ML20138C470

Insp Repts 50-327/86-04 & 50-328/86-04 on 860121-30 & 0212-13.Violations Noted:Failure to Comply W/License Conditions for Radwaste Disposal Site & Failure to Maintain Respirator Issuance Records & Perform Adequate Evaluations

ML20138C470
Person / Time
Site:	Sequoyah
Issue date:	03/19/1986
From:	Hosey C, Weddington R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20138C434	List: ML20138C430 ML20138C441 ML20138C470
References
50-327-86-04, 50-327-86-4, 50-328-86-04, 50-328-86-4, NUDOCS 8604020505
Download: ML20138C470 (19)

See also: IR 05000327/1986004

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p Kfrog UNITED STATES

Do

4'8 NUCLEAR REGULATORY COMMISSION

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[ E, REGION 11

g ,. j 101 MARIETTA STREET, N.W.

• '* ATLANTA. GEORGI A 30323

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MAR 2 ? 1986

Report Nos.: 50-327/86-04 and 50-328/86-04

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Licensee: Tennessee Valley Authority

A

500A Chestnut Street

Chattanooga, TN 37401

Docket Nos.: 50-327 and 50-338 License Nos.: DPR-77 and DPR-79

Facility Name: Sequoyah 1 and 2

Inspection Conducted: January 21.-30 and February 12-13, 1986

Inspector: VC <N

R. E. W6ddington /

ftv Nf5

Date Signed

Approved by: 9 3//7/f4

C. M. Hosey, Set-tion Chief, .

Date Signed

Division of Radiation Safety and Safeguards

SUMMARY

Scope: This special, unannounced inspection involved 66 inspector-hours onsite

in tN areas of radiation protection items described in the Sequoyah Nuclear

Performance Plan; nonroutine event followup; allegation followup; licensee

actions on previous enforcement matters and inspector identified items;

transportation; external exposure control; internal exposure control; control of

radioactive material; and review of dosimetry activities at the licensee's Muscle

. Shoals, AL facility.

Results: Four violations were identified: (1) failu~re to comply with license

conditions of a radioactive waste disposal site, - (2) failure to perform an

MPC-hour assessment, (3) failure to maintain respirator issuance records and (4)

three examples of failures to perform adequate evaluations.

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REPORT DETAILS

1. Persons Contacted

Licensee Employee

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• P. R. Wallace, Plant Manager

• D. E. Crawley, Health Physics Supervisor

• C. E. Kent, Chief, Policy and Technical Assistance Staff

• G. B. Kirk, Compliance Supervisor

i *W. G. Williams, Chemistry Unit Supervisor

• R. C. Pirchell, Mechanical Engineer

• R. L. Casteel, Licensing Engineer

• J. E. Wills, Licensing Engineer

• T. T. Gilbert,' ISI Unit Supervisor

• J. T. Traffanstedt, P.lanning

"C. L. Wilson, Nuclear Engineer

• R. M. Sexton, QA Evaluator

• C. G. Hudson, Project Engineer

• M. A. Palmer, Dosimetry Unit Supervisor

• S. P. Holdefer, Health Physics Assistant Supervisor

• J. S. Steigelman, Health Physics Assistant Supervisor

J. L. Lobdell, Supervisor, Dosimetry Section

D. Colvett, Dosimetry Section

J. Leamon, ALARA Coordinator-

.T. Dills, Health Physics Assistant Supervisor

J. M. Qualls, Stipping Coordinator, Operations

T. Black, Health Physics Training Officer

Other licensee employees contacted included six technicians and office

personnel.

! NRC Resident Inspectors

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K. Jenison, Senior Resident Inspector

L. Watson, Resident Inspector

• Attended exit interview

2. Exit Interview

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The inspection scope and findings were summarized on January 30, 1986, with

l those persons indicated in Paragraph 1 above. The following issues were

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

MPC-hour assessment (Paragraph 5.c); (2) an apparent violation for failure

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to maintain respirator . issuance records (Paragraph 9.a); (3) an apparent

violation for failure to. perform adequate surveys to release material from

the regulated area (Paragraph 7); (4) an apparent violation for failure to

perform adequate exposure evaluations for lost dosimeter rezero sheets

(Paragraph 8.c); (5) an apparent violation for failure to comply with

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license conditions of a radioactive waste disposal site (Paragraph 5.b); (6)

an apparent violation for failure to perform adequate evaluations of lens of

the eye exposure due to noble gas (Paragraph 8.b); (7) an Unresolved Item *

concerning potential exposures in excess of regulatory limits due - to

inadequate evaluations of lens of the eye exposures (Paragraph 8.b); and

staffing and technical expertise in the Dosimetry Section (Paragraph 4.h).

The licensee acknowledged the -inspection findings and stated there may be

technical disagreements in regard to the appropriateness of using bioassay

data to determine MPC-hours exposures. The licensee did not identify as

, proprietary any of the materials provided to or reviewed by the inspector

during this inspection.

3. Licensee Action of Previous Enforcement Matters (92702)

(Closed) Violation (50-327/85-20-01 and 50-328/85-20-01), Failure of

personnel to wear dosimetry devices as prescribed in procedures. The

inspector reviewed the licensee's responses of July 19 and October 30, 1985,

and verified that the corrective actions specified in the response had been

taken, except for an illustration in the General Employee Handbook on proper

placement of personnel dosimetry. A licensee representative stated that

they had decided to use the illustration as a poster in the plant and had

inadvertently omitted it from the Employee Handbook. The inspector verified

that posters illustrating proper placement of dosimetry were displayed in

strategic locations in the olant. A licensee representative stated a letter

would be sent to Region II to correct the previous response.

