ML20206G597
| ML20206G597 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 11/04/1988 |
| From: | NRC OFFICE OF SPECIAL PROJECTS |
| To: | |
| Shared Package | |
| ML20206G037 | List:
|
| References | |
| NUDOCS 8811220323 | |
| Download: ML20206G597 (9) | |
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NUCLE AR REGULATORY COMMISSION f W A SHING TON, D. C. 20555 r
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- ..a 5:r!*Y EVALUATIO', DEDCOT PV TWE Orr!CE or SPECI AL PD0?! CTS EvrtovEE CONCERN ELEWE':T RED 0DT OD 31104, "wEALTW PdVSICS POLICIES, PEACTICES, AND FANAGE*ENT CONTD0L" TEPNESSEE VALLEY AUTHOAITY SEOUOY w t.TCLE AC COWEC PLANT UNITt 1 % ?
CnCKET h05. 50 3?7 AND 50 328
- 1. Subje::
Catecery: Operatiers (300001 Sub: ate:erv: Healin Physics (31100)
Element: we alth Pnysics Folicies. Practices, and Panagement Control (31104)
E-:ic>ee C:n: erns: I;;-55 es! xx-55 063 001 SL;-56-009-002 At-85 022-A02 AA-55-05A-001 xx-Sb 026-x03
)A-55-066-001 XX-85 098-002 XA-55 009-C02 1-86 235-5;N i
'al 55-03E-001 JLH ES-C03 xx-EE 015-C01 JPA 85-0C'.
AK-55-026-001 R!1-55-A-:064 Tre cases f ar Ele-ent Re: ort 00 311.04, cated Oct::er 21, 1985, are the felic.ing e ;1:3ee concerns:
Concern 5;P 56-009-001: An incicent'at Seouoyan Ovelear Plant which l resulted in employees teing radioactively ccntaminated could hase teen prevented a*d refle:ts ranagements attitu0e to.ard ra0istien safety anc personal safety of the e ployees, C:n=ere 5"E 85-009 002. ine transfer of res:ensioility fer HP fr0* Wus:le f Sncais to Seau yan pla:es tne incivicual responsible for HP in a position wnere much
' ** essure frce plant manage ent Can te eterte0 a" nas cause0 ccepremises of D'eviously estaDI'she0
"; ::li:y regar0ing personnel ac:ess caring unit
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gatg;;c3:3 891104 ADOCK 050003; PDR FDc p
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Corcern XX-85-056-001: Three years ago HP at Sequoyah was notified of higher-than-expected radiation levels in the Reactor Building. When notified by telephone, HP personnel speculated on the reasons for the high radiation level, and did not respond immediately to investigate. Cl feels that wasting time sceculating on cause and not responding ireect-ately is a concern for safety, Concern w i5 009 002: There is no regard for personnel safety at operation plants. Management (known) directed that the oldest employees be assigned to "hot" work in order for them to reach their radiation levels first. A supervisor (known) made the statement that "older folks won't be long at:une."
C:n:ern xx-55-023-x02: RhP 02-2-00214 (sign-in sheet) contains falsified signatures.
Concern As-55-025-x033: RW0s are not being completed acccrding to procedure requirements.
RWP02-2-00214 is an example.
Cen:ern xx-55-095-002: Radiation areas are net monitored often enough.
- een I-fi-235 5 3: An anen/ cus incivid 3 mailed in a safety con: err. to (NSRS) re:.esting that emergency prececures te written u encompass all aspects of possible emergency situations in a C-Zone.
Procedures shoulo cover specific areas such as spread of contaminatien, possibility of injury, possibility of a fire, possioility of poor l
treathing atmosphere, etc.
Cc cern M 55 003: A: cording to TVA's General Employee Training (GET)classesandplantprocedures,empicyeesare I to be frisied as soon as exiting a ' C-Zere.
I an e ployee has to search for a Currently, frisker. In the precess of looking fer a l
frisker, an e ployee can contaminate doors and/or t*e flect, 'ne of TW s CDjectives is to keep co.n contam.i ation, an the current prc ess c:es not, ace:;uately control tne spreading of centa*i-nation.
