ML20059H043
| ML20059H043 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 08/21/1990 |
| From: | Gloersen W, Potter J, Shortridge R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20059H033 | List: |
| References | |
| 50-327-90-23, 50-328-90-23, NUDOCS 9009140202 | |
| Download: ML20059H043 (12) | |
See also: IR 05000327/1990023
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UNITED STATES
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NUCLEAR REGULATORY COMMIS$10N
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REGION 11
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101 MARIETT A STRE ET, N.W.
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ATLANTA,GEDR3tA 30323 '
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M)6 3 01990
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Report Nos.: 50-327/90-23 and 50-328/90-23
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Licensee: Tennessee Valley Authority
6N38a lookout Place
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1101 Market Street'
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Cnattanooga, TN 37402-2801
Docket Nos.: 50-327 a".1 50-326
Licensee Nos.:
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Facility Name: Sequoyah I and 2
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Inspection Conducte .
Ju e'25-29, 1990
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Inspecto :
R/B
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Fat ' Signed
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Approved by:
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d(P. . Potter,' ChWf
Uate' Signed
Facilities kediation Protection Section -
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Emergency Preparedness and Radiological
Protection Branch
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Division of Radiation Safety and Safeguards
SUMMARY
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Scope:
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This routine, unannounced inspecthn of radiation protection activities focused
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on the plant program to maintain occupational! dose to workers as low as
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reasonably achievable (ALARA).
Results:
No violations or deviations were identified. . All elements.necessary for an.
adequate ALARA program were in place.
However, there were weaknesses in
program implementation in the following areas:
accountability for. collective -
dose by department managers (Paragraphs 2.b and c); establishment of collective
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dose goals and management of collective dose (Paragraph 2.d); implementation of-
a comprehensive source term reduction program; at Sequoyah--(Paragraph 2.h).-
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reduction of contaminated areas of the plant (Paragraph 2.1); . awareness
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training for plant staff and radiological impact evaluators and implementation-
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of an ALARA standard for the station (Paragraphs 2.j and k). : Based on the
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telephone conversation discussed in Paragraph 3, the NRC, Region II-under_ stands
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that Sequoyah is taking action on several of these matters.
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9009140202 900830
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ADOCK 05000327
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REPORT DETAILS
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1.
Persons Contacted
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Licensee Employees
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- R. Beecken, Manager, Maintenance
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- H. Burrynski, Manager Site Licensing
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J. Bynum, Vice President, Nuclear Power Production
- W. Byrd, Manager, Project Controls & Financial Services
- R. Daniels Engineer, Nuclear Engineering
- G. Fiser, Superintendent, Chemistry and Environmental
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- S. Holdefer, Health Fhysicist,' Radiological Controls
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- G. Hudson, Corporate Manager, Radiological Controls
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- M. Lorek, Superintendent. Operations
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- J. Osborne, Health Physicist, Radiological Controls
- J. Proffitt, Acting Manager, Compliance Licensing
- W. Smith, Specialist, Quality Assurance
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- M. Sullivan, Superintendent, Radiological Controls
- P. Trudel, Project Engineer, Nuclear Engineering
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- C. Vondra, Plant Manager
- C. Whittemore, Engineer, Licensing
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Other licensee employees contacted during this' inspection included
craf tsnan, engineers, mechanics, technicians, and adn.inistrative
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personnel.
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Nuclear Regulatory Connission
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- P. Harmon, Senior Resident Inspector
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- D. Loveless, Resident Inspector
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- Attended exit interview
2.
MaintainingOccupational-ExposuresALARA(83728)
10 CFR 19.12, states, in part, that all individuals working in or
frequenting any portion of a restricted area; shall -be instructed in
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precautions or procedures to minimize exposure.
10CFR20.1(c) states,inpart.thatpersonsengagedinactivitiesunder
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licenses issued by the NRC should, in addition to complying with the
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requirements set forth in this part, make every reasonable effort to
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maintain radiation exposures, as low as reasonably achievable (ALARA). .
