ML20056D142

Insp Repts 50-327/93-28 & 50-328/93-28 on 930621-25. Violations Noted.Major Areas Inspected:Occupational Radiation Safety,Audits & Assessments,Organization & Mgt Controls & Training & Qualification

ML20056D142
Person / Time
Site:	Sequoyah
Issue date:	07/23/1993
From:	Rankin W, Shortridge R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20056D135	List: ML20056D133 ML20056D136 ML20056D142
References
50-327-93-28, 50-328-93-28, NUDOCS 9308050026
Download: ML20056D142 (11)

See also: IR 05000327/1993028

Text

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Report Nos.: 50-327/93-28 and 50-328/93-28

Licensee: Tennessee Valley Authority

3B 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 Conducted: June 21-2 , 1993

Inspector: / #L 7 3k3

R. B. Shortridge / Date Sfgned

Approved by: [Mu Mr h #

/n 7MJ/d

W. H. Rankin, Chieff Date Signed

Facilities Radiation Protection Section

Radiological Protection and Emergency. Preparedness Branch  ;

Division of Radiation Safety and Safeguards i

SUMMARY

Scope:

This routine, announced inspection was conducted in the area of occupational l

radiation safety, and included an examination of Audits and Assessments, l

Organization and Management Controls, Training and Qualification, External i

Exposure Controls, Internal Exposure Control, Surveys, Monitoring, and Control

of Radioactive Material, and the program to Maintain Exposure As Low As

Reasonably Achievable (ALARA). In addition, the inspector reviewed licensee

corrective actions for previous inspection findings and observed recovery

operations for a mispositioned spent fuel assembly.  ;

Results: l

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In the areas inspected, three violations of NRC regulations were identified.  !

Program strengths in contamination control / housekeeping and performance based

assessments were also identified. Based on a review of records, interviews .

with mechanics, supervision, and management, and the observation of  :

radiological operations, the inspector determined that the program to protect  !

the health and safety of the public and workers was adequate. The violations  !

are summarized as follows:

1. A worker failed to notify Radcon when she received an alarm on a portal

contamination monitor (Paragraph 6).

9308050026 930723 I

$DR ADDCK 05000327 PDR

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2. A person received a 15 percent maximum permissible organ burden and

Radcon management failed to send a summary report to the Site Vice

President with corrective actions as required by procedure

(Paragraph 6).

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3. An NRC inspector located a cleaning and sterilization chemical in the

2 "A" "A" charging pump room that was not being used in accordance with -

the use code on the label and information on the Chemical Review Form,

not was it secured to prevent misuse (Paragraph 7). This violation is a  !

repeat violation.

The inspector discussed an adverse trend with licensee management that ,

indicated a lack of compliance by plant personnel regarding working within the

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initial scope discussed with Radcon (Paragraphs 2 and 6).

During observation of the recovery of a leaning spent fuel assembly, the ,

inspector observed weak coordination and control of the operations and

notified the NRC inspector in the Control Room.

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REPORT DETAILS

1. Persons Contacted ,

Licensee Employees  :

• D. Adams, Program Manager, Chemistry

• J. Baumstark, Manager, Operations

• D. Bodine, Acting Support Manager, Chemistry

J. Delaney, Technician, Radiological Controls

• R. Driscoll, Site Manager, Quality Assurance

R. Dwyer, Senior Reactor Operator, Operations ,

• R. Eytchison, Vice President, Nuclear Operations

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• R. Fenech, Vice President, Sequoyah Nuclear Plant

D. Gallager, Supervisor, Modifications ,

• J. Gates, Outage Manager

• R. Goodman, Manager, Technical Trainino

• C. Kent, Manager, Radiation and Chemistry r

C. Kirk, Engineer, Westinghouse *

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J. Mullenix, Engineer, Quality Assurance

• J. Osborne, Manager, Environmental Control

• M. Palmer, Manager, Radiological Control Health

• S. Poage, Acting Manager, Nuclear Audits and Assessments

• R. Thompson, Manager, Licensing and Compliance

• P. Trudel, Manager, De;ign Engineering

• J. Ward, Manager, Engineering and Modifications i

• C. Whittemore, Engineer, Licensing and Compliance  :

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Other licensee employees contacted during this inspection included

craftsman, engineers, operators, mechanics, and administrative

personnel. i

Nuclear Regulatory Commission

• W. Holland, Senior Resident Inspector  !

