ML20245L319
| ML20245L319 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 08/01/1989 |
| From: | Collins T, Potter J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20245L305 | List: |
| References | |
| 50-327-89-11, 50-328-89-11, IEIN-89-027, IEIN-89-27, NUDOCS 8908220078 | |
| Download: ML20245L319 (7) | |
See also: IR 05000327/1989011
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UNITED STATES .
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LReport Nos.: 50-327/89-11 and:50-328/89-11
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. Docket Nos.:'50-327 and'50-328
-License Nos.: DPR-77and[DPR-79
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Facility Name: Sequoyah Nuclear Plant
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' Inspection'Condu ed) J n :2 -30, 1989
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Approved.by:
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.J. #. Potter, Chief
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Facilities-Radiation Protection Section
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Emergency Preparedness and Radiological Protection
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Division'of Radiation Safety and Safeguards
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SUMMARY
Scope:
This routine, unannounced inspection was conducted in the area of the radiation
protection program follow-up on previous inspector identified items and
a: 'IE'Information Notices.
1Results:=
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Based .on" interviews with licensee management, supervisor and personnel from
station departments, and records review, the inspector found that the radiation
protection program was generally adequate.
Hewever. one . violation was
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identified:
1)cfailure to ' adequately train personnel in use of radiation
protection equipment and-failure to evacuate an area when a radiation monitor
' alarmed as required by Radiological Control Instructions.
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REPORT DETAILS
1.
Persons Contacted
Licensee Employees
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-M. Edwards, ALARA Engineer.
- T. Flippo, Quality Assurance Manager
E. Hickman, Radiological Protection Manager
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- S. Holderfer, Health Physicist
- C. Mason, Plant Manager
M. Palmer, Radiological Health Manager
- R. Pierce, Mechanical Maintenance Group Manager
- S. Spencer Nuclear Engineer
J. Stiegleman, Radiological Controls Manager
M. Sullivan, Radiological Control Superintendent
Other licensee employees contacted during this inspection included
engineers, operators, mechanics,
technicians, and administrative
personnel.
Nuclear Regulatory Commission
P. Harmon, Senior Resident Inspector
- K. Jenison, Senior Resident Inspector
D. Loveless, Resident Inspector
- Attended exit. interview
2.
Occupational Exposure, Shipping, and Transportation (83750)
a.
Organization
The licensee was required by Technical Specification (TS) 6.2 to
implement the plant organization specified in Table 6.2.2-1.
The
responsibilities, authorities, and other management controls were
further outlined in Chapters 12 and 13 of the Final Safety Analysis
Report (FSAR).
TS 6.5.1 specifies the members of the Plant
Operations Review Committee (PORC) and outlined its functions and
authorities.
Regulatory Guide 8.8 specifies certain functions and
responsibilities to be assigned to the Radiation Protection Manager
(Radiological Control Superintendent) and radiation protection
responsibilities to be assigned to line management.
The inspector reviewed recent changes and proposed changes to the
plant organization to determine their effect on plant radiological
controls, by examining the resulting changes to administrative
procedures and position descriptions and discussed the changes with
the Plant Manager and the Radiological Control Superintendent.
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The inspector discussed with a Radiological Control Manager, a
Radiological Controls Foreman, a Maintenance Supervisor, and a
representative from plant engineering, the type, methods of, and
degree of interaction between plant groups. The inspector discussed
with the Radiological Controls Superintendent and selected
radiological controls personnel, how frequently they toured the
plant, radiation control areas (RCAs) and reviewed documentation of
'these tours.
The inspector also accompanied a Radiological Controls
Manager on a scheduled tour of the RCA on June 27, 1989. During this
tour, the inspector observed work in progress and posting of controls
for RCAs.
No violations or deviations were identified.
b.
Staffing
TS 6.2.2 specifies minimum plant staff and FSAR Chapters 12 and 13
also outline further details on staffing.
The inspector discussed
authorized staffing levels versus actual on-board staffing separately
with the Plant Manager and the Radiological Controls Superintendent.
The inspector concluded that the licensee's current staffing and
experience levels of the radiological controls section were adequate
to support routine plant operations.
No violations or deviations were identified.
c.
Control of Radioactive Materials and Contamination, Surveys, and
Monitoring
The licensee is required by 10 CFR 20.201(b), 20.401, and 20.403 to
perform surveys to show compliance with regulatory limits and to
maintain records of such surveys.
Chapter 12 of the FSAR outlines
survey methods and instrumentation. TS 6.8.1 requires the licensee to
follow written procedures.