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Other recontended elements of an ALARA program are contained in Regulatory
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Guides 8.8 and 8.10.
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The following are observations that the inspectors made during the
inspection. The observations were idcntified for licensee consideration.
for program improvement, but have no specific regula*;ory requirement.
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a.
ALARA Program
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The station's ALARA program was controlled by three administrative
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procedures, ALARA Planning, Site ALARA Connittee, . and ' ALARA
Suggestion Procram.
These procedures described personnel functions
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and responsibilities for the program and name the Site Director as
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having the ultimate onsite authority and responsibility for its-
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implementation. The Superintendent of Radiological Controls (RADCON)
advised the Plant Manager and supervisors regarding dose reduction,.
and plant supervision was responsible for implerrenting procedures to
reduce collective dese.
In addition, first .line supervision was
responsibic to actively pursue' and encourage the subniittal of ALARA .
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suggestions, and each individual was to be cognizant of, and work to
minimize, his or her dose.
b.
Dose Accountability
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The inspectors reviewed the licensee's method to account for the
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station's collective dose.
The review included an examination of
selected ALARA pre-job and post-job reviews and discussions with
licensee representatives.
It was observed that for the Unit 1. (UI,
C4) refueling outage, approximstely 90 percent of the station's
collective dose (893 person-rem out of g8? person-rem accumulated)
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underwent an ALARA review.
On the average, the licensee had been
performing ALARA reviews for. approximately 85' percent of the
station's collective dose.
The licensee had an adequate program for
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dose accountability although, as .noted. . in Paragraph 2.c of this.
report department management was not always utilizing the information,
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All jobs whose estimated collective dose was greater than l' man-rem
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received an ALARA review by the radiological controls group.
Jobs
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whose estimate was greater than five person-rem went to the ALARA
Comittee for review.
Job history files which were used during the
review process, were maintained by the radiological l controls group.
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The _ inspectors also reviewed radiologicalt incident reports (RIP,s)
covering the period from January to June 1990, and observed that
there were no significant ALARA program weaknesses or trends
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identified. One RIR identified an isolated event in which a group of
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resistance temperature detector (RTD) modification' fitters removed.
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insulation 'and lead shielding without proper health. physics (HP)
coverage. The licensee took inrediate corrective action and escorted
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the fitters from the work area and analyzed their personnel
dosimeters.
There were no individual doses which exceeded the-
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administrative limits.
The long term corrective actions included
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retraining on RWP requirenents, a review of the event, and a review
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on the proper method to notify HP.
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During this inspection, interviews with several departmental n.anagers
cn ALARA awareness and accountability were conducted.
The licensee
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had identified that it was not clear that line n.anagement was held
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accounttble for radiological dose performance goals.
Licensee
representatives indicated that in response to this finding, inclusion
of departnental collective dose performance e als in departnental
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managers' performance appraisals would be evaluated and considered.
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c.
Dose Management
The inspectors interviewed several departmental managers, reviewed
managsment tools used to. track. collective dose, and reviewed the
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departmental collective dose perfonnance against the dose allotnent.
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Theinspectorsdiscussedwithlicenseemantgersandsupervisorsthe
utility s ALARA program, including their knowledge of ALARA goals,
concepts, policies - and procedures
individual responsibilities,
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personnel exposure, and dose limits.
Additionally, the discussions-
included managers' cons.unication with co-workers and supervisors,
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participation in the ALARA suggestion program, the n.anagers'
perspective on how to iniprove the ALARA program, what events have
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caused increased personnel dose, and what events or conditions have
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helped reduce personnel radiation doses.
The: inspectors interviewed
n.anagers or supervisors from the following departments: maintenance,
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nuclear engineering, operations, technical support, and steam
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generator maintenance.
Each individual interviewed was generally
familiar with' the basic ALARA concepts. - Additionally. -individuals
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interviewed knew that they had a- basic responsibility for-
implementing the utility's ALARA program by performing tasks in a
manner- consistent with the utility's ALARA- policy.
