ML20214J135
| ML20214J135 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 11/13/1986 |
| From: | Russell J, Stewart D TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20214H850 | List:
|
| References | |
| 311.04-SQN, 311.04-SQN-R01, 311.04-SQN-R1, NUDOCS 8612010170 | |
| Download: ML20214J135 (42) | |
Text
i TVA EMPLOYEE CONCERNS REPORT NUMBER:
311.04-SQN SPECIAL PROGRAM REPORT TYPE:
Sequoyah Nuclear Plant Element REVISION NUMBER:
1 TITLE: Health Physics Policies, Practices, and Management Control REASON FOR REVISION:
Revised to incorporate SRP comments and SQN corrective action response.
Revision 1
?
l PREPARATION I
PREPARED BY:
D. C. Hall, Jr.
10/17/86 SIGNATURE DATE REVIEWS PEER:
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- DATE APPROVED BY:
$$$'Vh N/A ECS'P MJ0iAGER DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)
- SRP Secretary's slEnature denotes SRP concurrences are in flies.
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TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT EMPLOYEE CONCERNS TASK GROUP OPERATIONS CEG Subcategory: Health Physics Element: Health Physics Policies, Practices, and Management Control Report Number: 311.04 - SQN Revision 1 Concerns: SQP-86-009-001 11-85-063-001 SQP-86-009-002 II-85-028-102 11-85-084-001 II-85-028-103 I
II-85-066-001 II-85-098-002 II-85-009-002 I-86-238-SQN WI-85-038-001 JLH-86-003 11-85-015-001 JMA-85-001 II-85-026-001 RII-85-A-0064 l
Evaluator:
D. C. Hall Jr.
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D. C. Hall Jr.
Date T. L. Reese
/c-/7-f6 T. L. Reese Date R. L. Huskin
/#-/7-f6 R. L. Huskin Date D. L. Lovett
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D. L. Lovett Date Reviewed by:
buel8$mwinbr}j M/Mkb OPS CEG ember Dat'e
. W% Cu 10-//-$ d Approved by:
W. R. Lagergreji Date 1872T
Revision 1 I.
Title:
Health Physics Policies, Practices, and Management Control -
311.04-SQN The scope of the 311.04-SQN evaluation consisted of the investigation of 16 concerns. The concerns involved the following areas of the i
Eealth Physics (HP) program:
1.
Personnel contamination (Concern SQP-86-009-001) 2.
HP response to radiation / contamination alarms or indications of abnormal radiological conditions (Concerns 11-85-084-001 and 1
11-85-066-001) 3.
Distribution of personnel radiation doses (Concern 11-85-009-002) 4.
Containment "at power" entries (Concerns SQP-86-009-002 WI-85-038-001 and 11-85-015-001) 5.
Management support of HP programs (Concern 11-85-026-001)
I 6.
Verification of system contents (Concern 11-85-063-001) 7.
Radiation Work Permit (RWP) procedures (Concerns 11-85-028-I02 and 11-85-028-103) 8.
Radiological Survey frequency (Concern 11-85-098-002) 9.
C-Zone Emergency Proceduces (Concern I-86-238-SQN) 10.
Auxiliary Building Secondary Containment Enclosure (ABSCE)
. breaches (airborne radioactivity concern) (Concern JNA-85-001) 11.
Frisker Locations (Concern JLH-86-003) 12.
Adequacy of the SQN HP program in general (Concern RII-85-A-0064)
II.
Specific Evaluation Methodology 1.
Concern SQP-86-009-001 states: An incident at Sequoyah Nuclear Plant which resulted in employees being radioactively contaminated l
could have been prevented and reflects managements attitude toward l
radiation safety and personal safety of the employees.
lR1 i
2.
Concern SQP-86-009-002 states: The transfer of responsibility for HP from Muscle Shoals to Sequoyah places the individual responsible for HP in a position where much pressure from plant management can be exerted and has caused compromises of previously established HP policy regarding personnel access during unit l
operation.
lR1 Page 1 of 36
l l.
Revision 1 3.
Concern XX-85-084-001 states: Questionable practices by HP at Sequoyah in 1982 led to possible overexposures. HP would respond to radiation alarms and unplug units.
(R1 4.
Concern XX-85-066'-001 states: Sequoyah: Three years ago HP at Sequoyah was notified of higher-than-expected radiation levels in the Reactor Building. When notified by telephone, HP l
personnel speculated on the reasons for the high radiation level, and did not respond immediately to investigate. CI feels that l
wasting time speculating on cause and not responding immediately is a concern for safety.
IRl i
S.
Concern XX-85-009-002 states: Sequoyah: There is no rer,ard for personnel safety at operating plants. Management (known) directed that the oldest employees be assigned to " hot" work in order for them to reach their radiation levels first. A supervisor (known) made the st3tement that " older folks won't be long around."
lR1 6.
Concern XX-85-028-X02 states: Sequoyah: RWP 02-2-00214 (sign-in sheet) contains falsified signatures.
lR1 l
7.
Concern XX-85-028-X03 states: Sequoyah: RWPs are not being c mpleted according to procedure requirements. RWP 02-2-00214 j
is an example.
lR1 i
8.
Concern XX-85-098-002 states: Sequoyah: Radiation areas are not j
monitored often enough'.
l
[
9.
Concern I-66-238-3QN states: An anonymous individual mailed in a l
safety concern to (WSRS) requesting that emergency procedures be t-written to encompass all aspects of possible emergency situations in a C-Zone. Procedures should cover specific areas such as spread of contamination, possibility of injury, possibility of a fire, possibility of poor breathing atmosphere, etc.
lR1 10.
Concern JLH-86-003 states: According to TVA's General Employee Training (GET) classes and plant proceduros, employees are to be frisked as soon as exiting a "C-Zone."
Currently, an employee has to search for a frisker. In the process of looking for a frisker, an employee can contaminate doors and/or the floor.
One of TVA's objectives is to keep down contamination, and the current process does not adequately control the spreading of contamination.
Example: When exiting pipe chase on elevations 690 and 669, one has to pass through closed doors to get to a frisker. On elevation 669 an employee has to hunt for a frisker as evidenced on I
December 12, 1985.
IR1 I
l l
Page 2 of 36
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Revision 1 11.
Concern JMA-85-001 states: A high risk possibility of not securing ABSCE type breaches if a valid high-radiation condition occurs in the Auxiliary Building or during an announced evacuation or evacuation alarm sounded may cause persons to leave the Auxiliary Building before sealing penetration.
IR1 12.
Concern WI-85-038-001 states: Watts Bar Nuclear Plant: The practice of persons entering the lower contaminated area of the reactor containment for nonemergeccy repairs while the reactor is operating should be reevaluated. Recent studies indicate the biological effects of personnel exposure to neutron flux are more serious than previously believed. This practice is L
in effect at Sequoyah and resulted in an accident around 1983/1984 and is planned to be implemented at Watts Bar.
IR1 13.
Concern XI-85-015-001 states: Sequoyah: The practice of personnel entering the lower containment area of the reactor i
containment for nonemergency repairs while the reactor is operating should be reevaluated since recent studies indicate the biological effects of personnel exposure to neutron fluz are more serious than previously believed. This practice caused an accident in the incore instrument probe room at Sequoyah in 1985 and is still continued.
lR1 14.
Concern XI-85-026-001 states: Sequayah: Inadequate upper management support provided the HP department to enforce an effective radiological safety program. No disciplinary
{
action is taken when es;ployees intentionally bypass monitors.
lR1 15.
Concern XI-85-063-001 states: Sequoyah Operators and Health i
Physics: Failure to know and verify the contents of a syrten.
Example: HP gave go ahead to open a line in the unit 2 Turbine Building, saying everything was okay and clean.
After opening the line the next night, the entire area was roped off for contamination. This occurred in January / February 1984.
int l
16.
Concern RII-85-A-0064 states: This allegation expressed concerns I
about the Sequoyah hP program. The concerns are summarized below:
L l
i 1.
TVA does not have the ability to run an HP operation.
l r
2.
An individual lost a radioactive source at the site and never
(
reported the loss to management.
i i
3.
The location of radiation monitors are not as indicated on the ASIL-3 procedure.
4.
Smears are taken into the HP office to count and i
are then thrown into the trash.
)
i Page 3 of 36 1
1 I
Revision 1 5.
The smear counting area in the HP office was contaminated.
This " contaminated area" was used as an eating area.
6.
Air samples are taken improperly, e.
g.,
floor level.
Respirators were not worn by workers in high contamination areas (arear with surface contamination greater than ten thousand dpm).
i 7.
The individual claims he was dismissed from employment as a result of a conspiracy and that he was not treated fairly during his training period.
(This item is being handled solely by the Intimidation and Harassment Category.)
8.
HP technician did not cover the head and filters of air sampling monitors before and after exiting areas to be monitored.
Closure of this matter should involve an evaluation of the HP program and practices to include air sampling program, respiratory protection program, and training program.
Implementation and compliance with written procedures should be assessed.
lR1 This report was prepared in accordance with the Operations lR1 Concern Evaluation Group (Ops. CEG) evaluation plan and the l
Health Physics subcStegory evaluation plan.
l All E-forms, previous NSRS line management, and ERT reports assigned to element 311.04-SQN were evaluated. The evaluations were performed by lR1 four evaluetors and consisted of investigations of all open1 item l
concerns, evaluations and verifications of previous reports, responses, I
and investigations of closed 2 item concerns, interviews with I
cognizant personnel, and reviews of applicable regulstions and governing procedures. The specific items reviewed for each element are identified in the findings of that concern. All previous investigations and reports were assessed for the adequacy of the methodology, findings, and recommendations. Also, all respective corrective actions are verified completed or working.
With the exception of 11-85-028-102 and item 7 of RII-85-A-0064, all lR1 j
of the concerns are assigned solely to the Operations CEG.
l Note: 1 "open" item denotes no previous investigation (s) were performed.
IR1 2 " closed" item denotes previous investigations were performed.
l t
4 Page 4 of 36
Revision 1 Item 7 of concern RII-85-A-0064 raises a question of potential intimidation and harassment in that the CI states he was terminated as the result of a conspiracy and treated unfairly during his in-plant HP training. This item will be evaluated solely by the Office of lR1 Inspector General.
Concern XX-85-028-X02 raises allegations of I
document falsification and is, therefore, also a shared concern with l
the Office of Inspector General.
l III. Findings 1.
SQP-86-009-001 raises a concern that personnel at Sequoyah were contaminated and that the incident, which was preventable, reflected poor management attitudes regarding radiological health and safety. No information detailing the incident was available; therefore it is not known when the incident occurred, the area of the plant in which the incident occurred, the activity in progress which caused the incident, the number of persons contaminated, whether or not internal contamination was involved, nor the extent
)
of the contamination. The evaluation consisted of 2 parts. Part 1 is an evaluation of plant procedures intended to prevent both internal and external radioactive contamination of personnel.
