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Insp Repts 50-327/85-20 & 50-328/85-20 on 850520-24. Violation Noted:Failure to Adequately Determine Scaling Factors for Use in Classifying Low Level Waste Shipments & Failure to Wear TLDs
	ML20128L241
Person / Time
Site:	Sequoyah
Issue date:	06/17/1985
From:	Hosey C, Weddington R; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	;
Shared Package
ML20128L196	List: ML20128L190; ML20128L226; ML20128L241;
References
	50-327-85-20, 50-328-85-20, NUDOCS 8507110286
	Download: ML20128L241 (10)
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pMerg UNITED STATES

/ 'o NUCLEAR REGULATORY COMMISSION

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Report Nos.: 50-327/85-20 and 50-328/85-20

Licensee: Tennessee Valley Authority

500A Chestnut Street

Chattanooga, TN 37401

Docket Nos.: 50-327 and 50-328 License Nos.: DPR-77 and DPR-79

Facility Name: Sequoyah 1 and 2

Inspection Conducte : May 20-24, 1985

Inspector: /t/[ / M@

R. E. Weddington (/ Date Signed

Accompanying Personnel: B. K. Revsin

Approved by: !t%

C. M. Hoses, Sect 1 Chief

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Date Signed

DivisionofRadiat@ionSafetyandSafeguards

SUMMARY

Scope: This routine, unannounced inspection involved 42 inspector-hours on-site

in the areas of licensee audits; external exposure control and dosimetry; solid

waste; transportation; licensee program for maintaining radiation exposure as low

as reasonably achievable (ALARA) and open items.

Results: Three violations were identified: (1) failure to adequately determine

scaling factors for use in classifying low level waste shipments, (2) failure to

label containers of radioactive material and (3) failure to adhere to procedures

for wearing of thermoluminescent dosimeters (TLDs) and dosimeters.

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REPORT DETAILS

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1. Persons Contacted -

Licensee Employees

P. R. Wallace, Plant Manager u

L. M. Nobles, Operations and Engineering Superintendent -

D. E. Crawley; Health Physics,5upervisor , .

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R. C. Eirchill, Compliance Engineer , /c

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G. B. Kirk, Compliance Supervisor ,

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R. W. Proffitt, 'y,emical

W. Fortenberr Engineering Engineer Supervisor 'n '

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C. E. Bosley, Quality Ascurance Evaluator .. ~<

D. C. Craven, quality Assurance Staff Supervisor ,,

D. L. Cowart;gQuality Surveillancc Supervisor ,I s

J. W. Qualls, Shipping Coordinat6r, Operatt60s 5

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D. M. 'Knlley, Chemical Engineer, Radwaste Operations -

J.,S. Steigelman, Assistant Health'Pn9 sics S,upervisor '

C. G. Hudson, Project Engir:ese, Site Seivices k -

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W. L. Williams, Chemistry Unit Supervisor

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M. R. Harding, Engineering Group Supervisor < ~ l'

J. Leamon, ALARA Coordinator ,

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M. Palmer, Cosimetiry Section Supervisor T'

Other licen'.,ed, employees contacted included three technicians and office

personnel.

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K.Jenison,SeniorResidentInsjector . .

L. Watson, Residynt Inspector- ,. , ,

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'2. Exit Interview '

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g The ):nspection scope and findings were summarize'd on May 24, 1985,'with

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thoss persons indicated in paragrapAl above. The following issues were

discussed in detail: (1) an apparent violation for failure to afequately

determine scaling factors for use iCelassifying low level waste shipments

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5 (paragraph 6); (2) an apparent violation for failure to label containers of

radioactive material (paragraph 5); and (3) an apparent violation for

9 failure to sdhere to procedures for wearing of TLDs and dosimeters

r- , (paragraph 5). The licensee acknowledged the inspection findings and took

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no exceptions. 'The3 11censee did not jdentify as proprietary any of the

materials provided to .or reviewed by tbj inspector during this inspection.

