ML20214A124

Rev 1 to Health Physics:Health Physics Facilities,Clothing & Protective Equipment

ML20214A124
Person / Time
Site:	Sequoyah
Issue date:	10/21/1986
From:	Hall D, Lovett D, Southerland B TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20214A106	List: ML20214A103 ML20214A110 ML20214A124
References
1723T, 311.06-SQN, 311.06-SQN-R01, 311.06-SQN-R1, NUDOCS 8611190237
Download: ML20214A124 (19)

Text

<

i TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT EMPLOYEE CONCERNS TASK GROUP OPERATIONS CEG Subcategory: Health Physics Element: Health Physics Facilities, Clothing, and Protective Equipment Report Number: 311.06 - SQN Revision 1 Concerns: -XX-85-036-001 XX-85-055-001 XX-85-101-004 I-86-235-SQN SR-SQN-85-001-01 HLA-85-001 MRS-85-002 MRS-85-004 Evaluator: D. C. Hall, Jr. /O-z/-f6 D. C. Hall, Jr. Date Evaluator: D. L. Lovett /v-?/*F0 D. L. Lovett Date Reviewed by: b f[ /8-)/-fh OPS CEG Member Date Approved by: h. . % q s (0-21-il, W. R. Laglarbren Date 1723T 8611190237 861112 PDR ADOCK 05000327 p

PDR

Revision 1 I. TITLE: Health Physics Facilities, Clothing, and Protective Equipment, (311.06-SQN)

This report consists of the evaluation results of 8 employee concerns regarding the following areas:

1. Contamination Area (C-Zone) clothing (4 concerns).

2. Handling of personnel dosimetry devices (1 concern).

3. Respiratory protection device usage (1 concern).

4. Personnel contamination monitoring practicos (2 concerns).

II. SPECIFIC EVALUATION METHODOLOGY TLe following concerns were evaluated:

TX-85-036-001 Concern: This concern relates to Sequoyah, but may now be, or may become, a concern at Watts Bar:

Whoever orders "C-Zone" gloves (reuseable gloves for protecting workers from particular radiation sources) does not order enough small sizes. Large gloves must be made to fit by extensive tape wrapping, but they still do not fit. This is an OSHA type safety problem for persons who must climb or who handle certain tools that require a sure grip. This is a much more serious / common problem for the women who must use the "C-Zone" gloves.

XX-85-055-001 Concern: Self reading pocket dosimeters are collected in a metal box at the entry portal in the Turbine Building. Throwing dosimeters in a box could cause them to be knocked offscale.

XX-85-101-004 Concern: Sequoyah - CI expressed that insufficient attention to detail is given in regard to minimizing radiation exposure. Due to the policy of reusing outer gloves in radiation areas, CI has observed used gloves, available for rouse, which were contaminated to a level 5 times that of the area in which the employee was working. Construction department concern. C1 has no further information.

I-86-235-SQN An anonymous individual mailed in a safety concern to NSRS stating that the proper C-Zone clothing for entering the rooms at the Condensato Domineralizer Waste Evaporator Building is not readily available.

Previous attempts to place storage cabinets stocked with C-Zone clothing in the area have been turned down.

Page 1 of 15 i

e

• Revision 1 SR-SQN-8 5-001 During outages, some personnel in an area have been (SQN-85-001-01) required to wear face masks while others in the same area have not. At times HP did not wear one. Lower containment, May 1985 timeframe.

HLA-85-001 Concern: Personnel can leave the site without a final check for contamination.

MRS-85-002 Concern: No portal monitor exists at plant exit.

MRS-85-004 C-Zone clothes are not being patched by the laundry.

The concerns were evaluated in accordance with the Operations Concern Evaluation Group (OPS. CEG) Evaluation Plan and the Health Physics (HP)

Subcategory Evaluation Plan. Concern XX-85-101-004 was previously evaluated by NSRS (see report I-85-652-SQN, reference 3) and concern XX-85-055-001 was previously evaluated by the TVA Radiological Health Staff (references 1 and 2). These reports were evaluated for technical accuracy and completeness in addressing the concerns. All other concerns were investigated by reviews of applicable SQN programs for compliance with regulatory, TVA, and SQN procedural requirements, audit and inspective findings, reports on similar concerns, observation of plant practices, and interviews with cognizant personnel. All K-forms assigned to this element were reviewed.