Although it
appeared that u.anagers were aware of departmental dose goals, only
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one of the n.anagers interviewed knew his numerical departnental
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collective dose goal.
'Similarly, only one of the managers
intin!iewed knew the current accumulated collective dose for his
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department.
Mr.nagere generally understood where the ALARA
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requirements originated and what utility docun.ents described the
ALARA program objectives.
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The inspectors also reviewed the licensee's department collective
dose performance against the various departnental goals.
Each
department except the Operations Department had exceeded its fiscal
year (FY)1990dosegoal. The data are sunenarized below:
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Departrent
FY 90 Goal
FY 90 Actual
(person-rem)
(person-rem)
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Maintenance
209
269
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Modifications
200
418
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Technical Support Services
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13
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Radiological Control
100 ,
111
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Quality Assurance
27
38
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Operations
30
23
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Nuclear Engineering
30
57
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65
139
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Other
18
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As will be discussed in Paragraph 2.d. of this report, the higher
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than projected collective dose was due to the work scope of the
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outage including RTD bypass renioval
UHI removal, steam generato.
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nozzle dem installation, and reactor coolant pump modifications.
The inspectors also reviewed the licensee's pethods for tracking
collective dose for effective. dose managenient.
It was observed that
the licensee had a good program for accessing the data base:to track
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individual dose, departmental collective dose, and job collective
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dose. These data were easily displayed numerically or in the form of
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charts and graphs that could easily be used by. the departniental
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manager to track, trend, and manage their dose allotment.- Through
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discussions with the licensee, it was noted that-during the. last
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outage only the Maintenance Departn.ent received collective dose trend
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charts.
Although the information was available, the other
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departnients had not requested nor had . they been provided the
collective dose summary information in order to aid in n.anaging their
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departmental dose allotment.
d.
Collective Dose Goal
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The inspectors reviewed the licensee's procedures and methods used to
establish the collective annual dose goal.
Based on a review of
data, procedures, and interviews with managers and ALARA group
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personnel, the inspectors noted that the site annual collective dose
goalwasbasedonworkscopefortheyearandwasinitially(developed
by the ALARA Cemittee.
The Radiological Controls Group Radcon)-
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forwarded to each department head the anticipated work scope for the'
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year and dose rates expected.
The department section heads provided
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the number of man-heurs and developed their FY dose estin.ates for
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subn.ittal to the ALARA Conmiittee for approval. After a review by the
ALARA Conuittee, the annual collective dose goal' approval chain was
the Plant Manager, Site Director, Vice President Nuclear Power
Production, and Vice President Nuclear Power..
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In mid-1989, Radeon collected department inputs for FY 1990 and
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submitted 912 persen-rem to the ALARA Comittee for approval.
On
October 13,1pCS, the ALARA Comittee sut" ited the estimate to the
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Site Director. The initial estimate was disapproved, and the goal was-
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established at CBS person-rem.
The goal of 685 person-rem was
exceeded in' April of 1990 due to 6dditional work sco>e, .an escalated
schedule, and weaknesses that are. discussed in deta'l later in the
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inspection report.'
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In June 1990, the superintendent of Radcon submitted a change request
for a new annual ~ collective dose goal of 1,365 person-rem.
The
justification for the amended goal was that work scope changes had
not been icehtified during the initial goal developnent, and a shift
of 20 days of the Unit 2, Cycle 4 outage into FY 1990 (20 days of
U2, C4 outage are expected to result;in as much as 350 person-rem).
In addition. -durin0 this FY 1990 goal development process, site.
rnanagement reduced the site goal to below what was in the goal basis.
The justificetion for the change was submitted on June 15, 1990, from
the V. P. Nuclear Power Production to the Senior V. P. Nuclear Power
and was rejected.
During this inspection, the Radcon ALARA group was in the process of
preparing a justification' for another change to . establish the
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collective dose-goal at 1,035 >erson-rem., The' inspectors noted that
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currently the site collective cose was at 1,075 person-rem, and three
months remained in FY 1990.
