ML20057E779
| ML20057E779 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 09/30/1993 |
| From: | Rankin W, Testa E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20057E766 | List: |
| References | |
| 50-327-93-44, 50-328-93-44, NUDOCS 9310130143 | |
| Download: ML20057E779 (9) | |
See also: IR 05000327/1993044
Text
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UNITED STATES
/da RicN
NUCLEAR REGULATORY COMMISSION
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REGION H
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101 MAR ETTA STREET, N.W., SUITE 2930
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ATLANTA, GEORGIA N0199
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Report Nos.: 50-327/93-44 and 50-328/93-44
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Licensee: Tennessee Valley Authority
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3B Lookout Place
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1101 Market Street
Chattanooga, TN 37402-2801
Docket Nos.:
50-327 and 50-328
License Nos.:
Facility Name: Sequoyah I and 2
Inspection Conducted: September 13-17, 1993
Inspector:
OM A ([b 8 8-
'7/M/M
E. D. Testa, P. E.
Date Si~gned
Accompanying Personnel:
W. T. Loo
Approved by: LA.23
Y
. 96,
7[3d!98
W. H. Rankin, P. E., Chief
Date Signed
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Facilities Radiation Protection Section
Radiological Protection and Emergency Preparedness Branch
Division of Radiation Safety and Safeguards
SUMMARY
Scope:
This routine, unannounced inspection was conducted in the area of occupational
radiation safety, and int.luded an examination of changes to the program,
planning and preparation, centrol of radioactive materials and contamination,
surveys and monitoring and maintaining occupational exposure as low as
reasonably achievable (ALARA).
Results:
In the areas inspected, one cited violation (Paragraph 4.b) and one non-cited
violation (Paragraph 4.b) were identified. The licensee has shown continued
improvement in ALARA during outages and normal plant operations. The total
personnel dose for the removal and reinstallation of the core barrel for the
10 year inservice inspection was about 0.134 rem. This was one of the lowest
total personnel doses for this job to date in the industry.
Radcon audits
were found to be detailed and provided an indepth assessment of the program
strengths and areas for improvement. Technicians and professional radiation
personnel were found to be knowledgeable and aggressively committed to
minimizing personnel radiation doses. The Health Physics programs were found
to be adequately protecting the health and safety of the radiation worker and
public.
9310130143 931001
gDR
ADOCK 05000327
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REPORT DETAILS
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1.
Persons Contacted
Licensee Employees
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- D. Adams, Manager, Chemical Program
- R. Alsup, QA Audit Manager
- L. Bryant, Manager, Maintenance
- N. Catron, Emergency Preparedness
- E. Chandrasekaron, Corporate Chemistry
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- R. Driscoll, Manager, Site Quality
- B. Fenech, Site Vice President
- J. Johnson, Radcon
- C. Kent, Radcon Manager
- D. Lundy, Manager, Systems
- S. McCamy, Health Physicist
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- K. Meade, Licensing' Engineer
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- K. Powers, Plant Manager
- G. Rich, Manager, Chemistry
- R. Richie, Chemistry and Environmental Superintendent
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- R. Rogers, Site Support
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- R. Shell, Manager, Site Licensing
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- L. Strickland, Manager, Chemistry Process
- R. Thompson, Compliance Licensing Manager
- J. Vincelli, Radeon Field Operations Manager
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- J. Ward, Site Support
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- C. Whittemore, Licensing Engineer
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Other licensee employees contacted during this inspection included
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craftsman, engineers, operators, mechanics, and administrative
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personnel.
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Nuclear Regulatory Commission
- W. Holland, Senior Resident Inspector
- D. Jones, Senior Radiation Specialist
- P. Stohr, Director, Division of Radiation Safety and Safeguards
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- M. Thomas, Reactor Engineer
- Attended Exit Interview
2.
Changes (83728)
The inspector reviewed changes since the last inspection (Inspection
Report 93-28, dated June 21-25,1993) in organization, facilities,
equipment and personnel and how they relate to the occupational
radiation protection program. This inspection noted that no significant
organizational or personnel changes had occurred in the licensee's
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program since the last inspection. The position of Radiological
Controls Manager remains vacant. The Radiological and Chemistry Manager
was performing both jobs. An active job search was underway to fill the
vacancy.