Radiological control procedures further
outline survey methods and frequencies.
During plant tours, the inspector observed radiation level and
contamination survey results outside selected cubicles.
The
inspector performed independent radiation level surveys of selected
areas hnd observed satisfactory comparison with licensee survey
results.
The inspector reviewed selected survey records for the
month of June 1989, and discussed with licensee representatives
methods used to disseminate survey results. The inspector also noted
that only approximately eight percent of the RCA was controlled as
contaminated.
No violations or deviations were identified.
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d.
10 CFR 19.12 requires in part that all individuals working in or
frequenting any portion of a restricted area shall be kept informed
of the storage, transfer, or use of radioactive materials or of
radiation in such portion of the restricted area; shall be instructed
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in the health protection problem associated with exposure to such
radioactive materials or radiation, in precautions or procedures to
minimize exposure, and in the purposes and functions of protective
devices employed.
TS 6.8.1 requires that written procedures shall be established,
implemented and maintained in accordance with the applicable
procedures recommended in Appendix A of Regulatory Guide 1.33,
Revision 2,
February 1978, Section 7.e. . Radiation Protection
Procedure.
Radiological Control- Instruction RCI-1 Radiological Control Program,
Revision 36, dated August 13, 1988, Section 4.15 requires that all
individuals shall ~immediately evacuate the area and notify RADCON
upon observing a Rad Monitor alarming.
On February 2,1989, two auxiliary unit operators (AU0s) were working
in a pipe chase on Unit 2, elevation 690, posted as a radiation area.
While performing valve operations for recirculation of the refueling
water storage tank (RWST) to accommodate a chemistry sample a
portable area radiation monitoring (ARM), Ludlum Model-300, alarmed.
Preliminary investigation and interviews with the two AU0s determined
that the ARM was reset and the two AU0s continued to work in the
area.
At an undetermined time later the ARM alarmed again. The two
AU0s stopped work to read their self-reading pocket dosimeter (SRPDs)
(0-200 mrem) and noted they were offscale.
Recirculation operations
were secured and the two AU0s exited the area and notified health
physics (HP).
One AU0's thermoluminescent dosimeter (TLD) read
430 mrem and the other's TLD read 479 mrem. These readings reflected
doses for the quarter, however a majority of the AU0s' doses were
received as a result of this event. Radiation levels in the Unit 2,
690 foot elevation Pipe Chase were measured to be 2,500 mrem / hour on
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contact with the RWST recirculating piping and 500 mrem / hour in the
general area.
Licensee management representatives were informed that this event was
first discussed in NRC Inspection Report No. 50-327, 328/89-05 issued
on March 16, 1989.
In a letter dated July 14, 1989, the NRC notified
the licensee that a revised Notice of Violation relating to this
event would be issued in NRC Inspection Report No. 50-327, 328/89-11.
The inspector informed licensee management representatives that
failure to adequately train personnel in the use of portable ARMS
(Ludlum Model-300) and failure of the two AV0s to evacuate the Unit 2
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Pipe Chase when the ARM alarmed was an apparent violation of
10 CFR 19.12 and'TS 6.8.1 (50-327, 328/89-11).
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As Low As Reasonably Achievable (ALARA) Program
10 CFR 20.1(c) states that persons engaged in activities under
licenses issued by the NRC should make every reasonable effort to
maintain radiation exposure ALARA.
The recommended elements of an
ALARA program are contained in Regulatory Guide 8.8, Information
Relevant to Ensuring that Occupational Exposure at Nuclear Power
Stations will be ALARA and Regulatory Guide 8.10, Operating
Philosophy for Maintaining Occupational Radiation Exposures ALARA.
The inspector discussed the ALARA goals and objectives for 1989 with
licensee representatives and reviewed the person-rem estimates and
results.
The licensee's goal for 1989 was set at 625; however, the
licensee revised its goal to 725 person-rem due to the person-rem
expended during a refueling / maintenance outage in the spring of 1989.
The licensee expended 675 person-rem through June 1989.
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licensee maintains its desired goal of 725 person-rem for 1989, that
would be slightly higher than the national average for 1988 of 692
person-rem for a two unit pressurized water reactor (PWR).
No violations or deviations were identified.
3.
Inspector Follow-op Items (92701)
a.
(Closed) Inspector Follow-up Item (IFI) 50-327, 328/88-04-01.
This
item concerned the processing, pre-job reviews and actual termination
dates on radiation work permits (RWPs).
