ML20056E954
| ML20056E954 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 08/23/1993 |
| From: | Fenech R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9308250334 | |
| Download: ML20056E954 (7) | |
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Tennessee Valley Authonty, Post Office Box 2000, Soddy-Daisy. Tennessee 37379-2000 Robert A Fenech
%ce President, Sequoyah Nuclear Plant August 23, 1993 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Gentlemen:
In the Matter of
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Docket Nos. 50-327 Tennessee Valley Authority
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50-328 SEQUOYAH NUCLEAR PLANT (SQN) - NRC INSPECTION REPORT NOS. 50-327, 328/93 REPLY TO NOTICE OF VIOLATIONS (NOVs) 50-327, 328/93-28-01,
-02, AND -03 Enclosed is TVA's reply to J. Philip Stohr's letter to Mark 0. Medford dated July 23, 1993, which transmitted the subject NOVs. The violations involve noncompliance with Technical Specification 6.11, which requires that procedures for personnel radiation protection be prepared and adhered to for all operations involving personnel radiation exposure.
TVA disputes the second violation concerning the failure to submit to the SQN Site Vice President a report describing a personnel contamination i
event.
1 contains a summary of commitments made in this submittal.
l If you have any questions concerning this submittal, please telephone C. H. Whittemore at (615) 843-7210.
l Sincerely, Robert A. Fenech Enclosure l
cc: See page 2
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1 U.S. Nuclear Regulatory Commission Page 2 August 23, 1993 cc (Enclosure):
Mr. D. E. LaBarge, Project Manager U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852-2739 NRC Resident Inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy-Daisy, Tennessee 37379-3624 Regional Administrator U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323-2711 l
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ENCLOSURE 1 RESPONSE TO NRC INSPECTION REPORT NOS. 50-327/93-28 AND 50-328/93-28 J. PHILIP STOHR'S LETTER TO MARK 0. MEDFORD DATED JULY 23, 1993 Violation 50-327. 328/93-28-01
" Technical Specification (TS) 6.11, requires that procedures for personnel radiation prctection shall be prepared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained, and l
adhered to for all operations involving personnel radiation exposure.
" Radiological Control Instruction (RCI) - 1. Radiological Control Program, Revision 43, dated August 21, 1993, [ sic] requires in step 4.4, that 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, Radeon shall be immediately notified.
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"Radeon Management Directive - FO-10, Personnel Contamination Reports (PCRs), Revision 2, dated March 12, 1993, requires in step 6.1.2, that personnel skin or clothing contaminations shall be immediately reported 4
to a Radeon Field Operations Shift Supervisor.
" Contrary to the above, on April 28, 1993, a worker received a portal contamination monitor alarm and failed to report the event to a Radeon Field Operations Shift Supervisor.
"This is a Severity Level IV violation (Supplement IV)."
Reason for the Violation The reason for this violation was personnel error. An individual had exited an area requiring a radiation work permit (RWP) and did not follow procedures and notify Radiological Control when an alarm on a personnel contamination monitor (PCM) indicated contamination on a shoe. The individual attempted to decontaminate the shoe until no additional alarm was received on the PCM.
The individual proceeded to exit the RCA, where a second monitor did not alarm. The portal monitor at the gatehouse also failed to detect any presence of contamination. However'upon return to l
work later the same day, the gatehouse portal monitor alarmed when the-individual attempted to enter the site area. Radiological Control j
personnel responded to the alarm and determined that the left shoe of the i
individual was contaminated. Personnel error is also suspected in the improper use of the PCMs to exit the work area and RCA without alarming.
any of the monitors.
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Corrective Actions That_Have Been Taken and the Results Achieved Radiological Control personnel confiscated the shoe to determine the nature of the contamination. The egress of the individual from the plant was reconstructed and surveyed for contamination. The individual's home and car were also surveyed for possible radioactive contamination. No radioactive material was detected in these surveys.
The PCMs and the gatehouse portal monitors that the individual used exiting the plant site were response checked. All instruments passed the response check.
The contaminated shoe was placed in each PCM and, in each instance, the PCM alarmed.