• C. Hughey, Resident Inspector, Grand Gulf

B. Long, Reactor Inspector, Region 11

• K. Poertner, Resident Inspector, Oconee i

• Attended Exit Interview l

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2. Audits and Assessments (83750) l

The licensee has developed a performance based program of assessments  ;

that uses a rating system of one to four with one being the highest

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rating. Individual departments undergo assessments performed by quality  ;

assurance personnel.that can range from one to four months in length,  !

with a scope'that results in the departments whole purview being i

assessed. The inspector reviewed the radiological aspects of

assessments for both maintenance and operations areas. The inspector ,

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noted that the radiological findings identified in the assessments were

substantive and identified problems that if not corrected could lead to i

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NRC findings. The program required correction of problems identified,  :

and a reassessment at a later date of corrective actions taken. A t

licensee representative stated that to date the program has receive good

support from upper licensee management, and is meeting with general

acceptance at the department level.  ;

The licensee utilizes Radiological Awareness Reports (RARs) to identify l

radiological deficiencies and poor radiological performance. The '

reports are designed to provide information in the investigation section ,

that will lead to a root cause determination. The inspector noted that  :

only 14 RARs had been written in 1993, which appeared to be a low number i

considering the scope of work performed to date in this fiscal year. A

brief analysis of root causes showed an adverse trend in that five of ,

the RARs identified that workers did not always correctly identify their

work scope to RADCON, and in some RARs workers changed locations and

work scope without notifying RADCON. The inspector discussed the  ;

concern with licensee management and stated that the RADCON program was >

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supported by in-depth procedures but it appeared that the challenge was

to enforce RADCON requirements and improve worker compliance. Licensee

management acknowledged the inspector's concern and agreed to consider

it for evaluation. An example of where working outside the initially

identified scope of work lead to an internal exposures documented in i

Paragraph 6.

No violations or deviations were identified [

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3. Organization and Management Controls (83750)  :

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The inspector reviewed changes since the last inspection in  !

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organization, facilities, equipment and personnel and how they related ,

to the occupational radiation protection program. This inspection noted

l that several organizational and personnel changes had occurred in the  ;

1 licensee's program since the last inspection. The inspector noted that i

a majority of the plants management team was new since the previous '

inspection in August 1992. Since that time RADCON has undergone '

significant changes. Both RADCON and Chemistry report to the previous

Radiation / Chemistry Manager which was- formerly designated as Radiation  !

Protection Manager (RPM). Currently the RPM job is not filled. The

combination department RAD / CHEM has an administrative supervisor, i

chemistry control supervisor, environmental control supervisor, and the  !

unfilled position for the RPM. -

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One change that was reviewed in detail during the inspection was the r

Chemical Traffic Control (CTC) program. The Environmental Control  ;

Manager in April assumed responsibility for this program and is i

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undergoing changes to improve chemical controls. This area received a

violation in the previous inspection and the licensee has placed

considerable resources to correct the problem of the mis-use and storage i'

of chemicals. Another similar violation was identified in this report

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in Paragraph 7.b.

No violations or deviations were identified.

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4. Training and Qualification (83750) l

The inspector reviewed licensee response to a violation (92-25-01) cited

in Inspection Report 50-327 and 50-328/92-25 dated November 5, 1992.

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The violation was for failure to follow administrative procedures in r

that the licensee did not label or properly control numerous containers

of hazardous materials which could result in radiological hazards. ,

Three reasons listed for the cause of the violation were: (1) craft.had  !

not received craft specific training, (2) management and line  !

supervision did not enforce the program requirements for labeling and

storage of chemicals, and (3) supervisors of sections using chemicals

were not performing routine inspections of their work area. To correct

these deficiencies the licensee revised SSP-13.2, Chemical Traffic

Control (CTC) to specifically address disposal of unused material and  :

use of containers with residues. The painters attached to

Modifications department were given craft specific training and r

Modifications supervisors directed all chemicals under their cont ol be

properly labeled. Radcon supervisors also labeled all chemicals onder

their control. ,

In addition to the above, the licensee responded that Modifications'  !

craft personnel were immediately retrained on the CTC program j

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requirements as they applied to each craft discipline, and that craft  ;

specific training for CTC controls was also provided for the Chemistry,

Maintenance, Technical Support, and Operations sections.

The craft specific training referenced above was based on the revisions

of SSP-13.7 Chemical Traffic Control, Revision 5, dated February 18,

1993, and SSP-13.3, Environmental Compliance, Revision 4, dated June 22, .

