ML20247F346
| ML20247F346 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 03/13/1989 |
| From: | Adamovitz S, Marston R, Potter J, Shortridge R, Testa E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20247F334 | List: |
| References | |
| 50-327-89-05, 50-327-89-5, 50-328-89-05, 50-328-89-5, NUDOCS 8904030414 | |
| Download: ML20247F346 (23) | |
See also: IR 05000327/1989005
Text
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UNITED STATES .
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NUCLEAR REGULATORY COMMISSION .
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REGION 11
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101 MARIETTA ST., N.W.
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ATLANTA, GEORGIA 30323
MAR 161989
Report Nos.: 50-327/89-05 and 50-328/89-05
Licensee: Tennessee Valley Authority
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'6N38 A Lookout Place
1101 Market Street
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Chattanooga, TN 37402-2801
Docket Nos.: 50-327 and 50-328
License Nos.:
Facility Name: Sequoyah 1 and 2
Inspection-Conducted: January 30-February 3, and February 8-9, 1989
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Inspectors: b 8,
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E. D. Testa
Da~te Signed
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S. S. Adamovitz
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tate '51gned
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R. R.
rston
Date Signed
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$ $1
RF B. Shortri ge
D/tvSigned
Approved by:
J
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J.47. Pottar, Chief
D6td Signed
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Facilities Radiation Protection Section
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Emergency Preparedness and Radiological
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Protection Branch
Division of Radiation Safety and Safeguards
SUMMARY
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Scope
This was a special, unannounced team assessment / inspection in the areas of
Corporate and Site nuclear chemistry, radioactive waste, radiological controls
and Corporate Quality Assurance (QA) audits.
Unit 1 was operating at
100 percent (%) and Unit 2 was approximately 16 days into a refueling outage.
Results
The licensee's radiological controls program appeared to be sound and
improving.
The use of remote handling tools for steam generator nozzle dam
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installation was a positive step in controlling worker dose as low as
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reasonably achievable (ALARA).
g4030424890316
G
ADOCK 05000327
PNU
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Corporate. QA audits in the areas inspected appeared detailed and complete.
Positive steps were being implemented to reduce the number of standing general
Radiation Work Permits (RWPs). The licensee corporate and site staffs appeared
knowledgeable and sensitive to established goals.
'Within the areas inspected, one violation was identified for failing to perform
an adequatt radiation survey necessary to evaluate the extent of radiation
hazards present prior to operator entry (Paragraph 11).
Six inspectnr followup items (IFIs) were identified:
Worker comfort problems associated with supplied breathing air
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(Paragraph 9).
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Evaluation of breathing zone air samples versus general air samples
for respirators (Paragraph 9).
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Expansion of the identification of specific categories of event root
causes tc provide better data for evaluations and analysis
(Paragraph 10).
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Unexpected high beta dose rate in the steam generators
(Paragraph 12).
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Unexpected high airborne iodine concentrations in the containment
(Paragraph 13).
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Labels for clean laundry containers to distinguish them from dirty
laundry shipments into and out of the same plant location
(Paragraph 14).
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REPORT DETAILS
1.
Persons Contacted
Licensee Employees
- W. Aslinger, Assistar.t Site Representative for Employee Concerns
- J. Barker, Manager, Rad Con
J. Bates Manager, Corporate Chemistry Support Group
- H. Blair, QA Specialist NQA
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S. Bradley, Shift Supervisor Radiological Health
- J. Bynum, Vice President Nuclear Power Production
- R. Coleman, Radiological Assessor
- M. Cooper, Compliance Licensing Supervisor
- P. Crabtree, Shift Operations Supervisor
J. Dills, Quality Assurance Specialist - Corporate
- A. Dyson, QA Evaluator /QSS
- G. Fizer, Chemistry and Environmental Superintendent
R. Halton, Assistant Site Representative for Employee Cuncerns
- R. Hays. Radwaste Processing Coordinator
- J.
LaPoint, Site Director
- M. McMilland, Maintenance / Rad Con Work Coordintor
- J. Patrick, Operations Superintendent
- T. Phifer, Plant Reporting Engineer
W. Raines, Chief, Environmental Radiological Monitoring and
Instrumentation Branch
- H. Rogers, Plant Support Superintendent
- V. Shankes, Program Manager Chemistry
B. Smith, Quality Assurance Auditor
- J. Smith, Plant Reporting Supervisor
- S. Smith, Plant Manager
- S. Spencer, Licensing Engineer
- M. Sullivan, Superintendent, Radiological Controir
- K. Walker, Quality Evaluator
- J. Watts, Quality Evaluator
Other licensee employees contacted during this inspection included
engineers, operators, mechanics, technicians, and administrative
personnel.
Nuclear Regulatory Commission
- J. Brady, Project Engineer, TVA Projects Division
- P. Harmon, Senior Resident Inspector
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- L. Watson, Section Chief, TVA Projects Division
- Attended exit ir.terview
- Participated in teleconference briefing on February 9, 1989
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2.
Licensee Action on Previous Enforcement Matters
.This subject was not addressed during this inspection.
3.
Radiation Protection, Plant Chemistry, Radwaste and Environmental:
Organization and Management Controls (83522)
a.
Water and Waste Processing Group
The inspector discussed the organization, responsibilities, and
operations of the Water and Waste Processing Group (WWPG) with
cognizant licensee representatives, reviewed pertinent documentation,
and examined the facilities and equipment used by the Group.
The inspector determined that WWPG Supervisory personnel met the
qualifications specified in their position descriptions.
The Manager, Water and Waste Processing, reported to the Plant
Operations Superintendent who, in turn, reported to the Plant
Manager. The WWPG was divided into five subgroups which:
Managed, directed, and supervised packaging, loading (radwaste
only), storage, and shipping of all radioactive materials and
radwaste.
Directed development and implementation of the decontamination
program.
Directed the ir.plementation of radwaste minimization programs
and radwaste segregation and storage, and prepared shipping
documents.
Provided technical support to other operations and engineering
staffs.
Managed the technical and water processing units of the WWPG.
