ML20077L174
| ML20077L174 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 08/05/1991 |
| From: | Joshua Wilson TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9108120113 | |
| Download: ML20077L174 (5) | |
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August 5. 1991 U.S. 1. clear Regulatory Cominission i
ATTN:
Do c ene n t, Cont'ol Desk c
W t.hington, D.C.
20555 Gentlemen:
In the.Mattar of
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Docket Nos. 50-327 Tenne 8 se:e Valley Authority
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50-325 S5QUOYAd LCLEl.A PLANT (SQN)
.iRC INSPFCTION REPORT 50-327, J29/9'. RESPON5E l'O NOTICE OF '/10LATION 50-327, 3'J/91-10-01 The enclosusu provider. TO. response to B. A. WIAson's letter to D. A.
Nauman dated July 5,1991, which '.ransmit+.ad tt.e subject 'otice of violatirsn. eg;arding inuiv iduals f ailing to comply wi th ti.u rodietion work permit procedural requirements when entering high radiation areas.
l If you have any questions concerning this sulo1 tal, please telep%cae M. A. Cooper at (615) 843-8422.
Very truly your;,
TE.'NESSEE VALL:'Y AUIPOR'TY S /V
J 'L. Wilson inclasure ec:
See page 2 O) p'
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9103120113 91080")
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I PDR (40GCK 05000327 Q
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2 U.S. Nuclear keg'ilatary :otnmissior August 5, 141 cc (Enclosure):
Mr. D. E. 1.aFarge, Project Manager U.S. Nuclear regulat>ry Comnission Cte White Flint North 11555 Reckville Pike Rockvii.le, Maryland 10852 d
NRC Resident Insy ctor Sequoyah Nuclear l'lant 2600 Igo's Fe-t y Road Soddy Dainy. Tennesree 37379 Mt. B. A. Wilson, Project Chief (1.S. Nuclear Regt.latory (ommission M
Region 11 101 Marietta Street, NW, Suiti. 2300 3
l Atlanta, Georgia 30323 I
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b IGMLOSt"tE R7SPONSE TO Nhc INSPECTION REPORT NOS. 50-327/91-10 AND ;0-128/91-10
- 6. A. WILSON'S 1.ETTER TO D. A. NAUMAh l
DATED JULY 5, 1991 I
50-327,,328/91-10-01 Violation 1
" Technical Specification (TS) 6.12.1 re.luires that in lieu of the ' control device' er 'alare signal required t>y F.itograph 20.203(c) of 10 CFA 20, each high radia.lon area in which the intensity of radiation is greater than 100 mrem /hr but lens than 1,0C0 mren/hr shall be barricaded.nd conspleucusly posted as a high radiation arer. at.:) entran;e thereto sha41 be controlled by requiring issuance of a spec 2a1 Dndiatiou kotk Pcrmit. Any individual or group of individuals permitted to enter such arecs shall be provided with or
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accompanied by cne'of the following:
"1.
A radiation monitoring device which continuously indicates the ras'lation dose rate in the, area.
"2.-
A radiation monitoring device which cantinuously integrates the radiation dose rate in the area and alarms when a preset integre*.ed dose is received.
Entry into such areas with this monitoring device umy be made after the dose rate level in the area has been established and personnel have been made knowledgeable of them.
"3.
An individual quullfied in radiation protection procedures who is equipped with_ a radiation lose rate nonitoring device. This individual shall be responsible for providing positive cantrol over the activities within the area any shall perfarn periodic radlation surveillance at the frequency specified by the facility Health Physicist in the Special Radiation Work Permit.
" Contrary to the above, in the following exaeples, individuals entered a high radiation area without either a radiation monitoring dsvice which ci.atinuouely indicaeed the radiacion dose rate, that intebrated the radiation dose rate in
'he~ area and ainemed when a preset dose was received, or an individual qualified in radiation' protection procedures equipped with a dose rate nonitoring devica.*
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On July 10,;1990, a fire watch entered the Unit 2 annulus.
