IR 05000327/1990031

Insp Repts 50-327/90-31 & 50-328/90-31 on 900910-14.No Violations or Deviations Noted.Major Areas Inspected: Occupational Exposure During Extended Outages & Licensee Actions to Correct Previously Identified Weaknesses

ML20059N583
Person / Time
Site:	Sequoyah
Issue date:	09/26/1990
From:	Potter J, Shortridge R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20059N582	List: IR 05000327/1990031 ML20059N581
References
50-327-90-31, 50-328-90-31, NUDOCS 9010160271
Download: ML20059N583 (6)

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p trio UNITED STATES

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e1 1 'o NUCLEAR REGULATORY COMMISSION: .

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    . REGION 11:   '{ '
$-  j  101 MARIETTA STREET, N.W.-
*  2  ATLANTA, GEORGt A 30323 -

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 *****'   y q g gg Repo'rt Nos.: 50-327/90-31-and 50-328/90-31    l t

Licensee: Tennessee: Valley Authority , 6N38 A Lookout Place 1101: Market. Street' ,

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Chattanooga, TN . 37402-280 Docket Nos.:.'50-327 and'50-328 License Nos.: DPRL77'and DPR-79

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Facility Name:::Sequoyah.1 and 2 #

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- 4 Inspection Cond .e S ber 10-14,.1990 Inspectpr

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P App' roved by: / _

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f>6 4 : J 4P. Potter, Chief ' pate/ Sighe~d-e Facilities Radiation Protection Section Emergency Preparedness and~ Radiological Protection Branch Division of Radiation Safety and Safeguards >

    . SUMMARY:

Scope: ' Tiiis routine, unannounced-inspection was conducted ;in the areas:of. occupational exposure during extended outages, and reviews :of. licensee actions: to correct previously-identified weaknesses .in their program to maintain occupational-dose to workers as low as' reasonably achievable (ALARA).

' Results:

'No violations or deviations were identified._ The inspector. observed major improvement in the licensee program to maintain occupational. dose to workers'

ALARA. . Preparations for the refueling / maintenance' outageMappeared .:to_ be

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adequate. Weaknesses were identified in the. posting of.high-radiation areas in--

. containment. However, when identified the licensee took corrective actions <and the problems were. resolved prior to the end of the inspectio '
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t 9010160271 901002 , DR ADOCK 0500gg-{7 ,

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REPORT DETAILS 1

      , Persons Contacted Licensee Employees
*M._-Cooper, Site Licensing Manager- .
*T. Flippo Quality Assurance & Engineering Manager
*S.-Johnson, Media. Relations Specialist
*C. Kent, Radiation Protection Group' Manager
*A. Meller, Quality Assurance Auditor;
*J. Proffitt, Complionce Licensing Manager   ;
*L. Riales, Corporate RADCON _
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*M. Sullivan, Radiation Protection Manager   t
*R.-Thompson, Compliance Manager  . .
*P. Trudel, Nuclear Engineering Project Engineer
*E.-Wallace, Nuclear Licensing and-Regulatory Affairs Manager  ;
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Other licensee employees contacted during this inspection include craftsmen, engineers, operators, mechanics, and administrative. personne Nuclear Regulatory Commission

*P. Harmon, Senior Resident Inspector    i
*W. Little, TVA Section Chief
*S. Shaeffer, Resident Inspector    !
*B. Wilson, Chief TVA- Projects i
* Attended Exit. Interview    '

i Occupational Exposure During Extended Outages (83729)

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10 CFR.20.1(C) states, in part, that personsiengaged in activities'under f licenses issued by the NRC should, in- addition 'to ~ complying. with the

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requirements set forth in this part, make every reasonable effort -to maintain radiation exposures, as low as reasonably achievable .(ALARA).

Other recommended elements of an ALARA program are contained.in. Regulatory a Guides 8.8 and 8.1 ALARA Program Review The-inspectors reviewed the program to maintain worker dose ALARA and observed recent changes in response 'to NRC identified weaknesses. The - inspectors noted - that informational material : was ; developed by_ radiation. protection' (RP) and provided to managers and supervisors

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dose information on their respective _ employees. New material included-

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an ALARA notebook updated monthly that contained site dose -  ; information, detailed dose figures for each department head's i divisions and individual workers, and,any updated projections based i on current job status and any additional work -requirements. The' .j .