III. FINDINGS Concern XX-85-036-001 - TVA Protective Clothing Specifications, Specification 5 (reference 10) outline specifications for radioactive contaminant protective gloves. This specification also provides for color coding of gloves to identify sizes. Ir.terviews with Building Services personnel indicated that SQN Power Stores Section normally stocks five sizes of gloves, sizes 7, 8, 9, 10, and 11. Observation of the laundry and clothing storage on the elevation 690 showed that these gloves are in stock and are color coded as required in the specifications. It was noted, however, at the time of the walkthrough, few size 8 gloves were available. An individual in Health Physics stated that although any size glove can be ordered, it is not practical to maintain a stock of every size imaginable, and that orders are directed toward the most common sizes required. This individual also stated that, as result of an accident, in which wearing gloves that were too large contributed to the injury of an employee, size 7 gloves were ordered and stocked. It was determined through an interview with a safety department individual that, since size 7 gloves were ordered and utilized, there had been no other safety incidents caused by wearing gloves which were too large.

Concern XX-85-055-001: The findings of the TVA Radiological Health Staff Line Report (reference 1 and 2 of this report) are summarized below:

Page 2 of 15

Revision 1

1. Of an estimated 195,000 dosimeter drops into collection boxes in 1985, only 35 casos of offscale investigations were necessary

(.018 percent).

2. Employees are trained to and responsible for reading their dosimeters prior to dropping them off or picking them up, therefore, offscale readings will be immediately detected.

3. If an offscale investigation indicates that the offscale reading is potentially because of radiation expostre, the individual's TLD is processed and his dose record updated accordingly.

4. Pocket dosimeters are intended only to assist individuals in tracking and controlling their own exposure. Official dose

!, assessment and control is accomplished by means of TLD.

, 5. With the advent of the power block concept at SQN and WBN, pocket

. dosimeters are no longer dropped in collection boxes but, rather, are hung on racks to minimize the possibility of jarring them offscale. BFN personnel still drop their dosimeters into collection boxes.

Concern XX-85-101-004: This concern was evaluated by NSRS (Report No.

.; I-85-652-SQN). The findings of the report are summarized as follows:

1. The TVA Radiation Protection Plan (RPP) establishes contamination g limits for C-Zone clothing. These limits are implemented at the s

plant by SQN Radiological Control Instruction 1 (RCI-1).

2. As part of the NSRS investigation a random sample of C-Zone gloves

', and shoecovers was surveyed for loose and fixed contamination.

J None of the items surveyed exceeded the 4,500 counts per minute 3 (CPM) fixed contamination limit established by the RPP and no i,

smearable (loose) contamination was detected.

_3 3. Interviews with cognizant HP and laundry personnel indicated that U

there is no evidence that any C-Zone clothing has over been released as ready for reuse that did not meet the requirements of a the RPP and RCI-1.

4. C-Zone clothing is treated as radioactive material and the clothing bins are conspicuously posted as a radioactive materials area to alert workers to the presence of fixed contamination or the C-Zone clothing.

5. All C-Zone clothing is surveyed for fixed contamination but, because of the demonstrated effectiveness of the cleaning process, surveys for loose contamination are neither routinely required nor doomed necessary.

6. Surveys for alpha contamination are not routinely required so long

as analyses and surveys of the reactor coolant do not indicate a significant presence of alpha emitting radionuclides.

Page 3 of 15 t

. 1 Revision 1

7. NSRS investigators stated that while C-Zone clothing is covered in the General imployee Training (GET) HP courses, they do not believe the difference between fixed and loose contamination is adequately explained. GET training personnel stated that they do discuss fixed contamination on C-Zone clothing during the classos.  ;

8. Limits for fixed contamination pertain to direct dose and limits for loose contamination pertain to the potential for skin ,

contamination. The two limits are not numerically comparable. The dose equivalent of loose contamination activity normally encountered in the plant is extremely low when compared to direct sources of radiation: therefore, it is possible that fixed contamination levels on C-Zone clothing may exceed by several times the limits for loose contamination and still not exceed fixed contamination limits or be considered a significant radiation hazard. This is not considered an unusual condition and.within acceptable limits governing personnel exposure.

