ML20207L273

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Rev 2 to Sequoyah Nuclear Plant Element Rept, Alara
ML20207L273
Person / Time
Site: Sequoyah  Tennessee Valley Authority icon.png
Issue date: 12/30/1986
From: Hall D, Lovett D
TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20207K584 List:
References
311.05-SQN, 311.05-SQN-R02, 311.05-SQN-R2, NUDOCS 8701120063
Download: ML20207L273 (14)
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Text

3 TVA EMPLOYEE CONCERNS REPORT NUMBER: 311.05 SQN SPECIAL PROGRAM REPORT TYPE: Sequoyah Nuclear Plant - Element REVISION NUMBER: 2 TITLE: ALARA REASON FOR REVISION:

General revision ,

Revision 1 Revised to incorporate SRP comments and corrective action responses Revision 2 PREPARATION PREPARED BY:

D. L. Lovett. D. C. Hall Jr. 12/10/86 SIGNATURE DATE REVIEWS PEER:

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' IIATE SIGNATURE TAS:

seh.fT0/ /r lE b hW SIGNATURE DATE CONCURRENCES c EG-H: **-s Af//ffb S8P:Lni LOG}rA7, /2/so/8fs SIGNATURE DATE / SIGNATSM DATE APPROVED BY:

6\.')4kt..;U[. l.1 f36 fd h N/A DATE MANAGER OF NUCLEAR POWER DATE

\sECSP HANAGER

- CONCURRENCE (FINAL REPORT ONLY)

  • SRP Secretary's signature denotes SRP concurrences are in flies.

157BT 8701120063 870102 PDR ADOCK 05000327 P PDR

I TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT EMPLOYEE CONCERNS TASK GROUP OPERATIONS CEG Subcategory: Health Physics Element: ALARA Report Number: 311.05 - SQN - Revision 2 IN-85-869-001 XX-85-052-001 IN-86-044-001 WBN-0065 Evaluator: D. L. Lovett /z//0/66 D. L. Lovett Date D. C. Hall Jr. /z//a/#4 j D. C. Hall Jr. Date  ;

deviewed by: ,

[tfif//Nb/[(/pt[ /e/g/pt, OPS CEG Member D'a t'e Approved by: ( cmu /2[/t gf

.-4 W. R. Lagergren Date'

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  • Ravisicn 2 I. TITLE: ALARA - 311.05-SON This report evaluates four concerns dealing with the Sequoyah ALARA (As Low As-Reasonably Achievable) program II. SPECIFIC EVALUATION METHODOLOGY Four concerns were included in this element evaluation.
  • XX-85-052-001: Manway door at the bottom of steam generator takes approximately 20 minutes to open and 3-4 hours to close due to complicated process necessitated by poor design. If a come-along slips, it is most likely that personnel would be pinned between the swing-arm and hand rail. There are 5 rems / hour escaping while this door is open. A way to open/close this door must be found that would take only 20 minutes total.

Units 1 and 2.

IN-85-869-001: Duplicate of XX-85-052-001 written for Watts Bar.

IN-86-044-001: Process monitoring instrumentation (0-PI-77-197, 0-PI-77-176, 0-PI-77-34) is located in a high radiation area. Because these instruments have required excessive amounts of time to repair and recalibrate, the ALARA concept would be better served by moving the panel (0-L-14) to a lower radiation area.

WBN-0065: The time required to calibrate or repair 1-LT-77-125, 126, 410, 411, which are located in the raceway on unit 1 is a potential ALARA concern.

Concerns XX-85-052-001 and IN-85-869-001 were previously evaluated in NSRS Report I-85-558-SQN (Reference 3). Therefore, the scope of the investigation surrounding these concerns was directed towards the following:

Determining the validity of the NSRS Report.

Determining whether the recommendations and conclusions had been addressed.

Determining if the recommendations had been implemented.

Concern IN-86-044-001 was evaluated by first determining whether the panel 0-L-14 was, in fact, located in a high-radiation area and then determining whether an ALARA concern existed.

Page 1 of'll

Ravision 2 Concern WBN-0065 was evaluated by determining whether an ALARA concern existed. -This was done as follows:

Reviews of Radiological Work Permit (RWP) timesheets and radiological survey data were performed.