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notebook also included -memorandums concerning--ALARA- awareness and 1

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steps' to reduce dose for specific- job ~

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Another new iton was a detailed, database which _ managers could access' t

 .to view any espect of the plant's current collective person-rem. Dose figures coind be reviewed'on the department / division level, or could; .

be specjiied down to a givenL job. and the' individual. workers on that .I job. ALARA information coverage during: the outage included a daily updated dose sheet'which itemized the _ dose' for each of the work orders 1 being. performed. ' Thes sheet, provided information such as current dose to date, percent of -estimated dose, and percentage of_ . job still to be' completed. The licensee' stated that the rationale'was

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to e.ttempt to track 'the ' absorbed dose .upon completion. of the job. _ This identified problems!withijob performance and allowed management.- time 'to . discuss: and devise. other procedures. to complete _the ' job within the estimated person-rem. f Similarly, worker ALARA review ..

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planning'repo_rts were provided _to;each_ supervisor for his-particu_la . jobs. The report- included . dose data information for each of the supervisor's workers -and included all;the: Radiation Work Permits (RWPs) required for the job (s) to be performe ~ Inspection Report _90-23 identified that annual dose goals were not being effectively used for managing or reducing. collective dose. The licensee established monthly' collective dose goals for the-remainder of" fiscal year 1990. For July, August,-and September, the licensee-projected the collectivel doses to be 35,,20, and 370 person-re ^ Performance against these goals through September 13, 1990, was,10.9, 17.5, and 54.5 person-rem respectivel During. tours in the Unit' 2 (U2) containment,- the ; inspector observed -

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that the outage work was on schedule and'that radiological controls were effectively implemented concerning the installation of temporary shielding. Also, the Resistance Temperature Detectors (RTDs) were l being removed with the normal water inventory in theLreactor coolant i loops. Only the RTD system was' draine The inspector determined from _these and other observations detailed ; , in this report, that the licensee was .taking a more ;,ro-active approach to the station's program to maintain workar dose ALAR , t Review of ALARA Pre-job Briefings and Mockup Training

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The inspector attended the ALARA pre-job briefing for RTD-removal and removal of'the Upper Head Injection (UHI) System and noted that-all radiological aspects of the jobs were thoroughly ' discussed. ~The planned method of cutting piping for both systems was the use of a

 ' hand held plasma arc torch. During.the' previous refueling outage use
 : of the plasma arc cutting method- resulted in the spread of high -

levels _of contamination. In between outages the -licensee developed an - innovative method of containing 'the slag. generated during plasma cutting. Use of the new containment device is expected to result in a i

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 ' savings .of six to eight person-rem in decontamination- alone. The inspector noted during ' the mockup demonstration the protectiv clothing and simulated restrictions in plant were not used.1When queried, the' personnel in' training responded' correctly to. questions regarding-radiological controls for the operation ' Radiological Incident / Awareness Reports   !
 ~ Radiological Incident Reports'(RIRs) were reviewed from March of 1990 through September ~ 13, 1990.. No adverse trends.were noted other.than one identified on a recent. maintenance teamjinspection. During the: ,

previous inspection, the inspector noted that workers-had entered'the ' radiologically controlled area (RCA) of'the plant 11-times this year without wearing a thermoluminescent dosimeter (TLD)'andselfreading-dosimeter (SRD). The inspectors noted during tours of the RCA that = security-personnel and health physics technicians were monitoring.and-

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questioning . workers if - they ; were ' wearing personnel monitoring .