(Closed) Violation (50-327/85-20-02 and 50-328/85-20-02), Failure to label

containers of radioactive material. T .e inspector reviewed the licensee's

response dated July 19, 1985, and verified that the corrective action

specified in the response had been taken.

(Closed) Violation (50-327/85-20-03 and 50-328/85-20-03), Failure to

adequately establish 10 CFR Part 61 radioactive waste classification scaling

factors. The inspector reviewed the licensee's response dated July 19,

1985, and verified that the corrective action specified in the response had

been taken.

(Closed) Violation (50-327/85-26-03 and 50-328/85-26-03), Failure to perform

adequate personnel contamination surveys. The inspector reviewed the

licensee's responses of October 7,1985, and January 3,1986, and verified

that the corrective active specified in the. response had been taken.

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• An unresolved item is a matter about. which more information is required to

j determine whether it is acceptable or may involve a violation or deviation.

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4. Sequoyah Nuclear Performance Plan

Volume 2, Part III, Section 4.8, of the Sequoyah Nuclear Performance Plan

documents the licensee's review and evaluation in the area of health physics

as a part of the readiness review conducted by the licensee for restart of

the Sequoyah Nuclear Plant units. Within the Sequoyah Performance Plan, the

licensee committed to several actions in order to improve performance in the

health physics area 'and to minimize employee exposures. The inspector

reviewed the implementation of the plan's health physics items as discussed

below,

a. Implementation of a contamination area control program to minimize

contaminated areas in nonoutage periods. .

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The inspector reviewed records of biweekly contamination area reduction

meetings attended by the Assistant Plant Manager 'or Operations, the

Health Physics Supervisor and management representatives of crafts and

maintenance work groups. The purpose of the meetings was to review

trending data on contaminated areas and designate areas to be

decontaminated. A monthly report on contaminated areas was also

generated and distributed to appropriate plant personnel. The

inspector-determined that the program had been effective in reducing

the number of contaminated areas and that appropriate resources were

being dedicated to the program. Since the licensee has been in outage,

there have not been any biweekly plant management meetings .on

contaminated areas since August.1985. Licensee representatives stated '

that the biweekly meetings would resume after unit restart.

b. Use of a New Decontamination Facility

The inspector toured the new decontamination facility. An ultrasonic

and freon decontamination units had been installed and were

operational. An electropolishing unit was in the process of being

installed. The inspector verified that the licensee had prepared

radiation protection procedures and radiation work permits (RWPs) for

the operations performed in the facility and that operations personnel

assigned to the facility had received training on the operation of the

equipment.

c. More Effective Use of Computers in Radiological Program Management

The licensee has implemented a computer based health physics

performance and trending system. The inspector reviewed selected ALARA.

reports and determined that the computer generated data provide

management with an effective means of evaluating performance. Licensee

representatives stated that computerized historical trending of

radiological conditions is also being developed for specific areas and

RWPs.

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d. Inventory and Tracking of Radiation Shielding Materials

The licensee had established a centralized storage facility for

shielding material and had implemented an inventory and tracking

system. The inspector toured the storage facility and determined that

an adequate supply of shielding was on hand. Through discussions with

licensee representatives the inspector determined that use of shielding

was evaluated during pre-job ALARA reviews.

e. Reduced Utilization of Contract Personnel

During the most recent outage, the licensee's health physics staff was

augmented by health physics technicians from TVA's Watts Bar Nuclear

Plant, resulting in only sixteen con +ractor technicians being brought

in from outside. Licensee representatives stated they are planning to

establish an overage pool of health physics technicians at Sequoyah and

Watts Bar ~ that can be' shared during outages after Watts Bar is

licensed.

To support routine and outage operations, the licensee has designated

five health physics technician crews. Twenty-three fully qualified and

seventeen junior technicians comprised four crews which worked twelve ~

hour rotating shifts. A fifth crew consisting of five fully qualified

technicians were assigned to the weekday shift. .The inspector

determined that the staffing level was adequate to support routine and

outage operations.

During the most recent outage, the licensee augmented their dosimetry

section with five contractor dosimetry technicians. The staffing of

the dosimetry section was noted to be inadequate during the inspection

and is discussed in more detail in Paragraph 4.h.

f. Health Physics Technician Assignment to the Maintenance Section

The health physics technician was assigned to the maintenance section

in August 1985. Licensee representatives stated the technician

attended all the regular maintenance planning meetings and served

principally as a liaison between the maintenance and health physics

sections for development of radiation work permits and coordinating job

coverage. Training classes were also being developed for maintenance

personnel, such as good radiological control practices and ALARA.

g. Health Physics Training Officer

The Health Physics Training Officer is a former health physics

operations supervisor. The Training Officer was responsible for

ensuring that the technicians in the health physics department met

their training requirements. The inspector reviewed the records system

used to follow selected technicians and determined that their training

status was being adequately monitored. The inspector discussed with

the training officer several of his other responsibilities, including

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preparation of oral examination boards for technician qualification and

development of special training classes. The Training Officer also

stated that he was enrolled in TVA's teachers certification course.

h. Onsite Dosimetry Processing

The licensee stated in their Performance Plan that TVA's dosimetry

program was decentralized in the Spring of 1985 and, as a result of

this move, Sequoyah now has onsite the technical expertise to provide

24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day, seven days a week coverage for TLD processing and data

handling. It was noted during the inspection that the extent of the

decentralization has been to set up TLD readers and ca:ibrators at .

