ML20210U421
| ML20210U421 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 05/21/1986 |
| From: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | White S TENNESSEE VALLEY AUTHORITY |
| References | |
| IEIN-82-18, NUDOCS 8606020324 | |
| Download: ML20210U421 (8) | |
See also: IR 05000327/1986004
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MAY 21 1986
Tennespe Valley Authority
ATTN:V Mr. S. A. White
Manager of Nuclear Power
6N 38A Lookout Place
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1101 Market Street
Chattanooga, TN 37402-2801
Gentlemen:
SUBJECT: REPORT NOS. 50-327/86-04 AND 50-328/86-04
Thank you for your response of April 30, 1986, to our Notice of Violation issued
on March 27, 1986, concerning activities conducted at your Sequoyah facility. We
have evaluated your response and found that it meets the requirements of
10 CFR 2.201. We will examine the implementation of your corrective actions for
Violations 4.b and 4.c during future inspections.
After careful review of the bases for your denial of Violations 1, 2 and 3, and
your claim of licensee identification for Violation 4.a, we have concluded, for
the reasons presented in the Enclosure to this letter, that the violations
occurred as stated in the Notice of Violation. Therefore, in accordance with
10 CFR 2.201(a), please submit to this office within 30 days of the date of this
letter, a written statement describing steps which have been taken to correct
Violations 2, 3 and 4.a and the results achieved, corrective actions which will
be taken to avoid further violations, and the date when full compliance will be
achieved.
In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2,
Title 10, Code of Federal Regulations, a copy of this letter and its enclosure
will be placed in the NRC's Public Document Room.
The response directed by this letter is not subject to the clearance procedure
for the Office of Management and Budget issued under the Paperwork Reduction Act
of 1980, PL 96-511.
We appreciate your cooperation in this matter.
Sincerely,
Original Signed by R.D.!?alker
J.-Nelson Grace
Regional Administrator
Enclosure:
Staff Assessment of Licensee Response
cc w/ encl:
(See page 2)
8606020324 860521
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H. L. Abercrombie. Sequoyah Nuclear Plant
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R. Wallace, Plant Manager
V K. W. Whitt, Director, Nuclear
/ Managers Review Group
/ D. L. Williams, Jr. , Supervisor
Licensing Section
G. B. Kirk, Compliance Staff Supervisor
y J. E. Wills, Project Engineer
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. R. Denton, NRR
H. L. Thompson, NRR
). M. Taylor, IE
V)B.B. Hayes,01
V . R. Connelly, 0IA
/NRCResidentInspector
/ Document Control Desk
/StateofTennessee
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ENCLOSURE
Staff Assessment of Licensee Response
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1.
Violation 50-327, 328/86-04-01, Failure to comply with the license
conditions of an Agreement State licensee in regard to the accessibility of
cask rigging gear.
a.
Licensee Comment
The requirement that cask rigging gear allow crane hookup without
physically entering the cask was specified in Chem-Nuclear System site
criteria procedure and not in their license from the State of South
Carolina.
The shipment was in compliance with 10 CFR 30.41(c) in that
Chem-Nuclear was notified of the type, form and quantity of byproduct
material to be transferred and was in compliance with Condition 64 of
the State of South Carolina Radioactive Material License No. 097 in
that appropriate lifting devices of sufficient length were attached to
the disposal container.
NRC Response
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The letter dated October 3,1985, from the South Carolina Department of
Health and Environmental Control informed TVA that this shipment was in
violation of Condition 64 of Chem-Nuclear's license in that the waste
liner was found to have inappropriate lifting devices to remove it from
the cask. Although the definition of " appropriateness" may be further
clarified in the Chem-Nuclear procedure, the fact that the rigging gear
could not be used to unload the cask was clearly contrary to the
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requirement that the cask be equipped with such rigging gear.
Violation of an Agreement State's license is a violation of 10 CFR 30.41(c).
Further, it was the position of the State of South Carolina
and Chem-Nuclear that they could not remove the rigging gear from the
cask wi.,hout expending considerable exposure.
b.
Licensee Comment
Failure to meet Chem-Nuclear's 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
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is warranted.
Sequoyah personnel received a total of 540 millirem
during their recovery operations when the cask was returned to the
site.
Chem-Nuclear personnel could have freed the rigging gear with
substantially less exposure. Chem-Nuclear personnel are experienced in
dealing with radioactive materials and understand the associated
hazards.
Exposures are strictly limited at the burial site which
should preclude any substantial potential for personnel exposure. The
return of the cask to TVA reflected the burial site's strict compliance
with 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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Enclosure
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NRC Response
Examples of violation severity levels are given ir. 10 CFR Part 2,
Appendix C.
