IR 05000327/1990004
| ML20006G211 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 02/14/1990 |
| From: | Collins T, Potter J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20006G210 | List: |
| References | |
| 50-327-90-04, 50-327-90-4, 50-328-90-04, 50-328-90-4, NUDOCS 9003060037 | |
| Download: ML20006G211 (8) | |
Text
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r MEtt UNITED STATES
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g-REGION 11 -
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L kl If-ATLANT A, GEORGI A 30323 j
101 MARIETTA STREET,N.W
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.i FEB161990
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-Report-Nos.: :50-327/90-04 and 50-328/90-04
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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
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Facility Name:. Sequoyah 1 and 2
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-Inspection Conducted: Ja ry 22-26, 1990
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Inspector:
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D&te Signed
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. Approved by:-
O Jo W P. Potter', Chief
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Facilities Radiation Protection Section
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Emergency Preparedness and Radioloaical Protection Branch Division of Radiation Safety and Safeguards
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. SUMMARY Scope:
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ThisLroutine, unannounced inspection was conducted in the area'of the radiation
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= protection' program. and pre-outage activities in regard to the radiation
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protection program.
.Results:-
l The111censee's. radiation protection program continues to be effective in
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? protecting.the safety and health of station employees as - evidenced by
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interviews with licensee management, supervisors, and 1 personnel from station
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One licensee identified violation (LIV) was
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noted:
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Failure to have appropriate monitoring equipment when-entering high
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$88 IS0!< $$$h!7 h
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REPORT DETAILS
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Persons Contacted
Licensee Employees
- M. Cooper, Compliance Licensing Supervisor
- T. Flippo. Quality Assurance Manaoer
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- 0. Hickman, Radwaste Supervisor S. Holderfer, Health Physicist
- C. Kent, Radiological Protection Supervisor
- M. Palmer, Radiological Health Manager J. Stamey Health Physicist-J.-Stiegleman. Health Physicist
- M. Sullivan, Radioloaical-Control Superintendent
- K. Whittenbura Public Affairs J. Vince111, Radiological Controls Field Operation Supervisor
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' Other. licensee. employees contacted during this inspection included craftsmen, engineers. operators, mechanics, security force members, technicians, and administrative personnel.
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Nuclear Regulatory Commission P. Harmon, Senior Resident Inspector K. Jenison, Senior Resident Inspector D. Loveless Resident Inspector
- Attended exit interview 2.
Occupational Exposure, Shippina, and Transportation (83750)
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Organization and Manacement Controls
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Technical Specification (TS) 6.2. specifies minimum-plant staff and Final Safety Analysis Report (FSAR) chapters 12 and.13 also' outline further details on staffina.
The inspector reviewed the licensee's I
organization, staffing levels, and = lines of authority as they relate to the outage radiation protection program, and verified that the licensee. had no organizational changes which would adversely affect their ability -to impicment critical elements of their radiation protection program.
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The Radiological Control Superintendent had a staff of 99 in support
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of the radiological protection program at the station. Four general i
j supervisors are responsible for the routine operations of the l
radiation protection program which includes field operations, radwaste, ALARA, and dosimetry operations.
The licensee stated that
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they have 37 health physics (HP) technicians who are ANSI /ANS 3.1 -
1978 qualified and an additional 74 HP contract technicians will be L
assigned to support the upcoming Unit One Cycle Four (U1C4) refueling
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outage in' April 1990.
The inspector noted that' office. supervisors and staff were assigned to field operations, and that adequate vendor personnel will be available to support the VIC4 refueling outage.
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No violations or deviations were identified.
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External Exposure Control and Personnel Dosimetry:
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10 CFR 20.101(b) specifies the permissible radiation dose to the
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whole body to be entered on a NRC Form 4 or equivalent record prior-
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to allowing the individual to exceed the limits of 10 CFR 20.101(a).
'The inspector reviewed selected occupational exposure histories for
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individuals'who exceed the values in 10 CFR 20.101(a). The exposure histories were being completed and maintained as required by j
TS. 6.8.1 requires that written' procedures shall be established,
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implemented. and maintained in ' accordance with the applicable procedures recommended in Appendix A of Reaulatory Guide 1.33 Revision 2 February 1978, Section 7.e. Radiation Protection Procedures.
The. Inspector reviewed selected Auxiliary Building Radiation Work
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Permits (RWPs) for appropriateness of the radiation protection requirements based on work scope, location, and conditions.
During tours of the Radiation Controlled Area (RCA), the inspector observed the adherence of plant workers to the RWP requirements and discussed, the RWP requirements with plant' workers and Radiological' Control
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personnel at the job site.-
The inspector concluded that RWPs i
specified adequate controls and that workers were aware of these i
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controls.