Sequoyah. Raw data from the TLD reader is sent electronically to TVA's

2 Dosimetry Sectio.n in Muscle Shoals, AL, where the data is evaluated and

individual exposures determined and then sent electronically back to

Sequoyah. Official exposure files were still maintained at Muscle

Shoals with no duplicate files at Sequoyah. Muscle Shoals also issues

all employee termination letters,10 CFR 20.407 exposure reports 'and

other official exposure reports. Since the Muscle Shoals office is not

s staffed for backshift ~ and weekend coverage, personnel qualified to

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perform technical evaluations of unusual dosimetry results or to detect

problems would not always be available. It was also noted during the

inspection that Sequoyah did not receive any increase in personnel when

they were given additional dosimetry responsibility. The licensee does

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not have the in-house technical expertise to independently manage a

dosimetry program at Sequoyah. The dosimetry section has only one

fully qualified dosimetry technician, who functions as a shift

coordinator (i.e., lead technician on day shift). The remaining eight

personnel in the section are junior' technicians who have completed

training within the past year. The supervisor of the dosimetry section

is a recently promoted dosimetry technician. The licensee has a

professional position of dosimetry engineer, but it is currently

vacant. Licensee actions to increase the technical expertise and

, experience level in the dosimetry section was identified as an

inspector followu;2 ttem (50-327, 328/86-04-05).

No violations or deviations were identified.

5. Nonroutine Event Followup (93702)

a. High Airborne Radioactivity Event of July 29, 1985

1 The licensee reported the circumstances of the event in licensee

Reportable Occurrence Reports SQR0-50-327/85031, August 27, 1985, and

SQRO-50-327/85031, Revision 1, September 10, 1985. The event concerned

high airborne radioactivity in the Auxiliary Building, which was caused

by a leak from a sample line connection from the Volume Control Tank in

the Unit I pipe chase. Airborne radioactivity levels in the pipe chase

were determined to be 50 times a Maximum Permissible Concentration

(MPC) as defined in 10 CFR 20, Appendix B for particulates, 646 times

MPC for noble ' gas and 1.3 times MPC for iodine. The levels present in

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the Auxiliary Building were 28 to 44 times MPC for noble gas.

Initially the licensee believed than an unmonitored radioactive release

was taking place due to high air samples taken in the unrestricted area

outside the building. The licensee verified the Auxiliary Building was

under negative pressure and the Auxiliary Building gas treatment system

was operating. The air samples were recounted at the licensee's

training center and no radioactivity was detectable. The licensee

concluded that the initial sample counts .had not been correct due to

high background radiation levels in the facility counting room. Eleven

personnel were contaminate'd during this event, with the highest being a

worker that had 100,000 disintegrations per minute on his face. No

internal contamination was discovered 'on any of the subsequent whole

body counts performed on the personnel involved. By review of licensee

health physics logs, survey records and discussion with licensee

representatives, the inspector determined that the actions taken by the

licensee to maintain radiological controls during this event were

consistent with regulatory requirements.

No violations or deviations were identified.

b. Transportation Event of September 27, 1985

By letter dated October 3, 1985, the licensee was informed by the South

Carolina Department of Health and Environmental Control that their

radioactive waste shipment number 0985-119 was found, upon arrival at

the Chem-Nuclear operated burial site near Barnwell, SC, to be in

noncompliance with the disposal site's state license. The shipment

consisted of dewatered resins packaged in a high integrity container

(HIC) within a USA 6568-A shipping cask. License Condition 164 of South

. Carolina Radioactive Material License No. 97, ' issued to Chem-Nuclear

Systems, Inc., required that the licensee shall not receive shipments

of radioactive materials unless ~ appropriate lifting devices of

sufficient length have been provided and securely attached to

containers and palletized shipments within a cask. Upon removing the

lid from the cask, the disposal site operator found that the HIC

rigging gear was not accessible in that the rigging gear was wedged in

the space between the HIC and inner cask wall by internal bracing

material. A radiation level of 9 rems per hour (9 R/hr) was noted on

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top of the HIC. The disposal site elected not to receive the shipment

to preclude unnecessary radiation exposure while attempting to retrieve

the lifting cables. The shipment was sent' back to the licensee. The

State of South Carolina assessed the licensee a civil penalty of One

Thousand Dollars (51,000), which the licensee paid. Licensee

representatives stated that when their shipping coordinator was

performing his preshipment inspections, he became concerned that the

HIC might shift within the cask during transport. He directed that

. wooden wedges be placed in the approximately three inch space between

I the HIC and cask inner wall. The workers who performed this task

inadvertently wedged the rigging gear ~ into the space between the

containers. In their October 23, 1985, letter to the State of South

Carolina, the licensee stated that their shipping procedures had been

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< changed to require a final inspection prior to shipment to verify that

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lif ting devices are free 'and ' accessible. The inspector stated that

Lilure . of the licensee to ensure that the HIC rigging gear was

accessible for unloading was an apparent violation of 10 CFR 30.41(c),

which required that before transferring byproduct material. to a

specific licensee of an Agreement State, the licensee transferring the

material shall verify that the transferee's licensee authorizes the

receipt of the type, form, and quantity of byproduct material to be

transferred (50-327, 328/86-04-01).