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On_0ctober 23,?1990, modifications paraonnel ente' red the Unit 2 fan room #2.
"3.
On Aprit 13. 1991". modifications personnel entered the Unit 1,
_630 [tici feet elevation pipe chase.
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On May 3, 1991, a modificattons person entered Holdup Tank Room.B.
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"This is a Sevotity Level IV.ulciation (Supplement it).'
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n Admission or knial of the Alleged Violttion TVA admits the violatlon.
Reason for the Viol tion The four exsmples included in the ARC violation were identified and reported as 'iolathos of the SQN's radiological contti. program.
Each I..cideent was reported as r'. quired by Site Standard Practice 5.'a,
" Reporting of Radiological incidents." Each incident van reviewed atal prompt currcative action was tsken based upon the oarticular set of circumstances. The cause of each incident involved either personnel error, miscomunication, and/or lack of attention to
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ignoring posting in a radlologically controlled area (RCA).
The root cause for the reper.ced events was a failure of the trending pragram to identify anu escalate t he adverse t rend to appropr iat.e management 's attention (c
- appropriate corrective ai tions.
Corrective Stern That llave Been Taken and Results Achir,vyd In each irstan o, the personnel involved were premp'.ly counselad regarding the requirements and future expectations. As warranted by the individual case, additional lustruction through group safety meetings and disciplinary actionr were used to act,*. eve improved perf ormance. A altewide employee natice was Ir, sued June 13, IT11, detailins, requiretrents f or high radiation at aa (!!RA) entry. The problems with the !!RA er.try lu gue were discussed in the plan-of-the-day meeting to alert plant groups of the recurrence of the problems and the need to escalate n.anagement'r involvement ir these events.
This discussion was followed with formal orrespondence to site department managers requiring increased attention to cetail and emphasia on worker compliance.
'Ine encrunce u the RCA hu been modiis ed to provido increued int 3rface bnween Radiological Control pernannel and the plans work force.
This u expected to improve the worker awareaena of radiological c ond i t i or.a.
and through more rigorous briefingr, reduce the likelihood of inappropriate L
actions.
The radiologicat awareness report trending and evaluation process has been reviewed, and improvenents have hee.. Implemented to ensure problem are propery identifled, trended, and reported to management.
RAR violatione that are in noncompliance with SQN TSs or could potentially result la TS violationa are now separated and trendel in a separate category. The increased trending of violationa on entry int a HRAs will provide management an early warning of developing problems no ' hat esca Lted management attention and aggressive actions can be taken in prove.nt f urtrar occurrences.
As a result of these actions, there as a significant increased wor'<er and management awat wuss of these inappropriate actions and what is expected to comply with these requiremem s.
Radialogical Control's awareness of work activit i es withir the RCA aad wcrker brief!ngs associated with radiological coaditior.s within the plant have imoroved.
Th. radiological control program requires radiological control personnel be stationed at the entraace to the RCA.
Thercfore, personnel entering the RCA will be questioned by radiologleal control personnel as tol the reason for entering the RCA1 activities plannei and ensure the ladividuals have proper dosinstry.
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-3 A review of the usage of swing gates was per fortned and determined that under proper operatit;n, the gates provide an ef fective barrier to liras and that tiRAs are typically co med in more than one place. A site-wide dispatch has been it. sued stressing requircrnents for llRA "t.tries and the utilication of swing gates.- The purpose and proper utilization of Swing gates are also adoressed in General Ernployce Training.
The swing gates al.'.owing access to liras have been inspected to enture the gates are functioning properly and interferences have been eli 11nated.
1 Trending of deficiencies han been enhanced to provide increased emphasis on key radiological control performance areas, such as llRA entries.
Any adverse trends identifled vill be escalated to appronriote site manngement, and appropriate corrective action will be estc.blish d.
I Corre etive Steps Tha t_Wi_1_1 Be - T,iken to Avoid _ Fur
- pg r Vjola t ions Based on thu corrective actions describec there a'e no further corrective actions required.
Date When Full Comp)farice Will Be Achieved SQN is in full compliance.
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