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On June 3, 1985, a telephone conversation was held between, D. M. Collins of

the Region II office and P. R. Wallace, Plant Manager, concerning the

identification of a repeat violation for improper wearing of dosimetry and

the extent of licensee management's attention to this area. A licensee

representative stated that additional corrective actions, which included

health physics checking all personnel for proper wearing of dosimetry at the

main entrance to the regulated area and involvement of first line

supervision, were being implemented.

3. Licensee Action on Previous Enforcement Matters '

(Closed) Violation (50-327/84-27-01 and 50-328/84-22-01). The inspector

reviewed the licensee's response dated November 7,1984, and verified that

the corrective action specified in the response had been taken. However, a

similar violation was noted during the course of this inspection

(paragraph 5).

(Closed) Violation (50-327/84-34-01 and 50-328/84-34-01). The inspector

reviewed the licensee's response dated January 23, 1985, and verified that

the corrective action specified in the response had been taken.

4. Licensee Audits (83728, 86721, 83724, 84722)

The inspector discussed the audit and surveillance program in the areas of

radiation protection, radioactive waste management and transportation of

radioactive material with licensee representatives. The inspector reviewed

the following Quality Assurance (QA) audits:

QA Audit SQ-8400-10, Radioactive Waste Management and Process Control

Program, May 14-18, 1984.

QA Audit QSS-A-85-0010, Internal Radiation Control and Internal

Exposure Control, March 18 - April 14, 1985.

QA Audit QSS-A-0009, Health Physics Instrumentation, January 14 -

February 7,1985.

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QA Audit CH-8500-01, ALARA and External Radiation Control,

November 13-29, 1984.

The inspector reviewed the Radiation Incident Reports (RIRs) prepared by the

Health Physics Section during the first two quarters of FY 1985. The

inspector verified that appropriate corrective actions were documented.

The results of on-site QA surveillances in the area of the proper wearing of

dosimetry devices by licensee employees is discussed in paragraph 5.

No violations or deviations were identified.

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5. External Exposure Control and Dosimetry (83724)

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10 CFR 20.101 specifies the applicable radiation dose standards. The

inspector reviewed the computer printouts (Form NRC-5 equivalent) for the

period January 1 - May 20, 1985, and verified that the radiation doses

recorded for plant personnel were well within the quarterly limits of 10 CFR

20.101(a).

10 CFR 20.101(b)(3) requires the licensee to determine an individual's

accumulated occupational dose to the whole body on a Form NRC-4 or

equivalent record prior to permitting the individual to exceed the limits of

10 CFR 20.101(a). The inspector verified by examination of selected records

, that exposure histories were being completed and maintained as required by

10 CFR 20.102 prior to permitting individuals to exceed the values in

10 CFR 20.101(a).

The inspector reviewed the following plant procedures which established the

licensee's program for personnel monitoring of external dose in accordance

with 10 CFR 20.202:

RCI-1, Radiological Hygiene Program

RCI-3, Personnel Monitoring

, 10 CFR 20.401(a) requires each licensee to maintain records showing the

radiation exposure of all individuals for whom personnel monitoring is

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required under 10 CFR 20.202 of the regulations. Such records shall be kept

on Form NRC-5 or equivalent. The inspector reviewed selected individual

exposure records maintained by the licensee. All exposures were well below

regulatory limits.

10 CFR 20.202 requires each licensee to supply appropriate personnel

monitoring equipment to specific individuals and require the use of such

equipment.

Technical Specification 6.11 requires that procedures for personnel

l radiation protection shall be prepared consistent with the requirements of

10 CFR 20 and shall be adhered to for all operations involving personnel

radiation exposure.

l Licensee procedure, RCI-3, Revision 17, Personnel Monitoring, paragraph IX

requires that TLD badges and dosimeters be worn on the front of the person

and between the neck and waist. The badges shall be placed in a plainly

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visible position and the identification number side of the badge shall

always face away from the body.

During tours of the facility, the inspector observed during an approximate

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15 minute period that 17 percent (34 of approximately 200) of the personnel

observed at the elevation 690 entrance to the auxiliary building were not

properly wearing their TLD badges and dosimeters. The personnel either had

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their dosimetry below their waist on the side of their body or had clipped

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their TLD behind their security badge so that the plastic security badge and

key card were shielding the beta window of the TLD.