Concern I-86-235-SQN: The evaluation of this concern consisted of interviews with HP and Building Services personnel and a walk-through

] inspection of protective clothing storage areas.

l i It was observed during the walk-through inspection that protective 4

clothing is readily available for entering the Condensate Demineralizer l Waste Evaporator Building (CDWE). Interviews with HP personnel 1

disclosed that two principal areas exist for storing C-Zone clothing for employees. These areas are on the 690 foot and 714 fcot elevations of the Auxiliary Building. The 714 foot elevation area is usually stocked with C-Zone clothing only during outages. The 690. foot elevation area is the primary location for stocking clothing because .,

j the majority of employees pass this area in transit to their work i

areas. HP personnel also stated that the responsibility of paintaining 1 an adequate laundry stock at the primary location (690 foot elevation) .

rests with the Building Services Section.

During the course of the plant walkthrough, it was also found that clothing bins were available at the 706-foot elevation entrance to the t CDWE Building and that they were stocked with C-Zone clothing. An individual with Building Services stated that they do not routinely stock these laundry bins, and that personnel who access this area ,

usually pick up their clothing at the main clothing storage area on the 690-foot elevation, either for their individual use, or to stock the clothing bins.

Concern SR-SQN-85-001-01: This concern raises questions about the Respiratory Protection Program in general and, specifically, indicates the perception that HP is inconsistent in setting respiratory protection requirements. Thid evaluation was based on the assumption that three questions must be answered in order to fully address the concern. The three questions are:

T Page 4 of 15 1

.,. . , - , _ . - , - - - , - - - , , . . - . . _ _ . _ _ ---n, , .- - - - - . - - - - - - . -

_- _ . - - ~. - _ _ - _ _ . -. - .-

_ . - ~ _- - - - - . - -_

Revision 1

1. Have instances occurred at SQN in which only some of the individuals working in a particular area were required to wear 4 respirators? If so, is this indicative of a HP deficiency or is it i based on justifiabic reasons?

2. Are the HP personnel who are responsible for setting respiratory d

I protection requirements adequately trained and knowledgeable enough in respiratory protection to enable them to properly and consistently implement the Respiratory Protection Program.

3. Does the SQN Respiratory Protection Program adequately implement regulatory and agency requirements?

The evaluation of question 1 was performed primarily through interviews with cognizant HP personnel. The following conclusions were drawn from the interviews:

1. HP personnel who write RWPs attempt to maintain an awareness of all jobs ongoing in a particular area and set protective requirements accordingly. They admit, however, that they are not always able to do this and may be unaware that more than one activity is ongoing in the same area and that one or more of these activities may 4

. affect the protective requirements of the other jobs.

2. Because of this, (item 1), the responsibility to ensure that one i activity in a particular area is not affecting other activities, primarily falls on the HP technician who is providing job

coverage. HP technicians are instructed to evaluate all work ongoing in their areas of coverage, and, as necessary, modify the .

protective requirements for all jobs in that area. '

1

3. It was also stated that, while not common, it is not unusual to have some individuals wearing respirators while other individuals in the same general area are not required to wear them. There are two general reasons this may be allowed. First, some activities

, may produce only limited airborne activity which is not widespread over the general area and poses a hazard only to those persons involved in that particular job. In cases like this the HP technician is required to collect both breathing zone air samples (within close proximity to the job, generally no more than 6 feet away) and general area air samples to ensure the hazard is limited to the specific job location. Secondly, respirators are commonly issued to prevent facial contamination for jobs which only involve splashing or spraying of contaminated liquids and, therefore, pose i no threat of creating a widespread airborne radioactivity problem.

The evaluation of the second question consisted of a review of the training requirements for HP technicians and interviews with the technicians to determine their understanding of the Respiratory Protection Program.

l

\

h Ji h

Page 5 of 15 2

. - - + - - - - - - , yn ,--n --- ,- , -n- , . , . . - _ . - . - - - - -rn--, n,- . . - - - - . - . . - . - - -

Revision 1 As outlined in SQN ASIL-3, the TVA HP Technician Training Program is divided into a classroom phase and an in-plant phase. The classroom phase introduces the technician to health physics fundamentals, Regulatory Guides, 10CFR20, and other disciplines necessary to provide the technician with the background to complete the in-plant phase.