Licensee representatives stated that the current approved level of
69 people in the Group was scheduled to be reduced to 59. A licensee
representative stated that the losses would be spread through the
Group so as to minimize the reduction-in-force impact.
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The inspector reviewed Standard Practice, SQA129, Site Goals and
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Objectives, Sequoyah Nuclear Plant, for Fiscal Year (FY) 1988, and
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reviewed the WWPG Performance Measure / Goal for FY 1989.
The Group
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goals appeared to implement the Plant goals.
Specific goals for WWPG
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(FY1989)were:
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Ship no more than 8,736 cubic feet (ft3) per unit of Dry Active
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Waste (DAW) during the fiscal year.
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Ship no more than 1,300 ft3 per unit of resins, sludges, and
evaporator bottoms during the fiscal year.
Release an average of less than 550,000 gallons per month of
Liquid Radioactive Effluents during the fiscal year.
Licensee representatives stated that the Group had identified its
most significant problems and had developed corrective actions to
solve them.
Projected personnel reductions and the current outage
made the completion schedule uncertain.
The inspector toured the accessible parts of the radwaste processing
and storage systems, and discussed systems' operation and training
with systems' operators and supervisors. The personnel appeared to be
knowledgeable on the systems and their operation.
The inspector reviewed audits, surveillance, and evaluations of the
radwaste program conducted within the past year.
The audit program
appeared to be thorough and in-depth.
Corrective actions, where
required, appeared to be appropriate and timely,
b.
Site Radiologic:1 Controls Group
The inspector discussed the organization, responsibil4 cies, and
operation of the Radiological Controls Group (Rad Con) with cognizant
licensee representatives, reviewed pertinent documentation, and
examined the facilities and equipment used by the Group.
The inspector determined that Rad Con Supervisory personnel met the
qualifications specified in their position descriptions. The Rad Con
Supervisor had been at the site in this position sin e June 1988. He
had worked in the corporate office and various nucir.ir power plants
prior to his current job assignment.
The Radiological Controls
Superintendent reported to the Plant Manager. The Rad Con group was
divided into four subgroups which were called and were responsible
for:
Radiological Protection - Technical Support including ALARA
Radiological Health - Balance of Plant
Field Operations - Shif t Coverage
Administration and Health Physics (HP)
Information
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Administration and Reports
Licensee representatives stated that they were operating at the
current approved manpower level of 91 people in group. The group had
identified its most significant problems and had developed aggressive
action plans to solve them.
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Site Chemistry Department
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The Chemistry Department was managed b.v a Chemistry and Environmental
Superintendent who reported directly to the Plant Manager.
The
department was divided into four sections which included
Environmental, Chemistry Control, Technical Support, and Process
Control. Staffing for the department totalled 48 personnel including
supervisors and staff.
Ten additional positions, which were to be
divided among the various sections, had been cancelled due to TVA's
reduction-in-forcc plans.
The inspector reviewed a series of position descriptions which
defined the minimum qualifications, responsibilities, and primary
functions of each position in the department. Minimum qualifications
for chemistry supervisory personnel generally required a bachelor's
degree in an associated engineering or scientific discipline and four
years related experience. A review of individual resumes showed that
the related work experience for the superintendent and the four
section supervisors totaled 83 years.
In general, the licensee appeared to have a dedicated, knowledgeable
staff concerning chemistry matters.
Additionally, the technical
support staff was available to assist in the resolution of special
problems and to evaluate data concerning plant parameters.
The
chemistry staff had been reduced by the reduction-in-force cuts;
however, current staffing was considered adequate to maintain the
regular program but not to accomplish planned long-term goals.
The
department had issued a " Chemistry Improvement Program," and the
assigned due dates were based upon the additional ten staff positions
which had been eliminated. The current level of staff was considered
insufficient to achieve the original due dates and, at the time of
this inspection, the licensee had not rescheduled the dates based on
the reduced staff.
The chemistry count room had seven analysts to
maintain 24-hour coverage and this resulted in the back shift being
manned by a single individual.
The count room had arranged for a
temporary assignment of two Watts Bar technicians to alleviate the
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aNitional work loads caused by outage sampling.
The count room
supervisor also explained that, if required, low level activity
samples could be sent to the Training Center for analysis should the
count room became too backlogged.
Chemistry management exhibited a positive attitude toward identifying
and correcting program weaknesses.
Chemistry program improvements
and goals for the FY 1989 had been documented in the plan " Chemistry
Goals and Performance Indicators for Fiscal Year 1989." This plan
covered management improvement, quality performance, program
improvements, and safe and efficient operation.
Management
improvements included additional training and timely performance
appraisals.
Quality performance goals involved conducting chemistry
operations in such a manner as to minimize the number of INP0
findings or NRC violations, to quickly address any problem areas,
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and to evaluate causes of recurring problems.
To assist in problem
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identification, the chemistry department had initiated a " Chemistry
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Group Observation Program."
These observations would serve as an
additional, informal audit program.
The department had also
established an observation schedule.
The schedule covered selected
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plant systems for sampling and analysis, instrument calibrations,
onsite chemical controls, and Post Accident Sampling System (PASS)
operation.
Other general program improvements detailed in the " Chemistry Goals
and Performance Indicators" included incorporating the use of the
Nuclear Data Microvax system for gamme spectroscopy, effluent
management, and chemistry database management; establishing a
chemistry control program to monitor and trend plant parameters;
providing technical expertise to eval" ate and implement chemical
treatments of various plant systems; ar.d improving control of the
facility's solid waste disposal.
The chemistry department had also identified a series of long-term
goals which were summarized in the "Sequoyah Chemistry Improvement
Program."
The Improvement Program identified eight areas which
included standards development, online instrumentation upgrade, QA/QC
program development,
procedures
upgrade,
Microvax
program
development, chemical traffic control program, training upgrade, and
equipment deficiency corrections.
Generally, the goals established
by this program were broader based than the specific improvements
identified in the " Chemistry Goals and Performance Indicators for
Fiscal Year 1989," and some due dates extended beyond the current
fiscal year.