Part 2 is an evaluation of plant procedures regarding action taken when plant personnel become contaminated, including corrective action taken to peevent recurrence.
lR1 A.
Part 1 - Prevention of Personnel Contamination lR1 10 CFR 20 establishes general requirements for protection of personnel in restricted areas against exposure to licensed radioactive materials. These requirements include limits on concentrations of radionuclides in air with regard to internal exposure, requirements for handling radioactive materials with regard to external exposure, and survey requireraents pertinent to both internal and external exposure.
In addition, U.S. NRC Regulatory Guides 8.15 (Acceptable Programs for Respiratory Protection) and 8.8 (Information Relevant to Ensuring that Occupational Radiation Rxposures at Nuclear Power Stations l
Will Be As Low As Reasonably Achievable) establish guidelines for protecting personnel from both internal and external contaminailon hazards. Additional guidance and/or requirements are provided by 30 CFR Part 11. " Respiratory Protective Devices," and NUREG-0041, Manuti of Respiratory Protection Against Airborne Radioactive Materials.
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Page 5 of 36
^
Revision 1 The evaluation included a review of both TVA-wide and Sequoyah-specific implementing procedures. TVA CODE VIII, OCCUPATIONAL RADIAIION PROTECTION, establishes the general requirements for the radiation protection program.
The TVA Radiation Protection Plan defines more spacific requirements applicable to all TVA nuclear facilities, including requirements for airborne radiological assessment and protection programs, protective clothing requirements, survey requirements, and radiological incident and personnel contamination reporting requirements.
At Sequoyah, the primary radiological control program implementing procedures are the Radiological Control Instructions (RCIs). The RCIs establish general limits and guidelines governing the radiological protection program.
Detailed instructions which implement the RCIs within the HP Section are the ASILs, DSILs and HPSILs (section instruction letters). All TVA and Sequoyah procedures dealing with personnel contamination were reviewed and determined to be in compliance with regulatory requirements. Personnel contamination control programs are described by way of SQN RCI-1, RCI-3, RCI-4, and RCI-11.
In addition RCI-14 describes the RWP program with regard to prescribing protective requirements for workers. Sequoyah HP-SILs 2, 3, 5, 7, 8 and 10 provide detailed instructions regarding both internal and external personnel contamination control programs, including respiratory protection and bioassay programs.
B.
Part 2 - Personnel Contamination Incidents IR1 The evaluation of HP practices following incidents of personnel contamination were examined. HP-SIL 10 establishes procedures to be followed in the event of personnel contamination, both external and internal. This includes l
procedures for decontamination, reporting, and corrective I
action. In addition, actual records of personnel contamination were examined.
1 Page 6 of 36 l
1
Revision 1 Sequoyah HP divides the incidents into 2 categories, reportable and nonceportable. Nonceportable incidents require a Personnel Contamination Report, form TVA 17093, and are considered incidents which occurred because of unforseeable circumstances such as a punctured glove or torn protective clothing. Reportable incidents require, in addition to a Personnel Contamination Report, a Radiological Incident Report, (RIR) form TVA 17143, and are considered incidents which were preventable and caused by a failure to follow prescribed procedures. Examinations of the reportable and nonceportable summary files revealed that since 1984 there have been 180 reportable incidents of personnel contamination and approximately 400-500 nonreportable incidents (not counted).
~
Both the Personnel Contamination Reports and RIRs require review by applicable HP and plant management, and they require recommended corrective action. It was noted that the number.
of reportable incidents has declined, year to year, since 1984.
j 3
2.
Concern SQP-86-009-002 was evaluated with regard to the technical l
.I aspects and potential consequences of the alleged circumventing of l
HP personnel access requiremente. Since the concern referred to I
access requirement for personnel during plant operation, it was I
j determined that this reference pertained only to containment l
l entries. The investigation, therefore, centered on containment lR1 entries, practices, and governing procedures, both past and present. l to determine if indeed HP requirements had been detrimentally l
j alter 64 as a result of the referenced reorganization.
l J
j A review of several TVA forms 9880. Employee Status and 1
Information Record, for employees involved in the transfer of HP j
responsibilities from Muscle Shoals to the, Division of Nuclear j
Power identified June 1, 1982, as the effective date of transfer.
Interviews with several members of Sequoyah HP management revealed n
I that plant-level PORC-approved, instructions for Reactor Building l;
entry are contained in SQN AI-8, " Access to Containment." No specific HP instruction exists covering the same topic; however, certain hazards and/or conditions typically found inside the Reactor Building are addressed in several HP instructions.
A review of SQN-AI-8 (revision 17) and all of its prior revisions
]
(revision 0 first approved January 26, 1977) revealed no i
significant changes in entry limitations or requirements during or j
after the transfer of authority in question.
a 1
1
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K 11 l
Page 7 of 36
Revision 1 Interviews with several members of Sequoyah HP management indicated specific guidelines for Reactor Building entry had not been changed to any great extent during the past 4 years with the possible exception that past practice had been to lower reactor level to approximately 30 percent of full reactor power before entry. Radiation surveys taken at 10 percent and 100 percent r
indicated no significant increase in man-rem if the scope of work was limited.
Based on these findings, subsequent necessary entries have been made at power levels greater than 50-percent power. No plant instructions could be found supporting either the 30-percent or the greater-than-50-percent guidelines.
3.
Concern 11-85-084-001 was previously investigated by NSRS Report I-85-806-SQN.
Findings of the NSRS report are as follows:
(Designations for individuals have been extracted directly from the NSRS report.)
I A.
Based upon interviews with Public Safety Officers (individuals B, C, D, E, and F), no information was obtained that HPs failed to properly respond to radiation alarms (portal monitors, hand / foot monitors, or friskers).
B.
Individuals B, C D, and E stated that they had observed an 4
RN-14 frisker alarming at the 690-foot elevation containment air lock because of noble gases or other causes of high background. At one time, the frisker had read as high as 5,000 dps. When the HP arrived and confirmed the radiation level, the public safety officer post and frisker would normally be moved to an area of lower background. When the radiation levels were not confirmed, the frisker was replaced i
if it continued to alarm, i
j C.
Individuals B C, D, E, and F stated that the hand / foot monitors at the 690-foot elevation necess point from the Turbine Building to the Auxiliary Building frequently went i
off. Both the hand / foot monitors and the portal monitor would i
alarm because of high background from trash, tools, or laundry l
in the area. The HPs would respond to these alarms and move
{
the material causing the high background away from the monitors. These individuals could not recall any cases where l
l the monitors were unplugged or turned off when alarming to true radiation levels; if one hand / foot monitor was unplugged or turned off because of instrument malfunction, the adjacent j
hand / foot monitor comained operative.
1 D.
Individuals B, C. D, E, and F could recall no instances where i
the hand / foot monitor or portal monitor from the refuel floor to the Control Building had been turned off or unplugged when alarming to a confirmed radiation level.
Page 8 of 36
Revision 1 E.
Individuals B, C D, E. F, and G could recall no instances when both the hand / foot monitor and the portal monitor were out of service and a frisker was not then used to check for personnel contamination. No instances were recalled when the exit from the regulated area was left unmonitored.
F.
Individual H stated that entries into the Containment Building during plant operation allowed the transfer of small amounts of noble gas through the airlock. With the sensitivity of the RN-14 frisker to very small increases in background, the noble gases would frequently cause the frisker to alarm, thus requiring the relocation of the frisker station.
G.
No one interviewed stated that HP had zeroed their pocket chambers without recording the dose. However, an HP technician from the time period of concern (individual A) stated that on occasion he had zeroed a pocket chamber without recording the dose in the presence of the individual. Based I
upon the work an HP was doing when requested to read and zero a pocket chamber, past practices had included an occasional l
delay in recording the information.
Reading the dose and recognizing the individual would allow the HP to defer recording this information (SSN information was available in the HP laboratory). However, the current requirements of DSILs (reference 8) make this practice unlikely in that more information, including pocket chamber serial number, is now required to be recorded. Regardless of any delays in recording pocket chamber dose or failure to record that dose, the official record of exposure would be unaffected since it is based upon thermoluminescent dosimetry (TLD).
Conclusions of the report are stated below, as well as the results of the document search.
Concern XX-85-084-001 was not validated. Based upon the IR1 statements of the CI, the concern involved multiple events that l
would have represented general HP practices that should have been readily observed by other individuals. However, NSRS could find no evidence from the randomly selected individuals interviewed that such practices existed.
A review of applicable documentation supports the findings of the NSRS report I-85-806-SQN.
It was noted that Area Plan 3 l
(references 2 and 3 of the NSRS report) has been cancelled and i
superseded by the Radiation Protection Plan. Since all copies of l
the Area Plan (Radiation Protection Manual, Area Plan 3) were l
returned to the Distribution Center Clerk LP 45164 D-C it was l
not available for review; however, this did not affect the NSRS l
findings and conclusions.
i j
Page 9 of 36 i
Revision 1 4.
Concern XX-85-066-001 was previously investigated by Sequoyah line management in report XX-85-066-001 (reference 27), and involved the perception by the CI that because HP did not respond immediately to radiation alarms or unknown situations, the radiological safety of plant personnel could be compromised.
The Sequoyah Line kesponse report was reviewed for adequacy and determined to fully address the scope of the concern. Therefore, no follow-up was determined to be necessary.
Findings of the line report are as follows:
r A.
Sequoyah hts not experienced abnormal radiation levels during periods of operation.
8.
The only event that resulted in unanticipated radiation levels in the Reactor Building was the thimble tube ejection in April 1984. HP was present at the beginning of the event and maintained control throughout the recovery process.
C.
Follow-up conversations with Quality Technology Corporation (QTC) regarding additional information yielded only that unit I was operational and the alarm was in upper containment. No specific dates or persons contacted could be provided.
D.
HP supervisors cannot recall any instance that would coincide with the employee concern.
S.
Concern 11-85-009-002 was previously investigated by NSRS (reference 51). It should be noted that the NSRS report also addresses concern 11-85-009-001. II-85-009-001 was a concern which was retracted'by QTC when the CI indicated it contained inaccurate information as worded. The concern was reworded and reissued as IK-85-009-002. The concern involves an allegation by I
the CI that " hot" (high radiation area) work was assigned to older I
employees first, as directed by plant management. The NSRS investigation and review of radiation exposure records found no evidence that older individuals working at Sequoyah had received disproportionately high levels of exposure when compared to other i
workers in their sections or organizations. The NSRS report was reviewed and determined to fully address the scope of the concern; therefore, it was determined that no additional investigative action or follow-ups were required. The NSRS findings are stated as follows:
Page 10 of 36 i
i.
Revision 1 A.