No violations or deviations were identified.
3.
Facility Tours (83728)
During the onsite inspection, the inspector toured all levels of the
Auxiliary Building, the Unit 2 containment, the Control Room, and
selected areas of the Dry Active Waste (DAW) building and other outside
support buildings. The inspector noted that overall the housekeeping in
the Unit 2 containment was appropriate for the work underway. The
greenbag trash sorting area and the DAW building were orderly and a
campaign to reduce the volume in the DAW building was actively underway.
The inspector checked calibration dates for selected survey meters and
air samplers and found all to be in current calibration.
No violations or deviations were identified.
4.
Radiation Controls (83728)
a.
Posting
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 posting and labeling
against radiation and contamination levels in radwaste storage
areas, pump rooms, decon room, hot tool room, control room, and
other support buildings onsite. The inspector determined the
posting and labeling to be consistent and appropriate, and
followed the requirements of the licensee's procedures. All
step-off-pads from contaminated areas were clean and in good
condition.
b.
Surveys
10 CFR 20.201(b) requires each licensee to make or cause to be
made such surveys as may be necessary for the licensee to comply
with the regulations in 10 CFR Part 20 and are reasonable under
the circumstances to evaluate the extent of radioactive hazards
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that may be present.
During the tour, the inspector independently verified radiation
and contamination surveys. All radiation and contamination
surveys performed by the inspector did not find any abnormal
levels with the exception of one smear on a flashlight stored on
an equipment cart outside a contaminated area in the Railroad Bay
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Rad DI area (about 4500 dpm/100 cm ).
The licensee responded
immediately and took additional surveys and determined that the
flashlight was the only contaminated item on the cart. The
inspector took additional independent smears in various locations
in this area and in various other selected areas of the Auxiliary
Building, hot tool room and other support buildings and determined
that this appeared to be an isolated occurrence. The contaminated
flashlight outside of a contamination zone was identified as an
NRC identified procedural violation of _ Procedure RCI-1,
Radiological Control Program, Revision (Rev.) 44 dated August 28,
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1993, and Procedure RCI-21, Control of Radioactive Material and
Storage Areas, Rev. 1, dated July 31, 1992. This violation will
not be cited because of the aggressive efforts in investigating,
identifying, and correcting the violation. These actions meet the
criteria specified in Section VII.B of the Enforcement Policy.
Non-Cited Violation (NCV) 50-327, 328/93-44-01:
Failure to follow
Radcon Procedures RCI-1 Radiological Program and RCI-21 Control of
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Radioactive Material and Storage Area.
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During the tour of the Auxiliary Building, the inspector also
found a radioactive materials tool room bag outside of a
contamination zone at Panel 2-L-55A improperly tagged. The bag
contained several small test fittings and gauges. A smear of the
fittings was taken and they were found slightly contaminated
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(about 1600 dpm/100 cm ),
these tools appeared to be staged
outside of the contamination zone in preparation for 2-SI-SXV-000-
003.0, Full Stroking of Category A and B Valves During Cold
Shutdown, formally SI-166.3. The improperly tagged bag and
material were identified as an NRC identified violation of Radcon
Procedure RCI-21, Control of Radioactive Material and Storage
Areas, Rev. 1, dated July 31, 1992, Step 6.A.1-6.A.5 and
10 CFR 20.203 f(l)(2). The inspector also identified that the site
General Radiation Training (GET 23 Radiological Control) and
Retraining Category II was deficient in the explanation of rad
material tagging and controls. As a result of this finding the
licensee initiated a Problem Evaluation Report (PER) (SQ930520PER)
on September 14, 1993.
Violation (VIO) 50-327,328/93-44-02:
Failure to follow Radcon
Procedure RCI-21, Steps 6.A.1-6.A.5 and 10 CFR 20.203 f(1)(2).
One cited and one non-cited violation were identified.
5.