A determination was made of exposure received for maintenance on the level transmitters (LT) based on RWP timesheet data.

Interviews were conducted with cognizant ALARA personnel to determine whether the exposures expended in maintenance of the level transmitters were an ALARA concern.

In addition to the evaluation of the individual concerns, the most recent NRC and Nuclear Quality Audit and Evaluation Branch (NQA&E) evaluations of the SQN ALARA program were examined (Reference NRC inspection reports lR2 50-327/86-04 and 50-328/86-04, March 27, 1986, 50-327/86-36 and 50-328/86-36, July 23, 1986 and NQA&E report QSS-A-86-0022, dated September 19, 1986, L19-860919-901.)

The evaluations were conducted in accordance with the Operations CEG evaluation plan and the Health Physics subcategory evaluation plan and included reviews of regulatory requirements, TVA and SQN procedural requirements, radiological survey documentation, and ALARA pre and post job reports. Interviews with cognizant personnel were conducted. All K-forms and associated reports assigned to element 311.05-SQN were reviewed and evaluated.

III. FINDINGS The results of the evaluation of concerns XI-85-052-001 and IN-85-869-001 are as follows:

Site Services personnel are continually looking for better methods for removing and installing steam generator manway covers. Since the NSRS report was completed, hydraulic torque wrenches are now baing used to close the generator manways. Typically, the closure takes 3-4 hours actually handling the menway covers. There is, as stated in the NSRS report, additional time required for gasket installation, surface preparation, bolt and hole cleaning, and QC inspection.

i ECTG Report No. 301.08-SQN and NSRS Report I-85-558-SQN referenced a f proposed schedule for implementing a stud and nut configuration for d

the steam generator cover. An individual in SQN site services responsible for coordination of the Steam Generator outage program at WBN and SQN stated that contracts have been let at WBN and will be let at SQN in the immediate future for the stud and nut configuration to replace bolts that are currently used for securing the covers. A substitution of this type of system is expected to prevent galling of threads which has been a problem. This should also limit the amount of time required for installing the manway covers.

l Page 2 of 11 f

- - - - - -,n n---- n-.-, - - - - - ~ , - - . . - - , , , - . - - - - ,

I Ravisien 2 I Because of. limited space on the steam generator platforms, hydraulic lifting apparatus have not been found to be suitable for handling the manway covers. Instead,-SQN personnel are investigating the use of electric hoists to replace chainfalls and come-alongs currently in use.

i As a result of the evaluation, it was determined that personnel safety l

~

is a significant issue in handling the manway covers because of space constraints, weight of the manway covers, and restrictive protective clothing. It was found that efforts are being made to reduce manway closure times and to reduce exposure rates at the manway openings. The recent unit 2, cycle 3 eddy current testing of the steam generators showed IR2 that manway closure times have been reduced by implementing the hydraulic torque wrench system. Health Physics also purchased a manway opening ALARA shield that has been effective in reducing exposure rates at the Steam Generator openings. In addition, site services has studies underway to explore other mechanisms that will enhance safety and reduce closure times.lR2 A review of ALARA preplan reports85-063 and 86-020 were reviewed to lR2 determine the extent of precautionary recommendations taken to reduce personnel exposures during steam generator maintenance activities.

It was determined that the preplan reports adequately implemented the requirements of RCI-10, Revision 11. It could not, however, be determined whether the preplan reports were effective. This was due in part to the. fact that the exposures received are tracked under a generic job description.

During the recent steam generetor eddy current testing unit 2, cycle 3, a new manway shield was utilized to reduce general area exposures from the open manways. It was found that this shield was effective in reducing dose rates in the general area of the steam generator platform from 200 mrem / hour to 40 mrem / hour on Steam Generator #2 and from 800 meem/ hour to 50 mrem / hour on Steam Generator #3. This shield has contributed to an overall general area exposure rate reduction of 80-94 percent.

The results of the evaluation of IN-86-044-001 are as follows:

The panel 0-L-14 is not located in a high-rediation area. This was determined by visually inspecting the location of the panel and i reviewing radiation survey data from January 12, 1984, through March 13, 1986. According to the survey data general area dose rates in the area of the panel range from less than 2 to 7 mrem / hour.