The in-plant phase of the TVA HP Technician Training Program is designed to ensure that the trainee is competent in the application of HP practices in real-life circumstances.

Interviews were conducted with eight randomly selected HP technicians. This sample represented 45 percent of the HP technicians and was composed of SE-4 level and SE-5 level HP technicians.

The interview was directed toward determining if these technicians were aware of protective equipment requirements and how to apply these concepts in given real-life scenarios. Every technician interviewed demonstrated an ability to use independent and professional judgment in determining respiratory requirements, and demonstrated a good working knowledge of applicable regulatory, TVA, and SQN procedural requirements and instructions pertaining to respiratory protection. Each technician also stressed that respiratory requirements are assigned on a case-by-case basis with factors such as type of work to be performed, radiation levels, contamination levels, and air quality taken into account. It was also stated by one technician that respirators are also assigned to prevent facial contamination.

As a result of the interview, it was determined that the SQN HP technicians are knowledgeable of protective equipment requirements, and how they are established and documented on RWPs. The technicians demonstrated the ability and knowledge to make sound professional judgment in implementing the Respiratory Protection Program.

The evaluation of the third question consisted of a review of regulatory requirements, TVA and SQN procedural requirements, NRC Inspection Reports, Nuclear Quality Evaluation and Audit (NQE&A) Branch (formerly QAB) Audit Reports, and Institute for Nuclear Power Operations (INPO) Audit Reports. The findings of the review are as follows:

1. General requirements for respiratory protection are set forth by 10CFR20.103, 10CFR20.203, and 10CFR2O appendices A and B.

Additional requirements and/or guidelines are set forth by US NRC Regulatory Guide 8.15 and NUREG 0041. The TVA RPP and SQN RCI-4, RCI-14, TSIL-3 and TSIL-5 were reviewed and determined to comply fully with the referenced regulatory requirements and guidelines.

Page 6 of 15

Revision 1

2. A review of recent NRC Inspection Reports, NQE&A audits, and INPO evaluations revealed some weaknesses in the Respiratory Protection Program but those were determined to bo outside the scopo of concern SR-SQN-85-001-01 as stated. The weakness in the program or related programs, include:

a. Inability of the present whole body counter to detect 5 percent of the maximum permissible organ burden (MPOD) of some radionuclides. This problem, whilo related to the Respiratory Protection Program, falls more under the internal dosimetry and bioassay programs. Corrective action has been taken at SQN to resolve the item.

b. Failure to determine the exposure significance for an employee who received an internal disposition of radioactive material by evaluation of bioassay results. This is also an internal dosimetry and bioassay program deficiency but is related to the Respiratory Protection Program. SQN was cited with a Severity Level IV violation for this deficiency by NRC.

c. Failure to maintain written procedures regarding respiratory protection equipment issuance records when allowance is made for use of respiratory protection equipment in estimating exposures of individuals to radioactivo materials in air.

(Violation of 10 CFR 20.103(c)(2)). SQN was sited with a Severity Level IV violation for this deficiency by NRC.

No additional problems, deficiencies, deviations, or weaknesses were noted regarding the Respiratory Protection Program. The weaknesses and deviations identified above do not portain to concern SR-SQN-85-001-01, as stated, and there is no evidence or indication that SQN is not properly administering its Respiratory Protection Program or that the program does not fully and adequately implement all applicable regulatory and TVA requirements.

Concern HLA-85-001: TVA's RPP, Revision 3, (reference 5) assigns each employee the responsibility to protect himself and the general public from unnecessary exposure to radiation. RCI-1, revision 30, (reference 6) states that each employee leaving regulated areas within the plant " . .

. shall use the hand and foot counter or other contamination detecting instruments as provided." A supporting memorandum (reference 7) states that " contamination control is primarily the responsibility of the individual workor.

All personnel should monitor themselves when leaving radiologically controlled areas to provent the spread of contamination to l uncontrolled areas, fellow workers, and possibly their families."

Pago 7 of 15 l

Revision 1 GQN's HP department has provided instrumentation throughout the plant for employees to monitor themselves for contamination. These instruments are in the form of portal monitors and " friskers." The HP department also provides, at the main regulated area exit a permanently manned control point staffed with HP technicians to observe and control personnel and equipment exiting the regulated area. As stated in RCI-1 as well as supporting memorandum, any individual passing a hand and foot monitor af ter leaving the regulated areas or failing to frisk themselves after exit is subject to having a Radiological Incident Report (RIR) written and receiving subsequent corrective or disciplinary action.