After interviews with key department managers and plant managenent'
(Paragraph 2.c), the inspectors noted that< the parties associated
with establishing an annual site collective dose goal did not appear
+o be comunicating well; that the current effort underway, if
approved, would not result in a realistic goal since it had been
surpassed;-and that the licensee was not effectively using the goal
process as one of the managenent tools to control collective dose at
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the station.
The inspectors noted the recomendations in Regulatory
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Guide 8.8 that meeting appropriate ALARA goals and objectives
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provided measures of ALARA program effectiveness.
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During the exit meeting, the Plant Manager stated that a realistic
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collective dose goal would be developed for the remainder of FY 1990,
c.
ALARA Reviews
Licensee procedure requires that. pre-job ALARA reviews be performed
for. all jobs in which the collective dose was expected to exceed
I rerson-rem or where radiation dose rates exceed I rem per hour.
/11so, for jobs expected to result in collective dose greater than
5 person-ren, an ALARA Comittee review was required. The inspectors
selectively evaluated prc-job ALARA reviews performed in 1990.s and
verified that appropriate dose reduction techniques and lessons
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learned from previous similar work were considered in the reviews. To
aid workers in reducing dose, dose reduction techniques and
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were listed on an addendum
requirements developed by the ALARA group (RKP) and'went to the field
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to the applicable radiation work permit
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as'sp cial instructions with the RWP.
The inspectors requested post-job ALARA reviews for 12 of the U1,
C4 outage high dose jobs.-
Radeon was still working with other
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department personnel on the post-job debriefings and provided six
completed post-job reviews.
Based on an evaluation of the post-job-
reviews and discussions with plant personnel, the inspectors
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determined that problems occurred during the outage that resulted in
higher than anticipated dose to workers. The following are the more
significant problems: -(a) non-critical path work was performed in
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containment when the reactor coolant- system (RCS) water level was .
drained for RTD bypass removal; the loss of water shielding resulted.
in an increase in radiation levels of 200-300 percent. . Dose cost was
46 person-rem; (b) minimal amounts of temporary lead shielding were
used due to unavailability, delays, schedule, and seismic restraints;
( 'e cost was 15 person-rem;-(c) poorly traintd and or inexperienced
> ;ers; dose cost 11 person-rem; (d) overcrowding,in work areas .and
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large use of respirators due to. high levels of. loose surface
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.ntamination; dose cost unquantifiable.
The_insSectors noted that
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the licensee had purchased additional temporary s11elding and other.
problems identified in the post-job debriefings were placed.on an
action item list to be resolved prior to the upcoming Unit 2 outage.
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The inspectors reviewed dose estimates for 55 jobs that included RWP
hours and dose rate information.
The following sunnary shows -the
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estimated versus actual performance:
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Percent of.
Estimated
Actual
Estimate
Number of people
3,603
7,460
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RWP hours
103,238
11%917
1111
Whole Body Dose
694.366
893,018
129
(person-millirem)
Whole Body Dose Rate
6.72
7.27
116
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(person-millirem /hr)
The inspectors concluded that the process for estin.ating doses for
jobs was good for the majority of jobs and that the post-job reviews
were identifying significant problems, that when corrected, would
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improve dose control.
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ALARA Consnittee
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The inspectors reviewed and discussed - with cognizant licensee
representatives the current: ALARA Connittee organization and its
functional responsibilities.
Details regarding the Connittee
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organization and functions were_ outlined. in SQA-209, " Site ALARA
Comittee," Revision 1 dated April 9,1990. The Comittee consisted
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of at least one representative each from radiological controls,
maintenance, operations, modifications, site OA, and nuclear
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engineering whose attendance was required for a quorum.
Representatives from:the corporate. office were normally invited. .
- The Connittee reviewed ercas of potential exposure in the plant:to-
determine mechanisms to reduce doses and to review dose saving
suggestions for viability.
The Chairman of the Comittee was
nonna11y the= Maintenance Penager; however, this responsibility ~ was
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recently being shared with the Plant Manager.