RUP timeshoot data were reviewed to determine the number of entries made lR2 into the area for this period and the exposures received. This review covered entries made for inspection, decon, calibrations, lubrications, replacement of parts, replacement of lighting, pump alignment, installation, repair, removal of material, and sampling. From the period January 1, 1984, through August 4, 1986, a total of 152 meem over a j period of 107.28 hours3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br /> was received (based on pocket chamber data) for all j

jobs. This calculates to be 1.42 meem/ hour. For the 164 entries over this period, the averago exposure received per entry equals 0.93 meem.

For calibration of instrumentation, 20 mrem was received over 7.10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />.

This equates to an average of 2.82 mrem / hour or 3.33 mrem / entry.

Page 3 of 11

Ravisien 2 Interviews with ALARA personnel indicated that the PIs, 0-77-176, 0-77-197, 0-77-34 were not a significant ALARA concern due to the low dose rates in the area and the low exposure received in the course of maintenance on these PIs.

SQN RCI-10 establishes action levels to flag potential high exposure activities. These action levels are as follows:

1. Any activity which may result in a tot?1 exposure of five manrem to the whole body or greater per job. (Comb'aed exposure of all workers)
2. Any activity which may result in the exposure of an individual to one com to the whole body per day per RWP.
3. Any activity which may result in the accumulation by an individual of lR2 10 HPC (maximum permissible concentration) hours per day per RWP.

(Relates to exposure to airborne radioactive contamination after credit for respirator protection factors (PF's) has been applied). lR2

4. Any activity which may result in the extremity exposure of an individual greater than or equal to 25 percent of the allowable quarterly extremity dose limit per day.

The calibration and maintenance activities of concern In-86-044-001 do not exceed the action levels from RCI-10 listed above and, IR2 therefore, do not warrant ALARA evaluations or constitute ALARA concerns.

The results of the evaluation of concern WBN-0065 are as follows:

The level transmitters LT-1-77-125, 126, 410, and 411 are required to be calibrated on'an eighteen month frequency or at each refueling. These transmitters are located at the 679 elevation, unit 1 containment.

The panels in which these LTs are located, are not located in a lR2 high-radiation area.

The total exposure received, over the period of July 7, 1984 through October 7, 1985, for calibration, inspection, and repair of LTs 1-77-125, 126, 410, and 411, as recorded by pocket dosimeter data, was 321 meem.

This exposure was distributed over 48 personnel entries which equates to 6.69 mrem / person-entry.

These exposure levels do not exceed the action levels established lR2 in SQN RCI-10 to flag activities which require ALARA evaluation.

A review of NRC and Nuclear Quality Audit and Evaluation (NQA and E) Branch Reports was conducted regarding the SQN ALARA Program. The results are as follows:

i Page 4 of 11

Rsvisicn 2 NRC reports 50-327/86-04, 50-328/86-04 and 50-327/86-36, 50-328/86-36 indicated weakness in the SQN ALARA committee reviews of pre and post job assessments, and the employee suggestion program. These items will be lR2 reviewed by NRC in a follow-up inspection; however the NRC reports, with regard to the ALARA program at SQN, concluded that no violations or deviations were identified.

The Nuclear Quality Audit and Evaluation (NQA&E) Branch's audit report Number QSS-A-86-0022 revealed 4 deviations in the ALARA program at Sequoyah as follows:

1. QSS-A-86-0022-D02 - ALARA suggestion program is not being implemented in accordance with Standard Practice SQA - 145.
2. QSS-A-86-0022-D03 - Annual ALARA reports not submitted, as required by the R.P.P., within 90 days to the Manager of Nuclear Power.
3. QSS-A-86-0022-D04 - ALARA program does not incorporate all the requirements of Regulation Guide 8.8.
4. QSS-A-86-0022-D05 - Radiological safety-related activities documentation is not maintained in accordance with American Nuclear Insurer (ANI) requirements.