Concern MRS-85-002: This concern was evaluated by performing a visual observation which confirmed that there is a portal monitor at the plant exit. Use of this portal monitor by plant personnel is not mandatory and there are no regulatory, TVA, or SQN procedural requirements for the existance of a portal monitor at the plant exit. The monitor was placed there only for the benefit of concerned employees who wanted to perform a final contamination check prior to leaving the plant and to instill greater employee confidence in the SQN RPP (see memorandum, reference 4).

There does exist a requirement for portal monitors or other detection instruments to be available for personnel exiting the regulated areas. These regulated areas are defined to be areas within the plant where access is controlled for purposes of protection of individuals from exposure to radiation and radioactive materials. A tour of the regulated areas showed that portal monitors and/or some other contamination detection device are available for personnel use. These devices are located throughout the regulated area.

Concern MRS-85-004: This concern was evaluated by performing visual inspections of C-Zone laundry and conducting interviews with laundry personnel from the Building Services Section.

Twenty-one pairs of previously laundered C-Zone coveralls were randomly selected from the 690 foot elevation clothing storage area. These clothes were visually inspected for holes, tears, cuts, etc. Of the 21 pairs of coveralls inspected, 8 had been patched and 11 had one or more holes in them. Of the 11 with holes, some had been patched in adjacent areas. It was also found that of the coveralls inspected that had holes or patches, che holes found were all less than 1/2-inch in diameter (visual observation). An individual with Duilding Services stated that any clothes with holes or tears greater than approximately 6 inches long are discarded. rdthough at the time of the interview with this individual, no C-Zone clothing was being repaired it was apparent that the laundry personnel 6 patch C-Zone clothing.

A memorandum dated August 11, 1986, (reference 8) addresses a similar concern stated in an employee's exit interview meeting.

This memorandum contained the following response from HP management:

Page 8 of 15

e * .

Revision 1 Concern:

Sometimes clothing has holes in it. You have to inspect closely J before dressing out.

Response

!l All C-Zone clothing is inspected by laundry personnel for the

{

presence of holes, tears, etc. during the laundry cycle. This i inspection serves to purge the operational stock of worn-out I clothing. However, it is the responsibility of overy worker to g inspect their clothing, gloves, booties, etc. for holes prior to i dressing. This check minimizes the chances of workers becoming contaminated during the course of their work activities. This practice (i.e., requiring workers to inspect their own clothing) is standard throughout the nuclear industry and any worker who does not inspect his or her C-Zone clothing has fallen into a bad practice.

Conclusions XX-85-036-001: The concern was validated in that pricr to the accident referenced in section III of this report, SQN did not routinely stock ,

the smaller sizes of gloves. As a result of the accident, the smaller '

sizes are now stocked and no additional corrective action is necessary. The concern does not affect the safe operation of the plant.

XX-85-055-001: The concern was validated in that a small percentage '

(.018 percent) of dosimeters dropped into collection boxes were apparently jarred offscale. Collection boxes are no longer in use at SQN and, therefore, no corrective action is necessary. The concern does not affect the safe operation of the plant.

XX-85-101-004: The concern was validated in that fixed contamination levels can and sometimes do exceed loose contamination limits for C-Zone clothing; however, no evidence was found that any C-Zone clothing reissued for use has ever exceeded the fixed contamination limits. These limits are discussed in GET classes. No corrective action is necessary. The concern does not affect the safe operation of the plant.

I-86-235-SQN: The concern was not validated. C-Zone clothing is available for personnel entering the CDWE Building. The concern does not affect the safe operation of the plant.

SR-SQN-85-001-01: The concern was validated in that instances have occurred in chich some workers in a particular area have been required 2 to wear respirators while others have not. These occurrences can be -

justified, and eo evidence was found to conclude that the SQN .

Respiratory prot (ction program is not being properly and prof;!ssionall's administered in accordance with all applicable requirements. No ~

correctivo action l.s necessary. The concern does not affect 'the safo ~

operation of the plant.

