ML20197K051
| ML20197K051 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 04/30/1986 |
| From: | White S TENNESSEE VALLEY AUTHORITY |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8605200243 | |
| Download: ML20197K051 (9) | |
Text
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TENNESSEE VALLEY AUTHORITY CHATTANOOGA. TENNESSEE 37401 6N 38A Lockcut Place April 30,1986
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U.S. Nuclear Regulatory Commission Region II ATIN: Dr. J. Nelson Grace, Regional Administrator 3
101 Marietta Street. NH, Suite 2900 3
Atlanta, Georgia 30323 u-l
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Dear Dr. Grace:
SEQUOYAH NUCLEAR PLdNT UNITS 1 / "O 2 - NRC-0IE REGION II INSPECTION REPORT l
50-327/86-04 AND 50-328/86-04
-SPONSE TO VIOLATIONS l
Enclosed is TVA's response to J. A. Olshinski's March 27, 1986 letter to me transmitting IE Inspection Report Nos. 50-327/86-04 and 50-328/86-04 for i
our Sequoyah Nuclear Plant which cited TVA with one Severity Level III Violation and three Severity Level IV Violations.
TVA denies the Severity Level III Violation.
The degree of difficulty to retrieve the cask rigging gear does not constitute a violation of 10 CFR 30.41(c) or License No. 097.
Failure to meet Chem-Nuclear Systems, Inc.,
(CNSI) acceptance criteria does not constitute risk to the health and safety of the public nor raise substantial risks to radiation workers to tne extent that a Severity Level III violation is warranted in that the cask rigging was provided with lifting devices consistent with the requirements of the State of l
The Severity Level IV Violations 50-327, 50-328/86-04-02, and 50-327, 50-328/86-04-03 are denied as stated.
Part (a) of the Severity Level IV Violation 50-327, 50-328/86-04-04 is considered a licensee identified violation, but was not designated as such in the inspection report.
If you have any questions, please get in touch with R. E. Alsup at FTS 858-2725.
To the best of my knowledge, I declare the statements contained herein are complete and true.
Very truly yours, TENNESSEE VALLEY AUTHORITY
- p.. % d" A. White Manager of Nuclear Power Enclosures cc:
Mr. James Taylor, Director (Enclosures)
Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C.
20555 0605200243 860430 PDR ADOCK.05000327 G
PDR y
bd An Equal opportunity Employer
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ENCLOSURE' RESPONSE - NRC-OIE INSPECTION REPORT NOS. 50-327/86-04 AND 50-328/86-04 J. A. OLSHINSKI'S LETTER TO STEVEN A. WHITE DATED MARCH 27, 1986 Violation 50-327/86-04-01 and 50-328/86-04-01 10 CFR 30.41(c) required that before transferring byproduct material to a specific licensee of an Agreeinent State, the licensee transferring the g*
material shall verify that the transferee's license authorizes the receipt of the type, form, and quantity of byproduct material to be transferred.
Condition 64 of the State of South Carolina Radioactive Material License No.
097, required that Chem-Nuclear Systems, Inc., not receive shipments of radioactive materials unless appropriate lifting devices of sufficient s
length have been provided and securely attached to contait.ers and palletized.'
shipments within cask.
Contrary to the above, on September 27, 1985, the licensee's radioactive waste shipment number 0985-119 arrived at the Chem-Nuclear Systems, Inc.,
radioactive waste disposal site near Barnwell, SC with the cask rigging gear inaccessible for unloading in that the rigging gear was wedged in the space between the liner and shipping cask inner wall by bracing material.
This is a Severity Level III violation (Supplement V).
1.
Admission or Denial of Alleoed violation TVA denies the violation occurred as stated.
' 2.
Reason for Denial TVA does not consider that the degree of difficulty to retrieve the cask rigging gear constitutes a violation of 10 CFR 30.41(c) or License No.
097.
Failure to meet chem-Nuclear Systems, Inc., (CNSI) acceptance criteria does not constitute risk to the health and safety of the public nor raise substantial risks to radiation workers to the extent that a Severity Level III violation is warranted in that the cask rigging was provided with lifting devices consistent with the requirements of the Stato of Couth Caro 11ha.
10 CFR 30.41(c) requires that before transferring byproduct material to a specific licensee of an Agreement State, the licensee transferring the material shall verify that the transferee's license authorizes the receipt of the type, form, and quantity of byproduct material to be transferred. TVA notified CNSI, as indicated by the Prior Notification and Manifest form, that TVA was sending a resin shipment Type B, LSA, stable,containing 644 curies; therefore, the condition of 10 CFR 30.41(c) was met.