No violations or deviations were identified.
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-Internal Exposure Control i
10 CFR 20.103(a) establishes the limits for exposure of individuals to concentrations of radioactive material in air in restricted areas.
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and requires measurements of airborne concentrations of radioactive materials in restricted areas and appropriate bioassays to detect and-
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assess individual intakes of radioactivity.
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The' inspector reviewed selected results of bioassays (whole body l
counts) and the assessments of individuals' intakes of radioactive material during January to December 1989.
The irspector determined by review and discussion-with licensee representatives that only one intake had slightly exceeded one percent of a maximum permissible organ burden (MP0B) for the period and the licensee's discovery of the intake was from random selection of persons working in areas where respiratory protection was not required. The licensee assigned the individual appropriate Maximum Permissible Concentration - Hours
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(MPC-brs) = for. the' period.
The inspector concluded that - the licensee's-actions were adequate and in accordance with regulations.
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10 CFR'20.103(b) requires that the licensee use process _ or other d
engineerino controls to_ the extent. practicable, to limit
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concentrations of radioactive material-in air to levels below that specified in Part 20. Appendix B. Table 1: Column 1, so that
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concentrations, when averaged over the number of hours in any week ~
"during which individuals are in the area, are less than 25 percent of-
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the specified concentrations.
During tours-of the RCA, the inspector observed the use of High Efficiency Particulate Air (HEPA) filters as process and engineering
controls to limit ' airborne radioactivity concentrations in the plant, and the inspector discussed these controls with Radiation
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Control personnel.
No violations or deviations were identified.
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' Control of-Radioactive Material and Contamination, Surveys and Monitoring The licensee is required by 10 CFR 20.201(b), 20.403, and 20.401.to perform surveys to show compliance with regulatory limits and to
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maintain records of such surveys.
TS 6.8 requires the licensee to-follow. written procedures, and the radiological control procedures further outline survey methods and frequencies.
.The' inspector observed during plant tours, several surveys being performed by ' the ' radiation control. staff.
The inspector raviewed selected RWPs and survey records to-determine if adequate controls
and monitoring by radiation control personnel occurred for the workers -
involved. No deficiencies were noted.
During plant tours, the inspector noted radiation levels and contamination survey results outside selected cubicles.
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inspector performed independent radiation level-surveys of selected
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areas and compared them to licensee survey results.
The inspector reviewed selected -survey records during December 1989 and January 1990 and. discussed these records with radiation control
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personnel and the methods used to disseminate survey results.
The inspector noted that at the end of 1989 approximately 25,184 square feet (ftr) or 10 percent of the RCA was controlled as contaminated.
The licensee's goal for 1989 was 10 percent.
L No violations or deviations were identified.
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HighRadiationAreas(HRA)
TS 6.12.1 requires in lieu of the " control device" or " alarm signal" required by Paragraph 20.203(c)(2) of 10 CFR 20, each HRA in which o
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the. intensity of radiation is greater than 100 mrem /hr but less than 1,000 mrem /hr shall be barricaded and conspicuously posted as a'HRA
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'and the entrance thereto shall be controlled by requiring issuance of r
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'a Special RWP.
Any individual or group of individuals permitted to
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enter such areas shall be provided with or accompanied by one or more of the followino:-
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A radiation monitorino device which continuously indicates the
. radiation dose rates,in the area.
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A radiation monitoring device which continuously integrates the
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dose rates in the. areas ~and alarms when a preset integrated dose
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An individual qualified in radiation protection. procedures who is equipped with a radiation dose rate monitoring device.
TS 6.8.1 requires that writtcn procedures shall be established,
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impicmented, and maintained in accordance with the applicable l
procedures reconsnended in Appendix A of Regulatory Guide 1.33 Revision 2 February 1978, Section 7.e.
Radiation Protection
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Procedures.
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Radiological-Control Instructions RCl-15, Section 5.3 requires in part that individuals entering a posted-high radiation. area shall
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have a dose rate meter, a dose warning device or a HP technician with
a radiation dose rate meter.
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i The inspector was informed by the-licensee that on January 18, 1990, a chemistry technician had entered. a posted HRA (Unit 2 Reactor Coolant Sample Station) without a dose rate meter required by
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RWP-90-0-00006-00-00.
The inspector discussed this event vith licensee representatives and reviewed the RWP requirements fer this task and. determined that the individual failed to comply with the RWP
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requirements for entry into the Unit 2 Reactor Coolant Sample
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Station.
The inspector also determined by discussion and review of Radiological Awareness Reports that this event was an isolated event and not an apparent progransnatic problem.