A review of radiation exposure records of 179 craft workers and foremen assigned to Sequoyah during the period from October 1979 to March 1981 revealed that none of them had received a dose which would have prevented or restricted their work in regulated areas. A review of doses for subsequent periods for these same individuals indicated that one individual had received a quarterly exposure above the i
currently imposed 70-percent administrative limit, thus influencing the work assignments made by the supervisor but not limiting the employment of the individual.
I B.
Sequoyah exposure records were reviewed for the period of January 1980 to June 1985 to determine if any personnel had exceeded 70 percent of either quarterly limits or annual limits. Thirty-six individuals exceeded a quarterly dose of 2.1 ran or an annual dose of 2.8 rem. Of the 20 TVA lR1 employees, 10 were craft engineers / technicians and 10 were craft personnel. Of the 10 craft personnel, 6 were currently employed et Sequoyah. A comparison of the employment records and exposure records of the other 4 individcals who had i
exceeded the 70-percent administrative limit revealed the following:
1.
One craft employee exceeded 70 percent of his quarterly lR1 exposure limit in the period January through March 1984.
He was terminated at the end of his temporary appointment on April 13, 1984--into the next quarter for exposure i
limits. There was no indication that the employee's termination was affected by his exposure at Sequoyah.
2.
Another craft employee exceeded 90 percent of his annual lR1 limit in 1983. However, his temporary appointment at Sequoyah was terminated in February 1983, with a first quarter dose at Sequoyah less than 70 percent of the quarterly limit. There was no indication that the i
l employee's termination was affected by his exposure lR1 at Sequoyah.
l 3.
A third employee exceeded 90 percent of his annual limit lR1 l
in 1984 and resigned at Sequoyah to accept other employment. The employee had been previously employed in 1984 at Browns Ferry Nuclear Plant (BFN) and subsequently returned to BFN during 1984. He remained a TVA employee into the second calendar quarter of 1985.
Almost all of his 1984 dose was received at BFN. There
[
was no indication that this employee's resignation from l
Sequoyah was affected by his radiation exposure.
Page 11 of 36 l
Revision 1 4.
A fourth craft employee exceeded 90 percent of his annual lR1 limit in 1983 and resigned at Sequoyah to accept other employment. The employee left Sequoyah during the first quarter of 1983 and had received less than 70 percent of the quarterly dose at that time. Although the employee subsequently received radiation exposure in 1983, there was no indication that the employee's resignation was affected by his exposure.
C.
Based upon the exposure record of 179 craft personnel for the period October 1979 to March 1981, no pattern of selectIan of personnel for hot work based upon age was found in any of the craft sections.
D.
Based upon an interview with the first craft employee, plant lR1 management had discussed, in the 1979-1980 time period, options that could be taken if employees approached the quarterly or annual dose limits established by RCI-1.
No information was received from the employee or the craft supervisor (the seccad lR1 craft employee) of that timeframe that any direction was l
provided to preferentially expose older workers.
I E.
The supervisor who was alleged to have made the statement that
" older folks won't be long around" is no longer a TVA employee, could not be located from his last known address, and thus could not be interviewed.
F.
An individual who was craft foreman from the 1980 time period lR1 was unaware of any " management direction" regarding the assignment of personnel to " hot work" based upon age.
Conclusions from the NSRS report are as follows:
Concern (11-85-009-002) was not validated. NSRS could find no lR1 i
objective evidence that Sequoyah management told supervisors in the 1980 timeframe to assign older personnel to work in high radiation areas (" hot work"). There is no evidence that older personnel were preferentially assigned " hot work."
During the period in question, no individual received a dose high enough to require any consideratinn of work restrictions, even using the more conservative TVA policy exposure limits.
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Page 12 of 36 t
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Revision 1 6.
Concerns WI-85-038-001 and XX-85-015-001 raise questions about IR1 personnel exposure to neutron radiation during containment entries, specifically lower containment, while the reactor is at power (critical). Concern XX-85-015-001 was previously investigated at Sequoyah in a Sequoyah Line Response report (reference No. 54).
lR1 Concern WI-85-038-001 is an identical restatement of XX-85-015-001 except that it is directed at Watts Bar. A review of the two concerns and the Sequoyah Line Response resulted in the determination that the line response adequately addresses both IR1 concerns; therefore, both concerns are addressed as a single l
concern.
l Findings from the Sequoyah Line Response are as follows:
A.
Maximum neutron dose (aren) for an individual was 190 and 210 in 1983 and 1984, respectively.
B.
Maximum gamma dose (aren) for an individual was 3.110 and 3,360 in 1983 and 1984, respectively.
C.
Average neutron dose (aren) was 21 and 24 in 1983 and 1984, respectively, as comp 6 rod with average gamma dose (aren) of 259 and 451.
D.
Neutron dose is typically a factor of 10 less than gamma dose.
E.
Quality factor (factor used to convert an exposure to radiation into dose to humans) of 10 for neutrons is accepted by all scientific and rulemaking bodies.
.F.
Some recent literature publications suggest that quality factor be increased by about a factor of 2.
G.
Nearly all utilities enter containment for repales and maintenance at power.
j H.
Entry into containment at power was not the direct cause of the thimble tube ejection incident.
Conclusions from the report are summarized below:
A.
Even if quality factor increased by a factor of 5, the effect from neutrons would still be of less concern than gamma radiation.
B.
Entry into containment at power is acceptable from a dose standpoint.
Recommendations from the Sequoyah Line Response are as follows:
Sequoyah HP and Site Services Branch will continue to monitor quality factor discussions and recommend changes accordingly.
Page 13 of 36
_...J
Revision 1 This evaluation concurred with the findings of the Sequoyah Line Response report. A review of supporting documents justified the findings of the line response report, specifically in the area of neutron exposure quality factors.
It was found in one journal report of recent publication (reference 30) that quality factors for neutrons range from 3.43 to 13.4 depending upon neutron energies. It was also found.that a quality factor increase of a factor of 5, referened Sequoyah Line Response, based upon the 1983 and 1984 average neutron exposures reported, would not exceed the average gasuna exposures and that the total gamma component of the overall exposure would still be the most limiting criterion for lR1 exposure. It should also be noted that Sequoyah, as well as all TVA 4
nuclear facilities, use the quality factor required by 10 CFR 20.4(c)(3) in determining neutron dose.
1 I
A review of the NSRS report I-84-012-SQN (reference 31) did not indicate that the thimble tube ejection, the accident at Sequoyah
'.l referred to in the concerns, was a direct result of entry into j
containment while at power.
3
]
7.
Concern 11-85-026-001 alleges that Sequoyah HP receives inadequate j
upper management support in enforcing the radiological safety j
program. Also, the CI states that no disciplinary action is taken j
when employees intentionally bypassed monitors. The concern was j
previously evaluated at Sequoyah by line management in an Sequoyah Line Management Response report (reference 32). The repcet was reviewed for adequacy and determined to fully address tho scope of the concern.
f A follow-up interview was conducted to determine the status of the
[
reports corrective action recommendations.
?
Findings and recommendations of the line management report are
[
summarized below:
No actual incidents were identified in the investigation where IR1 1
employees did not receive disciplinary action for deliberately l
bypassing radiation monitors.
l Interviews with HP personnel and reviews of plant procedures and records did not indicate inadequate upper management support to enforce an effective radiological safety program. The plant ljj superintendent is immediately notified of all RIRs that have been L
designated as major by HP.
RIRs are then sent to the employee's supervisor for appropriate corrective action. Afterwards the 3
plant superintendent or designee reviews the action taken.
If he perceives the action to be inappropriate, he sends the RIR back to the supervisor for appropriate action.
l L
l Page 14 of 36 l
l
Revision 1
^
There were some instances where processing the RIRs took too long.
This is very ineffective when the employee is a temporery hire and has left by the time the RIR is processed. In some cases, the person initiating the RIR did not receive feedback as to the disposition of the RIR.
lR1 The recommendation from the report is that a summary of RIRs will be sent to all HP technicians for their information and those RIRs still active will be discussed with plant managers at the managers' meetings to ensure prompt action.
An interview was conducted with a supervisor in the HP Section to determine the status of the corrective action recommendation.
I Based upon the results of the interview, it was determined that i
the corrective action has not yet been implemented. The HP representative stated that summaries of RIRs were not distributed to HP technicians nor were they currently being discussed in plant managers meetings. The individual also stated that a procedure 4
revision will be implemented that will specify disciplinary actions to be taken with a RIR.
8.
Concern II-t'a-063-001 involves the perception by the CI that HP and Operations personnel may fall to know and verify system contents before authorizing the breaching of the system. The concern was previously investigated by NSRS (reference 52). A review of the investigation and report determined that the scope l-of the concern was fully addressed by NSRS and that further evaluation was unnecessary.
I Findings of the NSRS report are as follows:
I (Designations for individuals have been extracted directly from the NSRS report.)
L A.
Modifications personnel (individuals A and B) and HP personnel F
(individuals C and D) provided suggestions that any contamination in the Turbine Building, elevation 662.5 (under I
the condenser), would probably have been from work in the steam generator blowdown (SGBD) system. However, individual B 1
could find no record of any unit 2 blowdown lines that had L
been breached with water in them during the months noted in
{
the employee concern.
L l
B.
Individual E stated that work had been done on the SGBD system (time period not remembered) involving the installation of two 4-inch valves which had required the draining of the l
associated piping up to a boundary valve.
L F
He stated that there had been some leakage past the boundary l
valve and that the area had been roped off as a contamination zone as a precaution.
Page 15 of 36 L
i__,_-
Revision 1 13.
Individual E stated that when the SGBD system was cut into on the 685-feet level (adjacent to the flash tank), the workers had been dressed out as a precautionary measure. Once HP had-surveyed the inside of the pipe, the area wss declared clean and protective clothing requirements were removed.
D.
Based on HP surveys of the Turbine Building, elevation 662.5, unit 2 the only contamination area identified during the January-February 1984 period was on the SGBD pumps.
RWP 02-2-00925 timesheets 0001 and 0002 indicated general cleanup / decontamination of these areas at a time before 1400 on two days. This contamination area did not coincide with the concern of record because:
1.
These contamination areas were not established coincident with any work on the nearby SGBD piping.
i 2.
The timing of the decontamination on the RWPs was such that the CI would not have observed the decontamination process when he reported to work the "next night."
E.
Surveys of the unit 2 Turbine Building area during the January-February 1984 period showed that some areas around the SGBD system had been zoned as a regulated area because of radioactive material in the piping system as a result of primary-to-secondary leaks.
F.
Two modifications to the SGBD system in the 1983-1984 period were identified by RWPs in which radioactive /potentially i
radioactive piping was breached. However, as detailed below, neither of the cases fit the description provided by the CI.
1.
Work Plan 10476 required the draining and flushing of the steam generator blowdown lines to accomplish the tie-in of 4-inch lines. Although the work was performed in September 1983, details were compared with the event described by the CI to provide an indication of how HP imposed protective requirements and general practices. In this work, the following sequence occurred:
a.