During an inspection conducted during the period August 6-10, 1984

(inspection report nos. 50-327/84-21 and 50-328/84-22) it was noted that

licensee employees were not adhering to the requirements of RCI-3 in regard

to wearing of dosimetry devices and a Notice of Violation was issued. The

licensee stated in their response of November 7, 1984, that full compliance

was achieved on August 17, 1984.

During the period November 15, 1984, through March 5, 1985, the licensee's

on-site QA section performed seven surveillances (survey No. 9b-85-A-004) of

the proper wearing of dosimetry by licensee employees. The surveillances

revealed that from 8 to 44 percent of the individuals observed were not

wearing their dosimetry as specified by RCI-3. These special surveillances

were performed by direction of licensee management and the results were

reported to the Plant Manager. Licensee management indicated that actions

were taken in response to these findings, such as discussing during staff

meetings and conducting training sessions, yet full compliance had not yet

been achieved.

Failure to adhere to the requirements of RCI-3 in regard to the proper

wearing of dosimetry devices was a violation of Technical Specification 6.11

(50-327/85-20-01 and 50-328/85-20-01). This violation is similar to

violation 50-327/84-21 and 50-328/84-22. No credit was given for licensee

identification of this violation under the provisions of 10 CFR Part 2,

Appendix C, paragraph V.A in that corrective actions for a similar Notice

were not effective in preventing recurrence and the violation was not

corrected within a reasonable time.

10 CFR 20.203 specifies the posting, labeling and control requirements for

radiation areas, high radiation areas, airborne radioactivity areas and

radioactive material areas. Additional requirements for control of high

radiation areas are contained in Technical Specification 6.12.

Licensee procedure RCI-1 contains additional information on the posting and

control of radiological areas.

During tours of the plant, the inspector reviewed the licensee's posting and

control of radiation areas, high radiation areas, airborne radioactivity

areas, contamination areas, radioactive material areas and the labeling of

radioactive material.

10 CFR 20.203(f) requires that each container of licensed material shall

bear a durable, clearly visible label identifying the radioactive contents.

The label must also bear the standard caution symbol and the words " Caution

or Danger - Radioactive Material." 10 CFR 203(f)(3) provides exceptions to

labeling.

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On May 20, 1985, the inspector observed seven B45 metal shipping boxes in

the storage area outside the Unit 1 containment which were not labeled. One

box had writing on the side of the box which indicated that the box

contained pump parts for storage. The date " January 15, 1985," was also

marked on the box. Another box was marked to indicate that it contained

material for storage and had a dose rate of 350 millirem per hour under the

box. The highest dose rate measured by the inspector was 12 millirem per

hour at near contact with the outside of one of the boxes (all radiation

levels determined by the inspector was with a portable beta gamma survey

meter, Xetec 305A, Serial No. 03682, calibration due August 28, 1985).

There were also twelve yellow 55 gallon drums in the storage area next to

the B45 boxes. The drums had been labeled with paper tags, but at the time

of the inspection, exposure to the elements had deteriorated the tags such

that they were no longer legible or had fallen off of the drums.

On May 20, 1985, the inspector observed that the equipment decontamination

room on the 690 elevation of the auxiliary building contained numerous

yellow bags of material that were not labeled. The highest radiation level

detected was 10 millirem per hour.

On May 21, 1985, the inspector observed that the bins on the 690 elevation

of the auxiliary building which contained laundered used protective clothing

were not labeled. The highest dose rate detected was 2.5 millirem per hour

along the front of one of the bins.

On May 21, 1985, the inspector observed that seven yellow poly bags and a

metal box containing radioactive waste on the refueling floor were not

labeled. The containers measured up to approximately one millirem per hour.

On May 22, 1985, the inspector observed a yellow poly " bootie" laying on the

top of Health Physics Locker No. 3 in the Unit 1 penetration room. The bag

had " steam generator headsets" written on it and was not labeled. The

" bootie" read 11 millirem per hour at near contact.