As Low As Reasonably Achievable (ALARA) (83728)
10 CFR 20.1(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.
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The inspector discussed radiation work permit (RWP) job knowledge and
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general ALARA awareness with selected workers during facility tours.
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The workers were knowledgeable about the ALARA program and the RWPs
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under which they were working. The inspector reviewed records of health
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physics (HP) surveys and monitoring provided during selected RWP
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activities and found them adequate to meet the RWP requirements. The
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inspector also reviewed pre-job briefing and post-job ALARA planning and
reviews of RWP activities and verified that appropriate controls were
taken to maintain exposure ALARA.
The inspector noted that as of September 3, 1993, licensee records
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indicated that the current dose of 316.617 person-rem for FY 93 should
not exceed the FY 93 goal of 400 person-rem based on current work
schedules. The outage goal for Unit 1 Cycle 6 (UlC6) was 300 person-
rem. At the time of the inspection the outage dose was 254.772 person-
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rem.
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The inspector noted the continued downward trend of collective dose per
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reactor.
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Year
Person-rem / reactor
1982
570
1983
246
1984
559
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1985
536
1986
263
1987
210
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1988
339
1989
329
1990
839*
1991
349
1992
227
1993
170 (projected)
- Inspection Report 91-28, dated January 3, 1992
The inspector also reviewed the use of respirators and noted that the
number of issued respirators had been significantly reduced from about
7000 respirators in UICS outage compared to about 1200 respirators on
U2C5 outage.
The following ALARA Committee meeting notes were reviewed:
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January 25, 1993
February 11, 1993
February 23, 1993
March 11, 1993
April 2, 1993
May 11, 1993
June 4, 1993
August 13, 1993
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Procedure RCI-10, ALARA Program, Rev. 20, dated April 12, 1993,
established guidelines and instructions for the organization, function,
responsibility, and operation of the site ALARA Committee. The inspector
selectively reviewed documents and actions of the committee and
determined that it was performing the required functions. The ALARA
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suggestion program was reviewed. The program was outlined in Appendix B
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of RCI-10. A selective review of the 16 suggestions submitted thus far
this year indicated that the system was functioning as stated and that
the suggestions were receiving adequate review and are being tracked for
implementation or close out.
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Selected ALARA Planning Reports were reviewed (APR-0025, Ice Condenser
Modifications, and APR-0014, Scaffolding for UIC6 Outage) and they were
determined to have followed the procedural requirements of RCI-10.
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The inspector reviewed personnel dose tracking and determined that
approximately 2.468 person-rem had occurred due to rework.
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following jobs contributed most to personnel doses:
Job
Person / Rem
Nozzle Covers
0.775 person-rem
Transfer Canal
(Level Switches)
1.000 person-rem
Refabricate drain inserts
for ice condensers
0.500 person-rem
0.571 person-rem
TOTAL
2.468 person-rem
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The licensee was aggressively tracking personnel doses and job growth
doses in an effort to minimize personnel doses.
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No violations or deviations were noted.
6.
Radiological Awareness Reports (RARs) and Personnel Contamination
Reports (PCRs) (83728)
a.
RARs
The inspector reviewed selected RARs and found them to be
complete. Root causes and work groups were being tracked to
identify any early adverse trends.
b.
PCRs were reviewed and a total to date of 50 had occurred for
VIC6. This compares favorably with an outage goal of 65. Trends,
root causes, and work areas were being tracked. Approximately
29 percent of the PCRs were caused by personnel error with
approximately 46 percent resulting in clothing contaminations.
Maintenance and Modification groups contributed approximately
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57 percent of the PCR totals. The licensee had established a goal
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of <0.75 PCEs per 1000 RWP hours and at the time of the inspection
was at approximately 0.34 PCEs per 1000 RWP hours.
No violations or deviations were identified.
7.
Training (83728)
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10 CFR 19.12 requires the licensee to instruct all individuals working
in or frequenting any portions of the restricted areas in the health
protection aspects associated with exposure to radioactive material or
radiation, in precautions or procedures to minimize exposure, and in the
purpose and function of protection devices employed, applicable
provisions of the Commission Regulations, individuals responsibilities,
and the availability of radiation exposure data. The inspector reviewed
the following:
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GET 023.000, Rev. 4, " Radiological Control Retraining,"
Category II Student Manual which provides refresher radiological
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training for RWP workers.