      .I devices. Also, signs asking the same questions had been; installed in '

the RCA to heighten worker awareness.-_The inspectors did not observe _ any personnel without a TLD and SRD in the RC External Exposure Control

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10 CFR' 20.203(c) requires that each I high . radiation area Lbe conspicuously. posted wi S a' sign or signs bearing the radiation ; caution symbol-and-the words, CAUTION HIGH RADIATION ARE CFR 19.12 Instructions to Workers in part states, thatiall . ' individuals working -in or; frequenting' any portion of a restricted area shall be kept informed of the' storage or use of radiation:in ., such portions of the1 restricted' area, and=of their responsibility to ' report unnecessary exposur During tours of 'U2 containment, the inspector observed _ that" signs - j bearing CAUTION HIGH. RADIATION AREA were postedoacrossEthe< two > accesses leading into lower' containment at the polar crane c _ wal However, none ' of the many high radiation areas- inside lower containment were posted. The inspectors - performed radiation area surveys and observed' high' radiation general areas :(18" from the source) as high as . 800 mrem /h Radiation levels: similar to thisc were found on all three RTD Bypass Platforms. Upon entry' to the : lower containment,. personnel, who stopped at the handrail platform.to; get the~ orientation of the components in.the area, were standing in aL dose rate of'250 mrem /hr'(an 18" radiation level from a vertical run of pressurizer piping). The inspectors also-observed that hot _ spots i

 (dose rates 5 times 1 higher than backgroundLradiation levels and:

, greater than 100 mrem /hr) had not been posted at.any1of a number of-l such areas. In addition, the licensee did not post low: background L radiation areas. The inspectors queried approximately 10 separate L work groups concerning dose rates -in their inmediate work area and ? , noted that eight did not respond with any: numerical ~ answer, and the Ie

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- ,: s 4-    l two groups who:did were off by more' than 20 percent'. -The inspector notified s the licensee . of = their ' concerns and the licensee took:  a
 ' immediate corrective actions to post the lower inner containment. .The j inspector toured U2 containment the following_ y to determine-if the'  ~;
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and high # radiation : areas-had been poste ! The inspector. observed.that general areas;of the containment had~been posted, ' as well as; the low background 1 radiation ALARA area However,- radiation protection personnel did not postL 2 of 31 Steam - Generators with open hand holds where radiationJ1evels upL to; 600 mrem /hr existed at" the plane' of the . opening. . In addition, none a of the three RTD platform areas had been, posted as a high radiatio L area. The inspectors' notified the Radiation: Protection Manager of' the finding and were informed that these areas would be poste Contractor Health Physics Technicians  ; c - The . inspector performed a review of contractor health physics .(HP)' technician support required for the U2 outage.- Employees' resumes were reviewed for appropriate job rating by -the licensee in accordance with : ANSI N18.1,- 1971 qualification standard.- The- i licensee contracted with 108 HP technicians from vendors and-obtained 21 HP technicians from Browns Ferry and Watts Bara TVA. facilitie . The licensee stated that- 85 of the 129 were: ANSI senior level a technicians. The inspectors reviewed all= senior level technician -

 - resumes and determined that'these personnel.had sufficient experience  _

? to qualify in accordance with the ANSI standar ' Contamination Control The- ins,nector reviewed the licensee's program to._ control [ contamination at the source. - During tours, .the -inspector did not < observe any components or systems that were. leaking and.did not.have~ =? L drip containments installed. The total contaminated. area' for the.

L p(lant has been IR 90-23). significantly At the reduced time of the since- the previous last-inspe~ction, inspection the contaminated

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area of the' RCA was 30,612 square feet (ftr).1The contaminated area

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at the start of the U2 outage had been reduced eto .approximately 2 L 21,000 ft2 This figure is below the annual. goal of 10 percent or !- 23,000 ft2 . The licensee established an aggressive goal of having less than o 240-personnel contamination events (PCEs) for FY=90. At the time.o the inspection, the licensee had . experienced 314 PCEs. Licensee-representatives stated that while' the. annual goal had been exceeded, the rate of occurrence should be reduced during the outage period remaining in FY 90, due to the increased use of containments and ~ increased efforts of HP to heighten worker awareness in this area.

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5-  : k Exit-Interview

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The scope- and' findings were sumarized on September.14,1990, with those-persons indicated. in Paragraph 1*. The inspector. described the areas inspected and- discussed in deta11Ethe. inspection results. The , license >

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 -acknowledged the. inspection findings and took no exceptions..The licensee
 . did not identify as proprietary any of the material provided tto.f or
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