Goals and Performance Indicators" were based upon the current staff level and that the goals were considered attainable during the originally established time periods. From the broader based improvement plan, procedural upgrades had been initiated for approximately 50 chemistry instructions or procedure No violations or deviations were identifie . Post Accident Sampling System (84750)

The licensee's liquid Post Accident Sampling System (PASS) contained inline monitors 1or chemistry parameters and utilized diluted or undiluted grab samples for radioisotopic analysis. Inline measurements for chemistry parameters included dissolved oxygen, pH, conductivity, hydrogen, and chloride concentrations. Currently, due to the design of a

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the PASS isolation valves, both units inust enter a Limiting Condition for Operation (LCO) in order to use the system. A design change request had been initiated to modify the PASS so that the system could be operated without entering an LCO. Due dates for the design changes were April and October 1990 for Units 1 and 2, respectively. Other scheduled modifications for 1989 included replacing the PASS flow indicators and modifying the PASS tubing to allow sampling of the reactor coolant off-gas >

for hydroge No violations or deviations were identifie . Corporate Radiological Control (83522)

Corporate Radiological Control was composed of four departments. The departments were Environmental Radiological Monitorinq and Instrumentation, Radiological Heal th, Radiological Prote' lon, and Radiological Waste. The organization was composed of a staf* mnager, two site Radiological Assessors (Sequoyah and Browns Ferry), 42 me ers of the Environmental Radiological Monitoring and Instrumentation Department, nine members of the Radiological Health Department, nine members of the Radiological Protection Department and 13 members of the Radwaste Operation Department. Corporate Radiological Control was established to interact with the sites to develop standards, guidance and procedure The function of the Instrumentation Calibration, Repair and Control Department was described by the licensee. This department calibrated, maintained, and provided inventory control for all portable radiation survey instruments. The purchase of new or replacement instruments and the maintenance of a central instrument' inventory were provided by this department. The department also performed the environmental radiological monituring program which included the design, review, and reporting of sample dat The function of the Radiological Health Department was described by the licensee to cover three major area They were external dosimetry, internal dosimetry, and an integrated HP information system. The external dosimetry program was National Voluntary Licensee Accreditation Program (NVLAP) accredite The licensee described the functions of the Radiological Protection departmen The principal missions of the department include: planning and developing radiation protection policy, providing technical support to the site, and conducting a corporate assessment program to evaluate program effectiveness and consistenc The mission of the Radioactive Waste Department was described by the licensee. The department was tasked with the support of the sites in processing, packaging, transportation, and disposal of solid radioactive waste and processing, and packaging and decontamination of radioactive waste materials. Program assessment was a secondary mission.

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The inspector reviewed selected site support activities provided by the corporate support group and found active, aggressive program interaction The inspector verified portable survey instrument calibration and maintenance through discussion with licensee site personne The inspector also reviewed selected portions of the Radioactive Material Shipment Manua This manual outlined responsibilities, packaging and l shipping requirements, training, quality assurance and administration and i

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state and disposal site requirements. The licensee discussed the support of Sequoyah restart stating that approximately 202 man-days of effort from ,

the Radiological Protection Department were expended during 198 Personnel from the Radiological Protection Department were routinely assigned to the site Radiological Control organization to provide suppor Two personnel were assigned to the site during the current outag '

The inspector reviewed the FY 1989 Operating Plan and selectively discussed the goals and status of Performance Measures (goals). The program appeared aggressive, forward looking, accountable and the l personnel knowledgeable about current site refuelina activitie No violations or deviations were identifie . Corporate Chemistry (83522)

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The licensee discussed the corporate support for site chemistr Corporate support was derived from Nuclear Support Chemistr The l organization was staffed by a Chemistry and Environmental Manager who was supported by six Program Managers and six Project Managers. Chemistry Level 3 goals for FY 1989 had been established and the performance in those areas was tracked. Measurable objectives to assure accomplishment of goals were in place. The inspector reviewed the position descriptions and responsibilities outlined for the Chemistry and Environmental Protection Manager (PD NS-03-006). The licensee discussed the Draft Chemistry Assessment Progra The program consisted of periodic assessments of site chemistry and chemistry training programs and was performed by the corporate office.