Condition 64 of the State of South Carolina Radioactive Material License No. 097 requires that Chem-Nuclear Systems, Inc., not receive shipments of radioactive material unless appropriate lifting devices of sufficient length have been provided and securely attached to containers and palletized shipments within cask.
Appropriate lifting devices of sufficient length were attached to the disposal container; therefore, condition 64 of License No. 097 was met.
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Step 7.4.1 of the CNSI criteria procedure specifies that "All drums filters, boxes and/or containers shall be palletized and pallets shall have proper lifting devices attached and they must be of sufficient length to allow retrieval and crane hookup without physically enterinq
_the cask."
The portion of the step which was not met was ensuring crane hookup without physically entering the cask.
While this violated the CNSI acceptance criteria, it did not violate either 10 CFR 30.41(c) or License No. 097.
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TVA acknowledges that failure to meet the burial site acceptance criteria could have resulted in a potential CNSI violation of License No. 097.
However, the shipment was returned to Sequoyah where the cask rigging gear was properly positioned.
Sequoyah personnel received a total of 540 mrem exposure when knocking out the bracing, retrieving cables, raising the liner to install new bracing, and reinstalling the cask lid.
Substantially less exposure would have been received by the CNSI individual since the only action which would have been required was to remove the bracing.
These exposure levels are not considered substantial or excessive.
(TVA offered to' send personnel to the burial site to free the cables, which would have resulted in less exposure.)
State of South Carolina and the shipment returned to Barnwell forThe disposal.
To prevent recurrence, the Sequoyah shipment procedure has been revised to require a specific signoff that the cables are free.
(The procedure contained a step to check the cables but did not require a signoff.)
In addition, TVA has completed fabrication of a permanent _ bracing fixture which should preclude the possibility of the rigging being wedged in the space between the liner and shipping cask
____.... inner wall.
TVA was also cited by the State of South Carolina for violation of condition 64 of license No. 097.
Although TVA paid a one thousand dollar fine to the State of South Carolina, TVA did not concur that a violation of the license occurred.
payment of the fine was made for economic reasons since it would not have been cost effective to contest the fine.
In conclusion. CNSI personnel are experienced in dealing with radioactive materialo.and un.1erstand the asduciated hazards.
Exposures are strictly limited at the burial site which should preclude any substantial potential for personnel exposure.
of the cask to TVA reflected the burial site's strict compliance with The return their own dose limits (which are reduced by one-third of the allowables) and not their concern over a substantial potential for exposure.
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Violation 50-327/86-04-02 and 50-328/86-04-02
~ 10 CFR 20.103(a)(3) required that for purposes of determining compliance with the requirements of 10 CFR 20.103(a)(1), the licensee shall use detecting and evaluating airborne radioactivity in restricte 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 for timely detection
- E and assessment of individual intakes of radioactivity by exposed individuals Contrary to the above, the licensee failed to use the results of the measurements listed in 10 CFR 20.103(a)(3) to determine compliance with C a internal deposition of radioactive material on Decemberrequiremen 11, 1985, in that analyses performed during the period Decemberthe results of the ten 11-18, 1985, were not evaluated to determine the regulatory significance of the exposure.
This is a Severity Level IV violation (Supplement IV).
1.
Admission or Denial of Alleged Violation TVA denies the violation occurred as stated.
2.
Reason for Denial 10 CFR 20.103 requires the assessment of intakes resulting from employee exposure to airborne radioactive materials.
This assessment is to be performed by whatever means are appropriate to the particular situation (i.e., bioassay, calculation from air sample data, etc.).
bioassay data, TVA determined that the assessment of do critical organ and the comparison of that dose to regulatory criteria was most appropriate.
was of no regulatory significance.This was done with the result that the exposure The results of the whole body counts, and urine and fecal samples were evaluated to derarmin'o the regulatuty significance of the internal exposure.
Specifically, the total dose equivalent received by the critical organ (lower large intestine) as a result of the incident was calculated as 0.071 rem.
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r The requirements of 10 CFR 20.103(a)(1) consist of limiting the quarterly inhalation of radioactive material to 520 MPC-hours.
This is a derived limit based on the following primary 50-year committed dose limits:
Whole body, l.25 rem /qtr. (5 rem /yr.)
-k Bona, thyroid, and skin 7.5 rem /qtr. (30 rem /yr.)
