ML20207P653
| ML20207P653 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 01/05/1987 |
| From: | Gass K, Knightly J, Stewart D TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20207P454 | List: |
| References | |
| SWEC-SQN-30, SWEC-SQN-30-R01, SWEC-SQN-30-R1, NUDOCS 8701160371 | |
| Download: ML20207P653 (7) | |
Text
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. TVA EMPLOYEE CONCERNS REPORT NUMBER: SWEC-SQN-30
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- SPECIAL PROGRAM
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- REPORT TYPE: Sequoyah Nuclear Plant Element REVISION NUMBER: 1 TITLE: Chemical and Radiological Procedures I
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REASON FOR REVISION: To incorporate TAS and SRP comments.
SUMMARY
STATEMENT: The items in this report were identified by the Nuclear Regulatory Conunission (NRC) and were included in the Stone & Webster Engineering Corporation (SWEC) systematic analysis. Items -002 and -003 were adequately 3 '
addressed and were closed by the NRC. Item -001 remains open pending additional evidence of adequate corrective action.
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- SRP Secretary's signature denotes SRP concurrences are in files.
2242T 8701160371 870109 PDR ADOCK 05000327 1 "
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TENNESSEE VALLEY AUTHORITY WATTS BAR NUCLEAR PLANT EMPLOYEE CONCERNS TASK GROUP OTHER SITES CEG Element
Title:
Chemical and Radiological Procedures SWEC Concerns: A02850506013-001, -002, -003 Source Document: NRC Inspection Report 50-327, 328/85-15 Report Number: SWEC-SQN-30 t
Evaluator: (( b /.f '/- V L K. R. Gass Date Reviewed by: 9[ kWd J. J. Ynightly i kTh Date Approved by: IL u /12/9/flo A. G. Debliap datfe 0517T
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Repert SWEC-SQN-30 Chemical and Radiological Procedures I. INTRODUCTION During inspection activities covering the period of April 8-12, 1985 (Reference 1), the Nuclear Regulatory Commission (NRC) inspectors identified one violation (327, 328/85-15-02), an inspector follow up item (IFI) (327, 328/85-15-04), and an unnumbered concern which were included in the Stone & Webster Engineering Corporation (SWEC) systematic analysis, as follows:
A02850506013-001 (unnumbered concern), Failure to follow procedures -
chemical and radiological.
A02850506013-002 (Violation 50-327/328/85-15-02), Procedures did not control the time interval between sample collection and counting.
A02850506013-003 (IFI-50-327, 320/85-15-04), Counting room and chemistry laboratory professionalism and uncleanliness.
Information on the background, the corrective action taken, the verification methodology, the verification analysis, the completion status, and any pertinent references for the area of concern is included in this report.
II. VERIFICATION OF SWEC ISSUE A. A02850506013-001 - Failure to follow procedures - Chemical and Radiological.
- 1. Background The inspectors reviewed four TVA audit reports (references 4-7),
and observed that deviations concerning failure to follow '
procedures were identified in all audits. The inspectors noted that a similar failure to follow procedures violation by chemistry personnel was identified during a previous NRC inspection (50-327/85-25-01, 50-328/85-25-01). The inspectors discussed with cognizant SQN representatives the need to implement proper and timely corrective actions concerning procedure implementation. SQN representatives informed the inspectors that identified concerns regarding procedural adherence by plant personnel were being evaluated.
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- 2. Corrective Action Taken I
The previous violation (327, 328/85-25-01) concerning failure to follow procedures was closed by the NRC April 30, 1985 (reference 1). The closure document stated, "From a review of the chemistry laboratory QC records, the inspectors verified that all chemistry QC checks and calibrations were conducted in accordance with approved plant procedures." However, in the I same report, NRC expressed concerns over procedural compliance l based on the NRC review of TVA audit reports. TVAs Nuclear l Performance Plan, dated July 17, 1986 statused radio-chemistry lR1 procedures review as complete (Commitment Item VI.C.14) as part l l of the procedures improvement program. l
- 3. Verification Methodology The SWEC concern identified for Employee Concerns Task Group (ECTG) verification was stated as follows:
RIMS Number Issue RIMS Item A02850506013 NRC expressed concern RIMS-001 that deviations regarding failure to follow procedures (Chem & Rad Measurement pro-gram) require proper & timely corrective action ECTG reviewed the Sequoyah Compliance Licensing Files for internal and external correspondence related to this issue and NRC status and closure files. This review of the pertinent documentation, in addition to discussions with chemistry supervisory and quality assurance auditing personnel, formed the basis for this verification activity.
- 4. Verification Analysis ECTG reviewed the SWEC concern with the Division of Quality '
Assurance auditing group. It was stated during this interview (October 1986) that, although improvements have been accomplished, current audits have identified some centinuing problems with the countit room and chemistry laboratory facilities procedural con *ance.
. Cbemistry supervisory 1 personnel at SQN stated D ber 1986 that the new chemistry I procedures will aid proce 1 compliance in the future, and IR1 that improved chemistry s on internal auditing of procedural I compliance has been initi .. 1
- 5. Completion Status The ECTG verification indicated that the SWEC concern has not been fully resolved. The SWEC item remains open.
