IR 05000327/1990019

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Insp Repts 50-327/90-19 & 50-328/90-19 on 900423-27.No Violations or Deviations Noted.Major Areas Inspected: Radiation Protection Activities,Including Review of Licensee Organization & Mgt Controls & Training
ML20043D397
Person / Time
Site: Sequoyah  Tennessee Valley Authority icon.png
Issue date: 05/21/1990
From: Elliott M, Potter J, Shortridge R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20043D395 List:
References
50-327-90-19, 50-328-90-19, NUDOCS 9006070462
Download: ML20043D397 (7)


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UNITID STATES

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NUCLEAR REGULATORY COMMISSION

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REGION 18

,h 101 MARIETT A STREET.N.W.

  • e ATLANT A, CEDRGI A 30323

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  1. AY 2 4 1110 Report Nos.:

50-327/90-19 and 50-328/90-19 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 I and 2 Inspection Condu ted /

il 23-27, 1990

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Approved by:

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Facilities Radiation Protection Section Energency Preparedness and Radiological Protection Branch

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Division of Radiation Safety end Safeguards

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SUMMARY

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Scope:

This routine, unannounced inspection of radiation protection activities included a review of the licensee's organization and managenent controls, t raining, external and internal exposure ;ontrols, program to minimize

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exposure, surveys and control of radioactiie material,. transportation, and followup of previously identified inspection findings.

Results:

No violations or deviations were identified.

Based on interviews with l

licenseo management, supervision, personnel from radiation protection,

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records review, and observation of work, tle inspectors determined that the

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radiation protection program was adequate to protect the health and safety of the workers.

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9006070462 900524 DR ADOCK 0500

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REPORT DETAILS 1.

Persons Contacted Licensee Employees

  • W. Brooks, Engineer, Quality Assurance
  • J. Bynum, Vice President, Nuclear Power Production
  • W. Byrd, Manager, Project Controls and Financial Services
  • M. Cooper, Acting Manager, Site Licensing
  • T. Flippo, Manager, Quelity Assurance
  • C. Hudson, Manager, Corporate Radiological Controls
  • C. Kent, Manager, Radiation Protection
  • J. Osborne Health Physicist, Radiological Controls
  • M. Palmer, Manager, Radiological Health
  • J. Proffitt, Acting Manager, Compliance Licensing
  • W. Smith, Specialist, Quality Assurance
  • S. Spencer, Engineer, Licensing SJ. Steigelman, Health Physicist, Radiological Controls
  • J. Vince111, Manager Field Operations, Radiological Controls
  • C. Vondra, Plant Manager Other licensee employees contacted during this inspection included craftsmen, engineers, operators, mechanics, technicians, and administrative personnel.

Nuclear Regulatory Commission

  • P. Harmon, Senior Reside,1t Inspector

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  • S. Sanders, NRC Intern Program
  • Attended exit interview 2.

OccupationalExposure,ShippingandTransportation(83750)

a.

Organization and Management Controls Technical Specification (TS) 6.2 specifies minimum plant staffing and the Final Safety Analysis Report, Chapters 12 and 13 also outline further details on staffing.

The present Radiological Controls (Radcon) organization, staffing levels, and lines of authority related to outage activities were discussed with licensee representatives.

The Radcon superintendent had a staff of 97 in support of routine radiological operations at i

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the station.

To support the scheduled 64 day Unit One, Cycle Four (U1C4), refueling outage, the licensee staff was increased by 81 contract health physics (HP) technicians, 20 HP technicians from Browns Ferry Nuclear Plant, and three from Watts Bar Nuclear Plant.

Based on tours in Unit 1 Containment and Auxiliary Building to observe HP technician performance during job coverage, the inspectors determined that control of contract HP technicians was adequate and that the total HP staff had sufficient resources to adequately provide coverage for the scheduled work, b.

Controls The inspectors reviewed the licensee's Radiological Awareness Reporting (RAR) system.

The system was established to provide a method by which employees could make management aware of issues that affect the implementation and quality of the site Radcon program.

The inspector reviewed 40 RARs that had been issued in 1990 and

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determined that the system appeared to be functioning as intended and problems were being identified, investigated, and corrected as required, c.

Training and Qualification TS 6.3 requires that each member of the facility staff meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions.

Paragraph 4.5.2 of ANSI N18.1 stated that technicians in responsible positions were to have a minimum of two years working experience in their specialty.

The inspector discussed with licensee representatives, licensee (HP) technician continuing training and training required for

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HP contractor technicians prior to providing independent job

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coverage. A review of training records and schedules showed that the licensee had provided 346 hours0.004 days <br />0.0961 hours <br />5.720899e-4 weeks <br />1.31653e-4 months <br /> of training per licensee HP technician in 1989.

