ML20214R399
| ML20214R399 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Sequoyah |
| Issue date: | 09/19/1986 |
| From: | Hall D, Lagergren W TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML082421095 | List: |
| References | |
| 1662T, 311.03-SQN, 311.03-SQN-R01, 311.03-SQN-R1, NUDOCS 8609290165 | |
| Download: ML20214R399 (7) | |
Text
._
0 TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT EMPLOYEE CONCERNS TASK GROUP OPERATIONS CEG Subcategory: Health Physics Element: Exposure Limits and Records Report Number: 311.03-SQN, Revision 1 IX-85-007-001 XX-85-028-001 XX-85-048-003 Evaluator:
M w'e.
'///9/9/
7 r-IV C. H 1J
'Dats 4
~
/4/h[
f /!((
Reviewed by: ' OPSCEfMpber
'Date O/ #/ Vk vv/ :
M9/P/
Approved by:
.R(Lagerpen tat ( ~
B609290165 860923
)
PDR ADOCK 05000327 P
PDR 1662T l
.i
i 1
I I.
Title Exposure Limits and Records, 311.03-SQN The scope of the evaluation of element 311.03-SQN consisted of the investigation of 3 previously investigated concerns and confirmation of the validity and completeness of those previous investigations. The i
l concerns involved questions and/or allegations with regard to the following:
l
- daily exposure limits
- over-exposed employees being laid-off due to their exposure levels.
4
- H.P. authority to change exposure authorization
- Unmonitored exposure to radiographic operations.
l The evaluation of the concerns and previous investigations consisted of a review of the concerns and investigation methodology, review of applicable regulatory and TVA requirements and procedures, and interviews with cognizant SQN personnel. The concerns evaluated herein lR1
{
are assigned solely to the Operations CEG.
1 1
II.
Specific Evaluation Methodology I
Concern XX-85-007-001 states: Question daily limits of acceptable radiation exposure at Sequoyah and wonders if they will be the same here i
at Watts Bar? TVA does not have daily dosage limits; it has quarterly l
and yearly dosage limits. There were numerous cases'of over-exposure about 2-3 years ago. When over-exposed, employee will be laid off.
This is the corrective action TVA uses for over-exposure at Sequoyah.
C/I has no further information.
I Concern XX-85-028-001 states: While at another TVA facility individual j
was exposed to the maximum amount of radiation.
RWP was adjusted by j
Health Physics to reflect an increase in radiation allowance.
(name and 1
details known by QTC).
I Concern XX-85-048-003 states: At Sequoyah, C/I was exposed to radiation
{
during X-ray of pipe weld since neither TLDs nor other types of dosimeters were required to be worn during this time period 2, 4
1978/1979. C/I is concerned over dosages C/I, or other employees there may have received during RT of pipe welds. No follow-up required.
l The evaluations of the concerns assigned to element 311.03-SQN were l
performed in accordance to the Operations CEG Evaluation Plan and the lR1 Health Physics Subcategory Evaluation Plan.
I i
l All K-forms and previous reports and investigations assigned to element 311.03-SQN were evaluated.
l l
a
,I Page 1 of 6
The evaluations of the concerns consisted primarily of a review of previously conducted NSRS, QTC, and/or line investigations. The validity of the previous investigations was verified by interviews and reviews of applicable procedures and regulatory requirements.
As part of the evaluation of concern XX-85-007-001, the previous line managemiat investigation of Watts Bar specific concern IN-85-301-006 was also evaluated.
IN-85-301-006, in part, raises the same concern as XX-85-007-001, specifically the question of daily dose limits of SQN and l
WBN; therefore both concerns and the applicable previous investigations were evaluated. The findings and conclusions associated with the evaluation of XX-85-007-001 should be considered as fully adequate to address and resolve concern IN-85-301-006.
III.
Findings Evaluation Results A.
XX-85-007-001 raises concerns regarding the daily limits of lR1 acceptable radiation exposure at Sequoyah and raises the question, "Will the limits be the same at Wat.ts Bar?" In addition, XX-85-007-001 raises a concern about numerous over-exposures at Sequoyah and states that over-exposed employees are " laid-off."
Line management investigations were perfcrmed regarding these concerns (Re: memo dated 1/22/86. E. A. Belvin to W.H. Thompson, L61-860121-805, and memo dated 2/12/86, E. A. Belvin to W. H. Thompson, L61-860204-803.)
Federal regulations do not require daily dose limits. Title 10 Code lR1 of Federal Regulation Part 20.101 (10 CFR 20.101) establishes l
quarterly dose. limits and guidelines for total lifetime dose limits.
TVA implements the 10 CFR 20 requirements through the TVA RadioloSical Protection Plan (RPP). The RPP only establishes quarterly and yearly dose limits. These requirements apply to all TVA plants. Dose limits are established at SQN in Sequoyah Radiological Control Instruction 1 (RCI-1).