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The inspector reviewed the corrective actions taken by the licensee
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to preclude further events of this nature and concluded that the
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corrective actions were adequate to prevent recurrence. -
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inspector informed-licensee manacement representatives that this event' met the requirements of-10 CFR' 2 Appendix C, for licensee identified violations (LIVs); for failure to ensure personnel have the appropriate monitoring devices when entering HRAs, therefore, no violation would be issued.
The inspector informed licensee manacement representatives that this event would be tracked as a Non Cited-Violation (NCV) and reviewed again during subsequent inspections (NCV:
50-327 and 328/90-04-01).
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As Low As Reasonably Achievable (ALARA)' Program
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10 CFR _20.1(c) states that persons ' engaged in activities under a-
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license issued by the NRC should make every reasonable effort to maintain radiation exposures ALARA.- The recomended elements of an
ALARA program are contained in Rt.gulatory Guide 8.8, "Information -
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Relevant' to Ensuring the Occupational Radiation _ Exposure at Nuclear
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Power Stations will be ALARA." and Regulatory Guide 8.10. " Operating Philosophy for Maintainino Occupations Radiation Exposure ALARA."
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.The inspector ' discussed the ALARA goals and objectives for 1989 with licensee representatives and reviewed the person-rem estimates and results._ The' licensee's goal for 1989 was set at 625 person-rem or
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approximately 312.5 person-rem per unit.
As of December 31, 1989, the licensee's actual collective exposure was 706 person-rem.
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i reason the licensee exceeded their projected coal was an exposure
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over run during -the Unit 2 Cycle 3. (U2C3) refueling outage. -The
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following is a detailed outline of exposures expended and explanation-i for exceeding the original estimates.
Exposure Over Run (U2C3)
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Steam Generator: Activities with 27 MAN-REM l
Hicher Than' Expected Dose Rates First-Time Nozzle Dam Use
Nozzle Dam Leakage
I Increated Radcon Surveillance t
Additional. Laborer Support i
Unplanned Upender Repair 23 MAN-REM
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Transfer Cart Rails Bent
I Transfer Cart Binding
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Unplanned Flushing Decon Shielding-L
Unplanned RX Head Work 6 MAN-REM (
L Frozen Stud
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L Detensioner Lockup-In Service Inspection 10-REM Dose Rates 2-3 Times Higher Increased Sampling Mods / Repairs Not Estimated
Unplanned work resulting
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from access problems, broken L
equipment, etc.
- Inadequate plannino
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l Unplanned RCP Seal Line Repair 6 MAN-REM-l Engr. Design Inadequate Piping Misa11gned Rework Piping Supports
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Leaking Conoseals 6 MAN-REM Wrong Gaskets Lubrication Error-Snubber Work 5 MAN-REM
Inexperienced Workers Work Requests Not Preplanned Hicher Dose Rates
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- Locating Snubbers
RX Cavity Transfer Canal 5 MAN-REM
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Decon Contamination Effort Higher Than Expected
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The licensee has taken _the following corrective actions-to reduce-collective exposure for future outages and routine operation.
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Site ALARA Committee Chairman directed that all tasks estimated
to be five man-rem or greater will be reviewed by the site ALARA committee, rather than only estimates of 10 man-rem or greater.
Site ALARA Committee Chairman directed all organizations to
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. report tn the ALARA Comittee why man-rem for U2C3 was over or i
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under expected estimates.
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' Site ALARA Comittee is to review and approve all walk down
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requests proposed for the-Unit 1 Ice Surveillance-outage..
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Prepare procedure for. opening and venting primary systems which-'have the potential for airborne' concerns.
UHI and RTD. Removal Scheduled for VIC4
Surrogate Tour Video Training RadWaste System Up Grade d
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Proactive Plant Wide Decon Program RCP Seal Cartridge Notification
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Instrument Port Conoseal Modification The inspector reviewed ALARA evaluations for selected major jobs performed during 1989, and attended'several pre-job planning meetings
.for the upcoming UIC4 refueling outage in April 1990. The inspector observed the ALARA considerations for these tasks and determined that
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the license's controls for maintaining exposures ALARA were adequate.
No violations or deviations were identified.
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Exit Interview
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The inspection scope and findings were summarized on January 26, 1990,-
with those persons indicated in Paraaraph 1.
The inspector described the areas examined and discussed in detail the inspection findings listed below.
The licensee did not identify as proprietary any of the materials-provided to or received by the inspector during the inspection.
Item Number Description and Reference 4-
-i 50-327, 328/90-04-01 I:CV - failure to ensure a individual had appropriate monitoring devices when entering HRAs (Paracraph 2).
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