Page 9 of 15

Revision 1 IIL A-85-001: The concern was not validated in that adequate instrumentation and administrative controls are in place to ensure that personnel exiting areas roquiring monitoring can do so and are required to do so. This is not to say that personnel cannot deliberately by-pass the monitoring process or that all ateas on the site require exit monitoring, but that adequate controls are in place at SQN to reasonably ensure the monitoring is done. No corrective action is necessary. The concern does not affect the safe operation of the plant.

MRS-85-002: The concern was not validated. A portal monitor, though not required, is available for voluntary use at the plant exit. The concern does not affect the safe operation of the plant.

MRS-85-004: The concern was validated in that is is possible to find C-Zone clothing with holes. Although it is apparent that laundry personnel do routinely patch or repair damaged C-Zone clothing, the number of coveralls found with unpatched holes (approximately 50 percent of the inspected sample) could indicate that the plant's efforts to maintain serviceable C-Zone clothing are inadequate. Even though each worker does have the responsibility to ensure the serviceability of his protective equipment, the plant must also make every effort to ensure that adequate equipment and clothing, in good condition, are always available.

IV. Root Cause Concerns I-86-235-SQN, HLA-85-001, and MRS-85-002 were not validated, therefore, no root cause determination was necessary.

The root cause of XX-85-036-001 was determined to be the attitude, by the HP personnel responsible for stocking the protective clothing and equipment, that only those sizes of gloves which were most commonly used should be routinely stocked and personnel who needed other sizes could "make do." This demonstrated an apparent lack of regard for those personnel who needed other sizes and required an accident to remedy this attitude.

3; The root cause of XX-85-055-001 was determined to be a procedural deficiency which ri quired docimeters to be dropped into a metal collection bin. This deficiency has been corrected at SQN and WBN but still exists at 8FN.

The root cause of XX-85-101-004 was determined to be a misunderstanding of fixed vorsus loose contamination limits by the CI. There is no evidence of any programmatic or procedural deficiencies.

The root cause of GR-SQN-85-001-01 was determined to be a misunderstanding by the CI of the HP Respiratory Protection program.

There is no evidence of?any procedural or programmatic deficiencies.

i. ,

Page 10 of 15 l

Revision 1 The root cause of MRS-85-004 was determined to consist of three parts.

First, the CI was apparently unaware of the fact that C-Zone clothing is frequently subject to being damaged and that a large number of rips, tears, and holes do occur. Second, the CI was also apparently unaware that he/she, as well as all workers, are personally responsible for inspecting their C-Zone clothing to ensure its serviceability.

Finally, the large number of unrepaired coveralls found in the inspection indicates that the plant is not devoting enough attention to Ihe C-Zone clothing to ensure its proper maintenance and serviceability.

V. Generic Applicability The following concerns are generically applicable to all TVA nuclear facilities:

XX-85-036-001 XX-85-101-004

SR-SQN-85-001-01 HLA-85-001 MRS-85-004 Concern SS-85-055-001 is generically applicable to BFN.

Concern I-86-235-SQN is generically applicable to WBN.

No generic applicability could be determined for MRS-85-002.

I i

L i

i j

l

)

k l

page 11 of 15

[f k

I

='.

• Revision 1 1

VI. REFERENCES

1. " Investigation / Evaluation Report - Employee Safety Concern - QTC Concern IN-85-142-002," Fobruary 4, 1986 (RIMS L61 860121 804)

2. " Investigation / Evaluation Report - Employee Safety Concern - QTC Concern XX-85-055-001," February 4, 1986 (RIMS L618 60203 806)

3. NSRS Report I-85-652-SQN " Contamination of Laundered Anti-contamination Clothing," December 27, 1985

4. Memorandum from E. A. Belvin to H. L. Abercrombie, dated August 5, 1985, "Use of Portal Monitors at Sequoyah Nuclear Plants (SQN)" (RIMS L49 850805 800)

5. Tennessee Valley Authority: Radiation Protection Plan, Revision 3

6. SQN-RCI-1, Revision 30

7. Memorandum from D. E. Crauley to P. R. Wallace, "Sequoyah Nuclear Plant - Personnel Frisking Program," July 23, 1985 (RIMS SS3 850724 999)