c. Internal Contamination Event of December 11, 1985

At approximately 1700 hours0.0197 days <br />0.472 hours <br />0.00281 weeks <br />6.4685e-4 months <br /> on December 11, 1985, three workers exited

Unit 1 lower containment af *er performing work under RWP 02-1-85116,

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time sheet number 156, General Clean-up and Equipment Removal. One of

the workers discovered contamination on his person as he was performing

a whole body frisk and summoned health physics. Health physics

personnel- successfully decontaminated the worker. The highest

contamination discovered was 4000 disintegrations per minute (dpm) on

his mustache and 4200 dpm on a nasal smear. The other two workers were

not contaminated. The worker received a whole body count at 1804 hours0.0209 days <br />0.501 hours <br />0.00298 weeks <br />6.86422e-4 months <br />

on December 11, 1985, and nine subsequent whole body counts over the

period until December 18, 1985. Six urine samples were also collected

during the period December 12 to 18,1985, and one fecal sample was

collected on December 12, 1985. The highest activity detected on the

whole body counts was on December 12, 1985, which was equivalent to

15.67 percent of a maximum permissible organ burden (MP08) for

Cobalt-60. The urine and fecal analysis also showed small quantities

of various radionuclides. Based on the bioassay data, the licensee

calculated that the worker had received a dose commitment of 71

millirem to his lower large intestine.

! The licensee investigated the cause of the event. The worker had

entered the lower containment to bag used flexible hose from a porta'

high efficiency (HEPA) filter system so that they could be removed.

The ends of the hoses were covered and taped to contain the

contamination in the hose. The worker at some point-in the work cut up

some of the hoses in order to get them into the bags. He apparently

did not realize that cutting into the hoses changed the understood

scope'of work for which the RWP was approved. The licensee identified

that they would have senior health physics technicians at the

containment accesses during outages to better ensure that workers and

health physics communicate the intended scope of work and limitations

of the RWP. A memorandum was also sent to health ~ physics operations

personnel discussing the event and requiring that any work invol.ving

HEPA filter hoses require the use of respiratory protection.

During review of the above event, the inspector questioned the licensee

as to their evaluation of the regulatory significance of the worker's

exposure. Licensee representatives later informed the inspector, in

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response to his request, that the worker's exposure had been equivalent

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to approximately 78 MPC-Hours. Licensee representatives stated that,

for significant exposures, internal dose calculations were performed

and maintained with the individual's exposure records. No

. determination was made that the exposure was within the intake limits

of 10 CFR 20.103(a).

10 CFR 20.103(a)(3) required that for purposes of determining-

compliance with the requirements of 10 CFR 20.103, the licensee shall

use suitable measurements of concentrations of radioactive materials in

2 air for detecting and evaluating airborne radioactivity in restricted

areas and in addition, as appropriate, shall use measurements of

radioactivity in the body, measurements of radioactivity excreted from

the body, or any combination of such measurements as' may be necessary

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for timely detection and assessment of individual intakes of

radioactivity by exposed individuals. Failure of the licensee to use

measurements of radioactivity in the body ano excreted from-the body of

the worker involved in the December 11, 1985, event in order to

determine compliance- with the requirements of 10 CFR 20.103 was

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identified as an apparent violation of 10 CFR'20.103(a)(3) (50-327,

328/86-04-02).

d. Contamination Outside Condensate Demineralizer Waste Evaporator (CDW5)

Building

On January 14, 1986, a licensee employee reported to health physics

that he observed seepage from the exterior wall of the CDWE Building.

Health physics personnel investigated and . determined that the seepage

was moist crystallized boron. Radiation surveys showed a radiation

level at near contact with the wall of 69 millirem / hour and less than

5 millirem / hour at 18 inches from the wall. Health physics personnel

then posted the immediate area around the outside wall of the building

as a radiation area and a contamination zone. Initial soil samples

from the ground 'near the base of the wall showed a maximum

radioactivity concentration of 2.2E-2 microcuries per gram. A grid

survey of the area around the wall was then marked off. Licensee

representatives stated that 6 inch deep core samples would be taken

every 12 inches along the grid and that any area would be excavated and

placed in drums if the core sample indicated any detectable

radioactivity.

The inspector determined the area where the leak occurred was outside

the licensee's regulated area. A regulated area is defined in licensee

' procedure Radiological Control Instruction-1, Radiological Hygiene

Program, Paragraph III.A as an area within the plant site where access

is controlled for purposes of protection of individuals from exposure

to radiation and radioactive materials. This is the same definition as

is given in 10 CFR 20.3(a)(14) for a " Restricted Area,"

10 CFR 20.105(b)(1) required that the licensee limit radiation levels

in unrestricted areas such that no individual, if he were continuously

present in the area, could receive a dose in excess of two millirems in

any one hour. Through discussions with -licensee representatives, the

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inspector determined that the area outside the CDWE Building was inside