Chemistry management indicated that the due dates for the Improvement
Program were based upon the additional ten positions which had
subsequently been eliminated.
Based upon the reduced staff,
reevaluation of the due dates would be necessary and some program
improvements would be necessarily postponed or eliminated. However,
the licensee management also indicated that the program in.provements
identified in the " Chemistry Goals and Performance Indicators" were
based upon the current staff level and that the goals were considered
attainable during the originally established time periods.
From the
broader based improvement plan, procedural upgrades had been
initiated for approximately 50 chemistry instructions or procedures.
No violations or deviations were identified.
4.
Post Accident Sampling System (84750)
The licensee's liquid Post Accident Sampling System (PASS) contained
inline monitors 1or chemistry parameters and utilized diluted or undiluted
grab samples for radioisotopic analysis.
Inline measurements for
chemistry parameters included dissolved oxygen, pH, conductivity,
hydrogen, and chloride concentrations.
Currently, due to the design of
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the PASS isolation valves, both units inust enter a Limiting Condition for
Operation (LCO) in order to use the system.
A design change request had
been initiated to modify the PASS so that the system could be operated
without entering an LCO.
Due dates for the design changes were April and
October 1990 for Units 1 and
2,
respectively.
Other scheduled
modifications for 1989 included replacing the PASS flow indicators and
modifying the PASS tubing to allow sampling of the reactor coolant off-gas
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for hydrogen.
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No violations or deviations were identified.
5.
Corporate Radiological Control (83522)
Corporate Radiological Control was composed of four departments.
The
departments
were
Environmental
Radiological
Monitorinq
and
Instrumentation, Radiological Heal th, Radiological Prote' lon, and
Radiological Waste. The organization was composed of a staf* mnager, two
site Radiological Assessors (Sequoyah and Browns Ferry), 42 me ers of the
Environmental Radiological Monitoring and Instrumentation Department, nine
members of the Radiological Health Department, nine members of the
Radiological Protection Department and 13 members of the Radwaste
Operation Department.
Corporate Radiological Control was established to
interact with the sites to develop standards, guidance and procedures.
The function of the Instrumentation Calibration, Repair and Control
Department was described by the licensee.
This department calibrated,
maintained, and provided inventory control for all portable radiation
survey instruments.
The purchase of new or replacement instruments and
the maintenance of a central instrument' inventory were provided by this
department.
The department also performed the environmental radiological
monituring program which included the design, review, and reporting of
sample data.
The function of the Radiological Health Department was described by the
licensee to cover three major areas.
They were external dosimetry,
internal dosimetry, and an integrated HP information system. The external
dosimetry program was National Voluntary Licensee Accreditation Program
(NVLAP) accredited.
The licensee described the functions of the Radiological Protection
department.
The principal missions of the department include:
planning
and developing radiation protection policy, providing technical support to
the site, and conducting a corporate assessment program to evaluate
program effectiveness and consistency.
The mission of the Radioactive Waste Department was described by the
licensee.
The department was tasked with the support of the sites in
processing, packaging, transportation, and disposal of solid radioactive
waste and processing, and packaging and decontamination of radioactive
waste materials.
Program assessment was a secondary mission.
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The inspector reviewed selected site support activities provided by the
corporate support group and found active, aggressive program interactions.
The inspector verified portable survey instrument calibration and
maintenance through discussion with licensee site personnel.
The
inspector also reviewed selected portions of the Radioactive Material
Shipment Manual.
This manual outlined responsibilities, packaging and
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shipping requirements, training, quality assurance and administration and
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state and disposal site requirements.
The licensee discussed the support
of Sequoyah restart stating that approximately 202 man-days of effort from
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the Radiological Protection Department were expended during 1988.
Personnel from the Radiological Protection Department were routinely
assigned to the site Radiological Control organization to provide support.
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Two personnel were assigned to the site during the current outage.
The inspector reviewed the FY 1989 Operating Plan and selectively
discussed the goals and status of Performance Measures (goals).
The
program appeared aggressive, forward looking, accountable and the
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personnel knowledgeable about current site refuelina activities.
No violations or deviations were identified.
6.
Corporate Chemistry (83522)
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The licensee discussed the corporate support for site chemistry.
Corporate support was derived from Nuclear Support Chemistry.
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organization was staffed by a Chemistry and Environmental Manager who was
supported by six Program Managers and six Project Managers.
Chemistry
Level 3 goals for FY 1989 had been established and the performance in
those areas was tracked.
Measurable objectives to assure accomplishment
of goals were in place.
The inspector reviewed the position descriptions
and responsibilities outlined for the Chemistry and Environmental
Protection Manager (PD NS-03-006).
The licensee discussed the Draft
Chemistry Assessment Program.
The program consisted of periodic
assessments of site chemistry and chemistry training programs and was
performed by the corporate office.
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The inspector selectively reviewed the resumes and work histories and
found a broad base of experience in major nuclear power plant chemistry
areas, including auditing, procedure development, program evaluation, and
program management.
Interviews and discussions with selected members of the staff indicated
involvement with the site chemistry program; however, at the time of the
inspection, the corporate organization was not fully aware of the
unexpected levels of beta activity found in the Unit 2 Steam Generators
opened during the current refueling outage.
Discussion with both site and
corporate personnel indicated that there was less than open and free
communication links established between the site chemistry and the
corporate chemistry support group. The need for better communications was
an area of concern in the February 17, 1988 Corporate Evaluation of the
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Site Chemistry Program. The communication concern involved both corporate
and site chemistry programs.
The inspector selectively reviewed the Corporate Sequoyah Chemistry Audit
and Assessments Results for 1988, and found them to be detailed, in-depth,
with identified weaknesses tracked.
The audits involved procedures,
organization, and communication.
No violations or deviations were identified.
7.
Corporate / Site Quality Assurance (83522)
The inspector reviewed the qualification and training of the Corporate QA
staff who performed quality assessment audits of Sequoyah Nuclear Plant in
the area of Radiological Protection.
Selective review of the resumes and
audit certification records indicated substantial technical experience in
the area of health physics, including practical job experience.
