ML20056D142
| 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: |
| References | |
| 50-327-93-28, 50-328-93-28, NUDOCS 9308050026 | |
| Download: ML20056D142 (11) | |
See also: IR 05000327/1993028
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UNITED STATES
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WUCLEAR REGULATORY COMMisslON
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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:
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R. B. Shortridge
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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
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SUMMARY
Scope:
This routine, announced inspection was conducted in the area of occupational
radiation safety, and included an examination of Audits and Assessments,
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Organization and Management Controls, Training and Qualification, External
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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:
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In the areas inspected, three violations of NRC regulations were identified.
Program strengths in contamination control / housekeeping and performance based
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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
$DR
ADDCK 05000327
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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
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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
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repeat violation.
The inspector discussed an adverse trend with licensee management that
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indicated a lack of compliance by plant personnel regarding working within the
initial scope discussed with Radcon (Paragraphs 2 and 6).
During observation of the recovery of a leaning spent fuel assembly, the
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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
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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
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- R. Eytchison, Vice President, Nuclear Operations
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- R. Fenech, Vice President, Sequoyah Nuclear Plant
D. Gallager, Supervisor, Modifications
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- J. Gates, Outage Manager
- R. Goodman, Manager, Technical Trainino
- C. Kent, Manager, Radiation and Chemistry
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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
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- C. Whittemore, Engineer, Licensing and Compliance
Other licensee employees contacted during this inspection included
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craftsman, engineers, operators, mechanics, and administrative
personnel.
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Nuclear Regulatory Commission
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- W. Holland, Senior Resident Inspector
- C. Hughey, Resident Inspector, Grand Gulf
B. Long, Reactor Inspector, Region 11
- K. Poertner, Resident Inspector, Oconee
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- Attended Exit Interview
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2.
Audits and Assessments (83750)
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,
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with a scope'that results in the departments whole purview being
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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
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NRC findings. The program required correction of problems identified,
and a reassessment at a later date of corrective actions taken.
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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
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radiological deficiencies and poor radiological performance.
The
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reports are designed to provide information in the investigation section
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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
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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
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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
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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
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to the occupational radiation protection program. This inspection noted
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that several organizational and personnel changes had occurred in the
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licensee's program since the last inspection. The inspector noted that
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a majority of the plants management team was new since the previous
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inspection in August 1992.
Since that time RADCON has undergone
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significant changes.
Both RADCON and Chemistry report to the previous
Radiation / Chemistry Manager which was- formerly designated as Radiation
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Protection Manager (RPM). Currently the RPM job is not filled. The
combination department RAD / CHEM has an administrative supervisor,
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chemistry control supervisor, environmental control supervisor, and the
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unfilled position for the RPM.
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One change that was reviewed in detail during the inspection was the
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Chemical Traffic Control (CTC) program. The Environmental Control
Manager in April assumed responsibility for this program and is
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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
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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)
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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
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that the licensee did not label or properly control numerous containers
of hazardous materials which could result in radiological hazards.
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Three reasons listed for the cause of the violation were:
(1) craft.had
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not received craft specific training, (2) management and line
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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
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Modifications supervisors directed all chemicals under their cont ol be
properly labeled. Radcon supervisors also labeled all chemicals onder
their control.
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In addition to the above, the licensee responded that Modifications'
craft personnel were immediately retrained on the CTC program
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requirements as they applied to each craft discipline, and that craft
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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,
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1992, were combined to make a 45 minute videotape. The training course
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number was assigned as PPT 201.005 for the craft specific training.
In
reviewing licensee data, the inspector determined that at the time of
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the licensees response to the violation that some personnel in the
Modifications, Maintenance, Technical Support, and Operations
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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
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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
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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
relatched to transfer the fuel assembly to the core side upender. An
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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
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full set of protective clothing.
Radcon briefed the ope. rating crew on
the possibility of airborne radioactivity if gaseous bubbles were
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observed during any part of the recovery. There were specific
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.
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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
570 pounds (lbs) which increased to 1,000 lbs as the cell was uprighted
to within one pitch of vertical. After this step and during the next
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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
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to the Radcon Control Point to get better information. The inspector
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
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Program, Revision 43, dated August 21, 1992, requires in Step 4.4, that
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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.
Radcon Management Directive (RMD) - F0-10, Personnel Contamination
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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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The inspector reviewed an event where an individual alarmed a portal
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monitor at the security gate house on the way to work. On April 28,
1993, an individual exited the Unit 1 Lower Ice Condenser and received a
personnel contamination monitor (PCM) alarm at the reverse osmosis room
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on elevation 734'.
After getting some advice from a worker in
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protective clothing, the individual obtained some duct tape an proceeded
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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
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
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assumptions, the licensee calculated that the worker received a
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radiation dose of 76 millirem to the left foot for the entire time the
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contaminated shoe was worn. The inspector noted that this event was
identifieo by the licensee, however, based on the licensee's
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investigation and analysis of the event it appears that the worker did
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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
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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:
Step 6.1.2, internal exposures of greater than 5 percent of a
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maximum permissible organ burden.
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Step 6.2, each incident shall be investigated and summary reports
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provided to the Site Vice President to ensure effective corrective
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action.
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The inspector reviewed another personnel contamination event where
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workers, machining on the number four Reactor. Coolant Pump Main Flange,
became contaminated when they changed from machining on the outer land
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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
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from the inner land area read 25 mrad per hour and 2 millirem per hour
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contact and 60,000 disintegrations per minute per 100 cm . 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
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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.
Several cans of the aerosol were found in a
red storage can located in the 2 "A" "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.
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
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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
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and refueling in progress.
Licensee ALARA representatives stated that
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work was performed by vendors, for a specific scope of work, with ALARA
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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
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for 5.5 person-rem.
In general all licensee performance data reviewed
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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.
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Licensee Actions on Previously Identified Inspector Findings (92702)
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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
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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
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control of chemicals.
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The inspector reviewed several Quality Assurance Audit Reports
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that show CTC as still being a problem and the identification of
another violation in this report prevents this item from being
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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
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summarized the scope and findings of the inspection. The inspector also
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
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processes as proprietary. Dissenting comments were not received from
the licensee.
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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
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chemicals in accordance with procedure
requirements (Paragraph 7.b).
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