By procedure, the ALARA Comittee was required to meet quarterly;.
however,- during the outage period the Comittee would reet nore
. frequently, typically. weekly to tronthly.
Af ter reviewing Comittee
meetino . attendance records for 1990, the inspectors noted two
cancelled neetings due to lack of attendance.
The inspectors
reviewed the topics discussed during the ALARA Comf , tee neetings
which mainly consisted of review and approval of high dose jobs and a
review of ALARA suggestions.
Recently, the threshol . for requiring'
the site ALARA Comittee to review and. approve work Das reduced from-
10 to 5 person-rem.
Additionally, the site ALARA Comittee was
recently given the responsibility to review containment power entries
and establish designated containment power entry days for scheduling
and coordinating work.
Also, the site ALARA Comittee was. tasked
with performing quarterly reviews of departmental and station dose
goal performance and making recomendations and : adjustments .when
necessary.
The licensee's ALARA suggestion program was effective, with 'several
dose savings suggestions implenented.
In 1989,.33 ALARA suggestions
were submitted, and eight were being implemented to dete.
In 1990,
14 suggestions were submitted, and two were being implerented.
The
licensee's incentive program has resulted in individuals submitting
viable suggestions.
An liLARA subcomittee prereviews_~ all ALARA
suggestions and submits the best ones to the : ALARA Comittee for
consideration,
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Dose Reduction Initiative
The inspectors discussed with licensee representatives. from both the
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station and the corporate office, several dose reduction initiatives
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which have been implemented.
It was noted that the licensee had
implemented an induced crudburst control and cleanup program at the
station.
The program allowed the. licensee to control when a
crudburst would occur by adding hydrogen peroxide to' the primary
coolant system and removing the activated crud using the ion exchange
purification system. This-program helped the licensee lower the dose
rates and contamination levels in the primary system and irtprove-
water clerity for refueling operations.
During the U1, C4 outage,
hydrogen peroxide was added to the primary coolant with the system
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con.pletely full which maximized the Co-60 removal due to the
increased letdown ficw rate and circulation 'in .the' loops.
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licensee had also undertaken several other dose reduction projects.
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The following dose reduction initiatives were either completed or
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scheduled:
Reactor head instrument port conoseal c1kmp replacement
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RTD menifold removal (U1 con.pleted; U2 scheduled for FF4),duled
Upper head injection system removal (U1 completed; U2 sche
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Laser videodisc and photographic display system (U1' completed;
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U2 scheduled for RF4)
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Reactor coolant pun.p cartridge-type seal nodification (two RCPs-
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per unit remaining for modification)
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Modification on steam generator nozzle dam.s to reduce time for
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installation in steam generator channel head (Unit I completed;
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Unit 2scheduledforRF4)
Additionally, the inspectors' noted that.the licensee was considerin
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the acquisition of a permanent reactor-head shield to reduce genera
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area dose rates during fuel movement.
Acquisition of a head shield
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was slated for the Fall of 1991.
The inspectors also discussed with licensee representatives the use
of temporary shielding during the U1', C4 outage.
It was determined
that several scheduling constraints and seismic concerns precluded
shielding crews from installing some shielding near the RTD manifolds
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which resulted in- higher doses for- crews performing S/G sludge-
lancing operations.
Another contributing problem was a lack of lead
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shielding.
The inspectors discussed with representatives from the.
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corporate office and the station the use of standard load tables for
adding temporary shielding to piping and various components to aid in
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reducing the amount of time for approval and installation of
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temporary shielding during outage critical path periods,
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Source Term Reduction Initiatives
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The inspectors discussed with licensee representatives from the
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station and corporate office methodsi for reducing out-of-core
radiation sources ' which would offer -the greatest potential for
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continued reductions in occupational radiation dose.
The
techniques
discussed
included
cobalt . source
reduction.
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preconditioning of out-of-core surfaces, control of crud transport,.
and chemical decontamination.
Earlier this year, the licensee's corporate office had identified the
need-to formulate a concerted source term reduction program.for TVA.