The inspector selectively reviewed and discussed the following audit
reports:
SS-A-88-805, dated March 1988, QA Program Radiological Control
SS-A-88-808, dated June 1988, Radwaste Shipping, Radwaste
Storage, Process Control Program and External Radiation Control
Program
SS-A-88-815, dated August 1988, ALARA Program, HP Training and
Staff Qualifications
SS-A-88-901, dated January 1989, Radiological Effluent and
Environmental Monitoring and Dose Assessment Activities
The inspector determined that the audits were detailed, in-depth, and
adequately tracked identified items.
The licensee's chemistry program wt, evaluated by a series of onsite and
corporate audits.
The inspector reviewed selected audits for calendar
year 1988 which included the following audit reports:
Sequoyah Inspection / Audit Summary for 1988
"
Corporate Assessment of Sequoyah Nuclear Plant Chemistry Program
conducted May 23, 1988 to June 10, 1988
Sequoyah Chemistry Data Management Assessment, and Corporate Monthly
Reports for the months of October, November, and December 1988
The audits appeared thorough and the auditors knowledgeable of the various
program areas.
Identified problems were tracked and corrective actions
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were documented and thorough.
Programmatic weaknesses were also
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identified and specific examples given. The Technical Support Section was
implementing a program to " observe" chemistry activities including
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sampling, analysis, system operation, instrument calibration, and
laboratory housekeeping.
These observations would provide an additional
internal assessment of the plant's chemistry program.
No violations or deviations were identified.
8.
Radiation Protection, Plant Chemistry, Radwaste, Transportation and
Environmental: Training and Qualifications (83523)
The inspector reviewed the training program established for the Radiation
Control, Chemistry, and Water and Waste Processing Groups.
The
requirements for the training program were specified in Administrative
Instruction Al-14, "Sequoyah Site Training Program," Revision 40,
October 24, 1988.
This document included training and retraining
requirements for Managers, Operators, Scientists, Engineers, and
Technicians in the specified Groups.
The training was broken down into
classroom and on-the-job training and required written and oral tests.
The training programs for all levels of the Radiation Control and the
Chemistry Groups were specified in detail.
The Radiochemical Laboratory
Analyst training was specified to be 14 weeks in the classroom and
90 weeks on-the-job-training.
The Rad Con Technician training was specified as:
Basic Phase - 16 weeks, consisting of 10 weeks of Core training and
six weeks of Specialized (Field Operations, Dosimetry, or
Instrumentation / Respiratory Protection)
In-Plant Phase - 24 months
The Technical Staff and Managers Training consisted of:
Orientation (four weeks)
Systems (two weeks)
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Advanced Phase (24 weeks)
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Segment I (17 weeks)
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Comprehensive Exams (one week)
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Simulator (six weeks)
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It was noted by the inspector that the training programs evaluated placed
emphasis on systems knowledge.
Several lesson plans used by the training staff in training Chemistry and
Rad Con personnel were reviewed and were determined to be adequate.
Administrative Instruction AI-14, Part II.E., specifies Unit Operator and
Assistant Unit Operator training and retraining requirements, and lesson
plans were reviewed for Decontamination Worker training.
Licensee
representatives stated that, when it was determined that training was
needed, such as packer / loader or shipping / handling, the Water and Waste
Processing Group would notify their corporate counterparts, who would
arrange for the training to be provided.
Licensee representatives
provided the inspector with a recently developed matrix showing training
requirements for Managers, Engineers, AU0s, A0s (Auxiliary Operators), and
00s.
They stated that this program for training and retraining would be
implemented in the future.
No violations or deviations were identified.
9.
Internal Exposure Control and Assessment (83525)
a.
Engineering Controls and Respiratory Protection
During the inspection, the inspection team observed licensee
personnel response to an apparent problem with the breathing air
system.
On Monday, January 30, 1989, personnel involved with the
installation of nozzle dams in steam generators #2 and #3 using
robotics, complained that air supplied to their bubble hoods was
inadequate.
An Instrumentation / Respiratory Protection technician
entered containment to verify that the air manifold pressure gauges
were set correctly.
The technician found no problems with the
pressure settings.
On Tuesday, January 31, 1989, the personnel
working the steam generator continued to complain about not enough
air to the bubble hood and also complained about being hot.
The
Superintendent
of
Radiological
Control
instructed
the
Instrumentation / Respiratory Protection (I/RP) group to increase air
hose lengths to 100 feet, in order to increase the pressure setting,
and possibly increase the air flow to the bubble hoods. This did not
resolve the problem.
The workers were still complaining about
insufficient air to the bubble hood and being hot on Wednesday.
The
I/RP group entered containment to verify that there was proper flow
of air at the end of the breathing air hose that attached to the
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bubble hood.
In addition, pressure settings and air flow were
checked on every breathing air manifold in containment.
All data
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collected were within the ranges specified by the National Institute
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of Occupational Safety and Health (NIOSH), as required by 10 CFR,
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Part 20, Appendix A, Protection Factors for Respirators, footnote h.
At this point, the I/RP group came to the conclusion that the problem
was not insufficient air pressure to the bubble hoods and agreed to
do whatever possible to ir. crease worker comfort. On Thursday at the
7:30 a.m. outage status meeting, the plant manager stated that he was
not satisfied with the progress made in resolving the breathing air
problem and instructed the I/RP group to go out and " crank up" the
air pressure on the breathing air manifolds.
The Superintend e t of
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Radiological Controls, a member of the NRC Assessment Team, and two
members of the I/RP met with the plant manager in his office at 8:00
a.m. that morning.
The Superintendent of Radiological Protection
explained that, although the pressure gauges on the breathing air
manifolds have locked, anti-tampering devices, that someone had
previously turned a pressure regulator up to 75 psig, above the 45
psig NIOSH certification limit for a 100-foot hose, and for that
period of time the air pressure was at 75 psig, protection factors
were not taken. Also, that the pressure gauges on the manifolds were
at the limit for the NIOSH certification and to increase air pressure
beyond this limit would violate the NIOSH certification and result in
a violation of 10 CFR Part 20 NRC regulations.