The drain valve on each SGBD pump was used as a sample point before draining. A lab coat, gloves, booties and shoe covers, and surgeon's cap were required.
Page 16 of 36 l
9 Revision 1 b.
HP coverage was required when draining the system.
Based upon the survey referenced in the RWP, the drain and flush operation was conducted in the immediate area of the SGBD pumps. The area around the SGBD pumps had previously been zoned as contaminated.
Coveralls, taped gloves, taped booties and shoe covers, and a surgeon's cap were required.
c.
No evidence was found that the draining operation increased the level of contamination in the work area.
d.
The SGBD piping was subsequently cut, welding in 4-inch lines and associated valves. Protective requirements included coveralls, plastic suit, gloves, booties and overshoes, canvas hood, and full _ face mask. The plastic suit, hood, and facemask were required only while bretching the system.
2.
WP 11021 cut into tho SGBD system piping on the 685-feat level. This work was done in August of 1984. The following sequence indicates HP practices in that timeframe, a.
Special instructions required continuous HP coverage and a requirement to contain all water, b.
Protective requirements included continuous HP coverage and a requirement to contain all water.
G.
Modifications personnel (individuals A, B. E, and F) had no negative statements about the adequacy of HP personnel knowledge of plant systems.
Individuals A, E, and F stated that the HP technicians establish conservative protective requirements; at times, they believed excessive protection was required.
H.
A Modifications supervisor (individual A) stated that he considered Modifications personnel responsible for determining the contamination sample points before breaching a system and for understanding what contamination may be in the system and the potential leakage paths. He considered HP to be responsible only for performing surveys and setting protective requirements.
4 I
l Page 17 of 36 J
i Revision 1 An HP supervisor (individual G) considered HP personnel responsible for identifying potential contamination problem areas. Neither modifications nor HP personnel considered Operations personnel responsible for informing craft personnel of the contents of a system before breaching that system.
Conclusions of the NSRS report are stated below:
Concern XX-85-063-001 was not validated. No evidence was found lR1 that an event occurred as described by the CI.
Potentially contaminated systems in the Turbine Building had been breached on other occasions leading to scenarios similar to that described by the CI.
In these cases, the HP personnel treated these systems as potentially contaminated conducting surveys, and requiring i
protective clothing until the areas were declared clean. No evidence was found to corroborate the opinion that Operations and HP personnel do not provide adequate information or verify system contents.
9.
Concerns KK-85-028-X02 and 1X-85-028-103 rolate to the CI's l
perception that RWPs are not maintained in accordance with I
procedures and RWP timesheets contain falsified signatures.
lR1 A similar concern, II-85-028-001, was evaluated in the l
Operations CEG report 311.03-SQN. This report contains an i
evaluation of a QTC report regarding RWP timesheets and is considered pertinent to this report. The concerns were previously evaluated in NSRS report I-85-514-SQN.
The findings and recommendations of the NSRS report are summarized as follows:
I-85-514-SQN Revision to HPSIL-7 to Define Worker Signature Transfer Requirements The RWPs provide a unique opportunity for incorrect entries which may not be discovered until after the worker is no longer available to correct his docamentation. Although the NQAN and AI-7 provide overall guidance cn the correction of quality assurance records, HPSIL-7 provides no additional guidance on correction of RWP entries. Corrections have been made to the RWPs without any traceability to the original documentation. Thus, it j
cannot be conclusively demonstrated that the employees had made the data entries as required by HPSIL-7.
Page 18 of 36
,y
Revision 1 Recommendation
- HPSIL-7 should be revised to clearly define the requirements for transcription of information between RWPs I-85-514-SQN Traceability for Transcribed RWPs 02-2-00214 and lR1 02-2-00250 l
RWP 02-2-00214 Timesheet 0002 (1984), and RWP 02-2-00250 Timesheet 0030 (1934), sign-in sheets were transcribed without traceability to the original sign-in sheets.
Recommendation The Quality Assurance records for RWPs 02-2-00214 Timesheet 0002, 02-2-00250, and Timesheet 0030 should be supplemented with information providing traceability to the original worter sign-in sheets.
I-85-514-SQN-03 RWP Changes to Reflect Current Airborne radiological Information The need to transcribe data to a new timesheet due to " piggy backed" air data is indicative of programmatic problems with the RWP Timesheets. The Sequoyah HP-proposed changes to the RWP and RWP Timesheet should resolve the problem of individuals making entries on the timesheet for days beyond those covered by the airborne data.
Recommendation No action required beyond incorporation of the proposed changes to the RWP and RWP timesheet.
The Sequoyah line management response to the NSRS report (reference memorandum from Abercrombie to Whitt, dated January 16, 1986) is as follows:
Sequoyah Nuclear Plant Response to I-85-514-SON-01 Health Physics Section Instruction Letter (HPSIL)-7 will be revised to clearly define the requirements for transcription of information between RWPs. The revision will be completed by February 28, 1986.
4 RWP Timesheets 02-2-0214 Timesheet 0002, 02-2-0250, and Timesheet 0030 were reviewed to determine whether or not the recommended supplements had been made according to the NSRS recommendation. These timesheets were determined not to have been supplemented with the appropriate information as recommended by NSRS.
Page 19 of 36
Revision 1 A review of HPSIL-7 was conducted to determine whether the recommended revision to the section instruction letter had been affected.
It was found that ASIL-4 was revised to meet the recommendations of NSRS report I-85-514-SQN instead of HPSIL-7 lR1 as it was determined by Sequoyah HP that the revision was more l
appropriate there. This revision addresses the methodology for providing transcription copies of HP records.
An interview was conducted with an individual from HP to ascertain whether or not the revision to ASIL-4 addressed the handling of RWP timesheets. The revision has addressed the problem of transcriptions. Revisions to the RWP program have resulted in a decreased frequency of timesheet revisions.
In addition, report 311.03-SQN identified QA record deficiencies lR1 in Sequoyah RWP timesheets and identified a need for appropriate l
corrective action. These findings are applicable to this report.
I 10.
Concern 11-85-098-002 questions the frequency of radiological surveys and implies that they are not conducted often enough.
This concern was evaluated previously in NSRS report I-85-615-SQN (reference 33). A review of the NSRS report and applicable regulations, procedures and documents was conducted to verify the adequacy of the NSRS report which'was found to fully address the scope of the concern. The NSRS findings are as follows:
A.
The frequency of surveys required by Radiologice.1 Control Instruction RCI-1.Section I (reference 7), was found to satisfy the requirements and commitments. RCI I states:
Surveys shall be performed on a routine basis to assess radiation exposure rates, contamination, and airborne radioactivity levels. Additional surveys shall be performed whenever required by plant conditions or work requirements to ascure the protection of personnel and to monitor plant conditions.
B.
The specific frequency of radiological surveys required in areas with an active Radiation Work Permit (RWP) is established in RCI-14 (reference 8) and was found to meet the requirements of RCI-1.
RCI-14.Section III, requires that:
Periodic radiological surveys will be performed in all areas covered by an active RWP. The survey period will vary, depending upon radiological conditions, but will not exceed seven days....
Page 20 of 36 4
,__.,,._,.-,n--
Revision 1 Provisions are made for more frequent surveys if system changes occur to change the radiation dose rate.
If the job location is in an area where significant changes in dose rate are likely to occur, a radiological survey should be performed just before the start of work.
C.
The RPN requirement that a person should not unnecessarily expose himself to radiation while performing radiation surveys 1.e., maintain exposure of HP technicians as low as reasonably achievable (ALARA) has been satisfied by an exception in RCI-14 that:
At the discretion of the plant health physicist or his assistant, the survey period may be extended for ALARA
. purposes, in increments of 7 days, by making the extension in writing to the responsible shift supervisers.
Additionally, according to HPSIL-7 (reference 9), routine surveys (a survey once every seven days) may be deleted for an individual area if an RWP is not in effect in the particular area or if radiation levels exceed 1000 millirem per hour and no work is ccheduled in that area. Thus, radiation exposure of health physics personnel will be maintained ALARA if no surveys are required to support ongoing work.
l D.
For many areas of the plant which are routinely accessible, surveys are documented on proprinted survey sheets which establish the weekly survey routine to ensure that a survey is conducted once every seven days.
E.
Surveys are scheduled on these proprinted sheets for specific shifts throughout the week. A review of these proprinted sheets found that numerous areas outside the regulated area (i.e., the cafeteria and hallway by the electrical shop) were surveyed more frequently than once a week to check for the presence of transferable contamination.
F.
Routine surveys of the Containment Building and various rooms in the Auxiliary Building are scheduled based upon work planned during operation or for a particular outage. A survey status list and/or a monthly schedule of routine surveys are maintained at the HP lab / control point to ensure that the frequency of surveys meet the requirements of RCI-14. A l
review of the monthly schedule at unit 1 containment control point (marked-up calendar) indicated that containaent surveys were currently being conducted on a five-day schedule.
Page 21 of 36
Revision 1 G.
Surveys for the Auxiliary and Containment Buildings were reviewed for the period of July through September 1985. The frequency of radiation surveys of 15 locations for the duration of this period indicated that these locations had received a routine survey on a seven-day schedule.
H.
RWP timesheets from 1984 demonstrated that surveys had been conducted on at least a seven-day schedule in accordance with RCI-14.
Because of the nature of the work, one of the timesheets had radioactivity / contamination surveys performed on five days in an eight-day period.
I.
Based on interviews with individuals C and D (designated by NSRS report), few personnel (less than 25 percent) review the survey sheets at this time in the outage (two to three months into the outage) before entry into containment on an RWP.
Personnel were observed at the control points for unit 1 for a I
period during which approximately 20sindividuals processed through the centrol point, with none reviewing surveys. A check of the associated RWP timesheets showed that these individuals had previously worked in containment on those timesheets. Individual D stated that when an RWP timesheet is first opened, all radiation hazards are discussed by the HP with the associated foreman, using the survey map. The HP at the control point reiterates this information when the work crew enters the RWP for the first time. Additional instructions to workers on subsequent entries are provided to j
the workers only on a case-by-case basis. A control point HP Tochtician (individual C) was observed giving instructions to workers on special dosimetry requirements on a reentry on one job because of the nature of the work on reactor coolant pumps. Radiation i
levels were not reiterated to these individuals since it was unchanged from their last entry.
Conclusions of the report are as follows:
l Concern IX-85-098-002 was not validated. The frequency of IR1 j
radiation surveys, with the flexibility to have more surveys l
when changes in radiation levels are anticipated, was judged to adequately meet the requirements.
After a review of site procedures, it was determined that the conclusions are valid.
I i
l I
Page 22 of 36 t.
i.
9 Revision 1 11.
Concern I-86-232-SQN consists of a request to implement a procedure encompassing all aspects of possible emergency situations in a C-Zone.