With regard to the items above, number 1 points out that the RPP and referenced SQA-145 require that incentives and encouragement be provided l for employees to participate in the suggestion program. NQA&E findings (R2 indicate that SQN is not currently delns this. Item 2 indicated l that SQN was late in providing the Annual ALARA reports to the Manager of Nuclear Power in the years 1983, 1984, and 1985. Item 3 pointed out lR2 that the ALARA Preplanning Report requirements do not adequately address  !

Regulation Guide 8.8 requirements for decontamination, auxiliary lighting, pre-job briefing, and post-job review. Item 4 deals with record retention of RWP's and ALARA reports. Currently SQN procedures state that RWP's with no air data and all ALARA reports have a one year retention period. This is contrary to ANI requirements which require lifetime lR2 retention of radiological safety related documentstion. NQA&E interprets that RWP's with no air data and ALARA reports are radiological safety-related documents and should have a lifetime retention.

Conclusions The concerns XX-85-052-001 and IN-85-869-001 were validated, as l

! stated; however, plant efforts to improve the manway cover opening / closing procedures and to address the associated ALARA concerns are determined to be sufficient to proclude any need for additional lR2 corrective action.

i Page 5 of 11 l

Rsvisien 2 Concern IN-86-044-001 was not validated. The concern does not indicate a weakness in the ALARA program in that the referenced process monitoring equipment is not located in a high radiation area, maintenance and calibration activities are required infrequently, and radiation exposures associated with maintenance and calibration activities are typically very low. Radiological survey data for the maintenance and calibration IR2 activities indicate that the exposures encountered do not exceed the action levels established in SQN RCI-10 which require ALARA evaluations; therefore these activities do not constitute ALARA concerns nor do they warrant ALARA evaluation via the ALARA pre-job report process.

Concern WBN-0065 was not validated based upon the low exposures received for maintenance and calibration of the LTs. Radiological survey data indicates that the referenced activities involve personnel exposure levels too low to be considered ALARA concerns and, therefore, do not warrant ALARA evaluation.

lR2 The NRC inspections and NQA&E audit indicated several weaknesses and i deviations in the SQN ALARA program; however, this evaluation concludes that, within the scope of the concerns assigned to this element, the SQN ALARA program is effective and adequate in identifying and minimizing radiological hazards and meets applicable TVA and regulatory requirements.

The weaknesses and deviations identified by NRC and NQA&E, while outside the scope of the concerns, do warrant applicable corrective action by SQN plunt management.

None of the concerns evaluated affect the safe operation of the plant.

IV. ROOT CAUSE was found to be The root cause of concerns IN-85-869-001 and XX-85-052-001 principally the design of the steam generators and the relatively poor access to the hot- and cold-leg manways.

Concerns IN-86-044-001 and WBN-0065 were not validated and, therefore, do i

not require root cause evaluations.

i V. GENERIC APPLICABILITY The four concerns evaluated in this report are determined to be generically l

applicable to both SQN and WBN. No applicability was determined to exist i

for either Browns Ferry or Bellefonte Nuclear Plants.

s i VI. REFERENCES

1. SQN MI-3.1 f 2. RCI-10 Rev. 11
3. NSRS Report I-85-558-SQN i

l Page 6 of 11 1

. Rsvisien 2

4. Undated Notes " Proposed Project for Replacement of Steam Generator Primary Manway Bolts with Studs and Nuts and Tensioning System,"

prepared by Mike Hodge (Site Services)

5. ALARA Preplan Reports85-063 and 86-020
6. Westinghouse Technical Manual 1440-C228, September 1971, " Vertical Steam Generator for TVA Sequoyah Nuclear Plant"
7. SQN RCI-1, Rev. 29
8. Sequoyah Radiological Emergency Plan (REP) Implementing Procedures Document (IP)-15. Rev. 4
9. Radiological Survey Number 2EC-86-1713, July 25, 1986
10. 10 CFR 20
11. RWP Timesheets and Radiation Survey Data (See Support Materials)
12. SQNP SI-85 Unit 1. Revision 6
13. SQA-145, Revision 0 "ALARA Suggestion Program"
14. Employee Concern Task Group Report No. 301.08-SQN
15. TVA Code VIII - Occupational Radiation Protection
16. TVA Radiological Protection Plan (RPP)
17. NRC Inspection Report 50-327/86-04 and 50-328/86-04, dated March 27, 1986
18. NRC Inspection Report 50-327/86-36 and 50-328/86-36 dated July 23, 1986
19. NQA&E Audit Report Number QSS-A-86-0022, dated September 19, 1986 L19 860919 901 VII. IMMEDIATE OR LONG-TERM CORRECTIVE ACTION The plant should address the weaknesses and deviations identified by NRC and NQA&E and apply corrective actions as appropriate to improve the ALARA program.