The Plant Manager
stated that steam generator personnel were getting sick and were hot
and that worker comfort was his major concern.
The inspector
informed the Plant Manager that increasing the air manifold pressure
was a safety concern in that a bubble hood could be blown off a
person's head and result in possible personnel injury and that the
problem appeared to be one of heat stress.
As a result of the
potential of violating NRC requirements for breathing air, the senior
resident inspector (SRI), NRC Assessment Team Leader, and Assessment
Team Inspector attended a meeting with the Site Director and Plant
Manager.
During the meeting, the plant manager stated that he did
not intend to violate NRC regulations and apologized.
The NRC
Assessment Team Inspector ' evidenced a concern that this event may
have intimidated radiological control first line supervision.
The
NRC inspector discussed this issue with six first line supervisors.
The majority responded that the cressure to meet schedules did exist.
Later in the afternoon on Thursday, the decision was made to monitor
the breathing air manifolds and increase air pressure after bubble
hoods were donned.
This resulted in an increased flow rate of
approximately 20% while monitoring NIOSH flow rate and pressure
limits.
The inspection team informed the licensee that the
corrective actions taken would be reviewed during a subsequent
inspection and would be identified as IFI 50-327,328/89-05-01.
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b.
Air Sampling
10 CFR 20.103 establishes the limits for exposure of individuals to
concentrations of radioactive materials in air in restricted areas.
Section 20.103 also requires that suitable measurements of
concentrations of radioactive material be performed to detect and
evaluate the airborne radioactivity in restricted areas.
The inspector observed the preparation of a high integrity container
(HIC) for dewatering and the installation of dewatering equipment.
The operation was performed in the 706-feet elevation railroad bay in
accordance with RWP 89-0119 and procedure RHSI-6, Radwaste Handling
and Shipping Instructions.
Installation of the dewatering equipment,
on the HIC reading 50 rem per hour, was performed using good ALARA
and radiological work practices.
Prior to opening the HIC, a Rad Con
technician started a general area air sample that ran for the
duration of the 30-minute operation.
The air sample was located
approximately 25 feet from the work area.
Licensee representatives
stated that airborne radioactivity had not been encountered during
previous dewatering operations and that instructions in the pre-job
briefing specified a general area air sample instead of a breathing
zone (BZ) air sample.
The inspectors discussed the advantages of
evaluating BZ air samples taken for short durations during a job,
involving
highly
contaminated
components,
with
licensee
representatives.
The licensee agreed to evaluate air sampling
requirements in HPSIL-6, Airborne Radioactivity Surveys.
The
inspectors informed the licensee that-this would be reviewed during
subsequent inspections and would be tracked as IFI 50-327,
328/89-05-02.
No violations or deviations were identified.
10. Control of Radioactive Materials and Contamination, Surveys, and
Monitoring (83526)
An inspector discussed the method used to identify and correct adverse
trends for personnel contaminations with licensee representatives.
The
inspector reviewed the November 1988 monthly repcrt that trended a number
of indicators of plant performance. The inspector noted that the trend of
personnel contaminations did not reveal any adverse trends other than the
number of people contaminated.
Radiolo
Personnel Contamination Reports (PCRs)gical Control personnel stated that
were tracked and trended and a
trending analysis was performed.
When adverse trends were identified,
corrective actions were coordinated with the responsible people.
The
inspector reviewed a listino of personnel contaminations for one
department at the station that identified the root cause of the
contamination event and the type of event.
The trend report was sent to
the department with a request for their corrective actions to prevent
recurrence.
This initiative was recent and results from various station
departments could not yet be evaluated.
The inspector noted that while
the root cause of personnel contaminations were usually identified in the
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PCRs, categories for event causes had not been developed and that trends
to identify specific problem areas at the station could not be
established.
Licensee representatives stated that they would consider
expanding the identification of specific categories of event root causes
to provide better data for evaluation and analyses and trending.
The
inspector notified the licensee that this would be reviewed during
subsequent inspections and would be tracked as IFI 50-327, 328/89-05-03.
No violations or deviations were identified.
11.
External Occupational Exposure Centrol and Personal Dosimetry (83524)
10 CFR 20.201(b) requires each licensee to make or cause to be made such
surveys as (1) may be necessary for the licensee to comply with the
regulations and (2) are reasonable under the circumstances to evaluate the
extent of radiation hazards that may be present.
Technical Specification 6.12.1 requires that any individual or group of
individuals permitted to enter high radiation areas in which the intensity
of radiation is greater than 100 mrem / hour, but less than 1,000 mrem / hour
shall be provided with or accompanied by one or more of the following:
(a) a radiation monitoring device which continuously indicates the
radiation dose rate in the area, (b) a radiation monitoring device that
continuously integrates the radiation dose rate in the area and alarms
when a preset integrated dose is received, and (c) an individual qualified
in radiation protection procedures who is equipped with a radiation dose
rate monitoring device.
The licensee notified the NRC inspection team of an unplanned exposure
event at 4:00 p.m. on February 2, 1989.
Licensee representatives stated
that two AU0s were working in a high radiation area in Unit 1 auxiliary
building that was created by an inadvertent introduction of reactor
coolant or resin into the Chemical and Volume Control System (CVCS)
demineralized resin transfer piping.
The licensee representative stated
that the AU0s received doses of between 400 and 500 mrem and did not
exceed any administrative or NRC exposure limits. The inspectors learned
that the area was posted as a radiation area and that the workers did not
have an integrating dose rate monitoring device or an individual present
with a dose rate monitoring device to provide radiological protection job
coverage.
The event was in the preliminary stage of investigation and a
description of the event would be provided as soon as possible.
The
inspection team leader informed the licensee that this event would be
considered an unresolved iten.
The inspection team noted that licensee's
immediate corrective action was to post and lock the high radiation areas
in the Unit 1 and Unit 2, 690 elevation pipe chases.
Radiation surveys
revealed a contact reading on the piping for recirculating the refueling
storage tank water at 3,500 mrem / hour and 750 mrem / hour at 18 inches in
the Unit 1 pipe chase.