8. Memorandum from R. Prince to P. R. Wallace, "Sequoyah Nuclear Plant - Employee Exit Interview Concerns," August 11, 1986

9. NTB "GET Lesson Plans" GET Module 2.2 - 2, Revision 1 GET Module 2.2 - 5, Revision 1 GET Module 2.3, Revision 0

10. " Tennessee Valley Authority Protective Clothing Requirement,"

Specification Number 5, Revision 7

11. SQN RCI-4, Revision 20

12. SQN RCI-11, Revision 5

13. SQN RCI-14, Revision 5

14. SQN HPSIL-3, Revision 11

15. SQN HPSIL-31, Revision 0

16. SQN ASIL-3, Revision 10

17. SQN HPSIL-5, Revision 19

18. SQN FSAR Section 12.3 " Health Physics Program"

19. SQN HPSIL-7, Revision 12 Page 12 of 15

f s*. * .

Revision 1

20. NSRS Report Number I-85-734-SQN " Training of Health Physics Technicians," March 11, 1986

21. Lotter to Hugh Parris from E. P. Wilkinson, INPO, January 13 1984 (RIMG A02 840116 016)

22. Memorandum to N. E. Scott from C. C. Mason, " Health Physics Technician (HPT) and Radiochemical LaSoratory Analyst (RLA)

Trainir.g Program Evaluation" (RIMS L53 830621 954)

23. Letter to H. G. Parris from David M. Verelli, USNRC,

" Reports 50-327/84-34 and 50-328/84-34" (RIMS A02 341130 005 L44 841200 020)

24. Memorandum to H. L. Abercrombio from K. H. Whitt, " Nuclear Safety Review Staff Investigation Report Transmittal" (MATS 8280)

25. SQN units 1 and 2 Technical Specifications

26. ANSI N18.1-1971

27. NUREG 0041

28. TVA Area Program Manual 0301.06

29. Sequoyah Nuclear Plant - Office of Quality Assurance Audit Report CH-8400-14 " Health Physics Training and Staff Qualifications" (RIMS SS3 840926 936)

30. Memorandum to H. L. Abercrombie from G. W. Killian, " Evaluation of Corrective Action Response - Deviation Report CH-8400-14-02" (RIMS L17 841003 802)

31. Memorandum to H. L. Abercrombie from G. W. Killian, " Evaluation of Corrective Action Response - Deviation Report CH-8400-14-03" (RIMS L17 841030 802)

32. Memorandum to H. L. Abercrombie from G. W. Killian, "Sequoyah Nuclear Plant - Of fice of Quality Assurance Audit Report CH-8400-14, Health Physics Training and Staff Qualifications" (RIMS L17 850104 801)

33. Memorandum to G. W. Killian from John Hutton, " Division of Quality Assurance Audit Report CH-8400-14, Health Physics Training and Staff Qualifications" (RIMS L47 850117 806)

! 34. Memorandum to G. W. Killian from H. L. Abercrombie, "Sequoyah Nuclear Plant - Office of Quality Assurance Audit Report CH-8400 Health Physics Training and Staff Qualifications" (RIMS S53 850206 923) r l

I Page 13 of 15

Revision 1

35. Memorandum to H. L. Abercrombie from G. W. Killian, " Evaluation of Corrective Action Response to Deviation Report CH-8400-14-01" (RIMS L17 850228 000)

36. Memorandum to G. W. Killian from J. W. Hutton, " Division of Quality Assuranco Audit Report CH-8400 Health Physics Training and Staff Qualifications" (RIMS L44 850327 801)

37. Memorandum to J. Hutton from G. W. Killian, " Evaluation of Corrective Action Taken - Deviation Report Closure" (RIMS L17 850530 806)

38. , Memorandum to H. L. Abercrombie from G. W. Killian, " Evaluation of Corrective Action Taken - Deviation Report CH-8400-14-01" (RIMS L17 850807 800)

39. Memorandum to J. Hutton from G. W. Killian, " Evaluation of Corrective Action Taken - Deviation Report Closure" (RIMS L17 850816 802)

40. Memorandum to G. W. Killian from H. L. Abercrombie, "SQN-DQA Audit Report CH-8400 Health Physics Training and Staff Qualifications" (RIMS S53 850828 928)