the licensee's " power block," Dosimetry devices were required to be

-worn inside the power block." The inspector questioned several public

safety officers at the security access portal and they all stated that

personnel are checked for dosimetry before entry is allowed inside the

" power block." During tours outside of the regulated area and within

the " power block," the inspector observed that all personnel were

wearing dosimetry devices. It was therefore determined that since no

unmonitored personnel were likely to have been present in the vicinity

of the leak outside the CDWE Building, the ~ radiation level that was

present was not in violation of the requirements of

10 CFR 20.105(b)(1).

The licensee conducted an investigation to determine the source of the

leak. It was determined that there hcA been frequent standing water in

the CDWE Building due to seal failures en the pump on the recirculati.on

line from the waste evaporator vessel. Licensee representatives stated

that, if the recirculation line were isolated when the pump seal

failed, the highly borated water in the vessel would solidify and

recovery operations would be difficult. For this reason, they stated,

it was preferable to allow the contents of the vessel to drain onto the

floor. After the borated water crystallized, workers were sent into

the area to shovel the waste into 55 gallon drums. The inspector

reviewed selected RWPs for the CDWE Building and determined that

personnel exposures in_this area, due mostly to clean-up work, had been

approximately 23.9 man-rem. Licensee representatives stated that

engineering evaluations were in progress to determine solutions to this

problem. The inspector learned from discussions with licensee

representatives that the CDWE had not been designed to process primary

system- liquid waste and that the boron concentration in the. liquid

waste apparently exceeded the specifications of the pump. The

inspector also' learned that the ventilation from the CDWE Building feeds

into the Auxiliary Building ventilation system. When there is an

Auxiliary Building isolation, dampers close on the CDWE Building

ventilation exhaust, often resulting in buildup ~f o airborne

radioactivity in the area. The CDWE Building is therefore outside of

the secondary containment boundary. These design and operational

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problems are being examined by the NRC Resident Inspectors and will be

discussed in Inspection Report No. 50-327, 328/86-15.

The licensee could not determine how long the leak had been present on

the outside of the CDWE Building. Licensee representatives stated that

they do not periodically perform routine radiation surveys outside of

regulated areas within the plant site. During discussions with the

inspector, the licensee stated that they were in the process of

developing a routine survey program for areas outside ~the regulated

area. The inspector stated that the program would be reviewed during

subsequent inspections and was identified as an Inspector Follow-up

Item (50-327, 328/86-04-07).

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The-inspector discussed the reportability of the event with licensee

representatives. They. stated that the.only reporting requirement that

they could identify which might be applicable to this event was that

specified in - 10 CFR 20.403(b)(4), which required twenty-four hour

i notification for any event involving licensed material possessed by the

licensee that may have caused or threatens to cause damage to property

in excess of S2,000. However, they . stated that they believed the

definition of " property" to mean property that is outside the site

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boundary. The inspector informed the . licensee that their

interpretation was not correct. At the time of the inspection, the

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licensee had not completed an engineering and cost evaluation of the

damage. This area will be reviewed during subsequent inspections.

5 6. Allegations, Discussions and Findings

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4 a. Allegation (RII-85-A-0202)

Unqualified personnel have been hired into the Health Physics Dosimetry

Section. Personnel who read dosimeters on the 690' elevation are not

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in the position of monitoring and reading dosimeters and TLD badges,

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Discussion and Finding

l The inspector determined that approximately a year ago when the

licensee imphmented the " power block" concept, workers were given the

l responsibility of picking up and replacing their own dosimetry devices

at the badge rack just outside the security access portal. During the

period June through December ~1985, the~ licensee employed six personnel

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who were assigned to the badge rack. Their assigned duty was to assist

workers in picking up the dosimetry that was assigned to them from the

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correct slot and checking to see if it was replaced in the correct slot

.by the worker. The licensee believed that this added assistance would

help workers become accustomed to the new procedures and would give t

management confidence that workers were not wearing someone else's

dosimetry. The six badge rack monitors did not have any responsibility

for reading TLD or pocket dosimeters and were not involved in

accounting for personnel exposures. The inspector determined that

these personnel had not received any specialized health physic's

training, however, considering the scope of their duties, no training

in health physics was required.

This allegation was not substantiated,

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b. Allegation (RII-86-A-0008)

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Radioactive material is stor.ad in numerous locations around the plant

site, the implication being the number of such storage areas is

excessive.

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Discussion and Finding

During tours of the facility, including selected outside areas, the

inspector noted that the number of storage areas had been reduced since

previous inspections. All radioactive material storage areas observed

where controlled in accordance with 10 CFR 20.203.

This allegacion was not substantiated.

7. Control of Radioactive Material (83726)

10 CFR 20.201(b) required the performance of surveys that are necessary to

demonstrate compliance with 10 CFR Part 20 and are reasonable under the

circumstances. 10 CFR 20.301 required that no licensee shall dispose of

licensed material except by certain specified means.

The inspector observed radiological surveys being performed at the regulated

area boundary on the 690 elevation of the Service Building to release

material and equipment for unrestricted use. The licensee had established

at the regulated area exit a release survey station consisting of a table, a

scaler counter for counting smears and a portable beta gamma survey

instrument with a pancake GM probe for performing direct radiation surveys.

The release survey station was attended by a health physics engineering

aide, who was a person the licensee had trained to the specific portions of

the licensee's health physics technician qualification program which related

to the performance of unconditional release radiological surveys. The

inspector observed workers place material and equipment contained in sealed

yellow polyethylene bags on the table at the release station. The

engineering aide did not question the worker presenting the equipment for

survey as to what the equipment was, where it had been or where the worker

intended to take it so that he could adequately evaluate the scope of the

release survey that needed to be performed. The surveys that were performed

were essentially only spot checks for smearable contamination and direct

radiation. Areas of higher contamination potential, such as connectors on

cable sets, were not surveyed and equipment with potentially internally

contaminated areas were released without evaluation. Failure to perform

adequate radiological surveys to release material for unrestricted use was

identified as an apparent violation of 10 CFR 20.201(b) (50-327,

328/86-04-04).