Other organs 3.75 rem /qtr. (15 rem /yr.)
Because the critical organ for the incident was the lower large intestine, the derived limit of 320 MPC-hours /qte, is equivalent to a 50-yea _r committed dose limit of 3.75 rem /qtr. Thus, upon performing a basic calculation utilizing the lower large intestine equivalent dose-(as determined 12/23/85) of.071 rem, the internal exposure corresponded to 1.89 percent of the applicable' quarterly limit.
This was determined to be of no regulatory significance.
Subsequent to this event, to verify our determination that the exposure had no regulatory significance, the lung dose was calculated to be.081 rem, thus validating our assertion the exposure was of no regulatory significance.
Because of the lack of air sampling data and a measured rate of elimination of the radioactive material, which was far more rapid than predicted by the International Commission of Radiological Protection (ICRP) models for standard man, MPC-hours were not calculated for the incident.
Our understanding of the stated position of the NRC inspector was that regardless of the mode of intake (i.e., inhalation, injection, ingestion, or absorption), MPC-hrs must be calculated and tracked to demonstrate regulatory compliance.
While TVA agrees that in general MPC-hour determinations are adequate to assess the regulatory significance of chronic'Wkposure to airborne contaminants, the calculation of MPC-hours may have no logical relationship to the internal dose received by an individual or to the significance of such exposure for noncoutine airborne exposure and for modes of intake other than inhalation.
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TVA believes that while 10 CFR 20.103 does not require the determination of hPC-hours for all modes of exposure, it does require the assessment of all intakes. The NRC has not to our knowledge interpreted the regulations to require the tracking and evaluation of intakes (pCi of material), although it is a much more appropriate
,nede of demonstrating regulatory compliance and has a direct relationship to dose received. Since the relationship between intake and dose is defined in ICRP-2 methodology, the use of either to document employee exposure to internal radioactive material should be adequate for both regulatory and personal protection purposes.
TVA believes that the calculation of critical organ dose which was performed provided a more accurate evaluation of the regulatory significance of the exposure than could have been achieved by back-calculating MPC-hours based on bioassay results.
It would greatly assist the industry if the NRC would issue an IE Notice on this topic in order that the entire region can be informed of the NRC position.
o Violation 50-327/86-04-03 and 50-328/86-04-03 10 CFR 20.103(c)(2) required that the licensee maintain and implement a respiratory protection program that includes, as a minimum, written procedures regarding supervision and training of personnel and issuance records if the licensee makes allowance for use of respiratory protective equipment in estimating exposures of individuals to radioactive material in air.
Contrary to the above, the licensee failed to maintain written procedures regarding respiratory protective equipment issuance records in that no such records were maintained and allowance was made for use of respiratory protective equipment in estimating exposures of individuals to radioactive material in air.
This is a Severity Level IV violation (Supplement IV).
1.
Admission or Denial of Alleged Violation TVA denies the violation occurred as stated.
2.
Reason for Denial It is TVA's interpretation of 10 CFR 20.103(c)(2) that the radiation work permit (RWP) program actually functions as a respiratory protective equipment issuance record. TVA has utilized the existing RWP program to function as a method to maintain a record of respiratory protective equipment utilization. The RWP program utilizes an administratively controlled document which specifies, among other things, the required protective equipment.
l This document includes the names, work group, social security number and date of RWP utilization. Each worker is trained to understand that by virtue of his signature on the RWP timesheet, the worker is acknowledging that he has complied with all requirements of the RWP, including use of specified respiratory equipment. Through the use of this document, TVA can accurately determine which individual (s) wore respiratory protective equipment, the area of the plant where the equipment was utilized, and the duration of utilization.
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Violation 50-327/86-04-04 and 50-328/86-04-04
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10 CFR 20.201(b) required that each licensee shall make or cause to be made such surveys as may be necessary for the licensee to comply with 10 CFR Part 20 and are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present. A " survey" is defined in 10 CFR 20.201(a) as an evaluation of the radiation hazards incident to the production, use, release, disposal, or presence of radioactive materials or
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other sources of radiation under a specific set of conditions.
10 CFR 20.101(a) required a licensee to possess, use, and transfer its licensed material in a manner which precludes whole body and lens of the eyes occupational exposure of any individual in a restricted area of more than 1.25 Rems in any period of one calendar quarter except as provided in 10 CFR 20.101(b).
s 10 CFR 20.301 forbids a licensee to dispose of licensed material except by certain specified means.