41. Memorandum to H. L. Abercrombie from G. W. Killian, " Evaluation of Corrective Action Response - Deviation Report CH-8400-14-01" (RIMS L17 850920 802)

42. Letter to J. A. Coffey from G. W. Killian, " Division of Quality Assurance Audit Report CH-8400 Health Physics Training and Staff Qualifications," dated August 24, 1984 (RIMS L17 840905 803)

43. Memorandum to Those listed from G. W. Killian, " Transmittal of QAB i

Audit Report Q55-A-85-0012" (RIMS L17 850905 800)

44. Regulatory Guide 8.15-October 1976

45. Regulatory Guide 8.8, Revision 3-1978

46. 10 CFR 20, " Code of Federal Regulations" l

47. ANSI 3.1 - 1961 i

48. TVA Program Manual - 0202.12, Revision 2-March 10, 1986

49. TVA HPT002L.002 " Radiation Monitoring Equipment," Revision 2, June, 9, 1986

50. TVA HPT-LP 16 " Respiratory Equipment and Protective Clothing"

51. TVA HPT-LP14, Revision 0, July 21, 1983, " Radiation, Contamination, and Airborne Survey Techniques and Evaluations" l

i l

Page 14 of 15

, . . e .

Revision 1

52. llealth Physics Retraining Program Evaluations Periodic Evaluation Questionnaires for 1985, CHPST-51L-T-6, Revision 1,

, November 11, 1983 1

53. NRC Inspection Report 50-327/86-04 and 50-328/86-04 dated March 27, 1986 (A02-860728-016)

54. NRC Inspection Report 50-327/86-36 and 50-328/86-36 dated July 23, 1986 VII. IMMEDIATE AND LONG-TERM CORRECTIVE ACTION

MRS-85-004: Plant should evaluate a means to reduce the number of damaged C-Zone clothing articles issued for reuse.

No other corrective action is indicated regarding the other concerns etaluated in this report.

I i

e i

Page 15 of 15

w OPERATIONS CATEGORY Enclosuro 2 I

ECTG WRITER'S GUIDE OPERATIONS (OP) ELEMENT REPORTS NOTES / COMMENTS 1.0 Issue I. Title The brief introduction

. Characterization Very brief introduction touches on the source of j the concerns, i

1

! 2.0 Summary I. Title 1. The Conclusions are Very brief introduction towards the end of the i findings.

I III. Finding (Conclusions) 2. The Conclusions i services as a summary of the findings, i

3.0 Evaluators Cover Sheet 1. The printed name of the original evaluator (s) appears on the cover sheet.

2. The peer reviewer and CEG-H approval signa-tures are also on the cover sheet.

i 4.0 Evaluation II. Specific Evaluation Process Nethodology i

j 5.0 Findings III. Findings 1

i i .

l 1880T l

i

E clesuro 2 I ECTG WRITER'S GUIDE OPERATIONS (OP) ELMENT REPORTS NOTES / COMMENTS 6.0 Root Cause IV. Root Cause 1. At the element level (Collective Significance) the Root Cause is often not identifible.

2. Collective significance is not addressed at the element report level.

2 7.0 Attachments / II. Specific Eva'luation 1. A list of the concerns List of Concerns Nethodology with text are included within this section.

2. Other reports are sometimes attached.

l l

l

oo

• Enclosure 3 Page 1 of 1 SEQUOYAH EMPLOYEE INITIAL CONCERN ELEMENT REPORT NUMBER ISSUE Operations 30115 XX-85-102-005* Hardware Not Properly (Initial) Identified.

• Concern XX-85-102-005 and Element Report 30115 were added after 9/26/86 Operations 30803 XX-85-096-004* Corrective Maintenance (Initial) XX-85-096-005 XX-85-096-N07**

GSB-85-001 DHT-85-003 2850162005 SQP-6-014-002 XX-85-071-003

• KK-85-096-004 was transferred to XX-85-096-005.

• • Category changed from GN to OP and added to Subcategory 30803 after 9/26/86.

Operations 31106 XX-85-036-001 Health Physics (Initial) XX-85-055-001 Facilities, Clothing, XX-85-101-004 and Protective Equipment I-86-235-SQN SR-SQN-85-001-01 (SQN-85-001-01)

HLA-85-001 MRS-85-002 MRS-85-004 l

2537T l

i i <

'