No previous investigations of this concern have been conducted. The evaluation of this concern consisted of a review of current HP procedures governing radiological safety in contaminated areas and Sequoyah emergency procedures, policies and guidelines to determine the adequacy of each to mitigate C-Zone emergency situations. The following general programmatic areas were examined:
A.
Training of plant employees in their responsibilities during emergencies B.
Scope of responsibilities for different classifications of employees.
C.
Training of those employees permitted access to radiologically controlled areas.
I An interview with a supervisor identified plant instructions (listed in the reference section) issued to provide guidance to employees in the event of situations described in the concern. The supervisor explained how plant practice is to provide intensive training to those selected groups of employees who will be responsible for handling specific problems such as fire, medical, or the release of radioactive material. Nonspecific training is provided to the general plant staff.
and is designed to explain the responsibilities. The employee has to identify and report the emergency and then to evacuate the area while the selected groups handle the situation.
An interview with technicians and operations personnel reiterated the safety supervisor's position that specific groups such as Operations i
and Radiological Control are responsible for handling emergencies dealing with fires and injuries in contaminated areas. Other plant employees are expected to report such event and then evacuate the area.
An interview with a supervisor identified those GET courses provided to all plant employees that explain each employee's responsibility. The supervisor also identified specialized courses provided to employees who frequent the plant's radioactively contaminated areas.
These specialized courses-provide additional information concerning how the employee should react to fire and/or medical situations when radioactive materials are involved.
Page 23 of 36 1
m
Revision 1 Attendance of the GET class on Fire Protection (GET-7) verified that objectives as listed in the training plan (SGET-GET-7) were covered during video presentation and by classroom discussion.
The Standard Practice (SQS-25) provides guidance in how to select a protective breathing apparatus, how to use the plant Hazard Control Manual (SGA-181, SQS-7 and SQS-21) and how to recover from a spill of radioactively contaminated liquid (SQA-131).
The Hazard Control Instructions (HCIs) deals with general responsibilities of supervisors (G-2) and employees (G-3).
Additional HCIs cover specific problems such as fire and medical emergencies (G-15 G-21, and G-23), the release of plant gases (NN-20) and respiratory protection (PPE-20).
Abnorac1 Operating Instructions (AOIs) provides guidance for fires (AOI-30), abnormal releases of radioactive material (AOI-31) and chlorine releases (AOI-33).
l Site Radiological Emergency Plan and its Implementing Procedures Document (SQN-REP and SQN-IPPs) cover medical emergencies (IPD-10), and HP practices (IPD-14).
1,
?
Site Physical Security Instruction (PHSI-13) provides for the correct response to plant fires.
A site Employee) Handbook is given to each employee and provides a brief overview of safety, security, and personnel procedures and steps.
NRC Inspection Reports 50-327/85-07 and 50-328/85-07 reviewed lR1 TVA's actions during the radiological emergency preparedness drill held at Sequoyah between February 5 and February 7, 1985. No violations or deviations were identified.
1 General and Specific Training Plans (GET-7, GET-3.1, HP Level 0, I, and II) are designed to inform employees of their responsibilities and available procedures.
12.
Concern JLH-86-003 raises concerns about the location of fristers with regard to their proximity to contaminated area exits. This concern has not been previcusly investigated. The evaluation i
described in this report consisted of the review of applicable regulations and procedures, interviews with HP technicians and training supervisors, and field walkdowns to verify placement of friskers.
Page 24 of 36 i
Revision 1 Sequoyah Nuclear Plant, RCI-1, revision 30, " Radiological Program,"Section III, paragraph E, states that " frisking stations are located throughout the regulated area. These friskers are to be used when personnel contamination is suspected, and upon leaving a C-Zone."
In addition HPSIL-10, revision 8. " Personnel Decontamination and Confiscation of Contaminated Articles," states l
Personnel should frisk immediately after or as soon as practical upon exiting a C-Zone. Background readings can not exceed 200 dps, in accordance with RCI-1, and this means that there will be instances when a frisker will be a distance from the zone.
Because of this, it is possible that contamination could be tracked to a frisker.
Current HP procedures account for the possibility of spreading i
contamination on the way to a frisker. RCI-1 states.a person should contact HP immediately if contamination is detected, and stay there. An HP technician will respond to the location for J
assistance. The technician will also survey the pathway the employee took and any items they may have touched, such as phone, frisker probe, or door knob. If contamination is determined to have been spread, the area and items will be decontaminated immediately, if possible, or zoned off until it can be deconned.
Instructors for Sequoyah's GET inform personnel that a frisker will not always be readily available because of reasons such as background being excessively high.
The example was substantiated concerning the fact that exiting j
elevation 690 and 669 pipe chases requires passing through closed l
doors; however, an independent survey revealed that background
-levels in both pipe chases exceeded 200 dpa, therefore a frisker had to be placed elsewhere. On elevation 669, the frisker had been removed from the frisking booth near the elevator because of high background and placed near the
'A' holdup tank room.
Consequently, personnel may not have been aware it had been moved and would have had to look for the frisker.
13.
JNA-85-001 expresses a concern that in the event of a radiation or evacuation alarm or notice, the operator in charge of an Auxiliary lR1 Building Secondary Containment Enclosure (ABSCE) type breach may l
1 eave the area without sealing the breach. This concern was evaluated by a review of the governing procedures and interviews l
with Sequoyah Operations Section personnel. Sequoyah Technical Instruction 77 (TI-77) establishes the responsibilities and IR1 procedures governing the breaching of the ABSCE. Section 4.2.1 (note) on breaches requires an Unresolved Safety Question Determination (USQD) evaluation of the ability to isolate the breach within 4 minutes of receiving an Auxiliary Building Isolation (ABI) or high radiation signal. TI-77 requirements were confirmed in an interview with the Sequoyah Operations Supervisor who further stated that operators are instructed in this and are knowledgeable of their responsibility to seal any ABSCE type breaches before evacuating or leaving the area.
l i
Page 25 of 36 l
- ~
~-
Revision 1 14.
Concern RII-85-A-0064 raises 6 items of concern.
lR1 With the exception of one item, which involved charges of lR1 intimidation and harassment and was referred to the Office of I
the Inspector General, the items were evaluated as follows:
A.
IVA Lacks Ability to Run an HP Operation lR1 The evaluation included the review of NRC, INPO, TVA-QAB, and American Nuclear Insurers (ANI) audits / evaluations of the lR1 i
Sequoyah HP program from 1984 to the present. Applicable Section Instructions and Radiological Control Instructions a
were reviewed and implementation of the instructions i
observed. Program documentation was reviewed and randomly verified by field walkdowns. Interviewed personnel included I :
both HP technician and supervisory personnel.
The 1985 NRC-SALP Report gave radiological control at SQN a j
2 rating. The 1984 SALP Report gave Sequoyah radiological controls a 1 rating. These ratings indicate a " satisfactory I
performance" (2 rating) to a "high level of performance" j
(1 rating). Since 1984, Sequoyah HP has had only one Severity Level III NRC violation (however, no civil penalty was involved and the violation involved a radiation waste shipment, not radiological protection). During this period, there were eight NRC inspections, and Sequoyah HP had elSht Level IV and two Level V violations. The 1984 INPO evaluation i
listed three findings in the radiation protection area. The k
1985 INPO evaluation identified three findings and one Good i
Practice. Five QAB audits were conducted during 1984 and j
1985. A total of nine deviations were identified in the QAB l
Audit Reports.
The HP program at Sequoyah is currently under the direction of it
)
the Superintendent, Radiological Controls. This position was
]
created in 1986 and reports directly to the Plant Manager.
1 The Superintendent, Radiological Controls is designated as the i
" Radiation Protection Manager" (RPM) as defined by NRC in
)
The individual in this position meets the qualification criteria for the position of RPM according 4
~
B.
Unreported Loss of Radioactive Source IR1 L
HP SIL-11. " Leak Testing of Radioactive Sources," provides the guidelines for source inventory and control.
Sources are lI routinely inventoried on a weekly basis.
In addition, these I
sources must be signed for by qualified personnel before and l
after use. Interviews with HP technicians from different shifts demonstrated the procedure Page 26 of 36 L
I-l L4
Revision 1 was understood. None of the technicians could recall any instance of a lost or missing source. An independent survey of the source locker verified that all sources were accountable. Random source inventories from 1985 and early 1986 were reviewed with no discrepancies being found.
C.
Radiation Monitors Not Located According to ASIL-3 lR1 HP ASIL-3, revision 10. " Orienting of Health Physics Technicians for Inplant Work at Sequoyah," contains attachment C-6, which is a listing of radiation monitors and their locations. This attachment is used by HP technician trainees as an aid in learning the location of these monitors.
Two HP technicians who had completed their Performance Verification Sheets within the last year stated that all monitors are in the locations listed in Attachment C-6.
They did say that some were difficult to locate because of their location, e.g., behind pipes, hangers. A random verification was performed by walkdown, and all monitors checked were in proper location according to attachment C-6.
l D & E.
Smears Thrown into Trash / Smear Counting Area Used as an Eating IR1 Area l
Both of these items deal with the handling of smears in the HP lab counting room. The evaluation of these items consisted of interviewing HP field operations personnel and examination of applicable HP procedures. The findings of this evaluation are as follows:
1.
Smears are handled and counted on a designated counter top in the counting room. This stea is posted as a regulated area; therefore, eating, drinking, and use of tobacco IRl products are not allowed in this area.
2.
The remainder of the count room and HP field facilities is not a regulated area; therefore, eating, drinking, and use of tobacco products are allowed in these areas.
3.
The HP lab, counting room, and regulated counter top are required to be routinely surveyed at least daily. Any contamination detected is required to be immediately deconned.
(
Reference:
SQN HP-SIL-4) 4.
After counting, all smears whether contaminated or not, are placed in a " contaminated material" designated container and never in the clean trash receptacles.
l l
l I
i l
Page 27 of 36 l
Revision 1 5.
HP technicians do not normally eat in the counting room even though it is not prohibited except on the regulsted area counter top.
F.
Air Samples Improperly Taken/ Respirators Not Worn in High lR1
(>10,000 dpm) Contamination Areas l
Interviews with HP trainees and training supervisors indicated that technicians are taught to avoid locating an air sampler on a contaminated surface since a possibility exists that the sampler might collect loose surface contamination. This could result in a higher calculated airborne activity that would not be truly representative of the airborne activity. This would-result in the recording of higher airborne radioactivity concentration levels on applicable survey forms and RWPs might lead to a requirement for respiratory protection. These measures would, however, be conservative and would not lead to ar increased risk to the workers. It is also understood by those interviewed that situations can develop where there may be no alternate location to place an air sampler in order to obtain a representative sample of workers breathing zone. In this case, technicians are instructed to exercise caution such that the air sample would not become contaminated because of loose surface contamination.