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The inspector selectively reviewed the resumes and work histories and found a broad base of experience in major nuclear power plant chemistry areas, including auditing, procedure development, program evaluation, and program managemen Interviews and discussions with selected members of the staff indicated involvement with the site chemistry program; however, at the time of the inspection, the corporate organization was not fully aware of the unexpected levels of beta activity found in the Unit 2 Steam Generators opened during the current refueling outage. Discussion with both site and corporate personnel indicated that there was less than open and free communication links established between the site chemistry and the corporate chemistry support group. The need for better communications was an area of concern in the February 17, 1988 Corporate Evaluation of the

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Site Chemistry Program. The communication concern involved both corporate and site chemistry program The inspector selectively reviewed the Corporate Sequoyah Chemistry Audit and Assessments Results for 1988, and found them to be detailed, in-depth, with identified weaknesses tracked. The audits involved procedures, organization, and communicatio No violations or deviations were identifie . Corporate / Site Quality Assurance (83522)

The inspector reviewed the qualification and training of the Corporate QA staff who performed quality assessment audits of Sequoyah Nuclear Plant in the area of Radiological Protectio Selective review of the resumes and audit certification records indicated substantial technical experience in the area of health physics, including practical job experienc The inspector selectively reviewed and discussed the following audit reports:

SS-A-88-805, dated March 1988, QA Program Radiological Control SS-A-88-808, dated June 1988, Radwaste Shipping, Radwaste Storage, Process Control Program and External Radiation Control Program SS-A-88-815, dated August 1988, ALARA Program, HP Training and Staff Qualifications SS-A-88-901, dated January 1989, Radiological Effluent and Environmental Monitoring and Dose Assessment Activities The inspector determined that the audits were detailed, in-depth, and adequately tracked identified item The licensee's chemistry program wt, evaluated by a series of onsite and corporate audits. The inspector reviewed selected audits for calendar year 1988 which included the following audit reports:

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Sequoyah Inspection / Audit Summary for 1988 Corporate Assessment of Sequoyah Nuclear Plant Chemistry Program conducted May 23, 1988 to June 10, 1988 Sequoyah Chemistry Data Management Assessment, and Corporate Monthly Reports for the months of October, November, and December 1988 The audits appeared thorough and the auditors knowledgeable of the various program areas. Identified problems were tracked and corrective actions _

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were documented and thoroug Programmatic weaknesses were also )

identified and specific examples given. The Technical Support Section was

, implementing a program to " observe" chemistry activities including sampling, analysis, system operation, instrument calibration, and laboratory housekeepin These observations would provide an additional internal assessment of the plant's chemistry progra No violations or deviations were identifie . Radiation Protection, Plant Chemistry, Radwaste, Transportation and Environmental: Training and Qualifications (83523)

The inspector reviewed the training program established for the Radiation Control, Chemistry, and Water and Waste Processing Group The requirements for the training program were specified in Administrative Instruction Al-14, "Sequoyah Site Training Program," Revision 40, October 24, 198 This document included training and retraining requirements for Managers, Operators, Scientists, Engineers, and Technicians in the specified Groups. The training was broken down into classroom and on-the-job training and required written and oral test The training programs for all levels of the Radiation Control and the Chemistry Groups were specified in detail. The Radiochemical Laboratory Analyst training was specified to be 14 weeks in the classroom and 90 weeks on-the-job-trainin The Rad Con Technician training was specified as:

Basic Phase - 16 weeks, consisting of 10 weeks of Core training and six weeks of Specialized (Field Operations, Dosimetry, or Instrumentation / Respiratory Protection)

In-Plant Phase - 24 months The Technical Staff and Managers Training consisted of:

Orientation (four weeks)

- Systems (two weeks)

- General Topics (two weeks)

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Advanced Phase (24 weeks)

- Segment I (17 weeks)

- Detailed Systems Study (eight weeks)

- Applied Fundamentals on Theoretical Topics (seven weeks)

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- Comprehensive Exams (one week)

- SegmentII(sevenweeks)