1992, were combined to make a 45 minute videotape. The training course l

number was assigned as PPT 201.005 for the craft specific training. In  :

reviewing licensee data, the inspector determined that at the time of ,

the licensees response to the violation that some personnel in the  :

Modifications, Maintenance, Technical Support, and Operations l

departments had not received the PPT 201 005 course of chemical traffic

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control. However, this item will be reviewed for closure during a

subsequent inspection.

No violations or deviations were identified.

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5. External Exposure Control (83750)

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The inspector observed early licensea efforts to recover a once burned

spent fuel assembly (H-64) that was being reloaded into the core at  ;

position, Unit 1, G-7. The fuel assembly was leaning with the base at ,

core plate location G-7 and the top against the opposite wall or the  ;

baffle plate. The recovery was to be performed in accordance with Fuel

Handling Instruction (FHI)-3A, Revision 0, dated June 21, 1993. The ,

purpose of the instruction was to upright the fuel assembly (H-64) and

move it to the baffle so the manipulator crane gripper could be

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relatched to transfer the fuel assembly to the core side upender. An

alternate plan to move the fuel assembly using the polar crane was  ;

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provided for in the procedure but was not within Technical

Specifications and was not used. The draft procedure was briefed with

emphasis on taking the necessary time to perform the operation

correctly, obtaining good communications, and stop work authority. The

radiation work permit for the operation was 92-000-47, and required a '

full set of protective clothing. Radcon briefed the ope. rating crew on

the possibility of airborne radioactivity if gaseous bubbles were i

observed during any part of the recovery. There were specific

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discussions on evacuation, if required, lifting weight limits for the ,

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assembly, and the functions and responsibilities of the Outage Manager,

Senior Reactor Operator (SRO), Fuel Vendor Advisor, Technical Support

Advisor, their relationship in the control of the operation. '

The operating crew performed a dry run of a contingency operation and  !

received management authorization to perform the recovery. Within

several hours the lifting slings with "J" hooks had been installed under  :

the holddown springs on the leaning fuel assembly and the recovery  :

operation begun. Initial weight on the 1.5 ton dynamometer was l

570 pounds (lbs) which increased to 1,000 lbs as the cell was uprighted I

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to within one pitch of vertical. After this step and during the next

several steps the procedure provided several options, and discussions

took place between the SR0 and personnel in the control room. The

inspector noted that there appeared to be a conflicting directions at

the end of the first conversation and the inspector noted that the SR0

appeared to be in disagreement with directions he had received. The

inspector notified the NRC inspector in'the control room of the apparent

deterioration of coordination and control of the operation and relocated 1

to the Radcon Control Point to get better information. The inspector

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noted during the final uprighting / lifting of the fuel assembly that the

load limit specified in the procedure of 1750 lbs [ fuel assembly,

thimble plug, lifting apparatus (1251bs), plus an additional 100 lbs]

was exceeded. The inspector interviewed personnel after the operation

was stopped and found that different people on the operating crew

believed that the maximum weight taken on the dynamometer was between

1880 and 1980, which was substantially over the load limit (considering

the rigging was attached to the holddown springs on the fuel assembly)

and near the minimum load test rating on the auxiliary hoist on the

manipulator crane of 2250 lbs.

The inspector discussed his observations with the senior resident

inspector and was informed that the licensee had stopped the operation

and corrective actions would be forthcoming. This event was discussed

in detail in the Resident Inspector's Inspection Report 93-23, dated

July 21,1993.

6. Internal Contamination Control (83750)

Technical Specification (TS) 6.11, requires that procedures for

personnel radiation protection shall be prepared consistent with the

requirements of 10 CFR Part 20 and shall be approved, maintained, and

adhered to for all operations involving personnel radiation exposure.

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Radiological Centrol Instruction (RCI) - 1, Radiological Control i

Program, Revision 43, dated August 21, 1992, requires in Step 4.4, that j

prior to exiting the radiologically controlled area (RCA) all personnel

shall monitor themselves in a whole-body contamination monitor. If

contamination is detected or suspected, Radcon shall be immediately

notified.