I i
Random observations of HP technicians pulling air semples l
revealed proper sempling practices. All those observed set up j
the air sampler as close to breathing zcne as possible, j
considering location of work and available equipment. All were knowledgable of their task.
NUREG 0041 establishes guidelines by which respirators should be utilized. It states " Personnel who are responsible for f
establishing... and maintaining respiratory protection programs must exercise sound judgment by providing and using engineering controls, where feasible, and by avoiding unwarranted use of respirators." RCI-14, revision 5, provides guidelines for use of protective clothing. Attachment 3 states that except for (1) breaching a radioactive or potentially radioactive system or (2) welding, grinding or burning a contaminated component, respiratory protection is not recommended until contamination levels exceed 10,000 dpm, or 10 times the level expressed in the concern.
HP, according to TVA RPP, does have authority to prescribe respiratory protective devices when deemed necessary.
A review of randomly selected RWPs was performed, and in the cases reviewed, the initiating technician of the RWP followed the guidelines set forth in RCI-14, attachment 3.
i Page 28 of 36
l Revision 1 G.
(Not applicable to this report)
H.
Air Sample Heads Not Covered Prior to or After Sampling lR1 This item expressed concern over HP technicians not covering the air sampler heads before and after taking air samples.
i lhe evaluation of this item consisted of an interview with a Sequoyah HP shift supervisor and review of HP procedures. HP technicians are taught to avoid cross-contamination of air sample filters; however, the means by which they accomplish this is up to their discretion. There are no requirements for covering air sampler heads before or after sampling.
It should be noted also that if an air sample filter should become cross-contaminated, the resulting air data would indicate higher airborne activity than that which actually existed resulting in more conservative protective measures 1
l being required than necessary and in no way compromising worker safety.
a Conclusion l
1.
SQP-86-009-001 - The concern was not validated. No evidence of personnel contamination as a result of poor management attitudes
?
toward radiological safety was found. Reviews of Sequoyah procedures indicated that the programs in place governing both i
internal and external personnel contamination control and safety adequately implement and comply with regulatory requirements.
l Personnel contamination is documented and investigated by way of l
RIRs. This evaluation did not identify any deficiencies in the l
Sequoyah personnel contamination control program. The concern does not affect the safe operation of the plant.
l 2.
SQP-86-009-002 - The concern was not validated. Examinations of I
applicable procedures and interviews with cognizant personnel l
indicated that changes made to contalement access procedures were l
made prior to the transfer of HP to the DNP and that those IR1 changes did not compromise the health and safety of workers.
l
[
The concern does not affect the safe operation of the plant.
I E
l 3.
11-85-084-001 - The concern was not validated. The NSRS l
investigation could find no evidence that HP personnel did not lR1 L
properly respond to radiation monitor alarms. This report concurs l
1 fully with the NSRS findings and conclusions. The concern does l
not affect the safe operation of the plant.
I L
i f-i l
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Page 29 of 36 l
1
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Revision 1 4.
XX-85-066-001 - The concern was not validated. This report concurs with the Sequoyah Line Management Report findings and conclusions that HP, or any other safety organization, responds to an alarm or unknown situation with deliberateness and caution to prevent possible hazard and ensure personnel safety. The concern does not affect the safe operation of the plant.
I 5.
11-85-009-002 - (XX-85-009-001) The concern was not validated.
NSRS found no evidence indicating that older persons are assigned to the " hottest" (high radiation) work. This report concurs with
(
the NSRS findings and conclusions. The concern does not affect 4
the safe operation of the plant.
J 6.
WI-85-038-001 and 11-85-015-001. These concerns were not j
validated. As stated in the Sequoyah line response report, "Even 1
if [the] quality factor increased by a factor of 5, the effect from_ neutrons would still be of less concern than gamma radiation." Therefore, the practice of entering containment while a
I at power for nonezargency repairs does not need to be reevaluated. The investigation documented in the Sequoyah line 1
report indicates compliance with 10 CFR 20 requirements regarding j
rieutron dose assessment. The policy of allowing "at power" i
containment entries had no direct bearing on the thimble tube ejection accident at Sequoyah. This report concurs with the Sequoyah line response. The concern does not affect the safe 1
]
operation of the plant.
7.
11-85-026-001 - The concern was not validated in that HP does receive adequate upper management support to enforce the 0
radiological safety program. No evidence was found by Sequoyah line management to support the allegation that employees who q
)
intentionally bypass monitors were not disciplined. Some needed j
improvements in the present RIR program were noted and corrective j
action recommended to upgrade the program. This report concurs fully with the Sequoyah line report. The concern does not affect the safe operation of the plant.
8.
11-85-063-001 - The concern was not validated. NSRS found no
[j evidence that the incident occurred as described by the CI or to j
corroborate the opinion that Operations and HP personnel do not 3
provide adequate information er verify system contents. This report concurs with the findings and conclusions of the NSRS report. The concern does not affect the safe operation of the plant.
u Page 30 of 36 L-
i i
L Revision 1 l
9.
XX-85-028-X02 and XX-85-028-X03 - Concern KX-85-028-X02 was found t
to be indeterminate and XX-85-028-X03 was validated. Both concerns were evaluated by NSRS in report I-85-514-SQN and were subsequently evaluated by QTC. NSRS subsequently referred this concern to the Office of General Counsel (OGC) for further investigation. OGC completed its evaluation and issued report OGC-86-021 on March 20, 1986.
HP committed to revise their procedures concernins transcription of QA records. The revision to ASIL-4 is considered to meet this commitment. A recommendation to clarify QA record requirements for RWP timesheets and enhance worker awareness of their responsibility to properly handle QA records was made by Operations CEG report 311.03-SQN, and appropriate corrective action is being considered at this time by SQN personnel.
Official dose records are derived from TLD data and not RWP timesheets; therefore, these concerns do not affect the safe operation of the plant.
10.
Concern 11-85-098-002 - The concern was not validated. NSRS findings verified that radiological surveys are carried out according to procedural requirements, are sufficient to maintain an adequate assessment of plant radiological conditions, and comply with regulations. This evaluation concurs with the findings and conclusions of the NSRS report. The concern does not affect the safe operation of the plant.
11.
I-86-238-SQN - The concern was not validated. The evaluation of the concern concludes that existing radiological protection procedures, emergency procedures, and personnel training programs
. address the handl'ing and mitigation of any potential C-Zone emergency situations. No programmatic deficiencies were found.
The concern does not affect the safe operation of the plant.
12.
JLH-86-003 - The concern was not validated. The review of applicable plant procedures, personnel training, and plant walkdowns indicated that an adequate number of friskers are placed throughout the plant in locations as convenient as possible to existing C-Zones with regard to background radiation requirements and that personnel training regarding knowing frisker locations, using friskers properly, and knowing what action to take when contamination is indicated is in ccapliance with regulatory and i
plant procedural requirements. No programmetic deficiencies were found. The concern does not affect the safe operation of the plant.
Page 31 of 36
Revision 1 13.
JNA-85-001 - The concern was not validated. SQN TI-77 adequately addresses the securing of ABSCE breaches and it was determined that Sequoyah operators are properly instructed and aware of their responsibilities regarding this. The concern does not affect the safe operation of the pinnt since it was not validated.
14.
RII-85-A-0064 - The concern was not validated. Kone of the I
deficiencies expressed in the concern were found to exist and IR1 the concern does not affect the safe operation of the plant.
l IV.
Root Cause The following concerns were not validated; therefore, no root cause evaluation was necessary.
1.
SQP-86-009-001 8.
11-85-026-001 l
2.
SQP-86-009-002 9.
11-85-063-001 l
3.
11-85-084-001 10.
11-85-098-002 4.
II-85-066-001 11.
I-86-238-SQN 5.
II-85-009-002 12.
JLH-86-003 6.
WI-85-038-001 13.
JMA-85-001 7.
11-85-015-001 14.
RII-85-A-0064 Concern 11-85-028-Z02 was indeterminate.
Concern I1-85-028-103: The root cause of the concern, as stated, is I
determined to be a programmatic deficiency in a plant procedure which lR1 has been corrected by the revision to ASIL-4.
.l Y.
Generic Applicability Concern 11-85-028-103 is considered generically applicable to all'other TVA Nuclear Plants that employ RWP timesheets because of the scope and nature of the programmatic deficiencies noted in the HP's QA records i
disposition and management system, l
l Concerns WI-85-03J-001 and 11-85-015-001 are generically applicable to l
both Watts Bar and Sequoyah but are not validated for either plant.
All other concerns evaluated in this report pertain to l
Sequoyah-specific incidents, were not validated, and are therefore I
not generically applicable to any other TVA facility. No evidence of IR1 similar incidents or situations existing at other TVA nuclear plants I
was found.
l I
Page 32 of 36 i
Revision 1 VI.
References 1.
Title 10 Code of Federal Regulations, Part 20 2.
Title 30 Code of Federal Regulations, Part 11 3.
U.S. NRC Regulatory Guide 8.8 - ALARA 4.
U.S. NRC Regulatory Guide 8.15 - Respiratory Protection 5.
NUREG 0041 - Manual of Respiratory Protection Against Airborne Radioactive Materials.
6.
TVA Code VIII, " Occupational Radiation Protection" 7.
TVA Radiation Protaction Program (RPP) 8.
Sequoyah Nuclear Plant Technical Specifications (STS) 9.
Sequoyah Nuclear Plant Final Safety Analysis Review (FSAR) 10.
U.S. NRC Regulatory Guide 1.8, Revision 1 11.
Sequoyah Nuclear Plant Technical Instruction 77 (TI)77, " Breaching the Shield Building, ABSCE, or Control Building Boundaries" 12.
Sequoyah Nuclear Plant Radiological Control Instructions
-(RCIs) 1-14 13.
Sequoyah Health Physics Section Instruction Letters (SILa),
HPSIL 1-37, ASIL 1-15, DSIL 1-24 14.
NRC Fifth Systematic Assessment of Licensee Performance (SALP) for March 1, 1984 through March 31, 1985 dated September 17, 1985 15.
NRC Fourth Systematic Assessment of Licensee Performance (SALP) for January 1, 1983 through February 29, 1984 16.
INPO Evaluation of Sequoyah Nuclear Plant - April 1985 17.
INPO Evaluation of Sequoyah Nuclear Plant - April 1984.
18.
NRC Inspection Reports, Sequoyah Health Physics Program a.
50-327/86-04, 50-328/86-04, 03/27/86 b.
50-327/85-20, 50-328/85-20, 06/20/85 c.
50-327/85-26, 50-328/85-26, 09/06/85 d.
50-327/84-34.
50-328/84-34, 11/21/84 e.
50-327/84-21,22 50-328/84-21.22 09/17/84 f.
50-327/84-14, 50-328/84-14, 07/27/84 g.
50-327/84-12, 50-328/84-12 03/29/84 h.
50-327/84-04, 50-328/84-04, 03/12/84 Page 33 of 36 j
l
Revision 1 19.