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It was noted by the inspector that the training programs evaluated placed emphasis on systems knowledg Several lesson plans used by the training staff in training Chemistry and Rad Con personnel were reviewed and were determined to be adequat Administrative Instruction AI-14, Part II.E., specifies Unit Operator and Assistant Unit Operator training and retraining requirements, and lesson plans were reviewed for Decontamination Worker training. Licensee representatives stated that, when it was determined that training was needed, such as packer / loader or shipping / handling, the Water and Waste Processing Group would notify their corporate counterparts, who would arrange for the training to be provide Licensee representatives provided the inspector with a recently developed matrix showing training requirements for Managers, Engineers, AU0s, A0s (Auxiliary Operators), and 00s. They stated that this program for training and retraining would be implemented in the futur No violations or deviations were identifie . Internal Exposure Control and Assessment (83525) Engineering Controls and Respiratory Protection During the inspection, the inspection team observed licensee personnel response to an apparent problem with the breathing air syste On Monday, January 30, 1989, personnel involved with the installation of nozzle dams in steam generators #2 and #3 using robotics, complained that air supplied to their bubble hoods was inadequat An Instrumentation / Respiratory Protection technician entered containment to verify that the air manifold pressure gauges were set correctl The technician found no problems with the pressure settings. On Tuesday, January 31, 1989, the personnel working the steam generator continued to complain about not enough air to the bubble hood and also complained about being hot. The Superintendent of Radiological Control instructed the Instrumentation / Respiratory Protection (I/RP) group to increase air hose lengths to 100 feet, in order to increase the pressure setting, and possibly increase the air flow to the bubble hoods. This did not resolve the problem. The workers were still complaining about insufficient air to the bubble hood and being hot on Wednesday. The I/RP group entered containment to verify that there was proper flow of air at the end of the breathing air hose that attached to the

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bubble hoo In addition, pressure settings and air flow were checked on every breathing air manifold in containment. All data ,

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collected were within the ranges specified by the National Institute l of Occupational Safety and Health (NIOSH), as required by 10 CFR,

! Part 20, Appendix A, Protection Factors for Respirators, footnote At this point, the I/RP group came to the conclusion that the problem was not insufficient air pressure to the bubble hoods and agreed to do whatever possible to ir. crease worker comfort. On Thursday at the 7:30 a.m. outage status meeting, the plant manager stated that he was not satisfied with the progress made in resolving the breathing air problem and instructed the I/RP group to go out and " crank up" the air pressure on the breathing air manifolds. The Superintend e t of ,

Radiological Controls, a member of the NRC Assessment Team, and two '

members of the I/RP met with the plant manager in his office at 8:00 a.m. that morning. The Superintendent of Radiological Protection explained that, although the pressure gauges on the breathing air manifolds have locked, anti-tampering devices, that someone had previously turned a pressure regulator up to 75 psig, above the 45 psig NIOSH certification limit for a 100-foot hose, and for that period of time the air pressure was at 75 psig, protection factors were not taken. Also, that the pressure gauges on the manifolds were at the limit for the NIOSH certification and to increase air pressure beyond this limit would violate the NIOSH certification and result in a violation of 10 CFR Part 20 NRC regulations. The Plant Manager stated that steam generator personnel were getting sick and were hot and that worker comfort was his major concer The inspector informed the Plant Manager that increasing the air manifold pressure was a safety concern in that a bubble hood could be blown off a person's head and result in possible personnel injury and that the problem appeared to be one of heat stress. As a result of the potential of violating NRC requirements for breathing air, the senior resident inspector (SRI), NRC Assessment Team Leader, and Assessment Team Inspector attended a meeting with the Site Director and Plant Manage During the meeting, the plant manager stated that he did not intend to violate NRC regulations and apologize The NRC Assessment Team Inspector ' evidenced a concern that this event may have intimidated radiological control first line supervisio The NRC inspector discussed this issue with six first line supervisor The majority responded that the cressure to meet schedules did exis Later in the afternoon on Thursday, the decision was made to monitor the breathing air manifolds and increase air pressure after bubble hoods were donned. This resulted in an increased flow rate of approximately 20% while monitoring NIOSH flow rate and pressure limit The inspection team informed the licensee that the corrective actions taken would be reviewed during a subsequent inspection and would be identified as IFI 50-327,328/89-05-01.