SQN responded to the weaknesses and deviations identified by NRC and l NQA&E Branch Report QSS-A-86-0022 as follows (those were tracked by IR2 CATD 311.05-SQN-01,-02,-03, and -04): l Deviation No. OSS-A-86-0022-D02 l The SQN ALARA suggestion program is not being implemented in accordance IR2 with standard practice SQN-145. l Page 7 of 11

Rovision 2 l

Deviation Details A. Only one of the four ALARA suggestions submitted in 1986 has been I responded to. The remaining three (submitted in February. May, and lR2 June) remain incomplete. l SQN-145, "As Low As Reasonably Achievable (ALARA) Suggestion l Program." Revision O.Section III states, "...the ALARA engineer l will evaluate the suggestion and should provide a written response l l

within two weeks..."

SON Response to OSS-A-86-0022-D02 SQN agrees with the deviation. Deviation detail A states that the l deviation was the result of failure to provide a written response for l the ALARA suggestions within a two week time period. Esperience l indicates some ALARA suggestions require significant investigation before l an adequate response can be given. Therefore, SQN-145 was revised IR2 on August 14, 1986, the day of the audit finding, to remove reference to i response time limitations. Even though the response time limitations I have been removed from SQA-145, the ALARA staff will make every effort I to respond to the suggestions in a timely manner. l Deviation Details B. SQA-145, attachment 1 is not being used to document the. response as l l

required.

SQA-145, section III also states, "... the response will be recorded l on Part B of the ALARA suggestions form ..." (the suggestion form is lR2 l

attachment 1).

Response

SQN agrees with the deviation. In this particular case, the suggestion I response was made on a separate sheet due to inadequate space for a l proper response on attachment 1. This has been an approved method for i response in the past. In the event additional space is required for an lR2 adequate response, attachment 1 of SQA-145 will be labeled "see attached I sheet." As of August 22, 1986, all 1986 ALARA suggestions received l contain a properly documented response as required by SQA-145. l Deviation No. QSS-A-86-0022-D03 l

Contrary to the Radiation Protection Plan (RPP), SQN Annual Al. ARA Reports l are not being submitted to the Manager of Nuclear Power within 90 days lR2 after the beginning of the new calendar year. l i

Page 8 of 11

R3visicn 2 lR2 Deviation Details The SQN corrective action response to CATD 311.05-SQN-001, 002, 003 lR2 l

and 004 is as follows:

A. Site QA staff in survey 9-85 P-007 (September 13, 1985) identified l that the annual ALARA reports for 1983 and 1984 were submitted af ter l the 90-day limit. l B. The 1985 report was also submitted late. l Radiation Protection Plant, revision 2 in section 4.5: l Each site director shall submit an annual ALARA report . . . within lR2 I

90 days after the beginning of the new calendar year . . .

Response

l SQN agrees with this deviation. For the purpose of this audit, no response is provided in reference to the 1983 and 1984 annual ALARA l l

reports since they were addressed as a result of survey 9-85-P-007.

l The 1985 Annual ALARA Report was initially prepared in early March 1986 l and submitted to the plant manager for review in mid-March. The plant I manager requested a format change for the report which resulted in further l delay. The final report was submitted to the plant manager on l March 28, 1986, for approval. The RIMS tracking number was assigned on l April 2, 1986; however, the report was not submitted to the manager of the l Office of Nuclear Power until April 7, 1986. To reduce the possibility of l further deviations in this area. HPSIL-25 was revised on March 10, 1986, I to require submittal of the Annual ALARA Report from the Radiological l Control Section to the site director within 60 days after the beginning i of the new calendar year. This commitment should allow ample time for l management review and approval to meet the April 1 deadline. I l