SQN-NRC-0IE Inspection Report Nos. 50-327/84-34 and 50-328/84 Response to Violations, Abercrombie to Hufham, dated January 9, 1985 (S53-841218-913) 20.
SQN-NRC-0IE Report 50-327/85-20 and 50-328/85-20, Response to Violations, Abercrombie to Hufham, dated July 15, 1985 (S53-850712-964) 21.
SQN-NRC-0IE Repcrt 50-327/85-26 and 50-328/85-26 Response to Violations Abercrombie to Hufham, dat.ed December 30, 1985 (S53-851230-981) 22.
SQN-NRC-0IE Report 50-327/86-04 and 50-328/86-04, Supplemental Response to Violations, Gridley (TVA) to Grace (NRC), date July 3, 1986 LL44-860703-800) 23.
QAB Audit Reports i
a.
QSS-A-85-0009 (L17-850308-801) b.
QSS-A-85-0010 (L17-850510-801 c.
QSS-A-850012 (L17-850905-800) d.
QSS-A-85-0016 (L17-860225-803) l e.
24.
NSRS report I-85-514-SQN " Radiation Work. Permits" dated December 27, 1985 25.
Memorandum from K. W. Whitt to W. T. Cottle, " Corrective Action l
Response Evaluation," dated January 30, 1986 i
26.
Memorandum O. L. There to M. A. Harrison, " Response to NSRS report I-85-514-SQN." dated February 3, 1986 27.
" Investigation / Evaluation of NSRS Referred Employee Concern' 4
j II-85-066-001," (S01-851205-982) 28.
"Sequoyah Nuclear Plant (SQN) - Request For Evaluation of,,.
3e Concern 11-85-066-001" (Sol 851025 870) 29.
Investigation / Evaluation of NSRS Referred Employee Concern II-85-015 "Sequoyah/ Personnel in Containment While Operating,"
i dated August 28, 1985 30.
Radiation Protection Dosimetry, " Kerma Equivalent Factor for I
Photons and Neutrons Up to 20 MeV." Volume 14, Number 4 f.
pp 289-298, (1986), Nuclear Technology Publishing 31.
"Sequoyah Nuclear Plant (SQN) - NSRS Investigation of Unit 1 Incore Instrumentation Thimble Tube Ejection Accident on April 19, 1984 - NSRS Report I-84-012-SQN," (LOD 840830 516) l l
[
L Page 34 of 36 i
L
1 Revision 1 32.
Investigation / Evaluation Report, " Employee Safety Concern - QTC Concern :
XX-85-026-001," dated February 4, 1986, (L61-860204-800) 33.
NSRS Report I-85-615-SQN, " Frequency of Radiation Surveys," dated December 10, 1985 34.
Sequoyah Nuclear Plant Engineering Section Instruction Letter ESSIL-C5, revision 0, "By product Material Radiation Sources" 35.
Health Physics Technician Training Lesson Plant HPT-LP-14 36.
Sequoyah Nuclear Plant Radiological Survey, Form TVA 17069, Survey Number 0-85-2247 37.
Sequoyah Nuclear Plant HP Shift Coordinators Shift Daily Journal i
(Log). December 12, 1985 entries i
38.
Title 10. Code of Federal Regulations, Part 50 39.
U.S. NRC Regulatory Guide 1.101 " Emergency Planning..."
40.
NUREG 0654, revision 1, " Criteria for Preparation and Evaluation i
of Radiological Emergency Responses..."
i 41.
Sequoyah Nuclear Plant Hazard Control Instructions 42.
Sequoyah Nuclear Plant Standard Practices Manual a.
SQA - 131 " Recovery From a Spill..."
b.
SQA - 181
" Hazardous Material Control" c.
SQS - 7
" Hazard Control Plan" d.
SQS - 21 "SQN Hazard Control Instruction Manual" e.
SQS - 25
" Breath Apparatus" f.
SQS - 41
" Emergency Medical Treatment..."
g.
SQS Employee Complaints Concerning Safety and Health" 43.
Sequoyah Nuclear Plant SOI-26.2 " Fire Interaction Manual,"
revision 3, dated June 30, 1986 44.
Sequoyah Nuclear Plant A0I-30 AOI-31, and A0I-33 45.
Sequoyah Nuclear Plant Administrative Instruction, AI-14 " Plant Training Program" 46.
Sequoyah Nuclear Plant Physical Security Instruction, PHYSI-13
" Fire" 47.
Sequoyah Nuclear Plant Ratiological Emergency Plan 48.
Memorandum NRC to TVA dated February 27, 1985 "SQN REP Exercise Evaluation," 50-327/85-07 and 50-328/85-07 (A02 850304 020)
Page 35 of 36 l
1 l
e m
w w-w e----m pw--w
Revision 1 49.
Sequoyah Nuclear Plant General Employee Training (GET) Lesson Plans a.
GET-2,1 "HP Level I" b.
GET-2.2 "HP Level II" c.
GET-2.4 "HP Level 0" d.
GET-3.1 " Security and Emergency Planc" e.
GET-7 " Fire Protection" 50.
Sequoyah Nuclear Plant Administrative Instruction AI-8, " Access to Containment," revision 17 51.
NSRS Report I-85-513-SQN*, " Radiation Exposure of Older Personnel " dated December 27, 1985 (Concern 11-85-009-001 and 11-85-009-002) 52.
NSRS Report I-85-513-SQN*, " Work Areas Contaminated / Lack of Knowledge of System Contents." (concern II-85-063-001) 53.
Sequoyah Nuclear Plant, REP, Imp 1tmenting Procedure. (IP)-15 54.
Memorandum from H. L. Abercrombie to W. H. Thompson dated September 9, 1985, Sol 850830 802 VII. Immediate or Long-Term Corrective Action 11-85-028-103: Pertinent Procedures ** have been revised to reflect I
the current status of determining / classifying RWP-timesheets as QA or lR1 non-QA; however, all RWP-timesheets are retained as lifetime records.
l 11-85-026-001 - Recommendation to distribute RIR summaries to HP staff l
has been incorporated (first communications mailed for review 9/10/86) l and will be issued each quarter. In the future the stammary sheet will be IR1 mailed to the Plant Manager as a possible agenda item for his weekly I
meeting.
l The Corrective actions for these two concerns are being tracked on CATD lR1 Number 31104-SQN-01.
l
- Both NSRS reports are transmitted under the same NSRS report number.
- Pertinent reports: AI-7 Rev 39, RCI-14 Rev 5. ASIL-4 Rev 11 HPSIL-7 Rev 15.
Page 36 of 36
-_.-.m.._.,.--.
m
- ERENCE
- ECPS120J-ECPS121C TENNESSEE VALLEY AUTHORITY PAGE
. 23!
IGUENCY
- REQUEST OFFICE OF NUCLEAR POWER RUN TIME - 12:19:
' - ISSS - RNM EMPLOYEE CONCERN PROGRAM SYSTEM CECPS)
RUN DATE - 10/03/
s LIST OF EMPLOYEE CONCERN INFORMATION l
EGORY: OP PLANT OPER. SUPPORT SUBCATEGORY: 31104 NP POLICY, PRACTICES AND MANAGEMENT CONTROL S
GENERIC KEYWORD A H
APPL QTC/NSRS P
KEYHORD B CONCERN SUB R PLT BB5W INVESTIGATION 5
CONCERN KEYWORD C NUMBER CAT CAT D LOC FLeB REPORT R
DESCRIPTION KEYNORD D y,36-238-54N OP 31104 N SQN NNNN NS AN ANONYMOUS INDIVIDUAL MAILED IN A K-FORM SAFETY CONCERN TO NSRS REGUESTING TH AT EMERGENCY PROCEDURES BE NRITTEN T O ENCOMPASS ALL ASPECTS OF POSSIBLE EMERGENCY SITUATIONS IN A C-ZONE.
P ROCEDURES SHOULD COVER SPECIFIC AREA S, SUCN AS: SPREAD OF CONTAMINATION
, POSSIBILITY OF INJURY, POSSIBILITY OF A FIRE, POSSIBILITY OF POOR BREA THING ATMOSPHERE, ETC.
JL}{-36-0 03 OP 31104 N SON NNYN PER TVA'S GET CLASS AND PLANT PROCED REPORT URES, EMPLOYEES ARE TO FRISK AS SOON AS EXITING A "C-ZONE *. CURRENTLY, AN EMPLOYEE HAS TO SEARCN FOR A FRIS KER. IN THE PROCESS OF LOOKING FOR A FRISKER, AN EMPLOYEE CAN CONTAMINA j
TE DOORS AND/OR THE FLOOR. DNE OF T i
VA'S OBJECTIVES IS TO KEEP DOWN CONT AMINATION, AND THE CURRENT PROCESS D OES NOT ADEGUATELY CONTROL THE SPREA DING OF CONTAMINATION.
JNA-85-001 OP 31104 N SQN NNYN SS A HIGH RISK POSSIBILITY OF NOT SECUR REPORT ING ABSCE TYPE BREACNES. IF A VALID HIGH RADIATION CONDITION OCCURRS IN THE AUX. BUILDING OR DURING AN ANNO UCED EVACUATION OR EVACUATION ALARM SOUNDED MAY CAUSE PERSON TO LEAVE AU X. BUILDING PRIOR TO SEALINO PENETRA 3
TION.
! fII-85-A-0064 OP 31104 N SQN NNNN NS THIS ALLEGATION EXPRESSED CONCERN AB K-FORM OUT THE SE000YAN HEALTM PHYSICS PK00 RAM. THE ESSENCES OF THE CONCERNS A l
RE PROVIDED BELON:1. TVA DOES NOT MA 3
VE THE ABILITY TO RUN AM NP OPERAtt0 i
~
N. 2. AN IRDIVIDUAL LOST A RADICACTI VE SOURCE AT THE SITE AND NEVER REPO RTED THE LOSS TO MANAGEMENT. 3. THE j
LOCATION OF RADIATION MONITORS ARE N OT AS INDICATED ON THE ASIL-3 PROCED URE. 4. SMEARS ARE TAKEN INTO THE HE ALTH PHYSICS OFFICE TO COUNT AND ARE THEN THRONN INTO THE TRASH. 5. THE SMEAR CC'JNTING AREA IN THE HP l
4
-w-m.