8. External Exposure Control (83724)

a. Radiation Work Permits

Licensee representatives stated that as result of a TVA, Division of

Quality Assurance Audit finding identified in October 1985, they are

completely revising their radiation work permit (RWP) system and the

method used to track MPC-hours and ncble gas dose assessments. The RWP

that is currently in use at Sequoyah contains a description of the job,

general work instructions, such as to obey all radiological procedures

l or frisk when leaving the area, and signature spaces for approving

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officials. The RWP Time Sheet cover page indicates the applicable

protective requirements (protective clothing, special dosimetry,

respiratory protection), special work instructions, survey data and

high radiation area controls. T.he remainder of the time sheet is used

as a log of personnel entries into the RWP area. A health physics

technician is normally the only approving authority for the RWP time

sheet. When a particular job is complete, or at the end of the

calendar year, the RWP Time Sheet is terminated and sent to the ALARA

section. RWP Time Sheet log entries are entered into the ALARA

computer, which assigns individual MPC-hours and skin dose due to noble

gas. The skin dose exposure data is then sent to the dosimetry section

where individual exposure files are updated. MPC-hours are updated on

a separate printout by the ALARA section wh'ich goes to the -health

physics lab and control points. The TVA QA audit identified that

permitting RWP Time Sheets to be active for up to a year caused

Sequoyah to be in noncompliance with 10 CFR 20.401(a), which required

that exposure records be for periods of time not exceeding one calendar

quarter. The system also had caused some worker termination exposure

reports to be in error'since there was no mechanism to identify a

worker had outstanding noble gas skin dose from a time sheet that was

still active at the time the termination report was issued. Although

not discussed in the QA audit report, the time- sheet system also did

not allow worker skin dose and MPC-hour exposures to be known in

sufficient time to be taken into consideration when determining how

much exposure the worker could subsequently receive. Licensee

representatives stated that their new RWP system would include all of

the protective requirements on the sheet that is reviewed by the

approving officials and that the time sheet would serve only as an

entry log. Separate forms to track individual entries into areas where

MPC-hour or noble gas skin dose assignment is required were being

developed. The licensee. expects to have their new RWP system in place

by May 1, 1986. Review of the revised RWP system was identified as an

Inspector Follow-up Item (50-327, 328/86-04-06).

b. Lens of the Eye Exposure Due to Noble Gas

The licensee identified by means of a Significant Corrective Action

Repu.t (NCO-CAR-85-004-RWB) initiated by the health physics staff at

TVA's Watts Bar Nuclear Plant in mid-1985 that the algorithms used to

evaluate the readings obtained from the Panasonic TLD by the Dosimetry

and Offsite Support Staff at Muscle Shoals, Alabama were not consistent

with regulatory requirements. 10 CFR 20.401(a) requires that

individual radiation exposure records be maintained on Form NRC-5, or

equivalent, and in accordance with the instructions contained on the

form. Item 5 of Form NRC 5 states that, unless the lenses of the eyes

are protected by eye shields having a tissue equivalent thickness of at

least 700 mg/cm 2 , the eye dose should be determined through a tissue

equivalent absorber having a thickness of 300 mg/cm 2 or less. When TVA

began use of the Panasonic TLD, the algorithms used to eval ~u ate the

readings were developed internally in lieu of using the ones available

through the TLD vendor. The Watts Bar CAR identified that only the TLD

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14

elements under the 7 mg/cm 2 and 1,000 mg/cm2 shields were being

evaluated to determine worker exposures. The TLD also had two other

elements under 300 mg/cm 2 shields, but there were no algorithms to

routinely evaluate lens of the eye exposure as indicated by the

readings obtained from these two elements. In response to the CAR, the

licensee developed algorithms to correct this deficiency. They also

reviewed individual exposure histories.to determine if any significant

adjustments in documented exposures were warranted and concluded that

none we.re necessary.

The licensee occasionally had to make containment entries when the

reactor was at power. Noble gas concentrations' in containment during

these entries have been as high as 50' to .100 times a maximum

permissible concentration (MPC) as defined in 10 CFR 20. Appendix B.

The licensee had determined that the TLD element under the 7 mg/cm 2

shield could not accurately measure the worker's skin exposure due to

beta radiation and therefore developed a calculational technique based

on the noble gas concentration in containment and the workers stay

, time. The inspector reviewed an internal licensee memorandum which

stated that whole body dose, including lens of the eye dose, could

accurately be measured by the TLD element under the 1000 mg/cm2 shield

and therefore no calculational assessment was necessary. Since workers

entering containment were not required to wear eye protection, the

licensee's conclusion was not consistent with the instruction on Form

NRC 5. No assessments of lens of the eye exposure due to noble gas

were therefore being made. After the' licensee changed their algorithms

to consider the value from the TLD element under the 300 mg/cm 2 shield,

no evaluation was performed to determine if that element accurately

measured lens of the eye dose or if a calculational assessment was

necessary similar to that perforaed to assess skin dose. Failure to

perform an adequate evaluation to determine that lens of the eye

exposures were with the quarterly exposure limits specified in

10 CFR 20.101(a) was identified as an additional example of an apparent

violation of 10 CFR 20.201(b) (50-327, 328/86-04-04).