Deviation OSS-A-86-0022-D04 SQN's ALARA program does not incorporate all the requirements of l

Regulatory Guide 8.8 l

(R2 Deviation Details l

A. When plant groups exceed ALARA gonis, no corrective action is l documented. Currently there are six groups in excess of their IR2 goal. No documentation of the reason or any corrective action I taken was available for review by the audit team. l Page 9 of 11

. Rsvisien 2 Regulatory Guide 8.8-1978, section C.1.b.1.c states the " corrective l actions are taken when attainment of the specific objectives appear to l be jeopardized." l 1

Response l l

SQN disagrees with the deviation. Regulatory Guide 8.8 is a SQN reference l document as defined in the Radiation Protection Plan, revision 3, and as l such no commitments have been made concerning the entire implementation of l l

this document.

1 Standard Practice SQA 129 establishes performance goals for the site and l for individual plant groups. Performance against these goals is reviewed l by the managers on a monthly basis using the Plant Performance Report. l Additionally, a meeting is held at the end of the fiscal year to review l the overall performance. A meeting was held with the plant managers on lR2 October 28, 1986. One of the activity items resulting from the meeting l was a request to the Health Physics supervisor to provide a summary l report on work activities that had resulted in unanticipated exposures. l l

Deviation Details l

B. SQN's RCI-10 does not include Regulatory Guide 8.8 requirements for lR2 decontamination, lighting, pre-job briefing, or review of previous l jobs as a part of the pre-job report. l l

Regulatory Guide 8.8 section C.3.a states that, " . . . Preparations lR2 and plans should reflect the following considerations: l l

(5) . . . decontamination . . . l (6) . . . preoperational briefing . .. l lR2

" l (13) . . . auxiliary lighting . ..

Response l l

SQN disagrees with the deviation. Regulatory Guide 8.8 is a SQN reference l document as defined in the Radiation Protection Plant, revision 3, and is l not required for full implementation. l lR2 RCI-10, section IV, states that the responsible work supervisor shall l ensure that all workers are briefed on tha work, procedure, RWP protective l requirements and special instructions, radiological conditions, and ALARA l considerations prior to the start of the work. RCI-10. Attachment 1 l provides a flow chart for use in completing an ALARA Planning Report (APR). l Page 10 of 11

1 Rsvisica 2 Included in the flow chart is the block to "Brief Workers." RCI-10, i section IV also alstes that "ALARA" considerations which have been proven l effective for repetitive tasks should be incorporated into the controlling l l

procedures."

1 The Radiological Control Branch will issue specific guidance regarding the I application of ALARA considerations for work activities. While SQN l believes that our present ALARA planning is achieving its purposes, any I furthor detailed criteria issued by Radiological Control will be i l

implemented when it is issued.

I l

Deviation QSS-A-86-0022-D05 lR2

[

SQN is not maintaining documentation of radiological safety-related activities as required by American Nuclear Insurers (ANI). l l

Deviation Details RWP timesheets and ALARA planning reports are not maintained as QA records. l ANI/MAEI.U Information Bulletin 80-1A, " Records Retention and Documentation I of Radiological Safety-Related Practices" (L99 821201 001) states in i section VIII, titled " Work Assignments (Radiation Work Permits)": _l l

I

. . . It is the intent of this section to set fourth the records which i are necessary to establish where and when an individual was working in a radiation controlled area, what he was doing there, the radiological I environment in which he was working, the radiological controls and i evaluations where they were applied to his working in a radiation I controlled area, and any special requirements or conditions which may l have existed at the time. Additionally, the records must show that I proper authorization and control of an individual's radiation exposure I was exercised by responsible plant management individuals. l l

Response

I SQN disagrees with the deviation. ANI/MAELU Information Bulletin 80-1A is l an information notice and not a requirement referenced in any SQN l procedure. Telephone conversation with ANI personnel further concludes I that maintaining RWP timesheets and ALARA planning reports as lifetime l records is a recommendation and whether or not they are designated as "QA" l records is immaterial. It should be noted that standard practice at SQN l 1s to maintain all dose-related records including RWPs and ALARA planning l reports for lifetime of the plant. l Page 11 of 11

9 PAGE TENNESSEE VALLEY AUTHORITY RUN TIME -

REFERENCE - ECPSI20J-ECPS121C .