In April 1989, HP technicians were reorganized on six shifts.

This enabled the licensee to have one shift of HP technicians in training at all times (except during outages).

The inspectors reviewed the schedules for continuing training from August 1989 through September 1990, and noted that the schedule included training on systems, radiological containments, transportation and shipping, counting systems, industry events, and job coverage.

Licensee representatives stated that a training committee selects a majority of courses for continuous training based on request from HP techniciar,s.

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The inspectors reviewed resumes for contract HP technicians to determine qualifications.

The licensee requires that contract HP technicians who perform independently to be qualified to ANSI N18.1-1971.

Approximately 50 HP contractor technician resumes were reviewed to determine the persons qualifications for senior HP technician and correctness of job assignments.

No discrepancies were

dentified.

Licensee representatives stated that contractor HP technicians were given a pre-test to determine basic knowledge and 56 ills.

Upon successful completion of the pre-test, the contractor technician received a week of training that consisted of instruction in procedures and site specific requirements, and were then tested on the terminal objectives outlined in the lesson plan. Af ter successfully completing this portion of the training program, the technicians were given field assignmer ts.

The contractor HP technicians were then required to successfully complete on-the-job training modules applicable to their job assignment and have their qualification card updated, d.

External Exposure Controls The licensee was required by 10 CFR 19.13, 20.101, 20.102, 20.201(b),

20.202, 20.403, 20.407, and 20.408 to perform surveys, to maintain workers' rediation doses below specified levels, and to paintain reports of workers' r adiation doses.

The licensee was required by 10 CFR 20.203 and TS 6.12 to post specified areas and control access to these areas.

FSAR Chapter 12 also contained commitments regarding dosimetry and dose control.

The inspectors obsened work over a four day period in radiologically controlled areas (RCAs) of the plant Licensee personnel were observed wearing and monitoring electronic reading and self-reading pocket dosimeters as required.

Posting for radiation and high radiation areas were determined to be correct as verified by NRC radiation measuring equipment.

Locks were checked for securing locked high radiation areas with no discrepancies noted.

The inspectors reviewed NRC Form 5 data showing personnel exposures through April 24, 1990, and verified that the rcdiation doses recorded for plant personnel were within the limits of 10 CFR 20.101, e.

Internal Exposure Control The licensee was required by 10 CFR 20.103, 20.201(b), 20.401, 20.403 and ?0.405 to control intakes of radioactive material, assess such intakes, and keep records of and make reports of such intakes.

Based on record reviews and discussions with licensee representatives, the inspectors determined that, from January I to April 24, 1990, no individual received more than

Maximum Permis sible Concentration-hours (MPC-brs) in one week.

Licensee representatives

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stated that through random whole body counting (WBC) of 342 people in March, that 93 showed positive WBCs of which six were greater than one percent maximum permissible body burden (MPBB) with no WBCs greater than five percent.

The inspectors observed engineered controls to minimize the use of respiratory protection equipment; however, due to the potential for airborne contamination, respirators were required for decontamination work being performed on the refueling floor level of Unit I containment.

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Control of Radioactive Materials and Contaninetion Surveys, and Monitoring The licensee was required by 10 CFR 20.201(b) and 20.401 to perform surveys and to make records of such surveys necessary to show compliance with regulatory limits.

During plant tours, the inspectors examined radiation levels and contamination survey results outside selected rooms in the Auxiliary Building.

The inspectors readings compared favorably with survey results posted at the entry to each room.. The inspectors also reviewed radiation work permits (RWPs) controlling general and specific work.

The inspectors reviewed licensee data regarding contamination controls and noted that through April 25, 1990, the licensee had experienced 173 personnel contamination events (PCEs).

The licensee had a rate of 0.8 PCEs

?er 1,000 RWP hours worket prior to the start of the UIC4 outage but lad observed an increase in PCEs to 1.1 per 1,000 RWP hours during the outage.

Licensee representatives stated that 1.1 PCEs per 1,000 had been estab'ished as the station's average rate goal for 1990.

The inspectors loted that approximately 50 percent of the PCEs occurred in clean araas of the RCA.

Licensee representatives stated that area wipe downt and decontamination efforts had been increased in the clean areas to reduce the PCE rate.

Also, the FY 1990 station goal was to hive

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less than ten percent of contaminated controllable area.

In March,

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the licensee reported 22.919 square feet (ftr) of the 228,940 ft*

of RCA was contaminated.