Failure of the licensee to label the containers of radioactive material

described above was a violation of 10 CFR 20.203(f) (50-327/85-20-02 and

50-327/85-20-02).

6. Solid Waste (84722)

10 CFR 20.311 requircs that the licensee maintain a tracking system for

radioactive waste shipments to verify that shipments have been received

without undue delay by the intended recipient. The inspector reviewed the

tracking log maintained by the licensee and selected copies of returned

receipt acknowledgements in the shipping files for shipments performed in

1985.

10 CFR 61.56 specifies the waste characteristic and stability requirements

for low level radioactive waste. Through discussions with licensee

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representatives and review of selected records the inspector determined that

waste stability, when required, was achieved by use of approved containers

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or by solidification. Solidification was performed by a contractor and

included formation and testing of a demonstration product prior to each

batch processing.

10 CFR 20.311 requires a licensee who transfers radioactive waste to a land

disposal facility to prepare all wastes so that the waste is classified

according to 10 CFR 61.55.

10 CFR 61.55(a)(8) requires that the concentration of a radionuclide may be

determined by indirect methods such as use of scaling factors which relate

the inferred concentration of one radionuclide to another that is measured

if there is reasonable assurance that the indirect methods can be correlated

with actual measurements.

The inspector reviewed licensee procedure Technical Instruction (TI)-61,

Waste Classification and Scaling Factors, May 22, 1984.

The procedure described a manual method of computing waste classification.

The inspector verified that the computational steps in the procedure were

consistent with the methodology of 10 CFR 61.55(a)(3)-(7). The procedure

also contained only one set of scaling factors that was used to classify all

of the facility waste streams.

The licensee's set of scaling factors had been prepared by a contractor and

forwarded to the licensee in April 1984. The inspector reviewed the

contractor's report. The report stated that the scaling factors were

derived from off-site sample analysis results of facility waste streams.

The contractor had compared the licensee's sample results to those from

other operating PWRs. The contractor used the actual sample results for

nuclide concentrations that agreed statistically with their generic data

base or assigned generic scaling factors to nuclides that did not well

agree. Chapter 8 of the report contained six tables which compared the

results obtained from using the mix of actual sample and generic factors and

using entirely factors derived from actual samples. The tables indicated

that use of the mix of actual sample and generic scaling factors resulted in

nonconservative nuclide concentration determinations for 65 percent of the

19 scaled nuclides in each of the six evaluated waste streams, with 20

percent of those being nonconservative by greater than a factor of ten. The

most significant nonconservative result was for the dry active waste (DAW)

waste stream where 17 of the 19 scaled nuclide concentrations were

nonconservative by factors of up to 284.9. The inspector reviewed selected

records of low level waste shipments performed since May 1984 and determined

that use of the contractor provided scaling factors had not resulted in any

of the waste shipments reviewed being incorrectly classified.

Failure of the licensee to use actual measurements to determine scaling

factors as required by 10 CFR 61.55(a)(8) was identified as a violation of

10 CFR 20.311.

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During the review of licensee records the inspector noted that the licensee

used a single set of scaling factors to classify wastes from all of the

facility waste streams, although on-hand analyzed results indicate that at

least four waste streams were sufficiently different to require separate

scaling factors. Failure to use individual sets of scaling factors for each

distinct waste stream was identified as another example of an identified

violation of 10 CFR 20.311 (50-327/85-20-03 and 50-328/85-20-03).

A licansee representative stated that their contractor had been contacted

and that the contractor had stated that he had notified the licensee in

writing sometime during the summer of 1984 not to use the generic scaling

factors for classifying DAW shipments due to the same problems discussed

above. However, no one could recall having seen the document. A licensee

representative stated thtt new scaling factors were in the process of being

developed and that they would be specific to the facility.

7. Transportation (86721)

10 CFR 71.5 requires that licensees who transport licensed material outside

the confines of its plant or other place of use, or who delivers licensed

material to a carrier for transport, shall comply with the applicable

requirements of the regulations appropriate to the mode of transport of the

Department of Transportation in 49 CFR Parts 170 through 189.