Supplement V (Transportation) to 10 CFR Part 2, Appendix C
states -in Paragraph C.3.c that any noncompliance with packaging,
loading or other requirements that could reasonably result in a
substantial potential for personnel exposure is an example of a
Severity Level III violation. It should be noted that the example does
not require that the exposure be potentially substantial, excessive or
pose a risk to personnel.
The State of South Carolina inspector's
Report Number 85-09-10, dated September 27, 1985, stated that the liner
dose rate was 350 Rem / hour, 9 Rem / hour at the liner top, and that
facility personnel would receive excessive radiation exposure in an
attempt to retrieve the lifting cables.
The October 3, 1985, letter
from the South Carolina Department of Health and Environmental Control
to TVA stated that "due to the nature of this shipment, and the
placement of the lifting cables under the internal bracing, the burial
facility operator was instructed to return the shipment to avoid
excessive radiological
exposure during handling and offloading
operations."
Since the inaccessibility of the rigging would have
caused personnel exposures during unloading, the violation fits the
example of a Severity Level III violation.
2.
Violation 50-327, 328/86-04-02, Failure to use bioassay results to evaluate
the regulatory significance of an internal exposure.
a.
Licensee Comment
Due to the specific conditions of exposure and resulting bioassay data,
TVA determined that the assessment of dose to the critical organ and
the comparison of that dose to regulatory criteria was most
appropriate.
NRC Response
The licensee is required by 10 CFR 20.103(a)(3) to use bioassay results
to assess worker intakes in order to determine compliance with the
quarterly intake limit specified in 10 CFR 20.103(a)(1), which is
inhalation of air containing radioactive material at the maximum
permissible concentration (MPC) given in 10 CFR 20, Appendix B,
Table 1, Column 1 for 520 hours0.00602 days <br />0.144 hours <br />8.597884e-4 weeks <br />1.9786e-4 months <br /> in any period of one calendar quarter
(i.e. 520 MPC-hours). The licensee did not perform an evaluation of
the bioassay results to establish the regulatory significance of the
exposure. The internal dose evaluation was not relevant in that there
are no NRC internal dose limits,
b.
Licensee Comment
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-hours must be calculated and tracked to
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Enclosure
3
demonstrate regulatory compliance. While TVA agrees that in general
MPC-hour determinations are adequate to assess the regulatory signi-
ficance of chronic exposure 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
nonroutine airborne exposure and for modes to intake other than
inhalation.
NRC Response
10 CFR 20.103(a)(1) and footnote 4 thereto requires that uptake of
radioactive material by any organ as result of inhalation, absorption,
ingestion or injection of radioactive material shall not exceed that
quantity which would result from inhaling such radioactive material for
40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> per week for 13 weeks at uniform concentrations specified in
10 CFR 20, Appendix
B,
Table
1,
Column
1.
The regulations in
10 CFR Part 20 therefore clearly require that exposures be limited,
regardless of the mode of intake, such that the intake of radioactive
material by an individual will be less than would result from an
exposure of 520 MPC-hours.
Since the NRC limit for internal exposure
is expressed in terms of hours of exposure to stated concentrations of
radioactive material in air, confirmed worker internal exposures must
be evaluated and assessed relative to the regulatory limits for such
exposures.
IE Information Notice No. 82-18: Assessment of Intakes of
Radioactive Material by Workers, informed all NRC licensees that, while
there may be more current and technically correct methods of assessing
internal exposures, the regulations in 10 CFR Part 20 are based on
ICRP-2(1959) and that licensees must be able to demonstrate compliance
using the ICRP-2 methodology until 10 CFR Part 20 is revised.
The
staff also agrees with the licensee's statement that MPC-hours may not
have any relationship to internal dose and is another reason why
calculating internal dose is not an acceptable alternative to
calculating MPC-hours to determine the regulatory significance of an
exposure.
c.
Licensee Comment
TVA believes that while 10 CFR 20.103 does not require the deter-
mination of MPC-hours for all modes of exposure,- it does require the
assessment of all intakes. The NRC has not to our knowledge inter-
preted the regulations to require the tracking and evaluation of
intakes (uCi of material), although it is a much more appropriate mode
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.
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Enclosure
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NRC Response
Internal exposures are typically assessed in terms of MPC-hours.
Assessment of microcuries of radioactivity inhaled may also be
acceptable; however, the licensee did not do either. Since the internal
exposure limits in 10 CFR 20.103(a)(1) are cumulative over the period
of a calendar quarter, all
internal exposure assessments for
individuals would have to be maintained in consistent units. It would
not be appropriate, for example, to assign a worker MPC-hours for
routine entries into airborne radioactivity areas and to assess
microcuries of activity for an accident,
d.