Maintaining Exposure As Low As Reasonably Achievable (ALARA)

10 CFR 20.201(c) states that persons engaged in activities under a license issued by the NRC should make every reasonable effort to maintain radiation exposures ALARA.

The recommended elements of an ALARA program are contained in Regulatory Guide 8.8, "Information

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Relevant to Ensuring the Occupational Exposure at Nuclear Power

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Stations will be ALARA," and Regulatory Guide 8.10. " Operating Philosophy for Maintaining Occupational Radiation Exposure ALARA."

The inspectors discussed the program to maintain exposures ALARA with licensee representatives. The licensee had scheduled refueling /

modification outages for both units in 1990.

Currently the UIC4 outage was on day 40 of 64 and the ill day Unit 2

outage was scheduled to coneence on October 1,1990.

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daily status meeting updates and exposure data, the inspectors determined that the licensee was approximately one day behind in scheduled critical path work and had exceeded the outage and fiscal year (TY) collective dose goals.

Collective dose at tie station on

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April 27,1990 was 829 person-rem which exceeded the FY goal of l

685 person-rem, and the outage dose was 761 person-rem which exceed

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that goal of 575 person-rem.

Licensee representatives stated that l

an addition 100 person-rem had been approved making the FY goal 785 person-rem.

Also, an additional 100 person-rem was expected in the first 20 days of the Unit 2 outage scheduled later in the FY which would further increase the overrun.

Licensee representatives stated that a number of reasons contributed

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to the overrun of established goals.

The initial FY dose estimate'.

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based on the scheduled scope of work was 917 person-rem and the 1990 goal reconcended to corporate HP and upper management was S17 person-rem. Upper management adjusted and approved the station's collective FY dose goal of 685 person-rem but did not reduce the scope of work.

In reviewing 'the post-job ALARA reviews, the inspectors noted problems documented during the outage that indicated

that the outage workscope had been increased and unnecessar.y dose was being) acquired. The scope of eddy current work on steam generators (S/Gs increased from ten percent of two S/Gs, to 100 percent of four

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S/Gs.

Vendor equipment to repair S/G tube plugs installed by other vendors did not work initiall Reactor coolant puno removal and S/G cleaning (sludge lancing)y.were performed after the loops were drained; therefore, general area dose rates in these areas had increased by a factor of two.

Licensee representatives indicated that by draining the loops certain gains in the overall outage schedule may be realized which could offset the increased collective dose, but that any postulated dose cost or savings could not be determineduntiltheoutagewascompleted. The inspector determined that an assessment of the station s performance in maintaining collective dose ALARA would be made during a subsequent inspection when completed data are available, h.

Transportation of Radioactive Material 10 CFR 71.5 requires that a licensee who transports radioactive material outside the confines of its plant or other place of use, or who delivers licensed material to a carrier for transport, shall comply with all the applicable requirenents of the regulations appropriate to the mode of transportation of the Department of Transportation in 49 CFR Parts 170 through 18.....

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The inspectors selected records of radioactive waste shipments and material shipments performed during 1990.

The shipping manifests examined were prepared consistent with 49 CFR requirements.

The radiction and contamination survey results were within the limits specified for the mode of transportation and classification.

No violations or deviations were identified.

3.

Action on Previous Inspection findings (92701, 92702)

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(Closed) Inspector followup Item (IF1) 50-3?7, 328/89-?4-01:

followup on licensee review of corrective ections for work control practices that involve the potential for changing radiological conditions.

The licensee allowed work to continue on a valve that was under pressure and releesing noble gas.

After recognizing the problem, several breaches and subsequent noble gas releases were experienced prior to determining the root cause of the problem and securing the operation.

The licensee revised SQA186, " Root Cause Assessment for Adverse Actions / Conditions," Revision 6, dated March 9,1989, to provide e quarantii.e on a job where an investigation is underway to determine the problem and correct deficiencies prior to resuming work.

This item is closed.

b.

(Closed) NCV 50-3?7, 3?8/90-04-01:

followup on corrective actions for failure to ensute a person entering a high radiation area wore proper monitoring devices.

The person committing the violation received a disciplinary letter, was rebriefed on high radietion area entry requirements, and was recertified by attending general employee training.

This item is closed.

Exit Interview The inspection scope and results were summarized on April ?7, 1990, with those per sons indicated in Paragraph 1.

The inspectors described the areas exanined in detail and informed the licensee that an inspection focusing on the ALARA progran would be made at a later date.

The licensee did not identify any materials provided to, or received by the inspectors, as proprietary.

The licensee was informed that the items discussed in Paragraph 3 were considered closed.

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