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12 Air Sampling 10 CFR 20.103 establishes the limits for exposure of individuals to concentrations of radioactive materials in air in restricted area Section 20.103 also requires that suitable measurements of concentrations of radioactive material be performed to detect and evaluate the airborne radioactivity in restricted area The inspector observed the preparation of a high integrity container (HIC) for dewatering and the installation of dewatering equipmen The operation was performed in the 706-feet elevation railroad bay in accordance with RWP 89-0119 and procedure RHSI-6, Radwaste Handling and Shipping Instructions. Installation of the dewatering equipment, on the HIC reading 50 rem per hour, was performed using good ALARA and radiological work practices. Prior to opening the HIC, a Rad Con technician started a general area air sample that ran for the duration of the 30-minute operatio The air sample was located approximately 25 feet from the work area. Licensee representatives stated that airborne radioactivity had not been encountered during previous dewatering operations and that instructions in the pre-job briefing specified a general area air sample instead of a breathing zone (BZ) air sample. The inspectors discussed the advantages of evaluating BZ air samples taken for short durations during a job, involving highly contaminated components, with licensee representative The licensee agreed to evaluate air sampling requirements in HPSIL-6, Airborne Radioactivity Survey The inspectors informed the licensee that-this would be reviewed during subsequent inspections and would be tracked as IFI 50-327, 328/89-05-0 No violations or deviations were identifie . Control of Radioactive Materials and Contamination, Surveys, and Monitoring (83526)

An inspector discussed the method used to identify and correct adverse trends for personnel contaminations with licensee representative The inspector reviewed the November 1988 monthly repcrt that trended a number of indicators of plant performance. The inspector noted that the trend of personnel contaminations did not reveal any adverse trends other than the number of people contaminate Radiolo Personnel Contamination Reports (PCRs)gical Control were tracked andpersonnel trended and stated a that trending analysis was performe When adverse trends were identified, corrective actions were coordinated with the responsible peopl The inspector reviewed a listino of personnel contaminations for one department at the station that identified the root cause of the contamination event and the type of even The trend report was sent to the department with a request for their corrective actions to prevent recurrence. This initiative was recent and results from various station departments could not yet be evaluated. The inspector noted that while the root cause of personnel contaminations were usually identified in the L____--____---_-_--_ _ - i

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PCRs, categories for event causes had not been developed and that trends to identify specific problem areas at the station could not be establishe Licensee representatives stated that they would consider expanding the identification of specific categories of event root causes to provide better data for evaluation and analyses and trendin The inspector notified the licensee that this would be reviewed during subsequent inspections and would be tracked as IFI 50-327, 328/89-05-0 No violations or deviations were identifie . External Occupational Exposure Centrol and Personal Dosimetry (83524)

10 CFR 20.201(b) requires each licensee to make or cause to be made such surveys as (1) may be necessary for the licensee to comply with the regulations and (2) are reasonable under the circumstances to evaluate the extent of radiation hazards that may be presen Technical Specification 6.12.1 requires that any individual or group of individuals permitted to enter high radiation areas in which the intensity of radiation is greater than 100 mrem / hour, but less than 1,000 mrem / hour shall be provided with or accompanied by one or more of the following:

(a) a radiation monitoring device which continuously indicates the radiation dose rate in the area, (b) a radiation monitoring device that continuously integrates the radiation dose rate in the area and alarms when a preset integrated dose is received, and (c) an individual qualified in radiation protection procedures who is equipped with a radiation dose rate monitoring devic The licensee notified the NRC inspection team of an unplanned exposure event at 4:00 p.m. on February 2, 1989. Licensee representatives stated that two AU0s were working in a high radiation area in Unit 1 auxiliary building that was created by an inadvertent introduction of reactor coolant or resin into the Chemical and Volume Control System (CVCS)

demineralized resin transfer pipin The licensee representative stated that the AU0s received doses of between 400 and 500 mrem and did not exceed any administrative or NRC exposure limits. The inspectors learned that the area was posted as a radiation area and that the workers did not have an integrating dose rate monitoring device or an individual present with a dose rate monitoring device to provide radiological protection job coverage. The event was in the preliminary stage of investigation and a description of the event would be provided as soon as possible. The inspection team leader informed the licensee that this event would be considered an unresolved iten. The inspection team noted that licensee's immediate corrective action was to post and lock the high radiation areas in the Unit 1 and Unit 2, 690 elevation pipe chase Radiation surveys revealed a contact reading on the piping for recirculating the refueling storage tank water at 3,500 mrem / hour and 750 mrem / hour at 18 inches in the Unit 1 pipe chase. A survey of the Unit 2, 690 elevation pipe chase revealed one hot spot on the piping of 2,500 mrem / hour and 500 mrem / hour general are _ - _ _ _ _ _ - _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _- . _ _ _ _ - _ - _ - _ _ _ - - _ _ _ _ - - - _ _ - - _ _ _