As with the RPP, no requirement for daily dose limits lR1 exists. The only reference to a daily limit is in regard to Radiation Work Permit (RWP) requirements, and states that personnel exceeding lR1 50 mrem per day cust have an RWP.
Regarding the concern that there were numerous cases of over-exposures at SQN about 2-3 years ago, the line investigation indicated that there have been no cases of personnel over-exposure in excess of regulatory limits at SQN. This was confirmed by SQN Health Physics on 8/13/86.
It was also stated by the line report and confirmed that at SQN, as lR1 well as all other TVA facilities, it is possible for an employee to be laid-off or terminated if they exceed or come close to established exposure limits. When an employee is over-exposed or is close enough to his/her exposure limit to preclude any further exposure, plant policy is to find work for that employee for the remainder of the calendar quarter in an area where additional exposure to radiation is not possible. In rare cases, when no work in the employees particular skills exists outside of the radiologically controlled areas, the plant has no recourse other than layoff or termination of
[R1 Page 2 of 6
the employee. This action, though regrettable, is necessary to meet regulatory requirements and serve the best health and safety interests of the employee. Health Physics management at SQN indicated that, to their knowledge, no permanent TVA employee at SQN has ever been terminated or laid-off due to high exposure. This evaluation i
determined that the SQN line report adequately addresses the scope of I
the concern as stated, and concurs with the findings and conclusions lR1 of the report.
I B.
XX-85-028-001: This concern regarding an employee receiving the
" maximum amount of radiation" was previously investigated by ERT I
(re: memorandum from K. W. Whitt to H. L. Abercrombie dated 12/23/85, Nuclear Safety Review Staff Investigation Report Transmittal).
In addition to investigation of the concern, the ERT report brought to l
attention several deficiencies with 1984 SQN RWP time sheets. NSRS and SQN addressed these in follow-up investigations (Re: NSRS lR1 report #XX-85-028-001 & Sequoyah responses memorandums from K. W. Whitt to H. L. Abercrombie dated 1/16/86 and 3/3/86).
With regard to the concern that the CI was exposed to the maximum lR1 amount of radiation, the ERT investigation reviewed RWP time sheets l
and could not substantiate that the CI or any other individual had been exposed to radiation in excess of established limits. Additional interviews with the CI indicated his concern centered on item 2 of the RWP time sheet special instructions. This item states "Do not exceed (blank)
HREM per entry or 50% of RAD" (remaining allowable dose).
One of the applicable RWP time sheets did show that this amount had been changed by the H.P. section. The CI was made aware that the amount shown in item 2 is just a guideline based on what the H.P.
determines necessary to accomplish the job. The procedural i
i requirements of SQN RCI-14 do not prohibit the cognizant H.P.
l representative from revising the exposure allowance if it is so IR1 dictated by changing work conditions. Although the change was made to l the timesheet the CI was not put in a situation which would have I
allowed him to exceed his RAD. When presented with this informatior.
IR1 the CI agreed that Health Physics had not acted improperly in changing i the RWP time sheet.
During the course of the investigation ERT did note discrepancies in I
handling time sheets. The discrepancies consisted of several apparent lR1 violations of QA record requirements and included:
- inaccurate / incomplete or missing information
- improperly made corrections
- inconsistencies in handling of records lR1
- accountability errors
- procedural noncompliance Sequoyah's response to NSRS regarding the discrepancies included a commitment to revise appropriate HP procedures regarding QA record requirements. Revision to SQN HP ASIL-4 to accomplish this was confirmed. The following should also be noted:
Page 3 of 6
- NRC has no requirement stating that RWP time sheets should be QA records.
- Current SQN procedures do not require all RWP time sheets be maintained as QA records (HPSIL-7 and ASIL-4) lR1 l
- Regulatory Guide 1.lG requires that at least 80% of site dose (man-rem) be assigned to specific functions. The 1984 SQN RWP timesheet total accounted for 98.9% of the total site dose.
- RWP time sheet doses are not used as official dose records. TLD i
data is the official record.
l In an interview with SQN Health Physics management personnel it was l
stated that QA record requirements regarding RWP timesheets are not l
clearly defined in plant procedures and that there seems to be a lR1 conflict of opinions between NRC, TVA Central Office QA, and SQN l
plant management as to what extent QA record requirements should l
apply to RWP timesheets.
l
-The NSRS & ERI evaluations were confirmed and this evaluation concurs with their findings.
C.