The inspector reviewed selected records of radioactive waste and non-exempt

radioactive waste shipments performed during FY 1985 and verified that the

requirements of 49 CFR Parts 170 , through 189 had been met for those

shipments.

The inspector reviewed the following plant procedures and verified that they

were consistent with applicable regulations.

RCI-7, Revision 25, Shipment of Radioactive Materials, January 24, 1985.

RCI-7.1, Revision 2, Box and Drum Shipment of Radioactive Waste (LSA),

February 2, 1984.

RCI-7.2, Revision 0, Shipment of Radioactive Waste (LSA).

No violations or deviations were identified.

8. ALARA(83728)

10 CFR 20.1c states that persons engaged in activities under licenses issued

by the NRC should make every reasonable effort to maintain radiation

exposure as low as reasonably achievable (ALARA). The recommended elements

of an ALARA program are contained in Regulatory' Guide 8.8, Information

Relevant to Ensuring that Occupational Radiation Exposure at Nuclear Power

Stations will be ALARA, and Regulatory Guide 8.10, Operating Philosophy for

Maintaining Occupational Radiation Exposures ALARA.

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The inspector discussed the ALARA goals and objectives for the current year

with licensee representatives and reviewed the man-rem estimates and results

for the current year. I

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As of the inspection, the actual collective exposure for calendar year 1985

was 200 man-rem with 750 man-rem being the estimated exposure for the year.

As of April 1985, the licensee has disposed of 5500 cubic feet of DAW and

1700 cubic feet of resins, sludges and evaporator bottoms.

The inspector reviewed selected pre-job ALARA planning reports and post-job

evaluations for jobs performed during the unit's current outage.

The inspector reviewed a study the licensee had performed for containment

power entries made in 1984. The noble gas levels in containment during

those entries ranged from less than one to approximately one hundred times a

maximum permissible concentration (MPC). The licensee determined that the

maximum skin dose rate any worker was exposed to was approximately 40

millirem per hour. The study indicated that 91 persons had received skin

exposures greater than 500 millirem during the 1984 entries, with 22 of

those being greater than 1000 millirem. The highest exposure was 1966

millirem, which was well below the quarterly skin e tposure limit given in

10 CFR 20.101(a) of 7500 millirem. To reduce exposures, the licensee vented

the containment atmosphere into the annulus if levels greater than those

stated were encountered. The power entries were controlled by issuance of a

radiation work permit which provided for ALARA reviews and continuous

coverage by health physics personnel. They also stated they had permitted

only essential tasks to be performed during these entries. The inspector

reviewed documentation of recent containment entries while at power and did

l not identify any concerns relative to nonessential tasks being performed.

For the containment entry on March 21, 1985, the highest individual exposure

was 277 millirem with the job total being 1.515 man-rem among 13 workers.

The extent of contaminated areas within the facility had decreased during

the past year due to the active clean up program initiated by the licensee.

As part of this clean up program, the amount of contaminated space was

tracked each month and trended against previous months' contaminated areas.

This information is included in monthly reports to management.

l No violations or deviations were identified.

9. Health Physics Staffing

Staffing for the health physics section was reviewed at which which time it

was determined that adequatt numbers of staff were available to supervise

and to implement radiological control functions as required during normal

operation as well as for maintenance activities and emergency plan

implementation.

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10. IE Information Notices (92717)

IE Information Notice 85-06, Contamination of Breathing Air Systems, was

reviewed to ensure that receipt and review by appropriate licensee

management.

11. Followup on Previous Inspector Identified Items (93701)

(Closed) IFI (50-327,328/79-FI-04) Followup of IEB 79-19, Packaging of Low

Level Radioactive Wastes. The inspector verified that the actions stated in

the bulletin, where applicable, had been performed by the licensee.

(Closed) IFI (50-327,328/79-FI-06) Followup of IEC 79-21, Prevention of

Unplanned Releases of Radioactivity. Through discussions with licensee

representatives and tours of the facility the inspector did not identify any

of the potential problems addressed in the circular.

(Closed) IFI (50-327,328/84-21-08) Labeling Containers of Radioactive

Material. This area was identified as an apparent violation during this

inspection (paragraph 5).

ML20128L241

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