Exa?ple: Wren esiting ; ire chase 09 elevati:Ps 59.9 a: ifi, c e nas 10 0555 t " .? 0'Oia: :::*5
- Ost 10 3 fri 5wer, ; ele.at,0- 6f3 39 s??l'oyee 35 to nunt f:r 3 frisser ai evicence0 05 Cece er 12, 1955.
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3 Concern JMA 85-001: A high risk possibility of not securing s4SCE .
type breaches if a valid high-radiation conditten t occurs in the Auxiliary Building or during sn ,
announced evacuation or evacuation alarm soundec !
may cause persons tc leave the Auxiliary Building l before sea' ling penetration. k Concern WI-65-038-001: The practice of persons entering the lower !
contaminated area of the reactor containrent for nonerergency repairs while the reactor is !
operating should be reevaluated. Recent studies l incicate the biological ef fects of personnel l encosure to neutron flux are more serious than >
previously believed. This practice is in effect at SeQuoyah and resulted iri an accident arounc :
1953/1954 and is planned to be implementec at hatts Bar, i
i Cc :ce u-!E-015-C01: The practice of personnei entering tne le er containment area of the reactor containrent ;
fcr ncnemergency repairs while the reactor is coerating snould be reevaluated since recent stucies indicate the biological effects of !
l personnel exposure to neutron flux are more serious than previous' believed. This practice t cause: an accident -
the intore instruient !
- probe rocm at Sequoyr in 1985 and is still l continuec. l 4
C: cern m E5 026-C01: Inacecuate upper manage ent support provided the '
l hP cesarteent to enforce an ef fective racio-i logial safety program, ho cisciplinary actien is ta(en when e ployees intentionally bypass ronitors.
C:rcee ivii 063-C01: Secuoyah Cperators and Health Fnysics: Failure !
to knc anc serify tne contents of a spies.
4 t cuample: HP gave go ahead to coen a line in the i Unit 2 Turbine Bu11 ding. saying everything .as :
ekay and clean. After coening the line tae rest i
1 nignt, the entire area .as repec off for contami-nation. This occurred in January / February 1534.
i Concern :::-55-A :064: inis a' legation expressed concerns about the f" i Secu:p n HP prcgram.
- e ccreer s are su- 3Heet
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- 2. An incividual lost a radioactive source at the site and never reported the loss to management.
- 3. The location of radiation monitors are not as indicated on the ASIL-3 procedure.
4 Stears are taken into the HP office to count ano are then tnro n into the trash.
- 5. The s ear counting area in the HP office was ;
contaminated. This "contaminated area" as :
used as an eating area.
- 6. Air saTples are taken improperly, e.g. ,
floor level. Respirators were not worn by ,
orkers in high contamination areas (areas ;
ith surface contamination greater than ten -
tnousand dom).
- 7. The incividual claims he was dismissed fr:m employment as i result of a conspiracy and '
that he was not
- eated f airly during his ,
training perice. (,T hi s item is teing ,
handled solely : the Intimidation and '
Harassment Categc /.)
- 5. FP te:hnician did not cover the bead and i tilters of air sampling monitors before and i after exiting areas to te monitored.,
!!. 5;- ary o' Issue A. 3D'*i6 0.93 001. ;ertenrel at iepuoyah were contaminatec aac t*e incident, nien was preventacle, reflecteo poor management attity:es l regarding radiological and ;ersonal safety. No cetails of the even' are kno n.
5 $'E-56-0"i 022, "e:ent'ali:stion of tre i.'A WP program 3110 5 plant f Faelge ent to exert P:re pressure to co pro 9ise ractological saf ety.