IK-85-048-003: This concern was previously investigated (Re:
memorandum from J. W. Hufham to W. H. Thompson, dated September 27, lR1 1985, L05-850926-803). Based on information provided by QTC, the CI 1
was not present within the regulated area set up by the radiographers during any radiographic operations. The boundaries are set up such that the maximum exposure rate at the boundaries is less than 2.0 mr/hr, in accordance with the requirements for 10 CFR 20.105.
lR1 In addition, radiographers are trained in controlling radiographic operations according to the requirements of 10 CFR 34.
Based on the above information, no dosimetry outside the regulated area boundary was necessary. Anticipated doses at the boundary, even if the CI had been continually present there, would have been below the levels where monitoring is required. This evaluation concurs with the findings of the previous investigation.
Conclusions With the exception of one item in concern number II-85-007-001, none of the concerns assigned to element 311.03-SQN was validated. The item in XI-85-007-001 was validated, in that the plant does have the authority j
and ability to lay-off or terminate an employee who is close to or has l
exceeded his/her exposure limit when no work in his/her skill exists i
outside of the radiologically controlled areas. No permanent TVA lR1 l
employee at SQN has ever been subjected to this action, but the plant l
has and will continue to have this option in order to ensure regulatory compliance and to maintain the health and safety interests of its employees. The authority to take this action is completely legal, justified, proper, and warrants no corrective action.
l l
l Page 4 of 6
In addition to validation of the item in IK-85-007-001, this evaluation IR1 also concludes that the possibility of deficiencies in the control and handling of RWP time sheets exists. The deficiencies identified by the l
ERI report have, in part, been resolved by revisions to SQN ASIL-4, l
specifically those deficiencies pertaining to transcription of RWP l
timesheets. There still remains the lack of a clear definition of QA l
record requirements for RWP timesheets and the problem of plant employees I not entering data on timesheets according to QA record requirements.
l Employees do receive training in QA record procedures (GET-4) and are lR1 instructed that RWP tinesheets must be used according to QA record I
requirements (GET-2.2); however, the frequency of improper entries of RWP 1 timesheets indicates a need to identify the cause of this problem, l
including an evaluation of the existing training program. It should also l be noted that the deficiencies identified in the ERT report are not l
within the scope of concern XX-85-028-001 as stated and do not, l
therefore, constitute validation of the concera.
This evaluation fully concurs with the findings and conclusions of all previous investigations. No additional problems or concerns other than those already discussed were identified.
None of the concerns evaluated in this report affect the safe operation lR1 of the plant.
l IV.
Root Cause Concern XK-85-028-001: The root cause of the QA record problems identified by ERT with regard to RWP time sheets appears to be, primarily, a lack of knowledge of or disregard for the QA requirements lR1 governing the maintenance of QA documents. The problem is compounded by l
the fact that not all time sheets are required to be maintained as QA documents, a fact which may cause confusion among plant workers and HP personnel responsible for the time sheets.
No other concerns were validated which require root cause evaluation.
V.
Generic Applicability Within the scope of the concerns stated herein, the findings of this evaluation indicate that the concerns pertain to isolated events specific to SQN. No evidence was found that similar situations exist at other plants.
Regarding the findings of the ERT report it is concluded that the deficiencies identified constitute a weakness in QA record requirements and should be evaluated for generic applicability at other TVA facilities utilizing RWP timesheets. Operations CEG report 311.04-SQN also addresses generic applicability of RWP timesheet deficiencies.
l Page 5 of 6 i
References A.
Title 10 Code of Federal Regulation Part 20 B.
Title 10 Code of Federal Regulation Part 34 C.
Sequoyah Nuclear Plant, Radiological Control Instruction 1 (RCI-1)
D.
Sequoyah Nuclear Plant, Radiological Control Instruction 14 (RCI-14)
E.
IVA Radiological Protection Plan (RPP) section 3.0 F.
Sequoyah Administrative Instruction 7 (AI-7)
G.
Sequoyah Health Physics Administrative Section Instruction Letter 4 (ASIL-4)
H.
Memorandum to W. H. Thompson from E. A. Belvin dated 1/22/86 (L61 860121 805)
I.
Memorandum to W. H. Thompson from E. A. Belvin dated 2/12/86 (L61 860204 803)
J.
Memorandum to K. W. Whitt from H. L. Abercrombie dated 1/16/86 K.
Memorandum to H. L. Abercrombie from K. W. Whitt dated 3/3/86 L.
Memorandum to H. L. Abercrombie from K. W. Whitt dated 12/23/85 (ERT report XX-85-028-001 attached)
M.
Memorandum to V. H. Thompson from J. W. Hufham dated 9/27/85 (LOS 850926 803)
/
VII. Immediate or Long-Term Corrective Action This evaluation indicates that a clear definition of QA record requirements and worker responsibilities regarding RWP timesheets, including an evaluation of the adequacy of applicable General Employee Training (GET), courses are needed to ensure QA record requirement compliance in the handling and maintenance of RWP timesheets at SQN.
I Page 6 of 6 I