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Radcon Management Directive (RMD) - F0-10, Personnel Contamination

i Reports (PCRs), Revision 2, dated March 12, 1993, in Step _6.1.2,

requires that personnel skin or clothing contaminations shall be

immediately reported to a Radcon Field Operations Shift Supervisor. _

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l The inspector reviewed an event where an individual alarmed a portal i

monitor at the security gate house on the way to work. On April 28, l

1993, an individual exited the Unit 1 Lower Ice Condenser and received a l

personnel contamination monitor (PCM) alarm at the reverse osmosis room i

on elevation 734'. After getting some advice from a worker in i

protective clothing, the individual obtained some duct tape an proceeded )

l to decontaminate his left shoe and then repeated the frisk in the same '

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PCM and did not get an alarm. When the individual left the site he did

not get an alarm on the gate house portal monitor. Radcon confiscated

the left shoe and found contamination under the seam in the arch area on

the shoe, of approximately 10,000 net counts per minute (ncpm). After a i

number of tests on portal monitors, Radcon determined that the shoe may

have gotten through the gate house PCM but it was unlikely that it would

have entered any other PCM and not have alarmed the monitor. Later in

attempting to datermine if the person contaminated had performed the

personnel monitoring correctly, Radcon reported that the person did not

properly place his foot correctly on the PCM detector. Radcon performed

a survey of the worker's house and automobile but did not find any

contamination above licensee limits for release. Based on conservative

i assumptions, the licensee calculated that the worker received a

l radiation dose of 76 millirem to the left foot for the entire time the

l contaminated shoe was worn. The inspector noted that this event was

identifieo by the licensee, however, based on the licensee's j

investigation and analysis of the event it appears that the worker did j

not utilize personnel monitoring equipment as stated. The inspector

informed licensee representatives that due to the safety significance of

this event, and the fact that material was taken offsite, this is

l considered a violation of TS requirements and the above listed

procedures (VIO 50-327,328/93-28-01).

RCI-1, Radiological Control Program, Revision 43, dated August 21, 1992,

Step 6.1, states that the Radiological Control Manager (site) shall

notify the Manager, Radiological Control (Corporate) as soon as

possible, of the following incidents:

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Step 6.1.2, internal exposures of greater than 5 percent of a

maximum permissible organ burden.

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Step 6.2, each incident shall be investigated and summary reports I

provided to the Site Vice President to ensure effective corrective

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The inspector reviewed another personnel contamination event where

workers, machining on the number four Reactor. Coolant Pump Main Flange,

became contaminated when they changed from machining on the outer land i

of the RCP to the inner land. During machining on the inner land the  ;

tool bit broke and one of the workers leaned over the flange opening and

replaced the bit. Post job surveys revealed airborne activity of

5.49 E-10 micro curies per cubic centimeter. Metal shavings removed l

from the inner land area read 25 mrad per hour and 2 millirem per hour ,

contact and 60,000 disintegrations per minute per 100 cm2 . Radcon

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management, which had provided adequate engineered controls for.the

known scope of work (machining the outer land), was not notified of the '

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job scope change and did not provide any controls, and, as a result, the

worker received a 15 percent maximum permissible organ burden to the  ;

lower torso or 81 nanocuries of Co-60. The licensee developed

corrective actions based on their root cause analysis of the event with

completion of the corrective actions scheduled for October 1993. During  :

the review of licensee data the inspector noted that a summary report >

had not been provided to the Vice President to ensure effective

corrective actions. The inspector informed the licensee that the

failure to perform this procedure requirement was a violation of TS and

the above listed procedure requirement (50-327, 328/93-28-02). The

contamination did not result in an individual exceeding a regulatory

limit.  ;

Two violations and no deviations were identified.

7. Surveys, Monitoring, and the Control of Radioactive Material (83750)

a. Postings

10 CFR 20.203 specifies the posting, labeling, and control

requirements for radiation areas, airborne radioactivity areas and

radioactive material.

During facility tours, the inspector verified postings and

labelings against radiation and contamination levels in radwaste

storage areas, pump rooms, decon room, Control Room, and other

support buildings on site. The inspector determined the posting

and labelings to be consistent and appropriate, following

requirements of licensee procedure RCI-15, Revision 4,

" Establishing Updating Radiological Sign Postings," for informing

workers of the radiological' hazards in the area. All

step-off-pads from contaminated areas were clean and in good

condition.

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b. RCA Tours

The inspector noted that all areas of the RCA toured were very

clean and demonstrated good housekeeping. Although the licensee

was in outage and several thousand feet of radiologically

controlled laydown area had been created, the work areas and pump

rooms were very clean.

TS 6.11 requires that procedures for personnel radiation

protection shall be prepared consistent with the requirements of

10 CFR Part 20, and shall be approved, maintained, and adhered to

for all operations involving personnel radiation exposure.