Licensee Comment
TVA helieves 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.
NRC Response
Critical organ dose calculations cannot be used to assess the
regulatory significance of intakes of radioactive material in workers
since there are no NRC internal dose limits. The only applicable NRC
limit for worker intakes is the 520 MPC-hour in a calendar quarter
limit in 10 CFR 20.103(a)(1) and 10 CFR 20.103(a)(3) requires the use
of bioassay measurements to determine compliance with that limit.
Besides being clearly stated in 10 CFR Part 20, IE Information
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Notice 82-18, as previously discussed, was also issued to inform
licensees of the NRC position in regard to assessing worker internal
exposures. It was determined during the inspection that Health Physics
management at Sequoyah was knowledgeable of these requirements and was
aware of a recent NRC enforcement action against another licensee for a
similar problem.
3.
Violation 50-327, 328/86-04-03, Failure to maintain written procedures
regarding respiratory protective equipment issuance records.
Licensee Comment
It is TVA's interpretation of 10 CFR 20.103(c)(2) thtt 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. 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
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Enclosure
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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.
NRC Response
10 CFR 20.103(c)(2) requires that the licensee maintain written procedures
regarding issuance records for respiratory protective equipment.
Records
showing what type of respirator a particular individual wore during a given
time period are required in order for the licensee to demonstrate that
credit taken for the protection factor afforded by the respiratory
protective device was appropriate.
These records also enable the licensee
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to establish which individual wore a given respirator if it were later found
defective so that bioassays can be performed or, if any individual is
discovered to have received an internal exposure, the respirator he wore can
be identified and inspected.
It was determined during the inspection that
the licensee had no such procedures or records.
If there had been a
procedure which stated that the RWP timesheet functions as an issuance
record, the staff would have taken exception to such a statement. A worker
signs the RWP timesheet prior to performing work. His signature indicates
that he has read and will comply with the protective requirements listed on
the RWP.
Since the timesheet is signed prior to performing work, there is
no way that the signature can indicate that the worker actually obtained a
respirator and wore it during the work. The RWP timesheet only indicated
that certain individuals had indicated their understanding of the
requirement, not their compliance with it.
It should also be noted that
there are situations where more than one type of respirator may be specified
by the RWP, the wearing of respirators may be specified conditionally, such
as by verbal instructions of health physics personnel, or respirators may be
required only during certain aspects of the work. It is even more apparent
in these situations that the RWP timesheet does not indicate whether or not
a respirator had actually been issued to a particular individual.
4.
Violation 50-327, 328/86-04-04.a, Failure to perform adequate evaluations of
eye exposure due to noble gas.
Licensee Comment
The licensee should have been given credit for licensee identification of
this violation.
NRC Response
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Two potential violation. vere associated with lens of the eye exposure
evaluations:
not using the correct thermoluminsecent dosimeter (TLD)
element to assign whole body dose and not evaluating the adequacy of their
TLD to measure eye dose due to noble gas exposure.
The first potential
violation was identified by the licensee and credit was given.
No credit
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Enclosure
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can be given for the violation that was cited since it was not identified by
the licensee.
Licensee Significant Corrective Action Report NCO-CAR-85-004-RWB identified
in mid-1985 that the Panasonic TLD was not being properly evaluated to
assess worker exposures in that whole body exposures were being taken from
the 1000 mg/cm2 shielded TLD element instead of the 300 mg/cm2 shielded TLD
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element. The licensee changed their methodology for assessing exposures to
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correct this deficiency. A separate issue is the adequacy of the evaluation
of lens of the eye exposure due to noble gas during containment power
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entries. The only documented evaluation shown the inspector stated that
2 shielded TLD element.
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such eye exposure could be taken from the 1000 mg/cm
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After the licensee's corrective action report was written, no subsequent
evaluation was performed to determine if the revised method of evaluating
TLDs was adequate to also assess eye exposure due to noble gas or if a
calculational technique, such as that used by the licensee to assign skin
dose due to noble gas exposure, was also warranted. A subsequent review of
this issue by the inspector at the licensee's Dosimetry Section Office in
fNscle Shoals, Alabama, revealed that the failure to perform the eye dose
evaluations likely did not result in any exposures in excess of NRC limits.
However, the licensee should perform and document an evaluation to determine
if the 300 mg/cm2 shielded TLD element is adequate to measure eye dose due
to noble gas exposure or if a calculational assessment for such exposures is
warranted.
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