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The preliminary report of the event was received in Region 11 on February 8, 1989. The .'eport stated that two AU0s entered the pipe chase, that had been surveyed and posted as a radiation area on January 31, 1989, at 11:25 a.m. Two valves were opened for recirculation of the refueling water storage tank to accommodate a chemistry sample. At approximately 1:25 p.m., one of the AU0s in the 690 pipe chase read his self reading pocket dosimeter (SRPD) (0-200 mrem) and noted it was offscale. Both AU0s' SRPDs read offscale. Recirculation operations were secured one minute later and the AU0s exited the area and notified HP. One AU0's thermoluminescent dosimeter (TLD) read 430 mrem and the other's (TLD)

479 mrem. These readings reflected doses for the quarter; however, it was established that the majority of the AU0s' doses were received as a result of this event. Although the root cause of the unplanned high radiation area created in the piping for both units and the apparent loss of the cation demineralized bed has not Leen determined, the radiological aspects of the event have been identified. On February 9, 1989, the NP,C notified the licensee's regulatory compliance group by telephone that the unresolved items would be changed and would be considered an apparent violation (VIO) of 10 CFR 20.201(b) and Techanical Specification 6.1 for failure to adequately evaluate the radiation hazards present in the 690-foot elevation pipe chase in the Unit I auxiliary building (VIO 50-327, 328/89-05-04).

The inspector observed the remote installation of nozzle dams in the Unit 2 steam generator. The radiation dose rate in the steam generator were found to be as high as 150 Rad /hr beta and 10 R/hr gamma. The use of robotics and careful control of worker position in relation to radiation shield exhibited good ALARA work planning and prvctices. The licensee was analyzing material deposits to determine the isotope (s) causing the unusually high beta dose rate. The inspector notified the licensee that this would be reviewed during subsuquent inspections and would be tracked as IFI 50-327, 328/89-05-0 One violation was identifie . Radioactive Waste Systems; Water Chemistry; Confirmatory Measurements and Radiological Environmental Monitoring (84750) Liquid and Gaseous Radwaste Systems The inspector discussed liquid and gaseous radwaste systems with cognizant licensee personnel. Liquid effluent release points to the environment included the Liquid Radwaste System, the Condensate Demineralized System, the Turbine Building Sump, and the Units 1 and l 2 Steam Generator Blowdow Inputs to the facility's liquid radwaste system originated from the Reactor Building and the Auxiliary Building Floor Drains. The liquid then flowed to the Tritiated Drain Collector Tank (TDCT) and the Floor Drain Collector Tank (FDCT) which were currently interconnected. The original purposr; of the TDCT was to reclaim reactor grade water by routing the water to the TDCT for treatment by a filter-demineralized combination and then recycling, t _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .

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Nonreclaimable~ liquid whste would be collected in the FDCT for further processing and' final discharge. Future plans for the two tenks included installing isolation valves in the TDCT so that. the reusable water could be separated and the system's original intent 3 accomplishe From the FDCT, the liquid waste was processed by either the Condensate Demineralized Waste Evaporator (CDWE) or a andor-supplied radwaste system. Liquid flow was then routed to the Waste Distillate Tanks (A or B) and subsequently to the Monitor Tank or to the Cask Decontamination Collector Tank. Final release was accomp"ished via the Cooling Tower Blowdown line as a batch releas At the time of this- inspection, the licensee was implementing a program to evaluate a vendor demineralization system for.radwaste irrowsin This system would be considered as a possible '