Site Standard Practice (SSP)-13.2,' amical Traffic Control (CTC)

Program, Revision 5, dated February 18, 1993, in step 3.5.6,

requires that personnel using chemicals shall use them only for

their assigned task and in accordance with the use code on the

label and information on the Chemical Review Form. Personnel

shall keep chemicals for which they are responsible in their

possession, or secured to prevent misuse.

NRC inspectors reviewing plant systems in the Auxiliary Building

identified several cans of a chemical that apparently was being

used as a degreaser.

red storage can located Several

in the cans

2 "A"of"A"

the aerosol were found in a

Charging Pump Room on

elevation 669'. The inspector ascertained by interviewing several

workers in the Auxiliary Building that the chemical was used in

the cleaning of plant components. The inspector discussed the

chemicals with the site CTC Coordinator and learned that the

Chemical Review Form (CRF) listed the intended use for the

cleaning of bathroom walls, bathroom sinks, and water coolers.

The CRF listed the operational restrictions as allowed in the

power block to clean and sterilize bathrooms. The inspector

notified the apparent users supervisor of the location of the

chemicals and also notified the Site CTC Coordinator. The

inspector discussed the failure to utilize and control chemicals

properly with licensee management and informed them that this was

considered a violation of TS and SSP 13.2 requirements (50-327,

328/93-28-03). This violation is a repeat of a violation (50-327,

328/92-25-01) that was described in Inspection Report 92-25 dated

October 5, 1992.

One violation and no deviations were identified.

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8. As low As Reasonably Achievable (ALARA) (83750)

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10 CFR 20.](c) states that persons engaged in activities under a license

by the NRC should make every reasonable effort to maintain radiation

exposure as low as reasonably achievable. Program trends evaluated

included the following:

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The inspector reviewed licensee data for collective dose for the Unit 1 j

Cycle 6 (U106) refueling / maintenance outage. The licensee's goal for  :

the outage was 249.3 person-rem and the actual total collective dose to  :

date is 172.9 person-r= with all steam generator maintenance completed '

and refueling in progress. Licensee ALARA representatives stated that ,

work was performed by vendors, for a specific scope of work, with ALARA >

goals to hold the vendor accountable. The inspector noted that all

major tasks came in under budget. Licensee ALARA representatives stated

that they attribute much of their improved performance to good cleanup

after early boration and peroxide addition after shutdown. The licensee

was able to perform nozzle dam installation for four steam generators ,

for 5.5 person-rem. In general all licensee performance data reviewed  !

by the inspector appeared to be trend in the direction of improved dose

reduction performance.  ;

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No violations or deviations were identified. '

9. Licensee Actions on Previously Identified Inspector Findings (92702) ,

a. (0 pen) IFI 50-327, 328/92-13-01: Replacement of valves containing  !

stellite with valves containing little or no stellite.  :

The inspector did not review progress on this IFI during the +

inspection, however it is scheduled for review in subsequent

inspections.

b. (0 pen) VIO 50-327, 328/92-25-01, Failure to follow procedures for j

control of chemicals. ,

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The inspector reviewed several Quality Assurance Audit Reports l

that show CTC as still being a problem and the identification of  :

another violation in this report prevents this item from being  !

closed.

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c. (Closed) NCV 50-327, 328/92-25-02, Failure to follow the procedure

requirements for control of vacuum cleaners handling radioactive  ;

material.

The inspector reviewed the licensee's corrective action and found

it to be acceptable. To correct the problem of vacuum cleaner

openings the licensee placed a device similar to the flapper valve

at the end of a diesel exhaust pipe. All vacuum cleaners observed  ;

appeared to have this device. This item is considered closed.  !

10. Exit Meeting (83750) (92702)  ;

The inspector met with licensee representatives indicated in Paragraph I

at the conclusion of the inspection on June 25, 1993. The inspector 1

summarized the scope and findings of the inspection. The inspector also l

discussed the likely information content of the inspection report with

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regard to documents or' processes reviewed by the inspector during the '

inspection. The licensee did not identify any suc14 documents or

processes as proprietary. Dissenting comments were not received from

the licensee. .

Item Number Description and Reference

50-327,328/93-28-01 VIO - Failure to notify Radcon upon being

becoming contaminated (Paragraph 6).

50-327,328/93-28-02 VIO - Failure to submit a summary report to Vice

President upon identifying an internal

contamination greater than 5 percent of maximum

permissible organ burden (Paragraph 6).  :

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50-327,328/93-28-03 VIO - Failure to utilize and control '

chemicals in accordance with procedure

requirements (Paragraph 7.b). *

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