Failure to adequately evaluate lens of the eye exposure had the

potential of causing workers who had high whole body and skin exposures

to exceed the NRC quarterly whole body exposure limit if a sufficient

portion of the radiation assessed as a skin dose also penetrated to a

depth in excess of 300 mg/cm2 , but less than 1000 mg/cm2 . This issue

was designated as an Unresolved Item during the inspection. The

licensee informed Region II on February 7, 1986, that they had

determined that no exposure in excess of regulatory limits had occurred

based on their review of personnel exposure histories.

On February 12-13, 1986, an onsite inspection was conducted of the

licensee's Dosimetry Section in Muscle Shoals, AL, to independently

verify the licensee's conclusion.

'

Through discussions with licensee dosimetry section personnel and

review of selected procedures and records, the inspector evaluated the

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method by which raw TLD readings were converted to dose. Raw readings

from the four TLD elements were first . adjusted by multiplying each

l value by the TLD element and TLD reader calibration factors. A

<

background . radiation' value was also subtracted. The adjusted readings

were then compared to a predetermined response matrix. The response

1 matrix was a set of ratios used to' predict the value on any given

. element based on the type of radiation the TLD had been exposed to.

The basic response matrix had ratios for gamma, soft beta and hard beta

radiations. The ratios in the response matrix were determined by

dividing the value that would be on each of the elements by the skin

dose. The adjusted element values on the TLD being read were then

compared to the predicted values for each. element for each type of

radiation in the basic response matrix. The actual and predicted

element values were then tested for " convergence," which was defined as

the ratio of the predicted and actual values. A convergency flag would

"

appear if the predicted and average values differed by more than thirty

percent and the dose involved exceeded 50 millirem. If a convergence

flag appeared, the adjusted TLD element values were compared to an -

expanded response matrix which included low and high energy photon

radiation. The. expanded comparison also considered that the TLD may

! have been exposed to more than one type of : radiation. The actual TLD

element readings were compared to modified response matrix lines which

combined the matrix ratios for more than one type of radiation.

Successive trial fits were attempted until -the matrix which best fit

the actual values was discovered. The values from this response matrix

4 were then used to calculate dose from the skin dose indicated by the

actual TLD values.

The Panasonic TLD system had been put in place at Sequoyah in January

1985. At that time, the dose calculation system described above

calculated two dose values; dose to the skin (DS) from TLD element 1

,

and whole body dose (DC) from TLD element 4. Eye dose due to noble gas

'

would have been indicated by a high response on TLD elements 2 and/or 3

from high energy beta or low energy photon radiations. However, the

!- value on these two TLD elements were not considered in determining

L dose. After the Watts Bar CAR was written, the licensee added a new

i dose to the lens of the eye (DL) field to the dose calculation line of

l the computer printout. This change was made in October 1985. After

this date, the whole body dose was taken as the higher of DC or DL.

Licensee representatives stated that during this period, any

significant lens of the eye dose as indicated by TLD elements 2 or 3

would have produced a convergency flag, causing a more careful review

, of that particular reading. The licensee wrote a test computer program

l to determine how many convergency flags involving significant dose may

have been produced during this time period. The program searched the

, data base for all cases where the value on element 3 had been 50

,

percent higher tha.' element 4 and the dose recorded on element 3 was

, greater than 40 m. ilirem. Fourteen such cases were identified. This-

, -result indicated that there were only a limited number of cases in

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which dose the lens of eye may have been limiting in determining whole

body dose.

The second computer test the licensee conducted was to increase all the

whole body doses recorded in the data base during the' period September

1983, to June 1985, by 25 percent of the skin dose and then printout

all- totals greater than 3 Rem (i .e. , 0.25 DS+DC > 3R). The basis for

adding one quarter of the skin dose to DC was that, for high energy

betas, 25 percent of the skin dose would penetrate to a depth in excess

of 300 mg/cm2 and a convergence flag may not have been produced. In

actual practice, it was not likely that the exposure would have been

entirely due to high energy beta radiation. However, assuming the

worst case, no exposures in excess of 3 Rem were identified as' result

of this test.

The inspector reviewed quarterly exposure records' of all personnel who

had been badged at Sequoyah during the period January through September

1985. The inspector selected the names of two individuals from the-

printouts in order to review in detail how their quarterly exposure had

been determined. The first individual had an exposure at the end of

the.second quarter of 1985 of 5695 millirem DS and 240 millirem DC.

The second individual had a third quarter 1985 exposure of 2950

millirem DS and 2541 millirem DC. The inspector reviewed for each

individual each TLD reading and how it had been evaluated and any. skin

dose assessment due to noble gas. The inspector determined that at

most the assigned whole. body dose would not have increased'more than 2

millirem due to the readings recorded on TLD elements 2 and 3. Based

. on the above, the inspector concluded that failure to evaluate the

values on TLD elements 2 and 3.for lens of the eye exposure had not

caused any worker to exceed the NRC whole body quarterly exposure

limit. The inspector informed the licensee on February 28,-1986, that

the Unresolved Item was closed.

c. Dosimeter Rezero Sheets

During the onsite inspection of Sequoyah's dosimetry section, the

inspector reviewed how the licensee's daily dose printout is

formulated. The daily dose printout is used to monitor the exposure

status of each monitored employee and is used as the reference document

for individual exposure planning, such as computing stay times. The

printout column indicating the individual's current total quarterly

whole bcdy exposure is the summation of his TLD readings during the

period and pocket dosimeter data for periods which the TLD had not yet.

been read. The source for the pocket dosimeter data was the dosimeter

rezero sheet.