OFFICE OF NUCLEAR P0HER RUN DATE*-

  • FREQUENCY - REQUEST EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS)
  • 8 CNP - ISSS - RUM LIST OF EMPLOYEE CONCERN INFORMATION l SUBCATEGORY: 31105 ALARA i, CATEGORY: OP PLANT OPER. SUPPORT KEYHORD A S GENERIC KEYHORD B APPL QTC/NSRS P KEYHORD C
  • H S CONCERN KEYHORD '

CONCERN SUB R PLT BBSH INVESTIGATION R DESCRIPTION-i HUM 3ER CAT CAT D LOC FLQB REPORT HEALTH PHYSICS l

NNYY NS MANHAY DOOR AT THE BOTTOM STEAM GENE SAFETY CONDI IN 869-001 OP 30108 S HBN RATOR TAKES APPROX. 20 MINUTES TO OP DPERATIONS OP 31105 K-FORM EN AND 3-4 HOURS TO CLOSE DUE TO A C T50155 RADIATIO OMPLICATED PROCESS NECESSITATED BY P 00R DESIGN. IF THE COMEALONG SLIPS, i ' IT IS MOST LIKELY THAT PERSONNEL H0 ULD BE PINNED BETHEEN THE SIDING ARM AND HAND RAIL. THERE ARE 5 REMS /HO

'l UR EXCAPING HHILE THIS DOOR IS OPEN.

I ' A HAY TO OPEN/CLOSE THIS DOOR MUST I BE FOUND THAT HOULD TAKE ONLY 20 MI l NUTES TOTAL. CONSTR. DEPT. CONCERN.

J UNITS 1 AND 2. CI HAS NO FURTHER J

' INFORMATION. NO FOLLONUP REQUIR NNYY NS THE TIME REQUIRED TO CALIBRATE OR RE HBN-0065 OP 31105 N HBN PAIR 1-LT-77-125,126,410,411, HHICH

  • K-FORM ARE LOCATED IN THE RACENAY ON UNIT'l IS A POTENTIAL ALARA CONCERN HEALTH PHYSICS NNNY I-85-558-SON NS SEGUDYAH-MANHAY DOOR AT THE BOTTOM 0 SAFETY CONDI XX 052-001 OP 30108 S SQN F STEAM GENERATOR TAKES APPROX. 20 OPERATIONS OP 31105 K-FORM MINUTES TO OPEN AND 3-4 HOURS TO CLO T50153 RADIATIO J SE DUE TO COMPLICATED PROCESS NECESS 1

ITATED BY P00R DESIGN. IF A COMEALO

' NG SLIPS, IT IS MOST LIKELY THAT PER 1

SONNEL HOULD BE PINNED BETHEEN THE S HING-ARM AND HAND RAIL. THERE ARE 5 RENS/ HOUR ESCAPING HHILE THIS DOOR f' , IS OPEN. A HAY TO OPEN/CLOSE THIS D 4

t 00R MUST BE FOUND THAT HOULD TAKE ON i LY 20 MINUTES TOTAL. UNITS 1 AND 2.

CI HAS NO FURTNER INFORMATION. NO

' FOLLONUP REGUIRED.

HEALTH PHYSICS NO PROCESS MONITORING INSRUMENTATION SAFETY PROGRA (O

OP 31105 N HBN NNYY -PI-77-197,0-PI-77-176, 0-PI-77-34) OPERATIONS I IN 044-001 K-FORM IS LOCATED IN A HIGH RADIATION AREA. RADIATION

! T50177 BECAUSE THESE INSTRUMENTS HAVE REQ UIRED EXCESSIVE AMOUNTS OF TIME TO R EPAIR AND RECALIBRATE, THE ALARA CON I CEPT HOULD BE BETTER j TO ASERVED BY MOVIN LOWER RADI I

G THEAREA.

ATION PANEL (0-L-14)CIELEVATION HAS NO ADDI 676 NUC. PONE l I R CONCERN. UNIT. 1.

i r

T10 MAL INFORMATION. NO FOLLOW UP RE I

. QUIRED.

j I ) -

i e I

i I .

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