- - ~
a
3EFERENCE
- ECPS120J-ECPS121C TENNESSEE VALLEY AUTH"RITY PAGE 236 7REQUENCY
- REQUEST OFFICE OF NUCLEAR POWER RUN TIME - 12:19::
1NP - ISSS - RHM EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS)
RUN DATE - 10/03/l LIST OF EMPLOYEE CONCERN INFORMATION
?TEGORY: OP PLANT OPER. SUPPORT SUBCATEGORY: 31104 HP POLICY, PRACTICES AND MANAGEMENT CONTROL S
GENERIC KEYWORD A H
APPL QTC/NSRS P
KEYNORD B CONCERN SUB R PLT BBSH INVESTIGATION S
CONCERN KEYWORD C NUMBER CAT CAT D LOC FLQB REPORT -
R DESCRIPTION KEYNORD D sQP-86-009-001 OP 31104 N SQN NNNN NS AN INCIDENT AT SEQUOYAH, WHICH RESUL HEALTH PHYSICS T50273 K-FORM TED IN EMPLOYEES BEING RADI0 ACTIVELY SAFETY PROGRAM CONTAMINATED, COULD HAVE BEEN PREVE OPERATIONS NTED, AND REFLECTS MANAGEMENT'S ATTI RADIATION PROTCT TUDE T0HARD RADIATION SAFETY AND PER SONAL SAFETY OF THE EMPLOYEES.
DETA ILS KNOHN TO QTC, HITHHELD DUE TO CD NFIDENTIALITY. NO FURTHER INFORMATI ON MAY BE RELEASED. NUCLEAR POWER D EPARTMENT CONCERN.
@QP-86-009-002 OP 31104 N SQN THE TRANSFER OF RESPONSIBILITY FOR H HEALTH PHYSICS T50273 K-FORM EALTH PHYSICS FROM MUSCLE SHOALS TO SAFETY PROGRAM SEQUOYAH PLACES THE INDIVIDUAL RESPD OPERATIONS NSIBLE FOR HEALTH PHYSICS IN A POSIT RADIATION PROTCT ION HHERE MUCH PRESSURE FROM PLANT M ANAGEMENT CAN BE EXERTED, AND HAS CA USED COMPROMISES OF PREVIOUSLY ESTAB LISHED HEALTH PHYSICS POLICY REGARDI NG PERSONNEL ACCESS DURING UNIT OPER ATION. NUCLEAR PONER DEPARTMENT CON CERN. CI HAS NO FURTHER INFORMATION I 038-001 OP 31104 N HBH NNYN HATTS BAR: THE PRACTICE OF PERSONS E SAFETY PROGRAM T50026 REPORT NTERING THE LONER CONTAINMENT AREA 0 HEALTH PHYSICS F THE REACTOR CONTAINMENT FOR HON-EM GENERAL ERGENCY REPAIRS; HHILE THE REACTOR I EMPLOYEES S OPERATING, SHOULD BE RE-EVALUATED.
RECENT STUDIES INDICATE THE BIOLOG ICAL EFFECTS OF PERSONNEL EXPOSURE T I
O NEUTRON FLUX ARE MORE SERIOUS THAN PREVIOUSLY BELIEVED. THIS PRACTICE IS IN EFFECT AT SEQUOYAH AND RESULT ED IN AN ACCIDENT AROUND 1983/1984 A ND IS PLANNED TO BE IMPLEMENTED AT H ATTS BAR.
I l
l
ERENCE
- ECPS120J-ECPS121C TENNESSEE VALLEY AUTHORITY PAGE 237 QUENCY
- REQUEST OFFICE OF NUCLEAR POWER RUN TIME - 12:19:
- ISSS - RHM EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS)
RUN DATE - 10/03/.
LIST OF EMPLOYEE CONCERN INFORMATION GORY: OP PLANT OPER. SUPPORT SUBCATEGORY: 31104 HP POLICY, PRACTICES AND MANAGEMENT CONTROL S
GENERIC KEYWORD A H
APPL QTC/NSRS P
KEYHORD B 00NCERN SUB R PLT BBSH INVESTIGATION S
CONCERN KEYHORD C NUMBER CAT CAT D LOC FLQB REPORT R
DESCRIPTION KEYHORD D
)(X 009-002 IH 00000 S SQN NNNN I-85-513-SQN NS SEQUOYAH THERE IS NO REGARD FOR PER SAFETY PROGRAM T50193 OP 31104 K-FORM
$0NAL SAFETY AT OPERATING PLANTS. M SAFETY CONDITION ANAGEMENT (KNOWN) DIRECTED THAT THE OPERATIONS OLDEST EMPLOYEES BE ASSIGNED TO " HOT EMPLOYEES
' HORK IN ORDER FOR THEM TO REACH TH EIR RADIATION EXPOSURE LEVELS FIRST.
A SUPERVISOR (KNOWN) MADE THE STAT EMENT THAT "0LDER FOLKS HON'T BE LON O AROUND".
DETAILS KN0HN TO QTC, HI THHELD DUE TO CONFIDENTIALITY. CONS TRUCTION DEPT. CONCERN. CI HAS NO F URTHER INFORMATION.
' )f)f-85-015-001 OP 31104 N SQN NNNN XX-85-015-001 NS SEQUDYAH: THE PRACTICE OF PERSONNEL SAFETY PROGRAM T50078 K-FORM ENTERING THE LOHER CONTAINMENT AREA SAFETY 00NDITION OF THE REACTOR CONTAINMENT FOR NON-E OPERATIONS MERGENCY REPAIRS WHILE THE REACTOR I GENERAL S OPERATING SHOULD BE RE-EVALUATED S INCE RECENT STUDIES INDICATE THE BIO LOGICAL EFFECTS OF PERSONNEL EXPOSUR E TO NEUTRON FLUX ARE MORE SERIOUS T HAN PREVIOUSLY BELIEVED. THIS PRACT ICE CAUSED AN ACCIDENT'IN THE INCORE INSTRUMENT PROBE ROOM AT SEQUOYAH I N 1984 AND IS STILL CONTINUED. C/I HAS NO FURTHER INFORMATION.
)(X-85-026-001 OP 31104 N SQN NNNN SS SEQUOYAH: INADEQUATE UPPER MANAGEMEN HEALTH PHYSICS T50028 K-FORM T SUPPORT PROVIDED THE HEALTH PHYSIC TRAINING
$ DEPT. TO ENFORCE AN EFFECTIVE RAD OPERATIONS 10 LOGICAL SAFETY PROGRAM. NO DISCIP RADIATION PROTC' LINARY ACTION IS TAKEN WHEN EMPLOYEE S INTENTIONALLY BY-PASS MONITORS.
Mh(T50148 85-028-X02 IH 00000 S SQN NNYN I-85-514-SQN SEQUOYAH-RADIATION HORK PERMIT 02-2 FALSIFICATION OP 31104 REPORT
-00214 (SIGN-IN SHEET) CONTAINS FALS HEALTH PHYSICS IFIED SIGNATURES. NO FOLLOHUP REQUI HEALTH PHYSICS RED REPORTS
//(-85-028-XO 3 IH 00000 S SQN YYYY I-85-514-SQN SEQUOYAH-RADIATION HORK PERMITS ARE RECORDS T50148 OP 31104 K-FORM NOT BEING COMPLETED PER PROCEDURE R NONCONFORMANCE EQUIREMENTS. RADIATION HORK PERMIT HEALTH PHYSICS 02-2-00214 IS AN EXAMPLE.
NO FOLLOH REPORTS UP REQUIRED
REFERENCE
- ECPS120J-ECPS121C TENNESSEE VALLEY AUTHORITY PAGE 738
'FREQUEP:CY
- REQUEST OFFICE OF NUCLEAR PDHER RUN TIME - 12:190 ONP - ISSS - RHM EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS)
RUN DATE - 10/03/l LIST OF EMPLOYEE CONCERN INFORMATION QTEGORY: OP PLANT OPER. SUPPORT SUBCATEGORY: 31104 HP POLICY, PRACTICES AND MANAGEMENT CONTROL S
GENERIC KEYWORD A H
APPL QTC/NSRS P
KEYNORD B CONCERN SUB R PLT BBSH INVESTIGATION S
CONCERN KEYHORD C NUMBER CAT CAT D LOC FLQB REPORT R
DESCRIPTION KEYHORD D XX 063-031 OP 31104 N SQN NNNN I-85-775-SQN-NS SEQUDYAH OPERATORS AND HEALTH PHYSIC HEALTH PHYSICS T50175 K-FORM S:
FAILURE TO KNOH AND VERIFY THE C SAFETY PROGRAM CNTENTS OF SYSTEM.
EXAMPLE: HEALTH OPERATIONS PHYSICS GAVE GO AHEAD TO OPEN A LINE RADIATION PROTC' IN TURBINE BUILDING, UNIT 2, SAYING EVERYTHING HAS 0.K. AND CLEAN. AFT ER OPENING THE LINE, THE NEXT NIGHT, THE ENTIRE AREA HAS R0 PED OFF FOR C ONTAMINATION. THIS OCCURRED IN JAN/
FEB 84.
C/I HAS NO FURTHER INFORMAT ION.
HUC. POWER CONCERN.
XX 066-001 OP 31104 N SQN NNNN XX-85-066-001 NS SEQUOYAH - 3 YEARS AGO, HEALTH PHYSI HEALTH PHYSICS T50134 K-FORM CS AT SEQUOYAH HAS NOTIFIED OF HIGHE SAFETY CONDITION R THAN EXPECTED RADIATION LEVELS IN OPERATIONS THE REACTOR BUILDING. NHEN NOTIFIED RADIATION PROTC1 BY TELEPHONE, HP PERSONNEL SPECULAT ED ON THE REASONS FOR THE HIGH RADIA TION LEVEL, AND DID NOT RESPOND IMME DIATELY TO INVESTIGATE. CI FEELS TH AT HASTING TIME SPECULATING ON CAUSE AND NOT RESPONDING IMMEDIATELY IS A CONCERN FOR SAFETY.
NUCLEAR P0HER DEPT CONCERN. CI HAS NO FURTHER IN FORMATION. NO FOLLOH UP REQUIRED XX 084-001 OP 31104 N SQN NNNN 1-85-806-SQN NS QUESTIONABLE PRACTICES BY HEALTH PHY HF.ALTH PHYSICS T50181 K-FORM SICS 3 SEQUDYAH IN 1982 LEAD TO POSS SAFETY PROGRAM IBLE OVER EXPOSURE. H.P. HOULD RESP 0 OPERATIONS ND TO RADIATION ALARMS AND UNPLUG UN RADIATION PROTCT ITS.
DETAILS KNOHN TD QTC, HITHHELD DUE TO CONFIDENTIALITY. CONST. DEP T. CONCERN. C/I HAS NO FURTHER INFO RNATION.
XX 098-002 DP 31104 N SQN NNYN I-85-615-SQN SEQUOYAH - RADIATION AREAS ARE NOT M HEALTH PHYSICS T50152 REPORT ONITORED OFTEN ENOUGH. NUCLEAR P0HE SAFETY PROGRAM R CONCERN. CI HAS NO ADDITIONAL INF OPERATIONS ORMATION. NO FOLLONUP REQUIRED.
RADIATION PROTC1 16 CONCERNS FOR CATEGORY OP SUBCATEGORY 31104 r
-~
~ - -,,
~~
7 ---