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The corporate chemistry department initiated a plan to formulate
connittees to address source term reduction initiatives such as:
stellite control, system preconditioning, chemical decontamination,
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and elevated reactor coolant pH.
The licensee's_ Watts Bar= facility
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had comitted the resources to help develop and implement the source
term reduction initiatives.
With site-specific cdjustments, the licensee's corporate office
planned to apply the source term reduction initiatives at the other
TVA facilities.
As of this inspection, the licensee's source term
reduction plan was still in the developmental stages; consequently a
site-specific plan for the Sequoyah facility had not been addressed..
HowcVer, as noted in Paragraph 2.g, the licensee's Sequoyah facility
has taken the initiative to reduce future occupational collective
rediation dose by component removal, such as the RTD bypass manifolds
'and the upper head injection system on Unit-1, and hydrogen peroxide-
cddition at shutdown.
The inspectors noted that there was no
schedule for application of the Watts Bar initiatives at the Sequoyah
facility.
1.
Contaminathn Controls
The inspectors reviewed the licensee's program to control
contaniination at the source.
The inspectors noted the licensee had
exceeded the goal of 240 personnel contamination events (PCEs) by 12
at the end of June.
Licensee personnel stated that, although six
weeks of the Unit.2 outage is scheduled for this FY, they felt that
PCEs will be lower than the pre.vious two years of 409 in 1988 . and
435 in 1989.
During tours of the radiologically controlled area (RCA)- of: the
plant, the inspectors observed that large areas were being controlled
as contaminated after the outage.- Based on licensee data, the total
RCA was 228,940 square feet (ftr) of which 8,200 fte of reclaimable
and 17,200 ft2 of non-reclaimable area existed prior to the U1, C4 -
outage.
During the inspection the - licensee was maintaining
13,612 fte as reclainable and 17,000 fte as non-reclaimable
contaminated area for a total of 30, 612 ftr. : The -inspectors
determined that a significant cmount of non-reclaimable area at
Sequoyah was normally considered reclaimable at other utilities. The
inspectors interview d licensee personnel and learned that the higher
priorities. may have prevented engineering approval to- place pump
shaft guards on pumps in radioactive systems.
Such guards would help
contain contan.ination.
Consequently pun.ps with radioactive leaks
resulted in whole rooms being contaniinated rather than just the pump
bed.
Licensee personnel stated that at the end of the outage the intent
was to reclaim areas that became contaminated during the outage, but
resources to acconiplish - this were eliminated.
Also, licensee
representatives stated that durin
resources (training and staffing) g both normal and outage periods
were limited in comparison to the
task.
The inspectors discussed this issue with plant management and
were- inforned that the engineering problem regarding approval for
containnents would be given inmediate attention 'and that for . Unit 2
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outage personnel would be inade available for' decontamination work.
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Licensee managenent stated that it was their goal to reclaim
contandnated areas during the titre between obtages 50 that the total
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contendnated area would be the s6ne going into the next outage as
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there was going into the past outage.
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ALARA Training
The inspectors toured the Plant Op(erations Training Center and
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reviewed general erployee training GET) lesson plans.
1he lesson
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plans appeared to be well developed as were the instructor teaching
aids.
Based on interviews with instructors and plant. personnel, the
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inspectors learned that, other than GET, plant personnel did not'
receive additicr.61 classroom training in ALARA concepts, techniques,
or practical factors. The licensee, in the past year, had eliminated
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from the station's curriculum ALARA Awareness training and' Advanced
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Radiation Worker training. - In addition. the number of instructors-
providing the training had been cut back.
ALARA Committee neeting
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minutes 90-18. June 15,1990, recorded that employee exit interviews
revealed a number of concerns relating to dose reduction. The ALARA
Comittee, in seeking a resolution to this item, had requested that
GET be reviewed for ALARA content.
The inspectors ' concluded that
although training tret the requirements of -10 CFR 19.12, there had
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been reductions in that area of training that had been intended to
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result in better worker dose control.