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B. A02850506013-002 - Procedures did not control the time interval between sample collection and counting
1. Background
The inspectors reviewed SQN Lower Limits of Detection (LLD) for gaseous effluent analyses by gamma spectroscopy analyses. The inspectors noted that approved procedures did not-control the time interval between samyle collection and counting to ensure that Technical Specification (TS) LLDs were met. From discussion with cognizant SQN representatives and review of LLD determinations, the inspectors noted that waste gas decay tant analyses required analyses to be completed within two hours of sampling to meet required TS LLDs. From review of gaseous
' effluent sampling report data, the inspectors determined that ooring the period June - December 1984, there were multiple examples of failure to meet the required LLD of 1 E-04 microcuries/cc for Xe-138 as specified by TS Table 4.11-2. The inspectors informed SQN representatives that failure to meet the gaseous effluent lower limits of detection for Xe-138 was a violation (50-327,328/85-15-02) (reference 1).
- 2. Corrective Actions Taken In their response to the violation, SQN stated (Reference 2):
The LLDs for effluent releases, liquid and gaseous, have been reevaluated for all three of SQN's gamma-spectrometry systems. The Technical Instruction TI-12
" Radiological Analytical Methods," which describes counting methods, i.e., volumes, efficiency files, counting times, etc., has been revised to reflect maximum time periods between sample collection and counting times in order to meet Technical Specification LLD requirements. If these times cannot be met, analysts have been instructed to resample.
- 3. Verification Methodology.
i The SWEC concern identified for ECTG verification was stated as follows:
RIMS Number Issue RIMS ITEM A02850506013 Approved procedures did not RIMS-002 control time interval between sample collection and counting to ensure that Tech Spec lower limits of detection were met ECTG reviewed the Sequoyah Compliance Licensing Files for internal and external correspondence related to this issue and i
- NRC status and closure files. This review of the pertinent i documentation formed the basis for this verification activity.
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- 4. Verification Analysis The ECTG review of the pertinent documents indicated that the corrective actions for this concern and the violation have been completed and are adequate to resolve the concern and violation.
The violation was closed by the NRC (reference 3). The inspectors noted that " procedures are adequate to meet technical specification lower limits of detection for effluent samples.
- 5. Completion Status Based on SQN corrective actions and NRC closure of the violation, this SWEC item can be closed.
C. A028506013-003 - Counting Room and Chemistry Laboratory Professionalism and Cleanliness.
- 1. Background During the April 1985 inspection (reference 1), the inspectors toured the chemistry and counting room facilities. The inspectors noted a general uncleanliness in the laboratory, e.g., dirty absorbent paper, waste paper on counter tops, cleaning solutions being maintained on top of file cabinets, and spilled chemicals on analytical instrumentation. The inspectors informed SQN representatives that these conditions could adversely impact the accuracy of measurements conducted within the laboratory. SQN acknowledged the inspectors' comments and agreed to review work habits in the analytical areas. SQN evaluation of the counting room and chemistry laboratory l conditions, and QA/QC records for the associated analytical instrumentation were identified as inspector follow up item 327,328/85-15-04.
- 2. Corrective Actions Taken During the December 1985 MRC follow-up (reference 3) the NRC inspector toured the chemistry aad counting room laboratories with SQN representatives. The review of laboratory and counting room areas for cleanliness and improved record maintenance indicated (1) the laboratories were clean and organized, and (2) maintenance of selected chemistry records was adequate. The follow up item 327,328/85-15-04 was closed.
- 3. Verification Methodology The SWEC concern identified for ECTG verification was stated as .
follows:
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, RIMS # ISSUE RIMS ITEM A02850506013 Housekeeping practices in RIMS-003 chemistry and counting room facilities could affect meas-l urement accuracy and need j improvement
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}~ ECTG reviewed the Sequoyah Compliance Licensing Files for
] internal and external correspondence related to this issue and
- l NCR status and closure files. This review of the pertinent j documentation formed the basis for this verification activity. ,
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] 4. Verification Analysis j
1 The ECTG review of the pertinent documents indicated that the e corrective actions for this concern and the IFI have been 4 completed. The IFI was closed by the NRC (Reference 3).
j 5. Completion Status Based on SQN corrective actions and NRC closure of this item, t the SWEC concern is closed.
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III. References q
- 1. NRC Inspection Report Nos. 50-327,328/85-15, dated April 30, 1985,
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D. M. Vercelli to H. G. Parris
- 2. TVA Memorandum, dated July 31, 1985. "NRC-0IE Region II Inspection Report 50-327,328/85 Revised Response to Violation,"
J. A. Domer to J. N. Grace 1 3. NRC Inspection Nos 50-327/85-38 and 328/85-38, dated December 12, j 1985, D. N. Vercelli to H. G. Parris 1 ,
Li 4. Division of Quality Arsurance Audit Report No. SQ-8400 Sequoyah u- Chemistry Program, September - October 1984
- 5. Compliance Visits. Audits, and Inspections - Inplant Survey Checklist No. 10a-84-P-001, Chemistry - Water Quality, February -
li March 1984 1
] 6. Compliance Visits Audits, and Inspections.- Inplant Survey j
i Checklist No. 10c-84-P-002, Chemistry - Chemical Analysis, April -
Nay 1984 lI j 7. Compliance Visits, Audits, and Inspections - Inplant Survey Checklist No. 10b-84-P-003, Effluent Monitoring, May 1984
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