A survey of the Unit 2, 690 elevation pipe chase
revealed one hot spot on the piping of 2,500 mrem / hour and 500 mrem / hour
general area.
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The preliminary report of the event was received in Region 11 on
February 8, 1989. The .'eport stated that two AU0s entered the pipe chase,
that had been surveyed and posted as a radiation area on January 31, 1989,
at 11:25 a.m.
Two valves were opened for recirculation of the refueling
water storage tank to accommodate a chemistry sample.
At approximately
1:25 p.m., one of the AU0s in the 690 pipe chase read his self reading
pocket dosimeter (SRPD) (0-200 mrem) and noted it was offscale.
Both
AU0s' SRPDs read offscale.
Recirculation operations were secured one
minute later and the AU0s exited the area and notified HP.
One AU0's
thermoluminescent dosimeter (TLD) read 430 mrem and the other's (TLD)
479 mrem. These readings reflected doses for the quarter; however, it was
established that the majority of the AU0s' doses were received as a result
of this event.
Although the root cause of the unplanned high radiation
area created in the piping for both units and the apparent loss of the
cation demineralized bed has not Leen determined, the radiological aspects
of the event have been identified. On February 9, 1989, the NP,C notified
the licensee's regulatory compliance group by telephone that the
unresolved items would be changed and would be considered an apparent
violation (VIO) of 10 CFR 20.201(b) and Techanical Specification 6.12.1
for failure to adequately evaluate the radiation hazards present in the
690-foot elevation pipe chase in the Unit I auxiliary building
(VIO 50-327, 328/89-05-04).
The inspector observed the remote installation of nozzle dams in the
Unit 2 steam generator.
The radiation dose rate in the steam generator
were found to be as high as 150 Rad /hr beta and 10 R/hr gamma. The use of
robotics and careful control of worker position in relation to radiation
shield exhibited good ALARA work planning and prvctices. The licensee was
analyzing material deposits to determine the isotope (s) causing the
unusually high beta dose rate.
The inspector notified the licensee that
this would be reviewed during subsuquent inspections and would be tracked
as IFI 50-327, 328/89-05-05.
One violation was identified.
12. Radioactive Waste Systems; Water Chemistry; Confirmatory Measurements and
Radiological Environmental Monitoring (84750)
a.
Liquid and Gaseous Radwaste Systems
The inspector discussed liquid and gaseous radwaste systems with
cognizant licensee personnel.
Liquid effluent release points to the
environment included the Liquid Radwaste System, the Condensate
Demineralized System, the Turbine Building Sump, and the Units 1 and
l
2 Steam Generator Blowdown.
Inputs to the facility's liquid radwaste
system originated from the Reactor Building and the Auxiliary
Building Floor Drains. The liquid then flowed to the Tritiated Drain
Collector Tank (TDCT) and the Floor Drain Collector Tank (FDCT) which
were currently interconnected.
The original purposr; of the TDCT was
to reclaim reactor grade water by routing the water to the TDCT for
treatment by a filter-demineralized combination and then recycling,
t
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Nonreclaimable~ liquid whste would be collected in the FDCT for
further processing and' final discharge.
Future plans for the two
tenks included installing isolation valves in the TDCT so that. the
reusable water could be separated and the system's original intent
3
accomplished.
From the FDCT, the liquid waste was processed by
either the Condensate Demineralized Waste Evaporator (CDWE) or a
andor-supplied radwaste system.
Liquid flow was then routed to the
Waste Distillate Tanks (A or B) and subsequently to the Monitor Tank
or to the Cask Decontamination Collector Tank.
Final release was
accomp"ished via the Cooling Tower Blowdown line as a batch release.
At the time of this- inspection, the licensee was implementing a
program to evaluate a vendor demineralization system for.radwaste
irrowsing.
This system would be considered as a possible
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replacement for the CDWE.-
In order to maintain better control of plant water and waste. systems,
the licensee was working on a water management plan that was
scheduled for. implementation the end of calendar year 1989. The plan
included a contracted water balance study of major plant systems.
This water balance study would also identify liquid radwaste sources
and equipment leaks.
Radioactive waste streams-would be chemically
che.racterized in order to evaluate the most efficient processing and
disposal systems.
Suitable systems would be tested inplant and
possible alternatives to the present processing would be the final
step.
The licensee's gaseous effluent system utilized six monitored
effluent vents which were the Service Building Vent, Auxiliary
Building Vent, Shield Building Vents (Units 1 and 2), and the
Condenser Vacuum Exhausts (Units 1 and 2).
The Containment Vent
exhausted via the Auxiliary Building Vent, and the Shield Building
Vents exhausted gases from the waste gas header.
Inputs to the waste
gas header included nine Waste Gas Decay Tanks (WGDTs) and the
Auxiliary Building Gas Treatment System ( ABGTS).
The ABGTS and/or
the Emergency Gas Treatment System (EGTS) had to be operated in order
to discharge a WGDT.
The EGTS could be used under routine or
emergency conditions to draw vacuum in the annulus and exhaust to the
Each WGDT had a design capacity of 600 ft3
l
The inspector discussed with the licensee the capacities of the
plant's radwaste systems to handle the additional effluents generated
by outage conditions.
The licensee indicated that the liquid and -
gaseous radwaste systems had been adequate to process outage
effluents.
No special equipment or additional storage had been
required.
Current levels in the various liquid process tanks were
less than 50 percent of the tanks' capacities.
The inspector reviewed selected procedures concerning radwaste system
operation, sampling and effluent analysis. The procedures SI-400.1,
!
" Liquid Waste Effluent Batch Release," Revision 18; SI-401, " Steam
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Generator Blowdown Continuous Release," Revision 16; and 51-410.4,
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" Waste Gas Decay Tank Release," Revision 6, clearly defined the
division.of responsibilities between Chemistry and Operations. Upon
request by Operations, Chemistry would initiate a release data
package.
Effluent sampling and analysis were performed by Chemistry
personnel with Operations being responsible for actual valve line-up
and tank release.