Appropriate disciplinary action was taken with the individual involved.
Corrective Simps That Will be Taken to Avoid Future Violations All corrective actions have been completed.
Rare When Full Compliance Will be Achieved TVA is in full compliance.
Einlation 50-327. 328/93-28-Q2 "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.
I "RCI-1, Radiological Control Program, Revision 43, dated August 21, 1992, J
Step 6.1, requires the Radiological Control Manager (site) to notify the Manager, Radiological Control (Corporate) as soon as possible of internal exposures of greater than 5 percent of a maximum permissible organ q
burden. Step 6.2 requires that each incident shall be investigated and
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I summary reports provided to the Site Vice President to ensure effective corrective action.
" Contrary to the above, on May 28, 1993, a person received a 15 percent maximum permissible organ burden and Radeon management failed to send a summary report to the Site Vice President with corrective actions as required by procedure.
"This is a Severity Level IV violation (Supplement IV)."
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- Corrective Actions That Have Been Taken and the Results Achieved Immediate corrective actions included the identification and prompt I
removal of the aerosol cleaner from the RCA.
i The particular cleanser has been reclassified to a USE CODE IV, which prohibits the item from being carried into the RCA.
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Corrective Steps That Will Be Taken to Avoid Further Violations USE CODE III products will be reevaluated to determine if they are appropriately classified for use in the RCA.
The lessons learned in this event will be used to provide additional CTC training to the Modifications, Operations, Maintenance, and Radiological Control sections.
Nuclear Stores will also be provided additional CTC training concerning this event.
Ibe Date When_f.nl.1 Compliance Will Be Achieved TVA is in full compliance.
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i i i Rasis for Disputing Violation 50-327. 328/93-28-Q2 TVA disputes the violation. A radiological awareness report (RAR) was initiated on May 28, 1993, to document the event. On May 29, 1993, the event was reported to the Site Vice President in the daily status meeting.
It was also reported that the contamination did not result in an individual exceeding a regulatory limit. The RAR and corrective J
actions resulting from the investigation were approved on June 22, 1993, I
by the Radiological Control Manager. A copy of the completed summary report was forwarded to the Site Vice President on June ~24, 1993. The procedure (RCI-1 Step 6.2) does not specify a timeframe for submitting the summary report to the SQN Site Vice President.
Violation 93-28-Q3 "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 Procedure (SSP) - 13.2, Chemical 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 (CRF). Personnel shall keep chemicals for'which they are responsible in their possession, or secured to prevent misuse.
" Contrary to the above, on June 24, 1993,'NRC inspectors 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, nor was it secured to prevent misuse.
"This is a repeat Severity Level IV violation (Supplement IV)."
Reason for the Violation The reason for the violation was personnel error in failing to follow procedures. A can of aerosol cleaner, which was intended for janitorial use only in bathrooms, had apparently been used as a degreasing agent in the 2-AA charging pump room. Using this cleanser as a degreaser is a common practice outside the RCA. This particular agent was labeled as a USE CODE III chemical. Chemicals labeled as USE CODE III'are allowed in the RCA with restrictions. This particular chemical was' restricted from use on stainless steel and nickel-based alloys and from disposal in the floor drain system. This product was not being used in accordance with j
the information on the CRF nor was it secured to prevent misuse.
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e ENCLOSURE 2 RESPONSE TO NRC INSPECTION REPORT NOS. 50-327/93-28 AND 50-328/93-28 l
J. PHILIP ST0HR'S LETTER TO MARK 0. MEDFORD DATED JULY 23, 1993 Commitments 1.
All USE CODE III products will be reevaluated to determine if they are appropriately classified for use in the i
radiologically-controlled area (RCA). This will be accomplished by October 1, 1993.
2.
The lessons learned in this event will be used to provide additional Chemical Traffic Control (CTC) training to the Modifications, Operations, Maintenance, and Radiological Control sections. This will be accomplished by October 1, 1993.
3.
Nuclear Stores will also be provided additional CTC training concerning this event. This will be accomplished by October 1. 1993.
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