Contrary to the above, the requirement to perform evaluations necessary to demonstrate compliance with 10 CFR 20 and were reasonable under the circumstances to evaluate the extent of radiation hazards present was not met in that:
During the period January through September 1985, the licensee a.
l failed to perform adequate evaluations to demonstrate that individual lens of the eye exposures due to noble gas were in compliance with the lens of the eye quarterly exposure limits in 10 CFR 20.101(a) during personnel containment entries while the reactor was at power.
b.
On January 27, 1986, surveys of material and equipment being released for unrestricted use were inadequate to demonstrate that the material and equipment contained no detectable licensed material and that the disposal requirements of 10 CFR 20.301 were not applicable, The licensee did not make such evaluations of lost individual c.
exposure data a's were necessary to ensure that individual exposures were within the quarterly whole body exposure limits in 10 CFR 20.201(a) for the two pocket dosimeter resero sheets recorded as lost in 1986 and the nine rezero sheets lost in 1985.
This is a Severity Level IV violation (Supplement IV).
1.
Admission or Denial of Alleged Violation TVA admits a violation occurred, but that the violation was a.
appropriately identified by TVA.
b.
TVA admits the violation occurred as stated.
TVA admits the violation occurred as stated.
c.
c e
2.
Reason for Violation TVA takes exception to this example since it is a licensee a.
identified item, and it appears to meet the criteria of 10 CFR 2 Appendix C, Paragraph TN A.
TVA corrective action report (CAR) NCO-CAR-85-004-RWB was issued documenting the subject deficiency. In July 1985, corrections were made by TVA and i
verified as being adequate by a cross-check with the University 11 of Michigan. TVA reviewed exposure data from the January through September 1985 period and determined that the differences were insignificant and no corrections to this data were warranted.
TVA considers that this example should have been exempted from the statement of violation since Appendix C.V.A states, "Because the NRC wants to encourage and support licensee intiative for self-identification and correction of problems, NRC will not generally issue a notice of violation for a violation that meets all of the following tests:"
1.
"It was identified by the licensee" (TVA corrective action report NCO-CAR-85-004-RNB was issued documenting the subject deficiency) 2.
"It fits in Severity Level IV or V" (the NRC inspection report specified that this was a level IV violation) 3.
"It was reported if required" (this deficiency was not required to be reported) 4.
"It was or will be corrected, including measures to prevent recurrence within a reasonable time" (corrective action and measures to prevent recurrence were taken expeditiously) 5.
"It was not a violation that could reasonably be expected to have been prevented by the licensee's corrective action for a previous violation" (TVA has not been cited for a previous similar violation) b.
The Health physics Section (Hp) representative performing the survey failed to use prescribed survey techniques and failed to follow procedures, The dosimetry unit did perform a physical search for the lost c.
pocket dosimeter zero sheets; however, they did not seek other sources of dose data (i.e., radiation work permits) that were available to them.
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,e 3.,
Corrective Steps Taken and Results Achieved 4
a.
See paragraph 2.a above.
I b.
Only one survey was discussed with the site representative and although the survey was inadequate, the HP representative did
' detect transferable contamination.
It was requested that the item be decontaminated. The immediate corrective actions were 4{
taken via written and verbal communications to the HP shift supervisors. Instructions were provided restating management position to adhere to plant procedures.
Upon notification that the previous search / evaluation may not be c.
in compliance with 20.201(b), another search was conducted.
U simetry personnel were verbally instructed to ensure that an
o evaluation be performed which would include a review of s
pertinent radiation work permits (RWP). A decision was made t
that futher evaluations were not necessary for the two lost sheets.
This decision was made based on knowledge of existing work activities in radiation work areas and pocket dosimeter zero sheets data from similar time periods.
4.
Corrective Steps Taken to Avoid Futher Violations l
a.
See. paragraph 2.a above.
b.
The HP section supervisor met with each section crew and discussed this failure to follow procedure. Guidance was provided to avoid further problems for surveys of this type.
Health Physics Dosimetry Section Instruction Letter (HPDSIL)-2 c.
will be revised to increase the control over the pocket dosimeter zero sheets. The revision will detail an investigation process to include a review of pertinent RWPs, radiation survey sheets, or other evaluations as deemed necessary based upon the extent of the radiation hazards that may be present.
5.
Date When Full Compliiance Will Be Achieved i
a.
See paragraph 2.a above.
b.
Full compliance was achieved March 12, 1986 HPDSIL-2 will be revised by June 1, 1986 c.
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