The licensee also maintained a procedure, SI-544,
" Verification of Representative Sampling of Liquid and Gaseous
Effluents," Revision 6, to demonstrate compliance with representative
sampling techniques.
An appropriate recirculation time for liquid
tanks was determined to be the time required for recirculation of two
tank volumes or for the total gamma activity to reach a steady state.
For gaseous tanks, the total gamma activity of nuclides in the WGDTs
was compared to gaseous effluents. Analytical methods were discussed
in Technical' Instructions TI-11 and TI-12 for chemical and
radiological analysis, respectively.
The inspector determined that
the reviewed procedures and instructions adequately described the
licensee's program for radwaste die harges.
b.
Effluent Monitors
The inspector discussed process and effluent monitors maintenance and
calibration with Instrument Engineers.
Monitor calibrations were
performed by the Instrument Maintenance Section, and functional
checks were performed monthly.
Program modifications were being
considered to change the frequency of performance checks for
nontechnical specification monitors to quarterly.
The monitors
required by technical specifications would maintain monthly checks.
Licensee personnel indicated that recently there hadn't been
recurrent maintenance problems with the monitors.
In reviewing the
Semiannual Effluent Report for the first half of 1988, the inspector
noted that two monitors had been declared inoperable for periods
greater than 30 days.
The Turbine Building Station Sump Discharge
Monitor, 0-RM-90-212, required a design change in order for the
monitor to discharge directly to the Turbine Building Sump.
This
monitor was repaired and declared operable by March 2,1988.
Flow
indicators, FI-30-242, for Units 1 and 2 Shield Building Exhaust were
declared inoperable in October and November 1987, respectively. The
indicators could not measure exhaust flow rates of less than
8,000 fta per minute.
Thus the licensee was using design flow rates
of exhaust fans in operation to estimate exhaust rates.
The flow
indicators had not been repaired as of the issuance of the
January-June 1988 Effluent Report.
The inspector accompanied licensee representatives on several plant
tours during the week and examined several effluent monitors.
The
licensee had addressed the subject of unmonitored release pathways in
!
response to IE Bulletin 80-10
" Contamination of Nonradioactive
1
System and Resulting Potential for Unmonitored, Uncontrolled Release
I
of Radioactivity to Environment."
Seven plant systems were
identified as having the potential to become radioactive through
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interface with radioactive systems. These systems were monitored via
a sampling program.
c.
The licensee had implemented an in-leakage reduction program for the
main condenser during 1988 and had successfully reduced the Unit 2
,
air in-leakage from 45 SCFM to an average of 5.1 SCFM for the fourth
quarter 1988.
The licensee was using the INP0 supplied values of
6.7 SCFM median and 4.0 SCFM best quartile as goals for maximum
in-leakage.
d.
Primary Water Storage Tank (PWST)
0xygen levels in the Unit 2 PWST were reported as being 2,000 to
3,000 ppb during 1988.
Plant specifications limit oxygen
concentration to 100 ppb for reactor coolant system make-up water.
The licensee indicated that the cause of the high levels of dissolved
oxygen were inoperable diaphrams and had initiated a design change
Demineralized Water Storage Tank (DWST) gen blanket.
request, DCR-2701, to install a nitro
Since the
supplied water to the PWST, a
design change request, DCR-2801, was also implemented for a nitrogen
blanket.
Current dissolved oxygen levels for the DWST were 200 to
300 ppb.
The licensee expected the changes to be completed during
1989, or the first part of 1990.
e.
Component Cooling System
The . Component Cooling System had reoccurring problems of excessive
system leakage and required frequent additions of highly concentrated
chemicals because of an ineffective chemical addition system.
Originally, chemicals had been added through the drain pump casing.
The licensee changed this method to add chemicals through the surge
tank.
Excessive system leakage had been minimizcd by a system
walkdown and tightening loose valves.
The licensee had not
.
experienced leaks in the heat exchangers since the latter part of
l
1987, and these were plugged at that time. Since the heat exchangers
were close to the plugging margin (10%) on the B and C loops, the
licensee chose to replace the exchangers.
The B heat exchanger for
the B loop was being replaced during the current outage.
The other
two exchangers were scheduled to be replaced during the next two
outages.
No violations or deviations were identified.
13. Outage Management Control
The inspection team observed a number of events where licensee personnel
failed to effectively communicate and/cr cooperate with approved outage
plans.
The following are examples of specific events identified by the
inspection team to plant management.
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. On. Monday, January 30, 1989, the outage planning work group
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identified the need to perform air samples at four-hour intervals in
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containment to locate the sources of airborne noble gas and iodine.
l
Rad Con was not able to report on progress at the 7:30 a.m. planning
meeting on Tuesday and, was instructed to get with chemistry and
report back as to why this was not performed.
Investigation revealed
that . Rad Con and Chemistry were not in attendance -at the Monday
planning meeting and that no instructions had been placed.in the Rad
Con night order book to take the air samples.
On Tuesday, Rad Con
took 176 air samples to support routine outage operations and. to
locate the sources of .the elevated airborne- iodine activity.
On
Wednesday, Rad Con reported that the sources of airborne still~ had
not been located and were instructed by plant management to continue
'
air sampling but to map the location of air sat:ples.
On Thursday,
'
airborne concentrations of iodine were still above the 1 MPC limit
and .. personnel were still required to wear respirators into
containment.
The Plant Manager stated that 12 of the last 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />
hed been lost due to high airborne in. containment and the inabil'ty
to open the equipment hatch to move needed material into and out of
-containment.
The inspector informed the licensee that the higher than anticipated
airborne radiciodine concentrations in the containment would be
tracked as IFI 50-327, 328/89-05-06.
On Thursday. Rad Con requested that 0perations ensure thet the
equipment hatch was closed to within four or five feet from the floor
prior to raising reactor vessel water from mid-loop. This was to be
a precaution to ensure that negative pressure was maintained in
containment and to minimize the possibility cf an uncontrolled
release of airborne radioactivity to the environment. The inspecticu
team learned on Friday that the reactor vessel water level was raised
from mid-loop in preparation for reactor head removal, but the
equipment hatch to Unit 1 was not partially closed.