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Audit Program
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The inspectors reviewed audit reports perforrned by the fluclear
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Quality Audit and Evaluation- (NOA&E) group and surveillances
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performed by Quality Assurance Organizations for radiological
controls.
In general the eudits and surveillances were indepth and
substantive.
NQA&E audit Report ho. SQA 89002, dated January 9,
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1990, focused on ALARA and radiological effluent monitoring.
Overall, the audit found that the ALARA program was adequate- and-
cffective, and cited a number of strengths.
However, a condition
adverse. to quality was found regarding the failure to implement an
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ALARA standard.
In discussions with' ALARA group- personnel, the
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inspectors learned that the need for an ALARA standard was identified
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by the corporate office and that Nuclear Engineering (NE) had three:
design guides for use for ALARA reviews. These design guides had not
been formalized into the program,- DesignChanceNotices(DCNs)were
routed to Radcon engineers f 'a courtesy. and that Radcon had a
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backlog of up to six months between receipt and complation.
This
delay. in corrpletion was-attributed to the reduced level of'the ALARA
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staff and an increase in DCNs.-
In managerrent . interviews. the
Chairman.of the ALARA Comittee stated that a large number of DCNs
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were issued during the outage and that it impactec the work of the
' ALARA Connittee.
The inspectors reviewed thc change to Radcon
Instruction 10, Implenenting ALARA- for - Radiaticn Exposure and -
Radiological Environnental Imptets" and noted that the standard was
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approved.
However, it was not approved for in.pleneentation by NE due
to lack of staffing resources.
The new change implementing the
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standard would - require that radiological impact evalut,tions be
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conducted for most site radiological work. The standard also requires
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that ALARA Awareness training be given to all NE radiological in. pact
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evaluators.
The inspectors noted that the standard was approved by
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the station en July 17
1969, but had not been implenented in the
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- past year,
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The inspectors in reviewing surveillances of the radcon' program noted
a significant number of worker radiological knowledge problems were
identified as well as compliance problems.
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The inspectors determined that the audits and ~ surveillances were ;
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generally indepth and docunented substantive prcblems that were being
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addressed by the licensee.
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3.
Exit Interview
The inspection scope and- findings were supinarized on June 29, 1990, with
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-those persons indicated in Paragraph 1.
The items discussed are outlined
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in the sunnary to this report.
Licensee management stated that it was
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their position that the station.was operating the ALARA program with a
realistic collective dose ' goal.
The licensee stated that it was their
intent to fully account for the collective dose for the remainder of -
FY 1990; however, the licensee was not able to offer a specific number for
the collective dose goal.
The licensee made an oral- commitment. to
establish a realistic annual collective dose goal for the remainder of
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FY 19M. On July 30, 1990, D. Collins ,-' B. Wilson - J. ' Brady. . R. Shortridge :
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of Reglon II NRC and C. Vondra, C. Kent, and C. Whittemore of Sequoyah
Nuclear plant participated in a telephone : conversation relating to the
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weaknesses identified in the report and actions that are being taken by
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the licensee to resolve the weaknesses. . During the- telephone conversation,
the licensee outlined the following- insnediate actions: ' (1) the licensee
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has established a monthly collective dose goal and will manage collective
dose using this as e management tool-through FY 1990; (2) Sequoyah has
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formally established a task force to develcp a comprehensive source term
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reduction plan; (3) additional resources have been provided to recover
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contaminated areas of the plant' that resulted from the U1, C4 outage and
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plans are to recover these areas ' prior. to the U2, C4 outage; (4) the-
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licensee plans to use more temporary shielding for. the upcoming outage;
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(5) the licensee dons not currently plan to implement the ALARA Standard'
for Nuclear Enginee-ing or provide formal ALARA training other than than
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currently provided in GET or in preparation for special activities, and
(6) the licensee hhs included more senior nembers of .the plant staff on
the ALARA Conrnittee, which is now chaired by the Plant Manager.- The
licensee did not ide~ntify any of'the material provided to, or reviewed by
the inspector dur'.ng the inspection, as proprietary.
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