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replacement for the CDWE.-

In order to maintain better control of plant water and waste. systems, the licensee was working on a water management plan that was scheduled for. implementation the end of calendar year 1989. The plan included a contracted water balance study of major plant system This water balance study would also identify liquid radwaste sources and equipment leak Radioactive waste streams-would be chemically che.racterized in order to evaluate the most efficient processing and disposal systems. Suitable systems would be tested inplant and possible alternatives to the present processing would be the final ste The licensee's gaseous effluent system utilized six monitored effluent vents which were the Service Building Vent, Auxiliary Building Vent, Shield Building Vents (Units 1 and 2), and the Condenser Vacuum Exhausts (Units 1 and 2). The Containment Vent exhausted via the Auxiliary Building Vent, and the Shield Building Vents exhausted gases from the waste gas header. Inputs to the waste gas header included nine Waste Gas Decay Tanks (WGDTs) and the Auxiliary Building Gas Treatment System ( ABGTS). The ABGTS and/or the Emergency Gas Treatment System (EGTS) had to be operated in order to discharge a WGDT. The EGTS could be used under routine or emergency conditions to draw vacuum in the annulus and exhaust to the Shield Building. Each WGDT had a design capacity of 600 ft3 l The inspector discussed with the licensee the capacities of the plant's radwaste systems to handle the additional effluents generated by outage conditions. The licensee indicated that the liquid and -

gaseous radwaste systems had been adequate to process outage effluents. No special equipment or additional storage had been required. Current levels in the various liquid process tanks were less than 50 percent of the tanks' capacitie The inspector reviewed selected procedures concerning radwaste system operation, sampling and effluent analysis. The procedures SI-400.1,  !

" Liquid Waste Effluent Batch Release," Revision 18; SI-401, " Steam i Generator Blowdown Continuous Release," Revision 16; and 51-410.4,

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" Waste Gas Decay Tank Release," Revision 6, clearly defined the division.of responsibilities between Chemistry and Operations. Upon request by Operations, Chemistry would initiate a release data package. Effluent sampling and analysis were performed by Chemistry personnel with Operations being responsible for actual valve line-up and tank release. The licensee also maintained a procedure, SI-544,

" Verification of Representative Sampling of Liquid and Gaseous Effluents," Revision 6, to demonstrate compliance with representative sampling technique An appropriate recirculation time for liquid tanks was determined to be the time required for recirculation of two tank volumes or for the total gamma activity to reach a steady stat For gaseous tanks, the total gamma activity of nuclides in the WGDTs was compared to gaseous effluents. Analytical methods were discussed in Technical' Instructions TI-11 and TI-12 for chemical and radiological analysis, respectively. The inspector determined that the reviewed procedures and instructions adequately described the licensee's program for radwaste die harge b. Effluent Monitors The inspector discussed process and effluent monitors maintenance and calibration with Instrument Engineers. Monitor calibrations were performed by the Instrument Maintenance Section, and functional checks were performed monthl Program modifications were being considered to change the frequency of performance checks for nontechnical specification monitors to quarterl The monitors required by technical specifications would maintain monthly check Licensee personnel indicated that recently there hadn't been recurrent maintenance problems with the monitors. In reviewing the Semiannual Effluent Report for the first half of 1988, the inspector noted that two monitors had been declared inoperable for periods greater than 30 days. The Turbine Building Station Sump Discharge Monitor, 0-RM-90-212, required a design change in order for the monitor to discharge directly to the Turbine Building Sump. This monitor was repaired and declared operable by March 2,1988. Flow indicators, FI-30-242, for Units 1 and 2 Shield Building Exhaust were declared inoperable in October and November 1987, respectively. The indicators could not measure exhaust flow rates of less than 8,000 fta per minute. Thus the licensee was using design flow rates of exhaust fans in operation to estimate exhaust rate The flow indicators had not been repaired as of the issuance of the January-June 1988 Effluent Repor The inspector accompanied licensee representatives on several plant tours during the week and examined several effluent monitors. The licensee had addressed the subject of unmonitored release pathways in  !

response to IE Bulletin 80-10 " Contamination of Nonradioactive 1 System and Resulting Potential for Unmonitored, Uncontrolled Release I of Radioactivity to Environment." Seven plant systems were identified as having the potential to become radioactive through

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interface with radioactive systems. These systems were monitored via a sampling progra Main Condenser The licensee had implemented an in-leakage reduction program for the main condenser during 1988 and had successfully reduced the Unit 2 ,

air in-leakage from 45 SCFM to an average of 5.1 SCFM for the fourth quarter 1988. The licensee was using the INP0 supplied values of 6.7 SCFM median and 4.0 SCFM best quartile as goals for maximum in-leakag Primary Water Storage Tank (PWST)

