ML20059C428
| ML20059C428 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 10/26/1993 |
| From: | Fenech R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9311010153 | |
| Download: ML20059C428 (5) | |
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Tenner,s se vaney Aatncry rett office eu mol sadarDamy. Temessee 37379 xx.o 1
Robert A. Fenech v.ce hesomt, secpoye tociew Rant j
i October 26, 1993 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 i
Gentlemen:
1 In the Matter of
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Docket Nos. 50-327
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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 VIOLATION (NOV) 50-327, 328/93-44-02 The enclosure contains IVA's response to William E. Cline's letter to Mark O. Medford dated October 1, 1993, which transmitted the subject NOV.
The violation is associated with the failure to comply.with plant procedures. An unattended and unlabeled yellow bag, which contained radioactively contaminated material, was discovered in the auxiliary
'I building outside a radioactive materials storage area.
There are no commitments associated with this submittal.
If you have any questions concerning this submittal, please telephone K. E. Meade at (615) 843-7766.
Sincerely.
0 "A
Robert A. Fenech i
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Enclosure cc:.See page 2 010037 b
9a1101013a 9a1026 Q[m[
gDR.ADOCK 05000327 h
U.S'. Nuclear Regulatory Commission Page 2 October 26, 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 i
-Regional Administrator U.S. Nuclear Regulatory Commission Region II i
101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323-2711 l
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ENCLOSURE REPLY TO NRC INSPECTION REPORT NOS. 50-327, 328/93-44 WILLIAM E. CLINE'S LETTER TO MARK 0. MEDFORD DATED OCTOBER 1, 1993 Violation 93-44-02
" 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.
" Radiological Control Instruction (RCI)-1, Radiological Control Program,-
Revision (Rev.) 44, dated August 28, 1993, requires in Step 5.3.1 that
' Equipment and material being transferred from the RCA to a clean area, being transferred between different areas within the plant, or being unconditionally released offsite, shall be appropriately decontaminated and surveyed by RADCON. '
"RCI-21, Control of Radioactive Material and Storage Areas, Rev. 1, dated July 31, 1992, requires in Step 6.0.A,
'Any material, equipment, etc.,
which is greater than 100 cpm as measured with a frisker type instrument or is greater than 1000 dpm/100 sq.cm. transferrable as detected by the appropriate counting equipment shall be marked in accordance with 10 CFR 20 to include the radiation symbol and the words ' Caution, Radioactive Material' conspicuously affixed and shall have, as a minimum, the following information:
l 1.
Radiation levels (Beta and Gamma) 2.
Contamination levels (internal, if practical, and external) 3.
Date Surveyed 4.
Surveyed By 5.
Contents.'
"RCI-21, Step 7.1.A states, ' Radioactive material shall be stored in a Radioactive Material Area.'
RCI-21, Step 7.1.C states, ' Radioactive Materials Areas established within the RCA shall be posted as a minimum, Caution, Radioactive Material Area, Notify H.P. prior to entry.'
"RCI-21, Step 9.0.A.1 states, 'All. equipment / material being removed from a contaminated area shall be bagged or properly wrapped to prevent the spread of contamination.
Prior to removal, Field Operations shall be notified, and the equipment / material shall be surveyed by field Operations as soon as possible.'
i "Co,ntrary to the above, the.12censee failed to adequately control radioactive material in that on September 13, 1993, an unattended transfer bag containing unlabeled radioactively contaminated material in excess of 1000 dpm per 100 sq. cm. was found outside a Radioactive Material Storage Area.
"This is a Severity Level IV violation (Supplement V)."
J Reason for the ViolatiDD This violation was caused by a personnel error. The subject bag contained the fittings and tubing that were routinely used to install test gauges.
In this particular case, a test gauge was to be installed in order to perform a surveillance test.
Two assistant unit operators (AU0s) were preparing to install the test gauge, which was in a contaminated zone (C-zone), when a problem with the test procedure was encountered. The AUOs left the area in order to resolve the procedural discrepancy. The subject bag, which had never entered the C-zone, was left unattended at the stepoff pad. At this point, an NRC inspector performing a tour of the area noticed that the bag was unattended with no labels to explain its contents or why it was at that location. The inspector notified the appropriate Radiological Control personnel, and the bag was secured. The fittings and tubing in the bag were surveyed to determine their contamination levels.
The internal surfaces of the tubing were found to have a surf ace contamination level slightly above the radiological control limits. No other material in the bag was contaminated.
i The cause of this personnel error was carelessness on the part of the AU0s. The bag should not have been left unattended and should have contained the proper labeling.
Corrective Steps That Have Been Taken and the Results Achieved The Radiological Contr.
staff initiated a follow-up investigation that identified 20 additional bags stored in locked cabinets in the auxiliary building.
Theso bags also contained contaminated material without the proper labeling. Additionally, the interior surface of one of the cabinets was also contaminated. The noted discrepancies have been l
corrected.
An Operations superintendent standing order was issued to all Operations
-1 personnel explaining the event and the radioactive material control requirements.
A site bulletin was issued to all site personnel explaining the particulars of this violation and the radioactive material control requirements.
Enhancements have been made in General Employee Training to provide employees with additional information on the proper handling of radioactive materials.
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e The Radiological Control inspection and tour checklist has been revised to prompt personnel to inspect areas for proper storage and tagging of radioactive material.
The personnel involved in this event have been counseled on their responsibilities with respect to the control of radioactive material.
CarI_er11Ya lters l at Will be Taken to Avoid Further Violations The above actions will serve as recurrence control for this event.
Date When Full Compliance Will be Achieved SQN is in full compliance.
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