Elv t :Olicy en centait, ment ;c er entries is gisen as an eaa ple. {
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C. si-55-C54 CC1. ::ssi:le :veres:osure in '.352 c.e to cuestionacle <
r e a :t i :e s t, -: . - -:.': u :1.g ra:'atic' :mi tors *en resc:9:ing 1: s'a- s i
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. E e ;.~e l 5 a;:. "; 15 F0t'fie cy tele 0*0*e :# S4 39 r30 i ltiO r le.e's in t*e 'ea: :" ivil 0irg. -0 Cid 50t it*eciately '
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E. XX 85-009 002. High exposure work was assignet to older -orkers first i by the direction of plant management. 7 F. *( 55-025-x02. A radiation work permit sig : in sheet contained ,
falsifiec signatures. l G. n-55-025903. Radiatien work permits are not being completed in l accercance with licensee procedures, j H. O 85-095 002. Frequency of radiological surveys in radiation areas I is not aceQuate. l I. I 86-238 SQN. A prececure fer emergency actions in a contaminated I area is neeced.
J. JLH 56-003. Personnel contamint. tion survey instruments are n t l conveniently locatec in the proximity of contamination zone e(its.
- C:ntaminatien may be unnecessarily spread as a result. r
. ?A 55-001. Possibility that Auxiliary Building Secondary Containment Enc 1:sure ( ESCE) creatnes eay not be secured by personnel evacuating curing an e ergency.
u *I 35-035 .s1. Concern about nonemergency contain?.ent power entries !'
aac na: arcs of reutron exposure. This practice also has caused an accicent (most likely referring to the th' le tube ejection). l v u-55-015 0:1. Sa e corcern as WI 55-035 ::1.- !
N. u-55 026 001. Lack of ransgement su;;: t for health physics pr:gra- No cisciplinary action is taken wnen empicytes intention- [
ally op ass contamination monitors, t c
- 0. u EE 053 001. Operatiens ar1 health onysics personnel are not ;
irc.iec;eatle of system status befcre alln.irg ork to be perforced. [
t P. U : 55 A 0064. Neercus concerns about tre aesquacy of the health !
prjsics program. i III. E aluatien
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- . SU -56 :: H ;'. . T3; c:Jo not evaluate the specific alleged incicent i C.e to a l a c a. of cetails. Tnerefore TVA evaluated the adequacy ef the cerscrrel cc9ta .irati0n presentien progra"! and licensee responses to c c. entes conta-ination events. No ceficiercies in the program were ;
ice-tisc. er .as t*ere any'ew icence trat a cers nrel centamination !
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- 2. 'S 30 2. The transfer of HP responsibilities from Muscle 5- che Division of Nuclear Power was effective on June 1, 1
'nsee PORC approved procedures for containment power J been initially approved on January 26, 1977 and had not
. 3tantially changed since then. TVA concluded that the or, . ational changes had not resulted in any changes in containment po er entry- criteria that would affect worker safety.
C. XX-85-084-001. TVA interviewed personnel and reviewed various c circumstance where HP personnel might have occasion to deactivate monitoring equipment, such as relocating friskers due to increased radiation background levels. Nc evidence could be found that these actions were improper. There have been no exposures at Sequoyah in excei! c' reg','latory li"tits, D. XX-85-066-001. TVA investigation of the concern did not reveal any situatien invclving lack of timely response by HP to an emergency.
TVA concluded that a deliberate and cautious response may have been
-isinterpretec.
E. xx-85-009-002. TVA revie n d personnel radiation exposure records and could not identify any attern of workers being assigned high exposure iobs based on age. Crafts management was intervie ed and no cr.e could substantiate that there had ever been a management policy regarding exposure to older workers.
F. O-55-025 A02. TVA investigations revealed several discrepancies on radiation of entries and
, reprvducing work c armit when signatures sign-ina sheets, sucn sheet was as voic'ingt could not be recopied. .
determined that the signatures were actually falsified. TVA i '
cocitted to clarify their QA requirements and worker awareness in 7 tM s area.
l G. xx-35-025-X03. TVA identified numerous discrepancies in the acmiaistration of radiation work permits. No safety significant consequence of these discrepancies, such as f ailure to assign personnel procer exposure valves, was identifiec. TVA subsequently
- revised and clarified their RP procedures. j H. XX-85-098-002. TVA reviewed licensee procecural and regulatory ;
requirements for surveys. Records were reviewed to verify that these :
surveys were being performed. TVA concludeo that surveys were being performec at an acceptable frequency to moni*or changing radiological conditions and keep workers informed cons ent with maintaining -
exposures to personnel performing the surve,4 ALARA. ,
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- 1. I-86-238-SQN. TVA reviewed licensee radiation protection proce-dures, emergency and employee training programs. General training given to each employee covers their initial response to an emergency.