0xygen levels in the Unit 2 PWST were reported as being 2,000 to 3,000 ppb during 198 Plant specifications limit oxygen concentration to 100 ppb for reactor coolant system make-up wate The licensee indicated that the cause of the high levels of dissolved oxygen were inoperable diaphrams and had initiated a design change request, DCR-2701, to install a nitro Since the Demineralized Water Storage Tank (DWST) gen supplied blanke water to the PWST, a design change request, DCR-2801, was also implemented for a nitrogen blanket. Current dissolved oxygen levels for the DWST were 200 to 300 ppb. The licensee expected the changes to be completed during 1989, or the first part of 199 Component Cooling System The . Component Cooling System had reoccurring problems of excessive system leakage and required frequent additions of highly concentrated chemicals because of an ineffective chemical addition syste Originally, chemicals had been added through the drain pump casin The licensee changed this method to add chemicals through the surge tan Excessive system leakage had been minimizcd by a system walkdown and tightening loose valve The licensee had not

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experienced leaks in the heat exchangers since the latter part of l

1987, and these were plugged at that time. Since the heat exchangers were close to the plugging margin (10%) on the B and C loops, the licensee chose to replace the exchangers. The B heat exchanger for the B loop was being replaced during the current outage. The other two exchangers were scheduled to be replaced during the next two outage No violations or deviations were identifie . Outage Management Control The inspection team observed a number of events where licensee personnel failed to effectively communicate and/cr cooperate with approved outage plans. The following are examples of specific events identified by the inspection team to plant managemen _ _ _ - _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ .

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identified the need to perform air samples at four-hour intervals in l containment to locate the sources of airborne noble gas and iodine.

l Rad Con was not able to report on progress at the 7:30 a.m. planning meeting on Tuesday and, was instructed to get with chemistry and report back as to why this was not performed. Investigation revealed that . Rad Con and Chemistry were not in attendance -at the Monday planning meeting and that no instructions had been placed.in the Rad Con night order book to take the air samples. On Tuesday, Rad Con took 176 air samples to support routine outage operations and. to locate the sources of .the elevated airborne- iodine activit On Wednesday, Rad Con reported that the sources of airborne still~ had not been located and were instructed by plant management to continue '

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air sampling but to map the location of air sat:ples. On Thursday, airborne concentrations of iodine were still above the 1 MPC limit and .. personnel were still required to wear respirators into containmen The Plant Manager stated that 12 of the last 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> hed been lost due to high airborne in. containment and the inabil'ty to open the equipment hatch to move needed material into and out of-containmen The inspector informed the licensee that the higher than anticipated airborne radiciodine concentrations in the containment would be tracked as IFI 50-327, 328/89-05-0 On Thursday. Rad Con requested that 0perations ensure thet the equipment hatch was closed to within four or five feet from the floor prior to raising reactor vessel water from mid-loop. This was to be a precaution to ensure that negative pressure was maintained in containment and to minimize the possibility cf an uncontrolled release of airborne radioactivity to the environment. The inspecticu team learned on Friday that the reactor vessel water level was raised from mid-loop in preparation for reactor head removal, but the equipment hatch to Unit 1 was not partially closed. No uncontrolled release of airborne radioactivity to the environment had taken p'. ace, howeve No violations or deviations were identifie . Plant Tour The inspector, accompanied by the Superintendent, Radiological Controls, during a tour of the facility, noted that dirty and clean laundry was received and shipped from the railroad bay at the 706-foot elevatio Licensee workers were observed obtaining bags of clean hoods from shipping containers for clean laundry dress out inventory at the steam generator dressout facility. Although magnetic signs that indicated " clean laundry" l were available, they had not yet been placed on the containers. The licensee agreed to review the receipt and identification of clean laundry so that these containers are received and identified in a more timely manner. The inspector informed the licensee that this would be reviewed

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l during subsequent inspections and would be tracked as IFI 50-327, 1 328/89-05-0 No violations or deviations were identifie . Radwaste Solidification Incident Followup (92701)

After the licensee started processing the laundry and hot shower drain tank through the CDWE, it was discovered that the use of a laundry detergent (Turco 4324 NP) left a residue in the evaporator bottoms which caused an exothermic reaction when the vendor added stabilization, solidification, and defoaming agents to the waste bottoms in the liner This reaction led to an expansion and overflow of the contents in the liner. This occurred in May 1987. As an immediate corrective action, the licensee issued a memorandum in July 1987 to suspend the use of the cleaning agent "Turco."