!

Dosimeter rezero sheets were issued from the dosimetry office. Each

form was assigned a control number which was recorded in a log book.

At the beginning of each shift, a technician took a new rezero sheet to

the health physics lab and each active control point and picked up the

one that had been used the previous shift. The dosimetry data from the -

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rezero sheets was then entered into the computer data base that.was

used to generate the daily dose printout. Upon review of the rezero

sheet issuance log, the inspector observed that several control numbers

had not been checked in the space indicating that the rezero sheet had

i been processed. Licensee representatives stated that there had been

occasions when the technician exchanging the rezero sheets could not

locate the rezero sheet that had been in use the previous shift. A

reasonable search was then conducted in the area and there had been

times when 'the rezero sheet could not be found. The inspector stated

that the same type of investigation as is performed when a dosimeter or

TLD is lost should be' performed to assess what exposure data had been

lost. Each dosimeter sheet had spaces to record the readings of nine

dosimeters. Workers were required to have their dosimeters rezerced

'

when it reached 50% of its full scale. The rezero sheet was also used

for high range dosimeters in addition to the 0-200 millirem dosimeters

issued to each monitored individual, so the lost dosimeter data could

be.on the order of several hundred millirem. It was determined that 2

rezero sheets in 1986 and 9 in 1985 had been lost. Failure of the

licensee to evaluate the dose recorded on lost dosimeter rezero sheets

was identified as an additional example of an apparent violation of

10 CFR 20.201(b) in th'ta evaluations as were necessary to determine

.

compliance with the quarterly whole body exposure limits specified in

j 10 CFR 20.101 had not been performed (50-327, 328/86-04-04).

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9. Internal Exposure Control (83725)

! a. Respiratory Protection

4

10 CFR 20.103(c)(2)' required that the licensee may make allowance for

use of respiratory protective equipment in estimating exposures of

individuals to radioactive material in air provided that the licensee

maintains and implements a respi ratory protection program that

. includes, as a minimum, written procedures regarding supervision and

training of personnel and issuance records.

While reviewing the circumstances surrounding the internal exposure

,

event of December 11, 1985, described in Paragraph 5.c, the inspector

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reviewed certain aspects of the licensee's re spiratory protection

program. Licensee representatives stated that respiratory protection

'

devices are issued from the -respirator room and at health physics

control points during outages. A health physics technician verifies

that the worker requesting a respirator is trained and medically

qualified to use a respirator before it is issued to him. Licensee

'

representatives stated that no records are maintained which show that

an individual was issued a respirator and no licensee procedure

required maintenance of such records. Through review of selected

MPC-hour assignment records and discussions with licensee

representatives, the inspector determined the licensee made allowance

for use of respiratory protective equipment in estimating exposures of

individuals to radioactive material in air. Failure of the licensee to

,

maintain written procedures regarding respirator issuance records was

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identified as an apparent violation of 10 CFR 20.103(c)(2) (50-327,

328/86-04-03).

b. Respirator Filter Retesting

The licensee had been shipping respirator filters offsite for retesting

since November 1984. The licer see has the capability of performing

onsite testing of respirator t ilters using corn oil. The inspector

informed the licensee that it was-acceptable to use a corn oil test to

verify the integrity of the filter.

10. Inspector Follow-up Items (92701B)

(Closed) 50-327, 328/85-23-05, Overstated exposure estimates. When workers

were terminating employment at the licensee's facility, an exposure estimate

would often be requested from the _ dosimetry section Dosimetry personnel

gave the worker a form which indicated his total exposure as shown on

licensee records. Since the worker's current quarter TLD was not likely to

have been processed, the form stated that the exposure information was an

estimate. The Resident Inspector noted that the exposure totals included

exposures, i f any , received at other non-TVA facilities. The inspector

determined that since the exposure values were conservative and the form

clearly indicated the information was an estimate,' the licensee's practice

was not contrary to any regulatory requirements.

(Closed) 50-327, 328/85-47-04, Internal exposure event of December 12, 1985.

Findings related to this event are discussed in report Paragraph 5.c.

11. Enforcement Conference

An Enforcement Conference was conducted telephonically on March 14, 1986, to

discuss the transportation violation and civil penalty issued by the State

of South Carolina for the September 27, 1985, event involving

inaccessibility of. cask rigging gear. The following persons were present

during the discussion:

a. Tennessee Valley Authority

J. Domer', Assistant Manager of Licensing

L. Nobles, Operations and Engineering Superintendent-

G. Kirk, Compliance Supervisor

J. Qualls, Radwaste Supervisor

D. Kelley, Chemical Engineer, Radwaste Operations

B. Alsup, Project 1 Licensing Manager

E. Whitaker, Licensing Engineer

J. Anthony, Operations Group Manager

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b. Nuclear Regulatory Commiss' ion

D. Verrelli, Chief, Reactor Projects Branch 1

D. Collins,. Chief, Emergency Preparedness and Radiological Protection

Branch -

G. Jenkins, Chief, Enforcement and Investigation Coordination Staff

C. Hosey, Chief, Facilities Radiation Protection Section

W. Cline, Deputy Chief, Reactor Projects Branch 1

L. Trocine, Enforcement Specialist

Licensee representatives discussed the circumstances of the event, their

initial corrective action and long term corrective actions.

NRC representatives emphasized the sensitivity of transportation problems

and discussed the NRC enforcement policy in this area.

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