In addition, personnel responsible for reacting to the emergency are i given specialized training. TVA concluded that their procedures ana training were adequate.
J. JLH-35-003. TVA reviewed licensee contamination control procedures, interviewed HP technicians and training supervisors and conducted field walk downs to verify placement of friskers. TVA verified there are instances where survey instruments are not in close proximity to contamination zone exits for valid reasons, such as high radiation background levels in the area. TVA determined that workers are trainea in regard to locating survey instruments and actions they are to take i: contamination is discovered.
K. JMA-85-001. TVA determined that licensee procedure TI-77 established the responsibilities and procedures governing breaching of the AS$CE. The prccedtre requires that such breaches must be isolated witnin four minutes of receipt of an Auxiliary Building Isolation (ABI) or hign radiativn signal. TVA determined that operators were trained and knowledgeable of their responsibility to seal any Ad5CE breaches before evacuating or leav'ig the area.
L. WI-85-035-001. TVA reviewed records of ruiation expost.res received during containment power entries and de. ermined that neutron raciation excesures were typically a fact: of ten less than gamma radiation exoosures. Exposures receivec during nonemergency containment po.er entries were controlled :o levels below those that would warrent reevaluation of the policy. This policy, it is felt, did not contribute to the accident that was referred to.
M. XX-95-026-001. TVA conducted interviews and reviewed records of plant i nitiated radiological inciuent reports (RIRs). It was con ( that management support to the health physics program was a de c c . ..,. The allegation that no disciplinary action is taken when e ployees intentionally bypass contamination monitors could not be substantiated. Tne TVA review did identify some areas where improvements could be made in the administration of the RIR program.
O. u-85 063-001. TVA revie ed work plans, radiation work permits and racioicgical survey records of work performed in the area during the time peried in question. No evidence could be found to indicate that problems .ere encountered during this work. Interviews with modifications and health physics personnel did not reveal any concerns ith these groups regarding verification of system status es'c e a:.ir; .:n.
8 P. RII-85-A-0064.
(1) TVA lacks abil?ty to run an HP operation. TVA reviewed records of previous audits evaluation and inspections performed by NRC, INPO, TVA Quality Audit Branch and American Nuclear Insurers (ANI). No programmatic weaknesses in the health physics program was identified. i (2) Unreported loss of radioactive source. TVA reviewed procedures for byproduct material source accountability and interviewed HP personnel responsible .for accounting for byproduct material sources. No deficiencies in byproduct material source accounting Records of previous inventories were also were identified.
reviewed and no discrepancies were noted.
(3) Smears thrown into trash; smear counting area used as an eating area. TVA interviewed HP personnel and reviewed applicable HP procedures. TVA determined that appropriate controls are in place regarding counting disposal of smears and that the smear counting area is not used as an eating area.
(4) Air samples improperly taken; respirators not worn in contami-nation areas. TVA interviewed HP personnel, reviewed applicable regulations and licensee procedures and observed air sampling belnq performed. No deficiencies ir the air sampling program was identified. A review of randomi. selected radiation work permits also revealed tha; respirate . protection was specified based on contamination levels coni'itent with licensee l procedures. ,
(5) Dismissed from employment as result of a conspiracy. This item !
was reassigned by TVA to the intimidation and Harassment ,
- Category.
F (6) Air sample heads not covered p*'er to or af ter sampling. TVA [
interviewed HD personnel and eviewed HP procedures. TVA
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determined that HP technicians are instructed to preclude cross i contamination of air samoler filters, however there are no ,
1 specified methods of accomplishing tnis. If the air sample ,
filter was cross contaninated, there would be no compromise of worker safety since this would result in an overestimation of air activity and specification of conservative protection requirements.
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IV. Conclusion The NRC staff believes that TVA investigation of the concerns was adequate, and their resolution of the concern as described in Element Report OP 311.04 is acceptable, i
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