During the inspection, the inspector, accompanied by a licensee representative, inspected Warehouse 1 The inspector discovered ten 5-gallon plastic containers marked "Turco." The containers were very dusty and some were tagged with tags which read, " Returned from Harcsville," and dated either August 1987 or September 1987. A licensee representative later stated that the "Turco" had been sent to Hartsville, and had apparently been returned. The licensee representative also stated that since the "Turco" had never been reentered on the computer, it would not have been issued for us No violations or deviations were identifie . Action on Previous Inspection findings (92701) (Closed) IFI 50-327/88-31-01: Followup on the inclusion of the topics, hot particles, and hot particle control into general employee training (GET) and continuing trainin The inspector reviewed the GET lesson plan GET 002.1-5, Controlled Areas and HP Retraining, '2.5 Level I retraining and determined that the subject of het particles had been included in instructions to workers. This item is considered close (Closed)IFI 50-327/88-04-03: Followup on development of a procedure to monitor for iodine during emergency condition The inspector reviewed Radiological Control Instruction 20, Radiciodine Monitoring During Accident Conditions. The instruction provided the operational requirements necessary for the protection of employees from airborne radiciodine during accident conditions. This item is considered close (Closed) IFI 50-327, 328/88-38-04: Evaluation of the Nonradiological Confirmatory Measurements result Nonradiological samples had been

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l left with the plant che.nistry group with instructions for each sample to be analyzed in triplicate by three different analysts (where possible). The analyses were completed by August 5,1988, and the results sent to the NRC on August 11, 1980. The NRC evaluated the results and sent them to the licensee in the Nonradiological Confirmatory Measurement Results Supplement to Inspection Report Nos. 50-327/88-38 and 50-328/88-38. This item is considered close . Followup on Employee Concerns Program The inspector followed up on an Employee Concern in the area of radwaste shipmen The concern dealt with the possible shipment of unsolidified resin bottoms to the licensed burial site. The time table of events of this concern were as follows:

December 9. 1908, concern received in Employee Concern Program December 9,1988, at approximately 12:20 p.m. management briefed on concern December 9, 1988, File ECP-88-SQ-Q45 opened January 5, 1989, Results of internal investigation received in Employee Concern January 5, 1989, upgraded to Concern ECP-89-SQ-020-01 January 26, 1989, Management Brief to Site Director Plant deportability investigations underway January 39, 1989, Senior level management briefing February 1, 1989, Conclusions and recommendation preparations Employee Concern was still in the process of completing the final report al.d awaiting management actio No final determination could be made by the inspector until the licensee completed the final report and appropriate management action had beer. take . Exit Interview The inspection scope and findings were summarized on February 3,1989, with those persons indicated in Paragraph 1. The inspector described the areas inspected and discussed in detail the inspection results listed belo Although proprietary material was reviewed during the inspection, proprietary information is not contained in this repor During a teleconference between NRC and licensee representatives on February 9, 1989, the licensee report on the AU0's entrance into the high radiation areas was discussed. Dissenting comments were not received from the license _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _

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Item Number Description and Reference 50-327, 328/89-05-01 IFI - Determine the cause of wearer comfort probit's during the use of hoods and supplied breathing air (Paragraph 9.a).

50-327, 328/89-05-02 IFI - Evaluate breathing air sample versus general air sample requirements in Procudure HPSIL-6, Airborne Radioactivity Surveys (Paragraph 9.b).

50-327, 328/39-05-03 IFI - Expand the identification of specific categories of events root causes to provide better data for evaluation and analysis (Paragraph 10).

50-327, 328/89-05-04 VIO - Failure to perform radiation surveys necessary to evaluate the extent of radiation hazards present prior to entrance of two AU0's into a high radiation area (Paragraph 11).

50-327, 328/89-05-05 IFI - Determine the cause of the higher than anticipated beta dose rates in the steam generators at shutdown (Paragraph 11).

50-327, 328/89-05-06 IFI - Determine the cause of higher that expected airborne radiciodine concentrations in the containment (Paragraph 13).

50-327, 328/89-05-07 IFI - Provide positive control of shipment and receipt of laundry (Paragraph 14).

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