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GET 023.000, Rev. 6, " Radiological Control," Site Specific Packet
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which provides radiological training for RWP workers.
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From review of these training procedures and interviews with RWP workers
and HPs, the inspector determined that with the exceptions noted in
Paragraph 4.b, the Radiological Control Training Program provided
adequate training to workers potentially exposed to or required to
handle radioactive materials met the provisions of 10 CFR 19.12. The
inspector also reviewed selected training records for workers signed on
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RWPs. The inspector observed workers performing work on RWPs and found
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their work practices to be acceptable.
No violations or deviations were identified.
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8.
Audits and Appraisals (83729)
Technical Specification (TS) 6.5.2 requires that audits of plant
activities be performed under the cognizance of the Nuclear Safety
Review Board. Section 6.5.2.8 requires that audits encompass
conformance of facility operators to all provisions contained in the
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TS(s) and applicable license conditions at least once per 12 months.
The inspector discussed the audit and surveillance program related to
radiation protection with licensee personnel and reviewed the results of
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audits (Audit Report No. SSA93306 dated May 12, 1993, First Quarter
Assessment of 1993 dated April 28, 1993, and Assessment NA-SQ-93-018)
performed by Nuclear Assurance since the last inspection.
In general,
the audits were found to be well planned, well documented, and contained
items of substance relating to the radiation protection program.
Corrective actions of audit findings were being accomplished in a timely
manner. The inspector also discussed the Radeon Performance Based
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Evaluation Program to be implemented prior to the next scheduled
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refueling ' outage (Spring 1994). The Performance Based Evaluation
Program appears to provide a more formal method to evaluate and document
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worker and Radcon performance.
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The timeliness, depth, diversity, and details included in the audits
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were identified as a program strength.
No violations or deviations were identified.
9.
Licensee Actions on Previously Identified Inspector Followup Item'(IFI)
(92702)
(Closed) IFI 50-327,328/92-13-01:
Replacement of valves containing
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stellite with valves containing little or no stellite.
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The inspector reviewed progress to date and the target implementation
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dates for this IFI by interviewing management personnel and reviewing
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files, tracking lists and meeting minutes. Significant progress had
been made in this area with suppliers identified and an action plan
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developed.
10.
Licensee Actions Regarding Previous Enforcement Items
a.
(Closed) VIO 50-327, 328/92-25-01: The inspector reviewed the
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Reply to a Notice of Violation dated May 28, 1993, and.-
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independently verified the licensee actions to correct the
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violation and prevent its recurrence.
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b.
(Closed) 50-327,328/93-28-01: The inspector reviewed the Reply to
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a Notice of Violation dated August 25, 1993, and independently
verified the actions taken by the licensee and determined the
actions to be effective in preventing its reoccurrence.
c.
(Closed) VIO 50-327, 328/93-28-02: This violation was
administrative 1y closed in NRC letter to the licensee dated
September 9, 1993.
In that letter it was acknowledged that no
violation had occurred.
d.
(Closed) VIO 50-327,328/93-28-03: The inspector reviewed the
Reply to a Notice of Violation dated August 23, 1993, and
independently verified the licensee actions to correct the
violation and prevent its recurrence.
11.
Exit Meeting (83728) (92702)
The inspector met with licensee representatives indicated.in Paragraph I
at the conclusion of the inspection on September 17, 1993. The
inspector summarized the scope and findings of the inspection. The
inspector also discussed the likely.information content of the
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inspection report with regard to documents or processes reviewed by the
inspector during the inspection. The licensee did not identify any such
documents or processes as proprietary. Dissenting comments were not
received from the licensee.
Item Number
Description and Reference
50-327, 328/93-44-01
NCV - Failure to follow procedures for
control of a contaminated flashlight
(Paragraph 4.b).
50-327, 328/93-44-02
VIO - Failure to follow procedures for
tagging and labeling radioactive material
(Paragraph 4.b).
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