The inspector reviewed and
verified that the licensee has revised RCI-14, RWP Program and
incorporated the above mentioned issues. The RCI-14 RWP Program was
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approved and issued on April 4, 1988.
b.
(Closed) IFI 50-327, 328/88-31-03.
This item addressed the concern
for formal implementation of a " Hot Particle Program." The inspector
reviewed and verified that this licensee has formally addressed the
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" Hot Particle Program" in appropriate Radiation Protection
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Procedures.
c.
(Closed) IFI 50-327, 328/88-31-04.
This item concerned a lack of
coordination of insulation workers receiving radiation exposures
while in support of maintenance activities in containment.
The
inspector discussed this
issue with licensee maintenance
representatives and determined that a temporary position for an
insulator coordinator has been approved.
This position's
responsibility is to help reduce the exposure dose rates accumulated
by craft personnel performing insulation work during daily work
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schedules and outage periods.
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(C1nsed) IFI 50-327, 328/89-05-01.
This item addressed'the concern
for heet. stress to workers while wearing supplied air hoods inside
the steam generators.
The inspector discussed this issue with
licensee representatives and determined that the licensee routed the
breathing air throt. ;h
n ice. filled 55 gallon drum to lower the air
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temperature and wors .. stress for workers breathing the supplied air
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was reduced.
No .1.ther complaints were received from steam
generator personnel.
e.
(Closed) IFI 50-327, 328/89-05-02.
This item concerned the
licensee's air sampling techniques while performing dewatering
operations of-spent resin.
The inspector discussed this issue with
licensee representatives and determined by review that the licensee
has revised their Airborne Radioactivity Survey Procedure, HPSIL-5,
Revision 32, dated June 29, 1989, in regard to evaluating and taking
appropriate air samples while performing related activities prior to
and during work progressing.
f.
(Closed) IFI 50-327, 328/89-05-03.
This item concerned that the
licensee did not track or trend Personnel Contamination Reports
(PCRs) to determine the categories for causes of the events.
The
inspector discussed this issue with licensee representatives and
determined by review that the licensee has developed a computerized
PCR trending report to identify each event cause.
However, the inspector noted that the PCR trending report was not
reviewed on a specified frequency to evaluate root causes and
subsequently reduce the PCR events.
The licensee acknowledged the
inspector's concern and stated they would incorporate this review
into their Work Routines Program and perform this review on a monthly
frequency.
g.
(Closed) IFI 50-327, 328/89-05-05.
This item concerned the licensee
performance of analytical evaluations of the high beta radiation
levels in the nozzle dams of the Unit 2 steam generator.
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inspector reviewed several analytical evaluations performed by the
licensee - to determine the radionuclides composition in the Unit 2
steam generator nozzle dams.
The inspector concluded that these
analytical evaluations did not reveal any higher than normal isotopic
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concentrations normally found inside the reactor coolant.
h.
(Closed) IFI 50-327, 328/89-05-06.
This item concerned the higher
than anticipated airborne radiciodine concentrations in the Unit 2
containment.
The inspector discussed this issue with licensee
management representatives and was informed that the licensee
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completed their evaluation and investigation for the reasons why the
airborne radiciodine concentrations were hight.r than anticipated.
The investigation revealed that the purge system eductor inside
containment was installed improperly, so that, rather than removing
the radiciodine from the containment atmosrhere, radiciodine was
being vented into containment through tl e perge system.
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(Closed) . IFI . 50-327, 328/89-05-07.
This item concerned the use of
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magnetic signs on laundry containers revealing that the laundry was
" clean laundry" rather than contaminated laundry.
The inspector
toured the RCA and verified that clean laundry containers were
appropriately marked and labeled as clean.
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IE Information Notices (IEN) (92717)
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The inspector determined that the licensee had received IEN 89-27
" Limitations on the use of Waste Forms and High Integrity Containers for
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the Disposal of_ Low Level Radioactive Waste."
5.
Exit Interview
The inspection scope and results were summarized on June 30, 1989, with
those persons indicated in Paragraph 1.
The inspector described the areas
. inspected and discussed in detail the inspection results listed below.
The licensee acknowledged the inspection findings and took no exceptions..
The licensee did not identify as proprietary any of the material provided
to or. reviewed by the inspector during the irtpection.
The licensee was.
informed that the. items discussed in Paragraph 3 were considered closed.
Item Number
Description and Reference
50-327, 328/89-11-01
VIO - Failure to adequately train
personnel in radiation safety equipment
and failure of personnel to evacuate an
area when a radiation monitor alarmed
as required by Radiological Control
Instructions
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