No uncontrolled
release of airborne radioactivity to the environment had taken p'. ace,
however.
No violations or deviations were identified.
14. Plant Tour
The inspector, accompanied by the Superintendent, Radiological Controls,
during a tour of the facility, noted that dirty and clean laundry was
received and shipped from the railroad bay at the 706-foot elevation.
Licensee workers were observed obtaining bags of clean hoods from shipping
containers for clean laundry dress out inventory at the steam generator
dressout facility. Although magnetic signs that indicated " clean laundry"
l
were available, they had not yet been placed on the containers.
The
licensee agreed to review the receipt and identification of clean laundry
so that these containers are received and identified in a more timely
manner.
The inspector informed the licensee that this would be reviewed
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during subsequent inspections and would be tracked as IFI 50-327,
1
328/89-05-07.
No violations or deviations were identified.
15. Radwaste Solidification Incident Followup (92701)
After the licensee started processing the laundry and hot shower drain
tank through the CDWE, it was discovered that the use of a laundry
detergent (Turco 4324 NP) left a residue in the evaporator bottoms which
caused an exothermic reaction when the vendor added stabilization,
solidification, and defoaming agents to the waste bottoms in the liners.
This reaction led to an expansion and overflow of the contents in the
liner. This occurred in May 1987. As an immediate corrective action, the
licensee issued a memorandum in July 1987 to suspend the use of the
cleaning agent "Turco."
During the inspection, the inspector, accompanied by a licensee
representative, inspected Warehouse 11.
The inspector discovered ten
5-gallon plastic containers marked "Turco."
The containers were very
dusty and some were tagged with tags which read, " Returned from
Harcsville," and dated either August 1987 or September 1987.
A licensee
representative later stated that the "Turco" had been sent to Hartsville,
and had apparently been returned. The licensee representative also stated
that since the "Turco" had never been reentered on the computer, it would
not have been issued for use.
No violations or deviations were identified.
16. Action on Previous Inspection findings (92701)
a.
(Closed) IFI 50-327/88-31-01:
Followup on the inclusion of the
topics, hot particles, and hot particle control into general employee
training (GET) and continuing training.
The inspector reviewed the GET lesson plan GET 002.1-5, Controlled
Areas and HP Retraining, '2.5 Level I retraining and determined that
the subject of het particles had been included in instructions to
workers. This item is considered closed.
b.
(Closed)IFI 50-327/88-04-03: Followup on development of a procedure
to monitor for iodine during emergency conditions.
The inspector reviewed Radiological Control
Instruction 20,
Radiciodine Monitoring During Accident Conditions.
The instruction
provided the operational requirements necessary for the protection of
employees from airborne radiciodine during accident conditions. This
item is considered closed.
c.
(Closed) IFI 50-327, 328/88-38-04: Evaluation of the Nonradiological
Confirmatory Measurements results.
Nonradiological samples had been
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left with the plant che.nistry group with instructions for each sample
to be analyzed in triplicate by three different analysts (where
possible).
The analyses were completed by August 5,1988, and the
results sent to the NRC on August 11, 1980.
The NRC evaluated the
results and sent them to the licensee in the Nonradiological
Confirmatory Measurement Results Supplement to Inspection Report
Nos. 50-327/88-38 and 50-328/88-38. This item is considered closed.
17.
Followup on Employee Concerns Program
The inspector followed up on an Employee Concern in the area of radwaste
shipment.
The concern dealt with the possible shipment of unsolidified
resin bottoms to the licensed burial site.
The time table of events of
this concern were as follows:
December 9. 1908, concern received in Employee Concern Program
December 9,1988, at approximately 12:20 p.m. management briefed on
concern
December 9, 1988, File ECP-88-SQ-Q45 opened
January 5,
1989, Results of internal investigation received in
Employee Concern
January 5, 1989, upgraded to Concern ECP-89-SQ-020-01
January 26, 1989, Management Brief to Site Director
Plant deportability investigations underway
January 39, 1989, Senior level management briefing
February
1, 1989, Conclusions and recommendation preparations
Employee Concern was still in the process of completing the final report
al.d awaiting management action.
No final determination could be made by
the inspector until the licensee completed the final report and
appropriate management action had beer. taken.
18.
Exit Interview
The inspection scope and findings were summarized on February 3,1989,
with those persons indicated in Paragraph 1.
The inspector described the
areas inspected and discussed in detail the inspection results listed
below.
Although proprietary material was reviewed during the inspection,
proprietary information is not contained in this report.
During a
teleconference between NRC and licensee representatives on February 9,
1989, the licensee report on the AU0's entrance into the high radiation
areas was discussed.
Dissenting comments were not received from the
licensee.
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Item Number
Description and Reference
50-327, 328/89-05-01
IFI - Determine the cause of
wearer comfort probit's during the
use of hoods and supplied
breathing air (Paragraph 9.a).
50-327, 328/89-05-02
IFI - Evaluate breathing air
sample versus general air sample
requirements in Procudure HPSIL-6,
Airborne Radioactivity Surveys
(Paragraph 9.b).
50-327, 328/39-05-03
IFI - Expand the identification of
specific categories of events root
causes to provide better data for
evaluation
and
analysis
(Paragraph 10).
50-327, 328/89-05-04
VIO - Failure to perform radiation
surveys necessary to evaluate the
extent of radiation hazards
present prior to entrance of two
AU0's into a high radiation area
(Paragraph 11).
50-327, 328/89-05-05
IFI - Determine the cause of the
higher than anticipated beta dose
rates in the steam generators at
shutdown (Paragraph 11).
50-327, 328/89-05-06
IFI - Determine the cause of
higher that expected airborne
radiciodine concentrations in the
containment (Paragraph 13).
50-327, 328/89-05-07
IFI - Provide positive control of
shipment and receipt of laundry
(Paragraph 14).
Licensee management was informed that IFIs discussed in Paragraph 16 were
considered closed.
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